ML17334A830

Forwards Incomplete Procedures Entitled, Writers Guide for DC Cook Nuclear Plant Emergency Operating Procedures & Specific Tech Spec Guidelines for DC Cook Nuclear Plant Emergency Operating Procedures, Per 840612 Order

ML17334A830
Person / Time
Site:	Cook
Issue date:	09/28/1984
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AEP:NRC:0773I, AEP:NRC:773I, NUDOCS 8410040357
Download: ML17334A830 (129)

Text

Q REGULATORY ORMATION DISTRIBUTION SYS (RIOS)

ACCESSION NBR:8410040357 DOC ~ DATE'4/09/28 NOTARIZED+ NO DOCKET FACIL:50 315 Donal d C ~ Cook Nuclear Power Pl anti Unf t 1r Indi ana ~ 0500 50 316 Donald CD Cook Nuclear Power Planti Unit 2, Indiana 8 000316 AUTH, NAME AUTHOR AFFILIATION ALEXICH,MD PE Indiana 8 Michigan'lectric Co ~

RECIP ~ NAME RECIPIENT AFFILIATION OENTONrH ~ RE Office of Nuclear Reactor Regulatfoni Director

SUBJECT:

Forwards incomplete procedures entftledr "Writers Guide for DC Cook Nuclear Plant Emergency Operating Procedures" 8 "Specific Tech Spec Guidelines for DC Cook Nuclear Plant Emergency Operating Proceduresi" per 840612 orders

~up'W4 'a.m DISTRIBUTION CODE: A003D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR/Licensing Submittal: Suppl 1 to NUREG 0737(Gener ic Ltr 82 33)

NOTES: 05000315 OL:10/25/74 05000316 OL:12/23/72 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NARK LTTR ENCL NRR OPBi BC 7 7 INTERNAL; ADM/LFMB 1 0 IE/DKPER/EPB 3 3 NRR PAULSOW 1 1 NRR/OHFS/HFEB 5 5 NRR/OHFS/PSRB 1 1 NRR/DL/ORAB 1 1 NRR/DL/ORBS 5 5 NRR/OS I/CPB 1 NRR/qOSI/ICSB 1 1 NRR/OS I/METB 1 i NR 8&/ B 1 1 NRR/DSI/RSB 1 1

.G 1 RGN3 1 RG 2/ORSS/EPRPB 1 EXTERNAL: LPPR 2 2 NRC PDR 1 1 NSIC TOTAL NUMBER OF COPIES REQUIRED ~ LTTR 36 ENCL 35

I INDIANA 8 NICHIGAN ELECTRIC CONPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 September 28, 1984 AEP:NRC:0773Z i~'S lS  ?-

Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 i

Docket Nos. 50-315 and 50-316 w .V License Nos. DPR-58 and DPR-74 JUNE 12? 1984 CONFIRMATORY ORDER STATUS REPORT ON DETAILED CONTROL'OOM DESIGN REVIEW (DCRDR>9~AND UPGRADED

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EMERGENCY OPERATiNG PROCEDURES (EOPs)

?;o. 0??&:-ER Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation ~

l1 U.S. Nuclear Regulatory Canmission

Dear Mr. Denton:

I This letter is submitted in compliance wit~ your June 12, 1984 Licensing Order to the Donald C. Cook Nuclear Plant Unit Nos. 1 and 2. The order specifically obligated the American Electric Power Service Corporation to.

submit to the NRC by September 30, 1984 the following:

1. A Detailed Control Room Design Review (DCRDR) status report which will include the current proJect status and a completion date for, the DCRDR Summary Report which will include a proposed schedule for implementation, and

2. The Upgrade Emergency Operating Procedures (EOPs) - Procedures Generation Package.

The attacned table shows the status of the DCRDR aa of September 1, 'l984.

As the table indicates (Attachment 1), Phase I (Planning) of the DCRDR is essentially complete. This statement is predicated on the anticipated acceptance by your staff of the information provided in our August 6, 1984 submittal. Phase IZ tasks (Identification and Review) are progressing satisfactorily with several complete. See Attachment for status of the 1

various subtasks. Estimated start and completion dates are shown for those subtasks that are not yet completed. Please note that our previous estimated completion dates for the EOPs in the DCRDR validation task (6) have slipped from November 1984 to December 28, 1984 due to events and/or circuaatances as noted below. The EOP delay will in turn affect the Phase IZI assessment task.

Although we have. started a preliminary assessment of the existing information, an estimated completion date cannot be accur ately predicted.

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Mr. Harold R. Denton AEP: NRC: 0773I In our February 10, 1984 AEP:NRC:0773E letter we established a target date of December 1985 for the DCRDR Summary Report and implementation schedule.

Because of the previously referred to series of events and/or circumstances, we now estimate that a December 1986 date is more realistic for the DCRDR Summary Report and implementation schedule.

Due to these unanticipated events and to keep your staff apprised of our progress, we will provide you with an additional progress report during March 1985 and semi<<annually thereafter until submission of the DCRDR Summary Report.

The series of events and/or circumstances which will cause this delay are as follows:

The D. C. Cook Control Room Instrumentation h Control Characteristics Identification & Justification Documentation Program outlined in Attachment 2A of our August 6, 1984 AEP:NRC:0773H letter'is in the process of being contracted to a consultant. However, the additional work required by the April 5, 1984 NRC letter/memorandum (Attachment 2 of our August 6, 1984 letter) will cause delays in the DCRDR validation task as well as the Phase assessment task. The Instrumentation 4 Control Characteristics

'II Identification 5 Justification Documentation Program, which is now part of the DCRDR Summary Repor t in accordance with that April 5, 1984 letter, will delay our submittal of the DCRDR Report. The extent of the delay has not been fully evaluated as of this date.

2. The Appendix R commitments which require plant procedure changes, and which must be integrated with the DCRDR Program, were inadequately estimated previously. While the integration of the procedures is not anticipated to cause great difficulty, the Appendix R changes, including the procedures, is not scheduled for implementation until late 1985.

3. Recently, several D. C. Cook control room operators failed their annual requalification examinations. As a result, a more intensified training program has been established for these operators which reduces the staff of control room operators available to perform EOP verification and validation tasks. This additional training commitment was not anticipated and will also result in delaying the completion of our DCRDR planned schedule.

Attachment 2 of this letter contains the entire EOP's Procedures Generation Package (PGP). In summary, the PGP contains the Writers Guide, and the Plant Specific Technical Guidelines, that were used in developing the D. C. cook EOPs. The PGP also contains the D. C. Cook EOP's Verification/Validation and Tra'ning Program description's which we believe will enable us to successfully validate, train, and implement our Upgraded Emergency Operating Procedures.

4 Mr. Harold R. Denton &3& AEP: NRC: 0773I D

This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours, P. exich Vice President th Attachment cc: John E. Dolan W. G. Smith; Jr. - Br idgman R. C. Callen G. Charnoff E. R. Swanson, NRC Resident Inspector - Bridgman

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0 P

e Mr. Harold R. Denton AEP:NRC:0773I bc: J. G. Feinstein/

S. H. Horowitz/T. 0. Argenta/R. C. Carruth J. J. Markovsky/S. H. Steinhart/J. A. Kobyra R. W. Jurgensen R. F. Kroeger T. P. Bellman - Bridgman J. F. Stietzel - Bridgman B. H. Bennett/F. S. VanPelt, Jr.

J. B. Shinnock D. Migginton, NRC - Mashington, D.C.

AEP:NRC:0773I DC-N-6015. 1

0 ATTACHMENT 1 TO AEP:NRC:0773I D. C. COOK PLANT DCRDR STATUS REPORT ST ATU S ESTIMATH)

I o9/o1/84 I COMPLETIONI I DATE I I I IPHASE I I I Planning Phase 1OO Submit Program Plant Report to NRC 100 I I

IPHASE II Review Phase 66 03/01/85 Operating Experience Review 100 Control Room Operating Personnel Survey 1OO Cook LER Review 1oo I M Plant's LER Review 1OO I System Function 5 Task Analysis I 5o I 03/0 1/85 I SFTA of Selected Upgraded EOP's I 7o 11/o1/84 I8C Required List 8o I 11/01/84 IAC Characteristics Required List I 09/1 5/84 I 1 1/01/84 IAC Characteristics Justification Document I 1 1/01/84 I 04/01/85 I Control Room Inventory I 1oo Control Room Survey I 95 11/01/84 I Workspace 95 I 11/01/84 Communications I 95 I 11/01/84 Annunicators I 95 I 1 1/01/84 Controls 95 11/01/84 Displays 95 I 1 1/01/84 Labels 8 Location Aids I 95 1 11/01/84 Process Computers 95 I 11/01/84 Panel Layout I 95 I 11/01/84 Control-Display Integration 95 I 11/01/84 Verification of Task Performance Capabilities I 70 I 12/01/84 Validation of Control Room Functions I10/29/84l 12/28/84 I

I IPHASE III Assessment 4 Implementation Phase I 11/01/84 I Assessment I 1 1/01/84 I 06/01/86 Implementation I Unit One Enhancements I I Unit Two Enhancements I I I IPHASE IV I I Submit Program Summary Report and Implementation I Schedule to NRC I I 12/31/86 NOTE 1: The percentage presented here represent an estimate completion percentage; they do not reflect an exact mathematical counting.

ifreflect 2: Items shown as complete a status which may change during assessment evaluations it becomes apparent that further information is required for adequate assessment.

3: It is not possible to assess at this time.

ATTACHMENT 2 TO AEP:NRC:0773I PROCEDURES GENERATION PACKAGE TABLE OF CONTENTS PART I Writers Guide PART II Specific Technical Guidelines PART III Verification/Validation PART IV Training

ATTACHMENT 2 TO AEP:NRC:0773I PROCEDURES GENERATION PACKAGE PART I NRITERS GUIDE FOR DONALD C. COOK NUCLEAR PLANT EMERGENCY OPERATING PROCEDURES

0 0

WRITERS GUIDE FOR DONALD C. COOK NUCLEAR PLANT EMERGENCY OPERATING PROCEDURES July 1, 1984

0 0

TABLE OF CONTENTS SECTION PAGE

1. PURPOSE AND SCOPE

2. EOP DESIGNATION AND NUMBERING

2. 1 Procedure Title 2.2 Procedure Designation 2.3 Revision Numbering 2.4 Page Numbering and Identification

3. FORMAT

3. 1 Procedure Organization 6 3.2 Page Formats 6 3.3 Instructional Step Numbering 10 3.3. 1 Immediate Action Steps 10 3.3.2 Continuous Steps 10

4. WRITING THE PROCEDURE 12 4.1 Cover Sheet 12 4.2 Operator Actions 12 4.2. 1 Instruction Steps, Left-Hand Column 15 4.2.2 Instructions Steps, Right-Hand Column 17 4.2.3 Use of Logic Terms 19 4.2.4 Notes and Cautions 20 4.2.5 Transitions to Other Procedures or Steps 20 4.2.6 Component Identification 21 4.2.7 Level of Detail 24 4.2.8 Figures 24 4.2.9 Tables 25 4.2. 10 Attachments 27 6439B

TABLE OF CONTENTS (Cont)

SECTION PAGE 4.4 Foldout Page 27

5. STATUS TREE FORMAT 31

6. MECHANICS OF STYLE 34

6. 1 Spelling 34 6.2 Punctuation 34

6. 3 Capital i zation 35 6.4 Vocabulary 35 6.5 Numerical Values 36 6.6 Abbreviations and Acronyms , 37

7. REPRODUCTION 38 FIGURE

1. PRE-PRINTED PAGE FORMAT 8

2. PRE-PRINTED PAGE (2-COLUMN) FORMAT 9

3. COVER SHEET EXAMPLE FOR E-0 13,

4. COVER SHEET EXAMPLE FOR FR-H. 1 14

5. EXAMPLE INSTRUCTION STEPS 16 6439B

TABLE OF CONTENTS (Cont)

FIGURE PAGE

6. EXAMPLE GRAPH 26

7. EXAMPLE TABLE 28

8. EXAMPLE ATTACHMENT 29

9. EXAMPLE FOLDOUT PAGE FORMAT 30

10. EXAMPLE FOR STATUS TREES 32

11. STATUS TREE PRIORITY IDENTIFICATION 33 TABLE

1. DEFINITIONS OF LETTER DESIGNATORS FOR EOPs 3

2. PROCEDURE ELEMENTS 7 3.. ABBREVIATIONS USED IN EOPS 22 APPENDIX - ACTION VERBS 39 64398

1. PURPOSE AND SCOPE The purpose of this document is to provide administrative and technical guidance on the preparation of Emergency Operating Procedures (EOPs) for the Donald C. Cook Nuclear Plant. This guide applies to Optimal Recovery Procedures, Function Restoration Procedures, and Critical Safety Function Status Trees.

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2. EOP OESIGNATION ANO NUMBERING Emergency o p eratin g p ro cedures (EOPs) specify operator actions to be taken during pl.ant emergency situations to return the plant to a safe stable condition. Each procedure shall be uniquely identified to facilitate preparation, review, use, and subsequent revision.

2. 1 Procedure Title Every separate procedure shall have its own descriptive name which summarizes the scope of that procedure, or states, the event(s) which it is intended to mitigate 2.2 Procedure Designation Every separate procedure shall have its own alpha-numeric designation to supplement the descriptive title. Each procedure will begin with the prefix 01-OHP 4023. The prefix will be followed by an alpha-numeric designator.

Letter designators are to be assigned according to the definitions provided in Tabl e 1.

Optimal Recovery Procedures shall be designated by the letters E, ES or ECA

.plus a number designator. Number designators are assigned sequentially. Each E procedure number designator shall consist of a single integer. Each ES procedure shall consist of the number designator of the reference E procedure, plus a decimal integer, again assigned sequentially.

ECA procedures shall each have a number designator consisting of an integer plus a decimal integer. Related procedures shall be assigned sequential decimal integers.

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TABLE I OEFINITIONS OF LETTER OESIGNATORS FOR EOPs E

- a procedure for diagnosis and recovery from design basis events ES - a procedure which supplements the recovery actions of an E procedure ECA - a procedure which supplements both the E and ES procedures by providing recovery actions for low probability or unique event sequences which are not easily covered in the E or ES procedures or which may complicate or reduce the effectiveness of these procedures F - a procedure for diagnosis of challenges to a Critical Safety Function - represented in tree format FR - a procedure for restoration of a Critical Safety Function (CSF) to a satisfied condition S

- designator for SUBCRITICALITY CSF C

- designator for CORE COOLING CSF H designator for HEAT SINK CSF P - designator for INTEGRITY CSF Z - designator for CONTAINMENT CSF I - designator for INVENTORY CSF 0

6439B

Letter and number designators shall be separated by a hyphen.

Examples: E-0 ES"0.1 ES-1.2 ES-1.3 ECA-0.0 ECA-1. 1 ECA-2. 1 Critical Safety Function Status Trees shall be designated by the letter F plus a number designator. Number designators shall consist of the number zero plus a decimal integer which shall be assigned sequentially Letter and number designators shall'be separated by a hyphen.

Example: F-0. 1 F-0.2 Function Restoration Procedures shall be designated by the letters FR plus an additional letter which corresponds to the respective Critical Safety Function. All the separate procedures related to a particular Critical Safety Function are assigned decimal integers in increasing order.

The procedure letter and decimal integers are separated from the FR designator by a hyphen.

Examples: FR-S. 1 FR"S.2 64398

2.3 Revision Numberin The procedure cover sheet and procedure pages shall be updated to reflect the next sequential revision number. Revision numbering as described here applies to both procedures and status trees. The revision number will appear in the lower right hand corner of the procedure pages below the page number.

2.4 Paqe Numberin and Identification Each procedure page shall carry the procedure number in the upper right hand corner; the page number and revision number will be identified in the lower right hand corner of each page. Page numbering shall be sequential and each page will be specified as " of ". The last page of instructions will have the work "END" following the last instruction step.

64398

3. FORMAT This section describes the format that is to be applied consistently to all Emergency Operating Pro'cedures.

3. 1 Procedure Or anization All procedures in the EOP set are to employ a common structure consisting of five elements as shown in Table 2. Any individual procedure might contain only the three required elements, or additional elements as necessary to present the intent of the procedure.

The sequence of procedure elements is always in the order shown in Table 2.

Page numbering is sequential through all the elements comprising any procedure.'ll pages of the Emergency Operating Procedures will use the same page structure except the- Foldout Page which is discussed below. This page structure employs a pre-printed border to assure all margins are correctly maintained, and pre-printed designator boxes and page cues to ensure completeness and consistency (see Figure 1).

The pages for presentation of operator action steps will use a two-column format within the pre-printed border. The left-hand column is designated for expected operator action and response, and the right-hand column is designated for contingency actions when the expected response is not obtained. These pages will use pre-printed title blocks above the separate columns (including the "step" column) for uniformity (see Figure 2).

6'4398

TABLE 2 PROCEOURE ELEMENTS COVER SHEET (all procedures) - summarizes procedure intent and either entry symptoms or transitions INSTRUCTION STEPS (all procedures) - presents the stepwise operator instructions FIGURES (as required) - presents usually graphical data to supplement action steps ATTACHMENTS (as required) - presents non-graphical information to supplement action steps FOLDOUT PAGE (as required) - presents information which is applicable throughout the procedure(s) that it follows 64398

Symptom/Title Number FIGURE 1. PRE-PRINTED PAGE FORMAT 6439B

Symptom/Title Number STEP ACTION:EXPECTED RESPONSE RESPONSE NOT OBTAINED FIGURE 2. PRE"PRINTED PAGE (2-COLUMN) FORMAT 64398

The Foldout Page does not use the bordered-page format. It is intended to summarize only the information which an operator should have continuously available, so page content will vary by procedure. Each Foldout Page shall be titled at the top in large bold type "FOLDOUT FOR E-X SERIES PROCEDURES".

3.3 Instructional Ste Numberin Procedures steps will be numbered as follows:

1 High-level step

a. Substep (if necessary)

1) Detailed instructions (if necessary)

Substeps are lettered sequentially according to expected order of performance. If the order of substep performance is not important, the substeps are designated by bullets (o). If the logical OR is used, both choices must be designated by bullets. This same numbering scheme is to be used in both the right-hand and left-hand columns of the procedures.

3. 3 ~ 1 Immediate Action Ste s For those procedures which are the entry procedures into the EOP set, certain initial steps may be designated "immediate actions". This designation implies that those steps may be performed by the operator, based on his memory, without reference to the written procedure. These steps should be limited to verifications, if possible. Immediate action steps are identified by a NOTE (see Section 4.2.4) prior to the first action s ep.

Example:

NOTE: Steps 1 through 10 are IMMEDIATE ACTION steps.

10 6439B

3.3.2 Continuous Ste s beany pf the operator actions provided in a procedure imply continuous performance throughout the remainder of the procedure. This intent is conveyed by the use of appropriate action verbs such as monitor, maintain, or control.

6439B

4. WRITING THE PROCEDURE The following format is to be applied consistently when writing Emergency Operating Procedures.

4. 1 Cover Sheet Each cover sheet will contain two explanatory sections in addition to procedure and page designators. The first section will be titled PURPOSE and will briefly describe what the procedure is intended to do. The second section is a summary of those conditions which require entry into the procedure. This section will be titled SYMPTOMS OR ENTRY CONOITIONS. For procedures that are entry procedures into the EOP set, a symptom summary is sufficient (see Figure 3). For other procedures, which can only be entered by transition from previous procedures, a summary of the entry conditions (and procedure/step) should be provided (see Figure 4 for the preferred format).

Figures 3 and 4 should be used as examples for wording on all cover sheets.

4.2 0 erator Actions Steps directing operator action should be written in short and precise language. The statement should present exactly the task which the operator is to perform. The equipment to be operated should be specifically identified, and only those plant parameters should be specified which are presented by instrumentation available in the control room. It is not necessary to state expected results of routine tasks.

All steps are assumed to be performed in sequence unless stated otherwise in a preceding NOTE (see Section 4.2.4). To keep the individual steps limited to a single action, or a small number of related actions, any, complex evolution should be broken down into composite parts' 12 6439B

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Symptom/Tl tl e Number Ol-OHP 4023.

RESPONSE TO LOSS OF SECONDARY HEAT SINK FR-H. l, A PURPOSE This procedure prov1des act1ons to respond to a loss of secondary heat s1nk 1n all steam generators.

8 SY}fTOllS OR ENTRY CONDITIONS This procedure 1s entered from:

I) E-O, REACTOR TRIP OR SAFETY INJECTION, Step 8, rhen mlnlmum ARI flow ls not ver1f led; E) F-O.3, HEAT SINK Cr1t1cal Safety Funct1on Status Tree on a RED cond1t1on.

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Page 1 ot 13 Rev. 0, 8/)/84 FIGURE 4. COVER SHEET EXAMPLE FOR FR"H. 1 14 6439B

Actions required in a particular step should not be expected to be ~corn late before the next step is begun. If assigned tasks are short, then the expected actioo will probably be completed prior to continuing. However, if an assigned task is very lengthy, additional steps may be performed prior. to completion. If a particular task must be completed prior to continuation, this condition must be stated clearl in that step or substep.

Refer to Figure 5 as an example of the format for presenting operator actions in the following subsections.

4.2. 1 Instruction Ste s, Left-Hand Column The left-hand column of the two-column format will be used for operator instruction steps and expected responses. The following rules of construction apply:

o High Level Action steps should begin with an appropriate verb, or verb with modifier.

o Expected responses to operator actions are shown in ALL CAPITAL LETTERS.

o If a step requires multiple substeps, then each substep will have its own expected response.

Example:

Verify AFW Pumps Running:

a. MO pumps -'UNNING

b. TOAFP - RUiNNING IF NECESSARY o If only a single task is required by the step, the high-level step contains its own expected response.

Example: Check RCP Status - AT LEAST ONE RUNNING 0

6439B

Symptom/Tf t1 e Number REACTOR TRIP OR ~i, INJECTION 01-OHP 4023.

E<

sTEp AcTIoN/ExpecTEo nEspoNEE AESPONSE NOT OSTAINEO HOTE: ~ Steps 1 through 19 are IRRADIATE ACTION steps.

~ Foldout page should be open.

1. Yerify Reactor Trip: Hanually tr f p reactor. IF reactor will NOT trip, T11EN go

~ Rod batten lights - LIT to FR-S.1, RESPONSE TO RACER PNER GENERATION/AT'dS, Step 1.

~ Reactor trfp and bypass breakers - OPEH

~ Rod position fndfcasors-LESS ~i 25 SiEPS e Neutron flux <<DECREASING NOTE: Generator trip will be delayed for 30 seconds following turbine trip except for certain emergency coniIftfons.

2. Verify Turbine/Generator Trip:

a. All turbine stop valve a. Hanualiy trip turbine.

status lights - LIT

b. Generator output br eakers- b. IF breakers remain closed after OPEN Zf seconos, THEN depress emergency unit RIP pushbutton on generacor panel.

c. Generator field breaker s- c. Perform the following:

OPEN

1) Decrease generator manual voltage control to fts mfnfma.

2) RerxIve autonatfc voltage regulator from service.

d. Unit auxiliary power-TRANSFcRRED FRON NORNAL TO RESERYE SUPPLY Page 3 of ZO Rev. 0, 8/1/84 FIGURE 5. EXAMPLE INSTRUCTION STEPS 16 6439B

o Left-hand column tasks should be specified in sequence as if they could be performed in that manner. The user would normally move down the left hand column when the expected response to a particular step

~ '

is obtained.

Mhen the expected response -is not obtained, the user is expected to move to the right-hand column for contingency instructions.

o All procedures should end with a transition to another procedure, a transition to a normal operating procedure or with direction to consult the plant engineering staff for guidance.

4.2.2 Instruction Ste s Ri ht-Hand Column The right-hand column is used to present contingency actions which are to be taken in the event that a stated condition, event, or task in the left-hand column does not represent or achieve the expected result. Contingency actions will be specified for steps or substeps for which useful alternatives are available. The following rules apply to the right-hand column:

0 o Contingency actions should identify directions to override automatic controls and to initiate manually what is normally initiated automatically.

17 64398

o Contingency actions should be numbered consistently with the expected response/action for substeps only. A contingency for a single-task high-level step will not be separately numbered but will appear on the same line as its related step.

o Unlike the left-hand column, contingency instructions are to be written in sentence format.

o If the right-hand column contains multiple contingency actions for a single high-level action in the left-hand column, the phrase "Perform the following:" should be used as the introductory high-level statement.

o If the right-hand column contains multiple contingency actions which do not correspond to multiple substeps in the left-hand column, 'then different designators should be used in the two columns.

Example:

Establish Letdown: Establish excess letdown:

a. a) 2)

3) o The user is expected to proceed to the next step or substep in the left-hand column after taking contingency action in the right-hand column.

o As a general rule, all ~contin ent transitions to other procedures take place out of the right-hand column. (Oeliberate transitions may be made from the left-hand column.)

o If a contingency action cannot be completed, the user is expected to proceed to the next step or substep in the left-hand column unless specifically instructed otherwise. Mhen writing the procedure, this rule of usage should be considered in wording subsequent left-hand column instructions' 18 64398

o If a contingency action must be completed prior to continuing, that

'nstruction must appear explicitly in the right"hand column step or

.. substep.

~ I a

o As a general rule, steps will be wholly contained on a page unless the step is more than one page long.

4.2.3 Use of Lo ic Terms The logic terms ANO, OR, NOT, IF NOT, WHEN, can NOT, and THEN, are to be used to describe precisely a set. of conditions or a sequence of actions.

Logic terms will be highlighted for emphasis by capitalizing and underlining (see Figure 6).

, The two-column format equates to the following logic: "IF NOT the expected response in the left-hand column, THEN perform the contingency action in the right-hand column." The logic terms should not be repeated in the right-hand column contingency. However, the logic terms may be used to introduce a

~seconder contingency in the right hand-column.

When action steps are contingent upon certain conditions, the step shall begin with the words IF or WHEN followed by a description of those conditions, a comma, the word THEN, and the action to be taken.

IF is used for an unexpected, but possible condition.

WHEN is used for an expected condition.

ANO calls attention to combinations of conditions and shall be placed between each condition. If more than two conditions are to be combined, a list format is preferred.

OR implies alternative combinations or conditions. OR means either one, or the other, or both (inclusive).

19 64398

IF ... NOT or IF...can NOT should be used when an- operator must respond to the second of two possible conditions. IF should always be used to specify the first condition. (The right-hand column of the two-column format contains an implicit IF NOT.)

4.2.4 Notes'and Cautions Because the present action step wording is reduced to the minimum essential, certain additional information is sometimes desired, or necessary, and cannot be merely included in a background document. This non-action information is presented as either a NOTE or a CAUTION.

To distinguish this information from action steps, it will extend across the entire page and it will appear on the same page as and immediately precede the step to which it applies. Each category (NOTE or CAUTION) will be preceded by its descriptor in large, bold, letters. Multiple statements included under a single heading shall be separately identified by noting them I with bullets (o).

CAUTION denotes some potential hazard to personnel or equipment associated with the following instructional step. NOTE is used to present advisory or administrative information necessary to support the following action instruction. A CAUTION or NOTE may also be used to provide a contingent transition based on changes in plant conditions.

As a general rule, neither a CAUTION nor a NOTE will contain an instruction/operator action,; however, reference may be made to expected actions in progress.

CAUTIONs precede NOTEs when they occur together unless the NOTE contains information which clarifies the CAUTION.

4.2.5 Tran'sitions to Other Procedures or Steps Certain conditions require the use of a different procedure or step sequence.

Transitions are specified by using the words "go to" followed by the procedure designator, title (in ALL CAPITAL LETTERS) and step number.

20 64398

Example: Go to ES-0.1, REACTOR TRIP RESPONSE, Step 1 Transitions shall not contain a "return" feature (e.g., perform steps X through Y in some other procedure and then return).

Transitions to a different step later in the same procedure are specified in a similar manner.

Example: Go to Step 20 Transitions to an earlier step in a procedure are specified by using the words "return to".

Example: Return to Step 2 Transitions to a step which is preceded by a CAUTION or NOTE may include special wording (in ALL CAPITAL LETTERS) to emphasize that the CAUTION or NOTE is to be observed.

Example: IF conditions are NOT satisfied, THEN go to Step 22. OBSERVE CAUTION PRIOR TO STEP 22.

4.2.6 Com onent Identification Equipment, controls and displays will be identified .in "operator language" terms. Standard abbreviations which may be used throughout the procedures are listed alphabetically in Table 3. Where similar components are used in both primary and secondary systems, it is always necessay to clarify the location, even if the wording appears redundant.

Example: PZR PORV vs. S/G PORV identifies the pressurizer power operated relief valve as distinct from a steam generator power operated relief valve.

21 64398

TABLE 3 ABBREVIATIONS USED IN PROCEDURES AC - Alternating Current (Electrical Power)

AFW - Auxiliary Feedwater Alt - Alternate Aux Auxiliary ATWS - Anticipated Transient Without Scram BAST - Boric Acid Storage Tank BIT - Boron Injection Tank CB - Circuit Breaker CCP Centri fugal Charging Pump CCW Component Cooling Water

( CEQ CROM Hydrogen Skimmer Fans (Press.

Control Rod Drive Mechansim equalization fans)

CST Condensate Storage Tank CTS Containment Spray System CVCS Chemical and Volume Control System OC - Direct Current (electrical power and signals) 0/G Diesel Generator ECCS - Emergency Core Cooling System ESF Engineered Safety Features ESW - Essential Service Water FPT - Feed Pump Turbine L.

Hx Heat Exchanger LOCA Loss of Coolant Accident 22 6439B

TABLE 3 (Con't)

ABBREVIATIONS USED IN PROCEDURES MCC

- Motor Control Center MDAFP " Motor Drive .Auxiliary Feedwater Pump MFP - Main Feedwater Pump MFW - Main Feedwater System NESW - Non-Essential Service Water NIS - Nuclear Instrumentation System PD - Positive Displacement (in reference to pumps)

PORV - Power Operated Relief Valve PRT - Pressurizer Relief Tank PZR - Pressurizer RCP - Reactor Coolant Pump RCS " Reactor Coolant System Reg - Regulating RHR Residual Heat Removal System RMS - Radiation Monitoring System RVLIS - Reactor Vessel Level Indication System RWST - Refueling Water Storage Tank S/G Steam Generator SGTR - Steam Generator Tube Rupture SI - Safety Injection SUR - Startup Rate T/C - Thermocouple TDAFP - Turbine Driven Auxiliary Feedwater Pump VCT - Volume Control Tank 23 64398

4.2.7 Level of Oetai 1 To allow an operator to efficiently execute the action steps in a procedure, all unnecessary detail must be removed. Any information which an operator is re uired to know (based on his training and experience) should not be included. Many actuation devices (switches) in the control room are similar, even though the remotely performed functions are not, so certain action verbs listed here are recommended.

o Use "start/stop" for power-driven rotating equipment.

o Use "open/close/throttle" for valves.

o Use "control" to describe a manually maintained process variable ( flow, level, temperature, pressure).

o Use "trip/close" for electrical breakers.

o Use "place in standby" to refer to equipment when actuation is to be controlled by available (e.g., not reset or blocked) automatic logic circuitry.

4.2.8 ~Fi ures If needed to clarify operator action instructions, figures shall be added to a procedure. Any figure used will be constructed to fit within the pre-printed page format (see Figure I). Certain rules of construction'ill apply:

o All wording on the figure shall be at least as legible (type size and spacing) as the instruction steps in the procedures. e o Each figure wi 11 occupy a complete page and will be uniquely identified by a figure number and title. The figure number will consist of the procedure designator, without punctuation, followed by a hyphen and an integer. Multiple figures will be assigned sequential integers.

64398

Examples: Figure ES03-I Figure FRI3-I o Figure titles will explain the intent or content of the figure.

o The figure number and title wi 11 be placed at the bottom of the page just above the pre-printed border.

o If the figure is a graph, all the numbers and wording wil> be horizontal. By convention, the independent variable is plotted on the horizontal (Ã) axis. Grid line density should be consistent with the resolution expected from the graph. Any labeling required on the graph will have a white (not graph)" background . Figure 6 is an example figure showing presentation of a graph.

o All figures for a procedure are numbered sequentially and are located immediately after the instruction step pages. Figure pages are numbered as pages of that procedure. Any figures required for an ATTACHMENT are numbered in sequence with the procedure figures.

o References to a figure from an action step should use only the figure number and not the title.

4.2.9 Tables Tables may be used within the text of a procedure to clearly present a large number of separate options. A table will immediately follow the step or substep which makes use of it. Therefore, it does not require a unique number and title. Any table will be completely enclosed by a distinct outline; if necessary, .it. may extend into the adjacent column because of this delineation.

All information presented in a table shall be at.-least as legible (type size and spacing) as the instruction steps in the procedure.

All columns and rows of information in a table will be defined by solid lines.

P r

25 6439B

Symptom/Tl el e Number 01-OHP 4023.

LOSS QF EMERGENCT COOLANT RECIRCULATION ECA-I. I FlOM RATE (GPM)

I II !J ~

I

(

ii)

I li' s

I ~ ~

400

~ I i

! I i l

~

I) I

~ I e ~

l-

. ~ i ~ ": ~

~ .

H ti iu,'00

~ ~ <

t'I I i

~

I

~ ~ ~ ~

I I ~

iji t

~ ~ ~ ~

1 100

~

'l" I

I Ils:

!t' i ~

i i

g I I I 10 1000 10,000 TIME (MINUTES)

FIGURE ECA11-1, MINIMUM ECCS FlOM RATE VERSUS TIME AF i ER TRIP Page 14 of 14 Rev. 0, 8/1/84 FIGURE 6. EXAMPLE GRAPH 26 64398

All column and row headings shall be presented in ALL CAPITAL LETTERS.

Absence..of a table element will be indicated by a dash Figure 7 presents an example of a table.

4.2. 10 Attachments Supplementary information or detailed instructions which would unnecessarily complicate the flow of a procedure may be placed in an attachment to that procedure.

Attachments are identified by the title "ATTACHMENT" followed by a single letter designator. This title is centered at the top of a standard format page. The pre-printed title blocks will be the same as for the procedure.

Attachments will use a single-column, full-page-width format.

Physically, Attachments will be located after any Figures belonging to the procedure. Attachment pages are numbered in sequence with normal procedure pages. Figure 8 is an example ATTACHMENT page.

Only a single foldout page will be supplied for each "E-series" and "ECA-series" of procedures. The sheet will be located at the end of the last procedure in a series. Its page number will reflect its position in that procedure. The foldout page will be titled "FOLOOUT FOR E-X SERIES PROCEDURES", (see Figure 9) and will use a single-column, full-page-width, format.

Each set of operator information will be numbered sequentially and have an explanatory title." The title will be capitalized and underlined for emphasis. -

This page contains those important actions which can be performed at ~an step in the applicable procedure or procedure series.

-27 6439B

Symptom/Ti tl e Number 01-OHP 4023.

STEAH GENERATOR TUBE RUPTURE E-3 STE P ACTION/CXPECi KO AESPONSK nESPONSK NOT 08TAINEO CAUTION: RCS ANO RUPTURED 5/G(s) PRESSURES HUST BE MAINTAINED LESS THAN THE RUPTURED 5/G(s) PORY SETPOINT.

29. Control RCS Pressure And Makeup Flow To Minimize RCS-To-Secondary Leakage:

a. Perform apprapr iate action(s) fram table:

oiw sl ING DECREASING OFFSCALE I cYEL HIGH P R EYEL

~ ncreasc R. ncrcase ~ increase ~ a Hakeup Flow Makeup Flo>> Hakeup Flo>>

LESS THAN 26X (46X FOR ADVERSE CONTAINMENT)

~ Oearessurize ~ Maintain RCS RCS Using And Ruptured Step 29b 5/G( s) Pressures Equal B~i 26x Ocpressurizc Turn On Haintain RCS (46X FOR AOVFRSE RCS Using PZR And Ruptured CONTAINMENT) ANO Step 29b Heaters 5/G(s) Pressures 50X Equal BET)iEEN ~ Depressur ize Turn On Maintain RCS 50X AND 71X RCS Using PZR And Ruptured (55X FOR Step 29b Heaters 5/G(s) Pressures ADVERSE Equa 1 CONTAINMENT) ~ Decrease RCS Makeup Flow GREATER THAN 71X Decrease RCS Turn On liaintain RCS (55X FOR Hakeup FIow PZR And Ruptured ADVERSE Heaters 5/G(s) Pressures CONTAINMENT) Equal

b. Use normal PZR spray b. IF letdown is in service, per Step 29a T)(EN use auxi1iary spray. IF RT, THEN use ane PZR PORV.

Page 20 of 28 Rev. 0, 8/1/84 FIGURE 7. EXAMPLE TABLE 28 6439B

5ymp tom/Ti t 1 e Nenber 01-OHP 4023.

REACTOR TRIP RESPONSE ES-O.1 ATTACHMENT B The following conditions support or indicate natural r irculation flo~:

~ RCS subcooling base on core exit T/Cs - GREATER THAH 33oF

~ S/G pressures - STABLE OR OECREASING

~ RCS hot leg teaperatures - STABLE OR OECR~r ING

.Core exit T/Cs - STABLE OR OECREASING

~ RCS cold leg temperatures - AT SATURAT:OH cNERA URE FOR S/G PRESSURE Page oi Rev. 0, B/1/84 FIGURE 8. EXAMPLE ATTACHMENT 29 6439B

FOLOOVT FOR PROCEDURES EA THROVGH ES<.4

1. RCP TRIP CRITERIA Trip all RCPs if BOTH conditions listed below occur:

a. CCPs or SI puaps - AT LEAST OHE RUHHIHG

2. 'I

b. RCS pressure ACTUATIOH CRITERIA LESS THAN 1300 PSIG Actuate SI and go to E-O, REACTOR TRIP OR SAFETY INJECTION, Step 1, if EITHER condition listed below occurs:

o RCS subcooling based on core exit T/Cs - LESS THAN 33'F (48'F FOR ADVERSE CONTAINKHT) o PZR level - CANHOT BE HAIHTAINED GREATER THAN 10" (30" FOR ADVERSE CONTAIN%Hi)

3. RED PATH SUGARY

~ . SUBCRITICALITY - Nuclear power greater than SL

b. CORE COOLING - core" exit 7/Cs greater than 1200'F

-OR-Core exit T/Cs greater than 700'F

~

ANO RVLIS with narrow range less than no RCPs running

c. HEAT SINK - Narrow range level in all S/Gs less than 10 and total feedwater flow less than 450 gpn

d. INTEGRITY - Cold 'leg temperature decrease greater than 100'F in last 60 ainutes AHD RCS cold leg teaperature less than 222'F

e. CONTAINKHT - Contalmnent pressure greater than 12 PSIG

4. AFN SUPPLY SMITCHOYER CRITERIOH Switch to alternate AFH water supply if CST level decreases to less than 13'.

FIGURE 9 ~ EXAMPLE FOLDOUT PAGE FORMAT 30 6439B

I fttte Number SUDCRITICALITY 01-OIIP 4023.

F-0.1 POWER RANGE GREATER THAN 5%

dOTO FR.S.I INTERMEOIATERANGESUJI POSITIVE GO TO FR S.I INTERMEDIATERANGE SUR MORE POSITIVE TNAH 4.20PM POWER RANGE GOTO LESS THAN 5V I SOURCERANGK

~ ~ ~+~ ~4~0~~ FR S.Z NOT ENERGIZED INTERMEDIATERANGE SUR MORE NEGATIVE THAN 4.2 OPM CSF SAT INTERMEOIATKRAHGE SUR ZERO OR NEGATIVE SOURCERANGKSUR POSITIVE

~ OO ~ OiOOOIO FRSZ SOURCERANGE ENERGIZED 0

SOURCERAIIGESUR ZERO OR NEGATIVE CSF SAT FIGURE 10. EXAMPLE FOR STATUS TREES

5. STATUS TREE FORMAT Critical Safety Function Status Trees will be presented in the "branch" version (see Figure )0). The trees will be oriented horizontally on a page.

Color-coding and/or line-pattern-coding shall be used from each last branch point to its terminus (see Figure 11).

All text on the Status Trees shall be at least as legible (type size and spacing) as the instruction steps in the procedures.

Each Status Tree shall have at the top of the page, a designator block identical to that used in the standard procedure format, and containing the same information.

Statements shall be worded so that the favorable response is the downward branch (branch version) or yes exit (block version). Termini shall be ordered so that REOs are uniformly at the top and GREENs at the bottom. Termini order should be RED - ORANGE - YELLOW - GREEN if possible.

0 31 64398

STATUS TREE PRIORITY INDENTIFICATION Color Line Code Symbol Code Status/Response Red The critical safety function ls under extrem8

~challen e; Immedlare operator action ls required.

Orange The critical safety funollon Is under severe c~hallen e; prompt operator action is required.

Yellow ~~0~0 ~ The critical safoty function conditon Is off - norrhal.

Operator action may be taken.

Green The critical safety function Is satisfied. )go operator action Is needed.

FIGURE lI. STATUS TREE PR TY IDENTIFICATION

6. MECHANICS OF STYLE 6.1 ~Se11in s

All spelling should be consistent with modern usage as specified in the Webster' Third New International Dictionar and Webster's New Colle iate Oictionar 6s2 Punctuation Punctuation should be used only as necessary to aid reading and prevent misunderstanding. Word order should be selected to.require a minimum of punctuation. The following rules apply:

o Use a colon to indicate that an item or a list of items is to follow.

Example: Stop the following equipment:

I o Use a comma after conditional phrases for ease of reading.

Example: IF level exceeds 50;d, THEN o Use a period to indicate the end of complete sentences in righ:-hand column actions statements and in NOTEs and CAUTIONs and for indicating the decimal place in numbers. No periods are to be used in left-hand column action steps.

o , Use a dash to separate a required action and its expected response and also to indicate a null table element.

Example: Verify ECCS Pumps - RUNNING 34 6439B

Capitalization shall be used in the procedures for emphasis in the following cases:

o Logic terms will be capitalized and underlined.

o Expected responses ( left-hand column of instructions) are capitalized.

o Titles of procedures will be completely capitalized whenever referenced within any procedure.

o Operator action steps may be capitalized for emphasis o Abbreviations (see Table 3) are capitalized.

o Section headings on foldout pages are capitalized and underlined.

6.4 ~Vocabular Words used in the procedures should convey precise meaning to the trained operator. Simple words having few syllables are preferred. These are typical of words in common usage.

Verbs with specific meaning should be used. The verb should exactly define the task expected to be performed by the operator. A list of frequently used verbs is included as Appendix A ( located at the end of this document).

Some words have unique meanings as listed below:

manual (manually)- an action performed by the operator in the control room.

(The word is used in contrast to an automatic act:ion, which takes place without operator intervention.)

35 64398

local (locally) - an action performed by an operator outside the control room.

Example: "Locally close valve" means directly turning a handwheel to close a valve.

Certain other words are to be avoided simply because they are not adequately defined when used without modificaion. These include: approximately, rapidly and slowly. The same words become acceptable when some clarification is provided; clarification normally is part of a lower-level substep.

Example: Rapidly (up to 200'F/HR) cool down the RCS.

Inequalities are to be expressed in words rather than symbols: i.e., "greater than, less than". These words are always appropriate for comparing pressures, temperatures, levels and fl.owrates. The words "above" and "below" should not be used in this context; 6.5 Numerical Values All numerical values presented in the procedures should be consistent with what can be read on instruments in the control room (i.e., consistent with instrument scale and range).

The number of significant digits presented should be equal to the reading precision of the operator.

Acceptance values should be stated in such a way that any addition and subtraction operations are avoided, if possible. This is done by stating acceptance values as limits.

Examples: 2500 psig maximum 350'F minimum between 450 F and 500'F I

36 64398

Tolerances can be expressed by stating the normal value followed by the acceptable range in parenthesis. ~ I Example: 550 F (540 F to 560 F) " Correct

'50'F + 10 F Incorrect Engineering units should always be specified when presenting numerical values for process parameters. They should be the same as those used on the control room displays.

6.6 Abbreviations and Acron ms Abbreviations and acronyms should be limited to those commonly used by operators. Table 3 lists the common ones to be used for the procedures.

Abbreviations and acronyms should be used whenever possible to simplify the procedures.

Abbreviations and acronyms from Table 3 will be uniformly capitalized whenever they are used.

37.

6439B

7. REP ROOUCT ION Procedure reproduction may be done on a standard copier. Reproduced copies shall be checked to ensure that they are legible and useable. Page checks should be performed to ensure there are no missing pages.

38 6439B

APPENDIX TO WRITERS GUIDE FOR EMERGENCY OPERATING PROCEDURES ACTION VERBS actuate to put into action or motion; commonly used to refer to automated, multi-faceted operations Examples: Actuate SI, Actuate Phase A align to arrange components into a desired configuration Examples: Align the system for normal charging, Align valves as appropriate block to inhibit an automatic actuation Example: Block SI actuation check to note a condition and compare with some procedure requirement Example: Check PRZR level - GREATER THAN 20'o close to change the physical position of a mechanical device. Closing a valve prevents fluid flow. Closing a breaker allows electrical current flow.

complete to accomplish specified procedure requirements 0

39 6439B

APPENOIX (Cont) "

ACTION VERBS continue to go on with a particular process Example: Continue with this procedure control to manually operate equipment as necessary to satisfy procedure requirements on process parameters: pressure, temperature, level, flow, etc.

Example: Control PRZR level determine to calculate or evaluate using formulae or graphs Example: Oetermine maximum venting time energize to supply electrical energy to (something);

commonly used to describe an electrical bus or other dedicated electrical path Examples: Energize AC emergency buses establish to make arrangements for a stated condition Example: . Es ablish normal PRZR pressure and level control 40 6439B

APPENOIX (Cont)

ACTION VER8S evaluate to examine and decide; commonly used in reference to plant conditions and operations Example: Evaluate plant conditions equalize to make the value of a given parameter equal to the value of another parameter Example: Equalize charging and letdown flow initiate to begin a process load Example: Initiate flow to all S/Gs to connect an electrical component or unit 0

to a source of electrical energy, may involve a "start" in certain cases Example: Load the SI pump on the ac emergency bus maintain to control a given plant parameter to some procedure requirement continuously Example: Maintain S/G level in the narrow range minimize to make as small as possible Example: Minimize secondary system contamination 41 64398

APPENDIX (Cont)

ACTION VERBS monitor similar to "check", except implies a continuous activity open to change the physical position of a mechanical device to the unobstructed position. Opening a valve permits fluid flow. Opening an electrical breaker prevents current flow.

operate to turn on or turn off as necessary to achieve the stated objective Example: Operate PR2R heaters to increase pressure place to move a control to a stated position Example: Place controls in MANUAL place in standby to return a piece of equipment to an inactive status but ready for start on demand; commonly used to refer to a mid-position on a switch labeled AUTO or NEUT Example: Stop the SI pumps and place in standby 42 64398

APPENDIX (Cont)

ACTION VERBS

.reset to remove an active output signal from a retentive logic device even with the input signal still present; commonly used in reference to protection/safeguards logics in which the actuating signal is "locked-in".

The reset allows equipment energized by the initial signal to be deenergized.

Examples: Reset SI, Reset Phase A record to document specified characteristics Example: Record RCS average temperature sample to take a representative portion for the purpose of examination; commonly used to refer to chemical or radiological examination Examples: Sample for RCS boron concentration, Sample for secondary side radioactivity shut down to deenergize equipment and place in standby Example: Shut 'down unnecessary equipment 43 6439B

APPENOIX (Cont)

ACTION VERBS start to originate motion of an electrical or mechanical device, either directly or by remote control Example: Start one RCP stop to terminate motion of an electrical or mechanical device Example: Stop both 0/Gs throttle to operate a valve in an intermediate position to obtain a certain flow rate Example: Throttle charging flow control valve to establish desired flow trip to manually actuate a semiautomatic feature. Commonly, "trip" is used to refer to component deactuation.

Examples: Trip the reactor, trip the

'turbine, trip a breaker try to make a continued effort when success may not be immediately obtainable Example: Try to restore offsite power 44 6439B

APPENDIX (Cont)

ACTION VERBS turn on to supply electrical energy to a non-mechanical component Example: Turn on PZR heaters verify to observe that an ~ex ected characteristic or condition exists. Typically the expectation comes from some previous automatic or operator action. The appropriate contingency, either stated or implied, is to establish the expected cond 1 t 1 on.

Examples: Verify Reactor Trip, Verify ECCS Pumps - RUNNING 45 64398

ATTACHMENT 2 TO AEP:NRC:07731 PROCEDURES GENERATION PACKAGE PART 11 SPECIFIC TECHNICAL GUILELINES FOR DONALD C. COOK NUCLEAR PLANT EMERGENCY OPERATING PROCEDURES

0

0. C. COOK PLANT SPECIFIC TECHNICAL GUIOELINES JUNE 1984

D. C. COOK PLANT SPECIFIC TECHNICAL GUIDELINES TABLE OF CONTENTS SUBJECT PAGE

1. INTRODUCTION

2. COMPARISON OF SYSTEM DESIGNS

3. DISCUSSION OF ANALYSIS

4. BASIS FOR USING THE GENERIC WESTINGHOUSE ERGs 12

5. METHOD FOR DEVELOPIHG EOPs FROM ERGs 13

6. CONCLUSION 16 APPENDIX A - COMPARISON OF SYSTEM DESIGNS 17 APPENDIX B - ERGs, REVISION 1 LISTING 30 APPENDIX C EOP BACKGROUND DOCUMENTATION FORM 33

1. INTRODUCTION The development of plant-specific technical guidelines is one of the four elements of the Procedures Generation Package, which is required by NUREG-0899 and Supplement 1 to NUREG-0737. For the D. C. Cook Nuclear Plant Unit 1, the generic Westinghouse Emergency Response Guidelines (ERGs), Revision 1 will be used as the basis for writing the plant specific Emergency Operating Procedures (EOPs).

This document describes the method of developing plant specific EOPs from the generic Nestinghouse ERGs for the 0. C. Cook Nuclear Plant Unit l.

Also, plant specific information for the 0. C. Cook plant, which highlights differences from the generic Mestinghouse ERGs, is included in this document.

2. COMPARISON OF SYSTEM. DESIGNS During the development of th e generic Westinghouse Emergency Response Guidelines (ERGs), a generic reference plant design configuration was assumed, and the technical content included in the ERGs is based upon the reference plant design. The following systems are included in the reference plant:

Reactor Tri p Actuation System ESF Actuation System Nuclear Instrumentation System f Control Rod Instrumentation System Containment Instrumentation System'eactor Coolant System c

Chemical 8 Volume Control System Safety Injection System

~

Residual Heat Removal System

) Radiation Monitoring System Containment Spray System Containment Atmosphere Control System Component Cooling Water System Service Water System Main Feedwater and Condensate System Hain Steam System Auxiliary Feedwater System Steam Generator Slowdown System Sampling System Spent Fuel Storage and Cooling System Control Rod Drive Mechanism Cooling System Control Rod Control System Turbine Control System Electric Power System Pneumatic Power System

(Cont.)

0

2. COMPARISON OF SYSTEM DESIGNS To aid in the development of the plant specific EOPs for the 0. C. Cook plant, a comparison of 'the above systems from an emer enc o erations comparison will be done in a systematic and complete manner by reviewing all of the above systems. The purpose of the comparison is to identify areas of the 0. C. Cook plant which are different from the reference plant from the stand oint of emer enc s stem o erations, and thus these areas wi 11 be explicitly considered and included as appropriate during the development of the 0. C. Cook EOPs. The comparison for each system follows. Appendix A was developed to provide a detailed comparison of each system based upon its use in the ERGs. Appendix A should be referred to during the following comparison of each system.

REACTOR TRIP ACTUATION SYSTEM The function of the Reactor Trip Actuation System (RTAS) is to monitor specified process parameters and equipment status and to actuate reactor trip if conditions exceed specified limits. From the standpoint of emergency operations, the RTAS is the same for the 0. C. Cook and reference plant.

ESF ACTUATION SYSTEM The function of the ESF Actuation System (ESFAS) is to monitor specified process parameters and to actuate engineered safety features (ESF) operation if conditions exceed specified limits. From the standpoint of emergency operations, the ESFAS is the same for the 0. C. Cook and reference plant.

NUCLEAR INSTRUMENTATION SYSTEM The function of the Nuclear Instrumentation System (NIS) is to monitor and display the reactivity state of the reactor core. From the standpoint of emergency operations, the NIS is the same for the 0. C. Cook and reference plant.

COMPARISON OF SYSTEM DESIGNS (Cont.)

CONTROL ROD INSTRUMENTATION SYSTEM The function of the Control Rod Instrumentation System (GRIS) is to monitor and display the position of the reactor core control rods. From the standpoint of emergency operations, the CRIS is the same for the D. C.

Cook and reference plant.

CONTAINMENT INSTRUMENTATION SYSTEM The function of the Containment Instrumentation System (CIS) is to monitor the environmental condition and isolation status of the containment. From the standpoint of emergency operations, the CIS is the same for the D. C.

Cook and reference plant.

REACTOR COOLANT SYSTEM The function of the Reactor Coolant System (RCS) is to transfer heat from the reactor core to the main steam system or residual heat removal system to provide a barrier against the release of reactor coolant or radioactive material to the containment environment. From the standpoint of emergency operations, the RCS is the same for the D. C. Cook and reference plant.

CHEMICAL AND VOLUME CONTROL SYSTEH The function of the Chemical and Volume Control System (CVCS) system is to provide coolant to the reactor coolant system and to provide reactivity control for normal operations and any event that does not require engineered safety features operation; From the standpoint of emergency operations, the CVCS is the same for the 0: C. Cook and 'reference plant.

2. COMPARISON OF SYSTEM DESIGNS (Cont.)

SAFETY INJECTION SYSTEH The function of the Safety Injection System (SIS) is to provide coolant to the reactor coolant system and to introduce negative reactivity or restrict the addition of positive reactivity for events that require engineered safety features operation. From the standpoint of emergency operations, the SIS is the same for the D. C. Cook and reference plant except for Subsystem C as shown in Appendix A.

RESIDUAL HEAT REMOVAL SYSTEH The function of the Residual Heat Removal System (RHRS) is to remove residual heat from the reactor coolant system during plant shutdown operations at low reactor coolant system pressures. From the standpoint of emergency operations, the RHRS is the same for the D. C. Cook and reference plant.

RADIATION MONITORING SYSTEH The function of the Radiation Monitoring System (RHS) is to monitor the radiation levels in specified process systems and specified areas internal and external to the plant. From the standpoint of emergency operations, the RHS is the same for the D. C. Cook and reference plant.

CONTAINHENT SPRAY SYSTEH The function of the Containment Spray System (CSS) is to provide

, containment pressure suppression and airborne, fissi.on product removal for events that require engineered safety features actuation. Th'e D. C. Cook design is different from the reference plant as shown in Appendix A and these differences should be incorporated during the Writing of the EOPs.

COMPARISON OF SYSTEM DESIGNS (Cont.)

CONTAINMENT ATMOSPHERE CONTROL SYSTEM The function of the Containment Atmosphere Control System (CACS) is to provide containment heat removal and combustible gas mixture control. The

0. C. Cook design is significantly different from the reference plant as shown in Appendix A and these differences should be incorporated during the writing of the EOPs.

COMPONENT COOLING WATER SYSTEM The function of the Component Cooling Water System (CCWS) is to provide heat removal from system process and equipment via an intermediate closed-loop system. From the standpoint of emergency operations, the CCWS is the same for the 0. C. Cook and reference plant.

SERVICE WATER SYSTEH The function of the Service Water System (SWS) is to provide heat removal from system processes and equipment to the ultimate heat sink via an open-loop system. From the standpoint of emergency operations, the SWS is the same for the 0. C. Cook and reference plant.

MAIN FEEOWATER ANO CONOENSATE SYSTEH The function of the Hain Feedwater and Condensate System (HFCS) is to provide water to the secondary side of the steam generators during plant power operations. From the standpoint of emergency operations, the HFCS is the same for the 0. C. Cook and reference plant with'the exception of the feedwater flow control bypass valves as shown by Appendix A.

2. COMPARISON OF SYSTEM DESIGNS (Cont.)

AUXILIARY FEEDWATER SYSTEM The function of the Auxiliary Feedwater System (AFS) is to provide coolant to the secondary side of the steam generators during plant shutdown operations and for events that require engineered safety features operations. From the standpoint of emergency operations, the AFS is the same for the D. C. Cook and reference plant.

MAIN STEAM SYSTEM The function of the Hain Steam System (HSS) is to provide controlled heat removal from the reactor coolant system via the steam generators. From the standpoint of emergency operations, the HSS is the same for the 0. C.

Cook and reference plant with the exception of the bypass valves as shown

'y the comparison given in Appendix A.

STEAH GENERATOR BLOWDOWN SYSTEH The function of the Steam Generator Blowdown System (SGBS) is to provide letdown from the secondary side of the steam generators. From the standpoint of emergency operations, the D. C. Cook design is the same as the reference plant.

SAMPLING SYSTEM The function of the Sampling System (SS) is to provide a means for sampling process systems. From the standpoint of emergency operations, the 0. C. Cook design is the same as the reference plant.

2. COMPARISON OF SYSTEH DESIGNS (Cont.)

SPENT FUEL STORAGE AND COOLING SYSTEM The function of the Spent Fuel Storage and Cooling System (SFSCS) is to control fuel storage positions to ensure a subcritical geometric configuration and to provide heat removal to maintain stored fuel within specified temperature limits. From the standpoint of emergency operations, the D. C. Cook design is the same as the reference plan<.

CONTROL ROD DRIVE MECHANISM COOLING 'SYSTEM The function of the Control Rod Drive Mechanism Cooling System (CRDHCS) is to provide heat removal from the control rod drive mechanisms. From the standpoint of emergency operations, the D. C. Cook design is the same as the reference plant.

CONTROL ROD CONTROL SYSTEH The function of the Control Rod Control System (CRCS) is to control the position of the control rods in the reactor core. From the standpoint of emergency operations, the D. C. Cook design is the same as the reference plant.

TURBINE CONTROL SYSTEH The function of the Turbine Control System (TCS) is to control the turbine-generator., From the standpoint of emergency operations, the D. C.

Cook design is the same as the reference plant.

1 ELECTRICAL POWER SYSTEH The function of the Electrical Power System (EPS) is to provide ac and dc electrical power to equipment that require electrical power to accomplish their functions. From the standpoint of emergency operations, the D. C.

Cook design is the same as the reference plant.

2. COMPARISON OF SYSTEM DESIGNS PNEUMATIC POWER SYSTEM (Cont.)

~ 'he function of the Pneumatic Power System (PPS) is to supply pneumatic power (typically control air) to equipment that require pneumatic power to accomplish their functions. From the standpoint of emergency operations, the D. C. Cook design is the same as the reference plant.

3. DISCUSSION OF ANALYSIS The 0. C. Cook Plant design has been reviewed with respect to the reference plant analyses which were performed to support the development of the generic ERGs. This review has confirmed that the reference analyses are applicable to the 0. C. Cook Plant and that no additional analysis is required to support the use of the ERGs in developing plant specific procedures for the 0. C. Cook Plant. The reference plant for many of the analyses is a standard 4-loop non-UHI plant, but the analyses are intended to be generic and applicable to all Westinghouse-designed commercial PNR plants to the maximum extent practicable. Since the D. C. Cook Plant is similar to the reference plant, many of the analyses are directly applicable to D. C. Cook. Although the D. C. Cook Plant has an ice condenser containment system compared to the dry containment system for the reference plant, this difference does not affect the applicability of the analyses for 0. C. Cook. At the same time, note that these ice condenser design features have been incorpor~ted into the D. C. Cook EOPs. For those cases where the analysis is not directly applicable to the 0. C. Cook Plant, a comparison of the system design and plant parameters demonstrates that the reference analyses are bounding for the

0. C. Cook Plant, and that the conclusions are applicable to the D. C. Cook Plant.

0

4. BASIS FOR USING THE GENERIC WESTINGHOUSE ERGs To the greatest practicable extent, the Westinghouse Emergency Response Guidelines (ERGs) have been constructed to be generic and applicable to all Westinghouse-designed commercial PWR plants. It can be seen from the comparison made in Section 2 that the 0. C. Cook plant is very similar to the reference plant, which was used as the basis for developing the ERGs.

Also, as noted in the analysis discussion provided in Section 3, the analysis performed to support the generic ERGs is also applicable to the

0. C. Cook plant, and no additional analysis is required. Therefore, the

0. C. Cook EOPs will be based upon the generic Westinghouse ERGs, HP-Revision 1. When writing the EOPs, modifications to ERG steps must be made to account for the 0. C. Cook plant design differences which are delineated in Section 2.

12

5.3 Method (Cont.)

ERG step and the D. C. Cook step will be explained. This form along with the calculation for mathematical values used in the EOPs will be

. kept in the Background Information Manual for the 0. C. Cook EOPs.

The following additional instructions for writing the EOPs and completing the EOP Documentation Form are provided.

1. If the generic step is compatible with the 0. C. Cook plant design, then the step should be copied. into the 0. C. Cook EOP.

Since the technical basis for the step is explained in the ERG Background Document, there is no need to repeat this on the background documentation form.

2. When an ERG step specifies a numerical value to be calculated, the value will be determined and pui. into the D. C. Cook EOP.

The documentation form should indicate where the method of derivation is located.

3. When an ERG step requests plant specific details or actions to be added to the procedure, add the information to the procedure.

However, if the operator actions are highly routine or well within the knowledge of the operator, the specific information should not be included. The reason for this should be explained on the documentation form.

4. If the ERG guideline fails to identify or address systems or actions that are unique to 0. C. Cook (Refer to Appendix A), then steps should be included to encompass the necessary actions.

These should be explained on the documentation form.

5. If an ERG step specifies an action that cannot be performed at

0. C. Cook, the step will be deleted or modified and the reason explained on the documentation form.

14

5. METHOD FOR DEVELOPING EOPs FROM ERGs 5.1 Gollol'ol

. The generic Westinghouse Emergency Response Guidelines (ERGs),

Revision 1 will be used as the basis for writing the EOPs for the

'. C. Cook Nuclear Plant Unit 1. A final list of the Revision 1 ERGs is included as Appendix B.

This section describes the method that will be used to convert the generic guidelines into EOPs.

The EOP writing team will obtain and review the following source documents for D. C. Cook Unit 1:

Westinghouse generic ERGs, Rev.; 1 and background documents D. C. Cook Plant Specific Technical Guidelines D. C. Cook Writers Guide for EOPs Technical Specifications Setpoints Engineering Flow Diagrams System Descriptions Existing EOPs (See letter AEP-82-604, 12/14/82)

Calculated Mathematical Values used in EOPs (included in Background Information Manual) 5.3 Method The EOP writers will follow the ERGs step by step. The writer will research the source documents and then construct the EOP and an associated EOP Documentation Form (Appendix C). This D. C. Cook Background Documentation Form will list how each generic guideline step is used in the EOP and also list any additional steps added to the EOP with its basis, if applicable. Any difference between the 5.3 Method (Cont.)

6. If an ERG step is modified such that the intent of the step is

'hanged, then the basis wi 11 be explained on the documentation form.

7. Minor modifications to ERGs steps are acceptable without extensive justification provided that the change does not alter the intent of the guideline. Examples of these types of changes are as follows:

a. Oeletions of level of detail (see. item g3).

b. Rewording of ERG steps to conform to standard 0. C. Cook terminology, abbreviations and acronyms.

c. Rearranging ERG steps to streamline the procedure due to D. C.

Cook control room design and for operator convenience.

- 15

COMCLUSIOM For the D. C. Cook Nuclear Power Station Unit 1, the generic Westinghouse Emergency Response Guidelines (ERGs), Revision 1 will be used as the basis for writing the plant specific Emergency Operating Procedures. This document provides,a description of the planned method for developing the

0. C. Cook EOPs from the generic Westinghouse guidelines. Also, deviations from the generic guidelines from an emergency operations perspective resulting from differences between the reference plant and

0. C. Cook designs have been identified. It is intended that this document along with D. C. Cook Writers Guide for EOPs will be used to aid in the preparation of the 0. C. Cook EOPs.

APPENDIX A COMPARISON OF SYSTEM DESIGNS I I APPENDIX A COMPARISON OF SYSTEM DESIGNS REACTOR TRIP ACTUATION SYSTEM Reference Plant D. C. Cook

~ Reactor Trip Signal Same Turbine Trip Signal Same ESF ACTUATION SYSTEM Reference Plant D. C. Cook

~ SI Actuation and Reset Signals Same Containment Spray Signal (Hi-3) and Reset Feedwater Isolation Signal Reset Same

~ Main Steamline Isolation Signal Same Cont. Isolation Phase. A Signal Reset Same

~ Cont. Isolation Phase 8 Signal Reset Same

APPENDIX A COMPARISON OF SYSTEM DESIGNS NUCLEAR INSTRUMENTATION SYSTEM Reference Plant D. C. Cook Source Range Startup Rate Same Neutron Flux Recorder Same CONTROL ROD INSTRUHENTATION SYSTEH Reference Plant D. C. Cook 0 Control Rod Position Same

~ Control Rod Bottom Lights Same CONTAINMENT INSTRUMENTATION SYSTEH Reference Plant D. C. Cook

~ Containment Pressure . ~

Same Containment Temperature Same

~ Containment Recirculation Sump Level Same

APPENDIX A COHPARISON OF SYSTEM DESIGNS REACTOR COOLANT SYSTEM Reference Plant D. C. Cook

~ 4-Loop Same

~ Hot & Cold Leg RTD Bypass Same

~ Two PORVs & Associated Block Valves Three PORVs and Associated(l)

Block Valves

~ Three Code Safety Valves Same

~ RV Head Vent to Containment Same

~ RVLIS Same CHEMICAL & VOLUME CONTROL SYSTEH Reference Plant D. C. Cook

~ Two Centrifugal Charging Pumps ~

Same which are also used for SI

~ One PD Pump Same

~ Charging & RCP Seal Injection Same using one Charging Pump

~ Letdown-Regenerative HX, Same Letdown HX to VCT

~ 4% Boric Acid System l2X(l)

~ Boric Acid Pumps Supply Charging Same pumps through either normal make-up or Emergency Boration Path 20-

APPENDIX A COMPARISON OF SYSTEM DESIGNS SAFETY IN3ECTION SYSTEM Subs stem A Reference Plant D. C. Cook

~ Two Charging/SI Pumps take suction Same from RHST or Low-Head SI Pumps Charging/SI Pumps Shutoff Head > RCS Same Design Pressure 12% BIT is injected by Charging/SI Same Pumps to all 4 Cold Legs

~ BIT Contents are circulated by 2 Boron B.A, TransFer Injection Recirculation Pumps Pumps(1)'ubs stem B Reference Plant D. C. Cook

~ Two High-Head SI Pumps with Shutoff Same Head of - 1600 psig

~ High-Head SI Pumps take suction from Same RMST or Low-Head SI Pumps

~ Suctions of Charging/SI and High-Head Same SI Pumps connected

~ High-Head SI Pumps delivery to,4 Cold Same Legs (thru accumulator .lines) and all 4 Hot Legs 21

APPENDIX A COMPARISON OF SYSTEM DESIGNS Subs stem C Reference Plant D. C. Cook

~ Two Low-Head SI Pumps Same

~ Low-Head SI Pumps take suction from Same RMST or Containment Sump

~ Low-Head SI Pumps deliver to 4 Cold Same Legs and concurrently feed Charging SI and High-Head SI Pumps (Cold Leg Recirculation Mode)

Low-Head SI Pumps deliver to 2 Hot Legs Low-Head SI Pumps and concurrently feed Charging/SI and deliver to 4 Hot High-Head SI Pumps (Hot Leg Legs(2)

Recirculation Mode)

Switchover Initiation-Automatic Sump Switchover Valve Opening Initiation(2)

Manually Stopping Low Head SI Pumps Subs stem 0 Reference Plant D. C. Cook 4 Accumulator Tanks with Nitrogen Cover Same Gas RESIDUAL HEAT REMOVAL SYSTEM Reference Plant D. C. Cook

~ Two Low-Head Pumps Same

~ Low-Head Pumps take suction from Two Hot One Hot Leg(l)

Legs and return Flow to Four Cold Legs Suction Connection 0

APPENDIX A COMPARISON OF SYSTEM DESIGNS RADIATION MONITORING SYSTEM Reference Plant D. C. Cook

~ Condenser Air Injector Monitor Same SG Blowdown Monitor Same Containment Atmosphere Monitor Same Auxiliary Building Monitor Same CONTAINMENT SPRAY SYSTEM Reference Plant D. C. Cook

~ Two Low-Head Containment Spray Pumps Same

~ N/A Containment<3)

Spray Heat Exchangers

~ N/A RHR Spray to Containment<")

CONTAINMENT ATMOSPHERE CONTROL SYSTEM Reference Plant D. C. Cook

~ Four Emergency Fan Coolers N/A< 5>

~ N/A Air Recirculation Fans<6)

(Actuated on Hi-2

+ 10 min.)

~ Two Hydrogen Recombiners- Same Manual Actuation N/A Hydrogen Ignitors<7) l I APPENDIX A COMPARISON OF SYSTEM DESIGNS AUXILIARY FEEDWATER SYSTEM Reference Plant D. C. Cook

~ Two Motor Driven Pumps Same

~ One Steam Driven Pump Same Condensate Storage Tank Same 0 Alternate Water Supply Same

~ AFW Control Valves Same MAIN STEAM SYSTEM Reference Plant D. C. Cook

~ Steam Generator PORVs Same

~ Steam Generator Safety Valves Same

~ Condenser Steam Dump Valves Same

~ Hain Steamline Isolation Valves Same Hain Steamline Bypass Valves Locally Operated~B)

Hanual Valves

APPENOIX A COMPARISON OF SYSTEM OESIGNS COMPONENT COOLING WATER SYSTEM Reference Plant D. C. Cook

~ CCW Pumps Same

~ RCP Thermal Barrier Valves Same SERVICE WATER SYSTEM Reference Plant D. C. Cook

~ Service Water Pumps Same MAIN FEEOWATER ANO CONOENSATE SYSTEM Reference Plant D. C. Cook 0 Feedwater Flow Control Valves Same

~ Feedwater Flow Control Bypass Valves N/A(9)

~ Feedwater Isolation Valves Same 25-

APPENDIX A COMPARISON OF SYSTEH DESIGNS STEAM GENERATOR BLOWDOWN SYSTEH Reference Plant D. C. Cook

~ SG Blowdown Isolation Valves Same SAHPLING SYSTEH Reference Plant D. C. Cook

~ SG Blowdown Sample Isolation Valves Same SPENT FUEL STORAGE AND COOLING SYSTEM Reference Plant D. C. Cook Spent Fuel Pit level Same CONTROL ROD DRIVE MECHANISM COOLING SYSTEH Ref erence Plant D. C. Cook

~ Control Rod Drive Mechanism Fans Same

APPENDIX A COMPARISON OF SYSTEM DESIGNS CONTROL ROD CONTROL SYSTEH Reference Plant 0. C. Cook Control Rods Same TURBINE CONTROL SYSTEM Reference Plant D. C. Cook

~ Turbine Runback Same ELECTRIC POWER SYSTEM Reference Plant 0. C. Cook

~ Diesel-generators Same PNEUMATIC POWER SYSTEM Reference Plant 0. C.'ook 0 Instrument Air Compressor Same Instrument Air Valves Same 27

r APPENDIX A COMPARISON OF SYSTEM DESIGNS FOOTNOTES:

(1) No impact on the structure of D. C. Cook EOPs.

(2) ES-1.3 and ES-1.4 should be written to include the plant specific transfer to cold and hot leg recirculation procedure, which is included in the 0. C. Cook SIS System Description.

(3) The containment spray heat exchangers are utilized, if needed, during the recirculation phase. Therefore, cooling water to the containment spray heat exchangers is required during the recirculation phase of a LOCA when containment spray is required. ES-1.3, ECA-l.l and FR-Z.l should be written to include this design feature.

(4) The 0. C. Cook design has spray capability using the RHR pumps. RHR spray should be initiated if the containment pressure exceeds 8 psig following the initial blowdown. Also, RHR spray should not be used until the accident has progressed to the point when the ECCS is in the recirculation phase, or at least 30 minutes after the accident. RHR spray is in addition to the spray supplied by the containment spray pumps. The addition of RHR spray capability should be included into E-l and FR-l.l.

(5) The 0. C. Cook plant design does not include safety related containment fan coolers that automatically start on an SI actuation signal, Therefore, steps in E-O, ECA-"0.2, ECA-1.1 and'FR-Z.l should be modified to delete the emergency fan coolers.

L

- 28

APPENOIX A COMPARISON OF SYSTEM OESIGNS FOOTNOTES: (Cont.)

(6) The primary function of the air recirculation/hydrogen skimmer system is to assure containment pressure reduction after blowdown. This is accomplished by continuously circulating air from the upper to the lower compartment immediately after blowdown. The secondary function of this system is to prevent the unlikely accumulation of hydrogen in pocketed areas within the containment resulting from a LOCA. The air recirculation fans are automatically started by a Phase 8 signal after a 10 minute delay. The air recirculation/hydrogen skimmer system should be included in E-O, FR-Z.l and ECA-0.2.

(7) The Oistributed Ignition System (" hydrogen ignitors") is designed to provide additional hydrogen control capability in the unlikely event of a severe degraded core cooling event involving the generation of substantive amounts of hydrogen. The Oistributed Ignition System should be considered for inclusion in E-l, FR-C.1, FR-C.2, FR-Z.l, FR-H.l, FR-I.3, ECA-O.O and ECA-0.2.

(8) Hain steamline bypass valve operation outside the control room may be an impact and should be evaluated.

(9) Feedwater flow control bypass valves are not included in the 0. C. Cook plant., design. Therefore, steps in E-O, FR-H.2 and FR-H.3 should be modified to delete, the feedwater flow control, bypass valves.

~ I APPENOIX B EMERGENCY RESPONSE GUIOELINES,'EVISION 1 LISTING I I J

0

APPENDIX 8 EHERGENCY RESPONSE GUIDELINES OPTIMAL RECOVERY GUIDELINES E-0 Reactor Trip or Safety Injection ES-O.O Rediagnosis ES-0.1 Reactor Trip Response ES-0.2 Natural Circulation Cooldown ES-0.3 Natural Circulation Cooldown For Steam Void in Vessel (with RVLIS)

ES-0.4 Natural Circulation Cooldown for Steam Void in Vessel (without RVLIS)

E-1 Loss of Reactor or Secondary Coolant Es-l.l SI Termination ES-1.2 Post-LOCA Cooldown and Depressurization.

ES-1.3 Transfer to Cold Leg Recirculation ES-1.4 Transfer to Hot Leg Recirculation E-2 Faulted Steam Generator Isolation E-3 Steam Generator Tube Rupture ES-3.1 Post-SGTR Cooldown Using Backfill ES-3,2 Post-SGTR Cooldown Using Blowdown ES-3 ' Post-SGTR Cooldown Using Steam Dump ECA-O.O Loss of All A.C. Power ECA-0.1 Loss of All A.C. Power Recovery Without S.I. Requ'ired ECA-0.2 Loss of All A.C. Power Recovery With S.I. Required ECA-l.l Loss of Emergency Coolant Recirculation ECA-1.2 LOCA Outside Containment ECA-2.1 Uncontrolled Depressurization of All Steam Generators ECA-3.1 SGTR With Loss of Reactor Coolant Subcooled Recovery Desired ECA-3.2 SGTR With Loss of Reactor Coolant Saturated Recovery Desired ECA-3,3 SGTR Without Pressurizer Pressure Control

- 31

l APPENDIX B EMERGENCY RESPONSE GUIDELINES FUNCTION RESTORATION GUIDELINES F-0 The Critical Safety Function Status Trees F-o.l Subc ri ti ca i ty 1

F-0.2 Core Cooling F-0.3 Heat Sink F-0.4 Integrity F-0.5 Containment F-0.6 Inventory FR-S.1 Response to Nuclear Power Generation/ATMS FR-S.2 Response to Loss of Core Shutdown FR-C.1 Response to Inadequate Core Cooling FR-C.2 Response to Degraded Core Cooling FR-C.3 Response to Saturated Core Cooling Conditions FR-H.1 Response to Loss of Secondary Heat Sink FR-H.2 Response to Steam Generator Overpressure FR-H.3 Response to Steam Generator High level FR-H.4 Response to Loss of Normal Steam Release Capabilities FR-H.5 Response to Steam Generator Low level FR-P.1 Response to Imminent Pressurized Thermal Shock Conditions FR-P.2 Response to Anticipated Pressurized Thermal Shock Conditions FR-Z.l Response to High Containment Pressure FR-Z.2 Response to Containment Flooding FR-Z.3 Response to High Containment Radiation Level FR-I.l Response to High Pressurizer Level i FR-I.2 Response to Low Pressurizer Level FR-I.3 Response to Voids in Reactor Vessel 32

APPENOIX C

0. C. COOK EOP OOCUHENTATION FORH APPENDIX C Page 1 of D. C. COOK EOP DOCUMENTATION FORM EOP No. Rev.

T1t1 e Prepared by: Date D. C. COOK ERG STEP NO. STEP NO. EXPLANATION OR BASIS FOR DIFFERENCE

ATTACHYXNT 2 TO AEP:NRC:0773I PROCEDURES GENERATION PACKAGE PART III VERIFICATION/VALIDATION FOR DONALD C. COOK NUCLEAR PLANT EMERGENCY OPERATING PROCEDURES

EO VER TI N V 2BXLBZ Verification/Validation (V&V) of EOP's is the evaluation performed to determine that the actions specified in the procedure can be carried out by the operator to manage emergency conditSons effectively.

This evaluation will be carried out in two phases. The first phase, Table Top Review, will address objectives that are geared toward verifying the technical adequacy of the EOP's. The second phase, Control Room Walk Through, will address objectives focused on the human engineering aspects of the written document's usabilS.ty. Problem areas (hereafter referred to as discrepancies) identified by the V&V process will be documented, investigated, and resolved. It is our intentS. on to perform V&V of all significant modification to the EOP's after initial implementation.

A portion of the Detailed Control Room Review effort will be performed concurrently with the V&V process to address the human engineering aspects of the EOP operator hardware S.nterface.

The scope of the evaluation accomplished by V&V will be defined by addressing several criteria. These criteri.a or objectives are presented as follows, lS.sted under the program phase during which they are addressed:

That the EOP's are technically correct, i.e., they accurately reflect the Technical Guidelines (including source documents and EOP Documentation Form).

That the EOP's are wrStten correctly, i.e., they accurately reflect the writers guide.

That the language and level of information presentation in the EOP's is compatible. with the minimum number, qualification, training, and experience of the operating staff.

That the EOP's are usable, i.e., they can be understood and followed without confusion, delays, errors, etc.

That there is a correspondence between the EOP's and the control room/plant hardware, i.e., control/equipment/indications that are referenced are available (inside and outside of the control room), use the same designation, use the same units of measure, and operate as specified in the EOP's.

That there is a high level of assurance that the EOP's will work, i.e., the procedure guides the operator in mitS. gating transients and accidents. NOTE: Since the D. C. Cook EOP's will be based on the generic Westinghouse Owners Group Emergency Response Guidelines (ERG's) and a generic validation has been performed on the ERG's, this criteria will not be specifically addressed. However, a selected set of plant specific EOP's will be used in D. C. Cook licensed operator training at the SNUPPS simulator in Zion, Illinois during the 1984-85 Requalification Program. In this way, a check of the generic program can be made to 1nsure the plant specific conversion did not detract from the overall workability of the EOP's.

3. R Each EOP will be examined and evaluated step by step for compliance with

'the objectives presented above. The objectives are broken down into specific items to create a systematic checklist. In order for an objective to be satisfied, each specif1c 1tem must be a characteristic of the EOP.

Each objective is broken down as follows:

That the EOP's are technically correct, i.e., they accurately reflect the Technical Guidelines (including source documents and EOP Documentation Form).

o Are entry cond1tions or symptoms correctly stated?

o Is the arrangement and content of steps, caut1ons, and notes supported by information from source documents?

o Are calculated or translated quantitative values cor rect?

o Is the plant hardware identified by the EOP available for the operator to use?

That the EOP's are written correctly, i.e., accurately reflect the writers guide.

Are the EOP's legible, i.e., are graphs and tables clearly readable, is printed material visible within the borders on all pages2 Is the format consistent throughout the procedure set2 Is EOP identification complete and correct?

Are steps, cautions, and notes clearly and consistently presented, understandable, and distinguishable from each other2 Are transitions within the EOP's consistent and in compliance with the rules of referencing and branch1ng contained in the writers guide?

That the language and level of information presentation in the EOP/s is compatible with the minimum number, qualification, training, and experienoe of the operating staff.

o Aze the EOP's 1ncompat1ble with shift manning levels and policies2 That the EOP's are usable, i.e., they can be understood and followed without confusion, delays, errors, etc.

o Do the EOP's contain sufficient information, consistent with training, to enable the operator to properly execute the EOP instructions2 o Does the operator comprehend the information presented in the EOP's2 That there is a correspondence between the procedures and the control zoom/plant hardware, i.e., control/equipment/indications that are referenced available (inside and outside of the control room), use the same designation, use the same units of measure, and operate as specific in the EOP's.

o Are the EOP's compatible with plant hardware and plant zesponse2 That there is a high level of assurance that the EOP's will work, i.e., the procedures guide the operator in mitigating transients and accidents.

o Again, since the D. C. Cook Plant EOP's are based on the Westinghouse Group ERG's, credit is taken for validation/verification of this objective based on the generic ERG validation. We will check this objective by using a selected set of plant specific procedures at the SNUPPS simulator in Zion, Illinois.

The Operations Department Superintendent (O.S.) will have the responsibility for implementing the V&V program at D. C. Cook. The Operations Department Administrative Compliance Coordinator (A.C.C.) will have the responsibility for conducting the V&V program. The review teams (comprised of licensed operators) will be responsible for verifying objectives are met and discrepancies are documented. The Plant Nuclear Safety Review Committee (PNSRC) 1s responsible for final approval of the EOP's. Task responsibilities are as follows:

The A.C.C. will train the review teams in the use of the V&V procedure.

The A.C.C. w111 interface with the Detailed Control Room Design Rev1ew Coordinator.

The O.S. and A.C.C. will resolve all discrepancies. (The A.C.C. will ensur e that all resolutions are incorporated as necessary into the EOP's.)

5.

The ultimate goal of the VEV program is to identify areas where the plant specific EOP's may deviate from the generic procedures, criteria in the writer guide, and technical guidelines, and/or plant characteristics or policies.

It is the responsibility of the review teams, through the use of the VhV procedure, to ensure that objectives are met and/or discrepancies documented. The review teams should also make recommendations to resolve discrepancies when appropriate.

6.

Once a discrepancy is identified and documented, a resolution must be developed. The solution which resolves the discrepancy may take any of various forms, e.g., procedure change, increased operator training, hardware modification, etc. In all cases, the resolution will be documented. The VhV on any given EOP will not be considered complete until all discrepancies applicable to it are resolved. Proposed changes will be evaluated for their impact on other emergency r esponse capabilities.

7~

All documentation forns generated during the VIV program will be considered part of the Emergency Procedures and retained in accordance with Plant Managers Instruction - 2130, Plant Records.

ATTACHMENT 2 TO AEPrNRCr0773I PROCEDURES GENERATION PACKAGE PART IV TRAINING FOR DONALD C. COOK NUCLEAR PLANT EMERGENCY OPERATING PROCEDURES

l' W'l t~

C T 0 Prior to implementation of the upgraded Emergency Operating Procedures, operators will receive a two-phase training program on the background, structure, and use of these procedures. After implementation, a third phase of the program will begin which will include continuing traMing, review, and simulator use of the EOP's.

As a minimum, the training program will include:

1. Background and Procedure Development.

Why and how the procedure was developed.

Background document(s) used in writing the procedures.

Development and purpose of the Critical Safety Function Trees.

2. Use of the Upgraded Emergency Operating Procedur es.

How and when each EOP will be used.

The interrelationship of the EOP's.

Description of the flow path through the EOP including an in-depth study of procedure steps, contingency actions and use of the critical safety functions status trees with the functional restoration guideline.

Phase I of the training program will provide a solid understanding of the background and scope of the EOP's. This phase will include the forementioned minimum requirements. Training will be conducted in a classroom environment. Following the completion of Phase I, Phase II of the training progr am will begin. The minimum requirements for Phase II training will be the same as Phase I with the following exception; Phase II training will place more emphasis on Emergency Procedure objectives and use than on the scope and background. Participants of both Phase I and Phase II training will be all operators who are responsible for the use of the EOP's and Shift Technical Advisors.

Phase II training will be, for the most part, classroom instruction, and control room walk through for specific procedures.

Following completion of Phase II training the upgraded EOP's will be implemented. This will begin Phase III of the training program.

Phase III will be the continuing training on the EOP's.

at This training will will be rolled into the current Requalification Program D. C. Cook and include as a minimum:

1. Classroom discussion and review of the EOP's.

2. Industry events and plant equipment changes that would lead to reassessment of specific guidelines in the EOP's.

3. Use of the EOP's during scenarios developed in simulator sessions at the SNUPPS simulator in Zion, IL.

Periodic review of selected portions of the Phase II training program.

2. SU/~

The D. C. Cook training program for the upgraded Emergency Operating Procedures will begin during the 1984-85 Requalification period with all licensed operators and Shift Technical Advisors being fully versed in the structure and use of these procedures before they are implemented.

Training will then continue as part of the Requalification Program. The scope of all phases of the training program will be:

Provide all individuals responsible for the use of the EOP's with a comprehensive working knowledge of the development, writing, and use of those Emergency Procedures.

This will ensure that operators will have the knowledge to better cope with situations that deviated from the initial assumptions for which the procedures were written.

-