ML17346A562

Revised Emergency Operating Procedures,Including O-ADM-110 Re Verification Guideline for Emergency Operating procedures,O-ADM-111 Re Emergency Procedure Validation Plan & Procedures Generation package.W/841001 Ltr

ML17346A562
Person / Time
Site:	Turkey Point
Issue date:	09/26/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
L-84-270, PROC-840926, NUDOCS 8410040468
Download: ML17346A562 (157)

Text

REGULATORY'lFORMATION DISTRIBUTION SY, e.M (RIDS)

ACCESSION NBR;8410040468 DOC ~ DATE: 84/09/26 NOTARIZED NO DOCKET FACIL:50-250 Turkey Point PlantE Unit 3i Florida Power Iand Light 05000250 50 251 Turkey Point Planti Unit 4i Florida .Power and Light 05000251.

AUTH, NAME AUTHOR AFFILIATION HILLIAMSiJ kl ~ Fl or.ida Power 8 Light Co, RECIP ~ NAME RECIPIENT AFFILIATION EISENHUT<DGG ~ Division of Licensing

SUBJECT:

Revised emergency operating proceduresgihcluding 0-ADM 110 re verification guideline for emergency operating procedures,O ADM-111 re emergency procedure validation plan 8 procedures generation package AH/841001 ltr.

Su/remittal:

fC DISTRIBUTION CODE: A00 CORI S RECEIVED:LTR ~ ENCL ~ SIZE; TXTLE: OR/Liceneine SuPPl l tc NUREG-0737(Generic Ltr S2-33)

NOTES- 05000250 OL; 07/19/72 05000251 OL: 04/14/73 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME'RR LTTR ENCL ID, CODE/NAME LTTR ENCL ORB1 BC 7 7 INTERNAL: ADM/LFMB 0 IE/DEPER/EPB 3 3 NRR PAULSONgN 1 1 NRR/DHFS/HFEB 5 5 NRR/DHFS/PSRB 1 1 NRR/DL/ORAB 1 1 NRR/DL/ORB5 5 5 NRR/DS I/CPB 1 1 NRR/DSI/ICSB 1 1 NR 8'/D S I /MET 8 1 1 NRR/ B 1 1 NRR/DSI/RSB 1 1 FILES 1 1 RGN2 1 1 Rbi EPRPB 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NTIS 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 36 ENCL 35

l

>>11 I a <<'e>>I f 1>>Q f f. e V

" li I. ,

f>>'r f lii>> f "ll ">> II ~ ~

,V'iT ,y7 ~7, I li ~

<<life'VII<I-4 f 1 4>>F V>> If I't'<<>>f ,' f g jl f qg" 1%(V r elf fr,,q9 eil>> v PQ<<P )[ti<<>>F>> 1, >>>> g>> J I >>

t

~r f ti<<sr fly fl. k'il f tk;7f r f<< <<) til>> 1>>0 <p f L<a"

( V<<'hg "",, iFV f FV <<FF e

,, i~ V . I

~ Vt V I l<<

~ >>

ft "IJ fa i

<0

Title:

Verification Guideline for Emergency Operating Procedures Safet Related Procedure Responsible Department: Procedure Upgrade Reviewed by PNSC: 84-165 Approved by Plant Manager-N: 9/26/84

'DR 84i00404b8 84092b PDR ADOCK F

O-ADM.110 05000250 PP~~

e

'Ps

Verification Guideline for 0-AD M-110 Fmergency Operating Procedures LIST OF EFFECTIVE PAGES Revision

~pa e Date 1-16 9/26/84 O-AOM.110

Verification Guide)ine for A<p D.a Da'<<

0-ADM-I 10 Emergency Operating Procedures 9/26'S4 TASLE OF CONTENTS Section ~Pa e 1.0 PU R POSE 4 2.0 REFF. RFNCES \ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 4 3.0 RES PONSI B I LITIES ~ ~ ~ ~

4.0 DEFINITIONS ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 5 5.0 PROCEDURF.

5.1 EOP Verification Process ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 5.1.1 Preparation Phase 5.1.2 Assessment Phase 7 5.1.3 Resolution Phase ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 7 5.1.4 Documentation Phase 7 ENCLOSURES/ATTACH M ENTS:

Attachment 1 - General Verification Checklist................ 8 Attachment 2 - Technical Accuracy Verification Checklist......... 13 Attachment 3- Discrepancy Sheet... ~.................... 16 o-aoN.i:0

s li

Verification Guideline for 0-A DJH-110 Emergency Operating Procedures 1.0 PURPOSE

~Pur ose The purpose of this procedure is to guide the administrative process used in the verification of the emergency operating procedures (EOPs) and to assign responsibilities for carrying out the activities of the process.

1.2 ~Sco ~

This procedure identifies and directs the phases of the verification process.

1.3 A~li This procedure applies to initial EOP implementation and revisions for Unit 3 and Unit 4 of the Turkey Point Plant. This procedure applies to the verification of a)l emergency operating procedures.

2.0 REFERENCES

2.1 Administrative Procedure 0190.14, Document Control and Quality Assurance Records 2.2 ADM-109 - Writers Guide for Emer'gency Operating Procedures 2.3 ADM-111- Turkey Point Plant Validation Guideline for Emergency Operating Procedures 2.4 INFO 83-004 - Emergency Operating Procedures Verification Guideline 3.0 RESPONSIBI I.ITIES 3.1 Plant Mana er-Nuclear The Plant Manager - Nuclear shall approve all EOPs and revisions.

3.2 0 erationsSu ervisor The Operations supervisor shall have overall responsibility for the EOP verification process. He shall determine when EOP verification is needed and its scope. He shall approve the verification resolutions.

3.3 Procedure U ade Su ervisor The Procedure Upgrade Supervisor shall manage the written correctness and technical accuracy evaluation process.

OADM i10

Verification Guideline for cpp;oia oa'.e 0-A DM- l I 0 Emergency Operating Procedures ,

9/26/S4 4.0 I) K F I N ITI ON S 4.1 Emer enc 0 eratin Procedures IEOPs)

Plant procedures directing operator action necessary to mitigate the consequences of transients and accidents that cause plant parameters to exceed reactor protection system setpoints, engineered safety features setpoints, or other appropr iate technical limits.

4.2 EOP Source Documents Documents or records upon which EOPs are based.

4.3 EOP Technical Accuracy A characteristic of EOPs that indicates the degree to which proper incorporation of generic and/or plant-specific technical information from EOP source documents and plant hardware has been made.

4.4 EOP Verifica tion The evaluation performed to confirm the written correctness of the EOPs and to ensure that the generic and/or plant-specific technical aspects have been properly incorporated.

4.5 EOP Written Correctness A characteristic of EOPs that indicates the degree to which proper incorporation of information from the PTP Writers Guide for EOPs and other appropriate administrative policies has been made.

4.6 Emer enc Res onse Guidelines(ERGs)

The detailed and complete network of generic emergency response guidance developed by the Westinghouse Owners Group for Westinghouse plants. The idance includes Optimal Recovery Guidelines, Critical Safety Function tatus Trees and Function Restoration Guidelines.

0 AOM.I '10

A.

t

Verification Guideline for APP(Dvigu 0-A D M-110 Fmergency Operating Procedures Od't'/26'84 5.0 P ROC F DU RE 5,1 EOP Verification Process

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0

]

~ ~ ~ ~ ~

~ a& ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

l NOTE I l The process of EOP verification consists of four phases'reparation, assessment, I

I resolution, and documentation.

l ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~~ 0 5.1.1 Pre aration Phase

1. The preparation phase consists of the following activities:

a. Designate Personnel: The Operations Supervisor shall appoint the necessary personnel as evaluators to conduct the comparative evaluation. Personnel should be appointed based on operating experience and understanding of plant hardware, the ERGs, and the writers guide.

b. Obtain and Review the EOP Source Documents: The listing of EOP source documents is provided on Attachment 1, General Verification Checklist. These. shall be reviewed by the personnel conducting the assessment phase to ensure they are complete, current, and applicable. Any additional applicable source documents shall be listed.

5.1.2 Assessment Phase In the assessment phase the evaluator shall:

a. Make a general review of the EOP using the procedure-specific portion of the evaluation criteria and source documents.

b. Indicate on Attachment 1, General Verification Checklist, that the evaluation was performed, either by initialing indicating acceptance or by designating the appropriate discrepancy on Attachment 3, Discrepancy Sheet.

c. Make a step-by-step review of the EOP using the step, caution, note-specific portion of the evaluation criteria and source documents.

0-aoM.>>0

Verification Guideline for ~~:>~Ovd Ddif 0-A DM-110 Emergency Operating Procedures 9/26/84 5.1 EOP Verification Process 5.1.2 . Assessment Phase (Cont'd)

1. d. Complete Attachment 2, Technical Accuracy Checklist Verification, and forward the verification checklist with any discrepancy sheets to the Procedure Upgrade Supervisor.

5.1.3 Resolution Phase

1. In the resolution phase, the Procedure Upgrade Supervisor shall:

a. Review the evaluator's comments and resolve any conflicts between the writers'nd evaluators'omments.

b. Forward potential solutions to the Operations Supervisor for .

review and approval.

c. Update applicable source documents and procedures with approved resolutions as directed by the Operations Supervisor.

5.1.4 Documentation Phase

1. The documentation developed throughout the process shall be maintained in accordance with Administrative Procedure 0190.14, Document Control and Quality Assurance Records.

END OF TEXT 0 Aov, i io

H II

~ )

Verification Guideline for 0-ADM-1]0 Emergency Operating Procedures ATTACHM ENT ]

(Page 1 of 5)

GENERAI. VERIFICATIONCHECKI.IST EOP

Title:

EOP Number: Revision:

Unit:

Revision!

Approval Date

1. Westinghouse Emergency Response Guidelines, (ERG)

2. Techni'cal Specifications, Turkey Point Plant FSAR, Turkey Point Plant 4 ADM-109,Writers Guide for Emergency Operating Procedures ADM-100, Procedure Preparation, Review, and Approval Other 1.0 PROCEDURE-GENERAL 1.1. Written Correctness Initials 1.1.1 L~e'bi lit

a. Are the printed borders visible on all procedure pages?

b. Are the text, tables, graphs, figures, and charts legible to the evaluator?

1.1.2. EOP Format Consistenc

1. Do the following segments exist in each EOP:

a. TITLE

b. ENTRY CONDITIONS

c. OPERATOR ACTIONS

Verification Guideline for s. so eea'a:a 0-A DM-110 Emergency Operating Procedures 9/26/N ATTACHMENT 1 (Page 2 of 5)

GENERAL VERIFICATIONCHECKLIST 1.0. PROCEDURE-GENERAL 1.1. Written Correctness (Cont'd)

Initials

2. Is the operator actions segment presented in a dual-column format?

3. Is the page layout consistent?

1.1.3. Identification Information

1. Is the procedure title descriptive of the purpose of the procedure.

2. Does the cover sheet correctly provide the following:

a. Procedure title

b. Procedure number

c. Unit number

d. Revision date

e. Number of pages Does each page correctly provide the following?

a. Procedure designator

b. Revision date

c. Page of numbers 4

4. Does the procedure have all its pages in the correct order?

0aoM>>0

0 Verification Guideline for A ~P'0 ad 0-ADM-1 1 0 Emergency Operating Procedures Od1'26'84 ATTACHMENT 1 (Page 3 of 5)

GENF RAL VERIFICATIONCHECKLIST 2.0. STEP CAUTION NOTE-SPECIFIC 2.1. Written Correctness Initials 2.1.1. Information Presentation

1. Are instruction steps numbered correctly?

2. Are operator-optional sequence steps identified?

Are instruction steps constructed to comply with the following:

a. Steps deal with only one idea.

b. Sentences are short and simple.

c. Operator actions are specifically stated.

d. Objects of operator actions are specifically stated.

e. Objects of operator actions are adequately stated.

f. Punctuation and capitalization are proper.

g. Abbreviations are correct and understandable to the operator.

4. Oo instruction steps make proper use of logic structure?

5. When an action instruction is based on receipt of an alarm, is the setpoint of the alarm identified?

6, Are notes and cautions used appropriately?

7. Are" notes and cautions placed properly?

0-ADM 110

0 Verification Guideline for 4>>; 'O~d" 0-A I) M-110 Emergency Operating Procedures Dd'0'I26IS4 ATTACHMENT I (Page 4of5)

E GENERAL VERIFICATIONCHECKLIST 2.1. %'ritten Correctness 2.1.1 Information Presentation (Cont'd)

Initials

8. Are notes and cautions constructed to comply with the following:

a. They do not contain operator actions.

b. They do not use extensive punctuation for clarity.

c, They make proper use of emphasis.

9. Are numerical values properly written?

10. Are values specified in such a way that mathematical opera-tions are not required of the user?

ll. Is a chart, or graph provided in the procedure for necessar'y operator calculations?

12. Are units of measurement in the EOP the same as those used on equipment?

2.1.2. Procedure Referencin and Branchin Do the referenced and branched procedures identified in theEOPs exist for operator use?

2. Is the use of referencing minimized?

3. Are referencing and branching instructions correctly worked?

a. "go to" (branching)

b. "refer to" (referencing)

O.ADM.110

4 Verification Guideline for <<Wb'dVd OdiP P-ADM-) ]0 Emergency Operating Procedures 9'26/84 ATTACHM ENT 1 (Page 5 of 5)

GENERAL VERIFICATIONCHECKI.IST 2.1. Written Correctness 2.1.2 Procedure Referencin and Branchin (Cont'd)

Initials 4 Do the instructions avoid routing users past important information such as cautions preceding steps?

5. Are the exit conditions compatible with the entry conditions of the referenced or branched procedure?

Verification Completion Date:

Performed By:

Reviewed By:

All actions required by the verification have been completed:

Approved:

0-ADM i )0

0 Verification Guideline for APPrOvy pg'.f.

0-A DM-110 Emergency Operating Procedures 9/26~84 ATTACHM ENT 2

~(P g 1 3)

TECHNICALACCURACY VERIFICATIONCHECKLIST EOP Title.

EOP Number: Revision:

Unit:

Revision!

Approval Date Westinghouse Emergency Response Guidelines, (ERG)

2. Technical Specifications, Turkey Point Plant

3. FSAR, Turkey Point Plant 4 ADM-109, Writers Guide for Emergency Operating Procedures

5. ADM-100, Procedure Preparation, Reviewer, and Approval Other:

1.0. STEP CAUTION NOTE-SPECIFIC 1.1. Technical Accurac 1.1.1 En Conditions or S toms Information Initials

1. Are the entry conditions of the ERG listed correctly?

0 AOM I 10

t 0

0 e

Verification Guideline for *pwepvy 0-A DM- I I 0 Emergency Operating Proced ures o4'f'/26/N ATTACHhI ENT 2 tltg2 3)

TECHNICALACCURACY VERIFICATIONCHECKLIST 1.1. Technical Accurac (Cont'd) 1.1.2. Instructional Ste Caution and Note Information Initials

l. Are EOP/ERG differences documented or in the Basis Document?

2. Is the ERG technical foundation (strategy) changed by the following changes in EOP steps, cautions, or notes:

a. Elimination

b. Addition

c. Sequence

d. Alteration

3. Are correct, plant-specific adaptations incorporated per ERG:

a. Systems

b. Instrumentation

c. Limits

d. Controls

e. Indications

4. Have licensing commitments applicable to EOPs been addressed.

5. Are differences between the licensing commitments and the EOPs or ERGs documented?

1.1.3. uantitative Information

1. Do the quarititative values, including tolerance bands, used in the EOP comply with applicable EOP source document?

0 ADM 1 io

(

'E

Verification Guideline for dgbggovd 3dtt.

0-A DM-I ] 0 Emergency Operating Procedures 9/26/84 ATTACHM ENT 2

~(gg g 3>

TECHNICALACCURACY VERIFICATIONCHECKLIST 1.1 Technical Accurac Initials 1.1.3 uantitative Information (Cont'd)

'. Where ERG values are not used in the EOP, are the EOP values computed accurately?

3. When calculations are required by the EOP, are equations presented with sufiicient information for operator use?

1.1.4. Plant Hardware Information

1. Is the following plant hardware specified in the EOP available for operator use?

a. Equipment

b. Controls

c. Indicators

d. Instrumentation Verification Completion Date:

Performed By:

Reviewed By:

All actions required by the verification have been compl'eted:

Approved:

0 AOM 110

I ~ ~

~ s

~ ~

~ ~

~ ~ 0 ~

~ ~ .. ~

~ ~ ~ '

I ' I

0 Florida Power &, Light Company Turkey Point Nuclear Plant 0-ADM-111

Title:

Emergency Operating Procedure Validation Plan Safe Related Procedure Responsible Department: Procedure Upgrade Reviewed by PNSC: 84-l 65 Approved by Plant Manager-N: 9/26/84

'0 ADM.111

i

4CC'Cvd Qd'.f.

0-ADM-1) 1 Fmergency Operating Procedure Validation Plan 9/26/84 LIST OF EFFECTIVE PAGES Revision

~Pe e Date 1-17 9/26(84

'0 APtv'i 1)

~ 1

~

~

e 0

0

~ ~

~

' ~; ~

~

~ I ~

~ ~ ~

~

~ ~

~

~

i i

~ ~ ~ ~ ~ ~ ~ ~

P

~ I~ ~ ~ ~ ~ ~

~ ~

~

~

~ ': ~ ~

~ . ~ ~

~ ~ ~ ~ ~ ~ ~

c i

~

, P 0

A~p oval osage 0-A I) M-111 Emergency Operating Procedure Validation Plan 9/26/84 1.0 PURPOSE 1.1 This procedure provides guidance in the administrative process used in validation of the emergency operating procedures (EOPs) and to assign responsibilities for the process.

This procedure applies to EOP validation prior to implementation as well as to validation subsequent to implementation for Unit 3 and Unit 4 of Turkey Point Plant.

2.0 REFERENCE 2.1 PTP. Technical Specifications , 2.2 Turkey Point Plant FSAR.

2.3 Westinghouse Owners Group Emergency Response Guidelines, Revision 1, da ted September 1982.

2.4 Emergency Operating Procedures Validation Guideline (INFO 83-006).

3.0 RESPONSIBII ITIFS 3.1 Plant Mana er Nuclear The Plant Manager - Nuclear shall approve all EOPs and revisions.

3.2 Procedure U rade Su ervisor 3.2.1 The Procedure Upgrade Supervisor shall be responsible for the following:

1. Managing the validation program and ensuring its smooth coordination with the training program.

2. Determining ifvalidation is needed and its scope.

3. Selecting the validation method or methods.

4. Appointing an observer/reviewer team

a. One person per operator for the walk-through validation method (one-on-one).

b. One person for the table-top validation method (one-on-group).

I I.":, ~va: Date 0-AD%I-111 Emergency Opera ting I'rocedure Valid ation P)an 9/26/84 3.2 Procedure U ade Su ervisor 3.2.1- (Cont'd)

5. Reviewing discrepancies and resolutions forwarded to him by observer/review personnel.

6. Forwarding recommended resolutions and procedure changes to the, Plant Manager for approval.

4.0 D E FI N ITI0NS 4.1 Emer enc 0 eratin Procedure EOPs Plant procedures directing operator actions necessary to mitigate consequences of transients and accidents that 'cause plant parameters to exceed reactor protection setpoints, engineered safety feature setpoints, or other appropriate technical limits.

4.2 Emer enc 'Res onse Guidelines ERGs Guidelines that provide technical bases for the development of EOPs.

4.3 EOP Source Documents Documents or records upon which EOPs are based.

4.4 EOP Validation The evaluation preformed to determine that the actions specified in the EOP can be followed by trained operators to manage the emergency conditions in the plant.

'0 AoM 'J ll

0 4'

0-AI)M-))1 Fmergency Operating Procedure Validation Plan 9l26'84 4.0 I)F.F1 NITIONS (cont'd) 4.5 ~Mock-U

'Static device (e.g., models, photos, drawings) that portrays Control Room hardware and configuration.

4.6 Reference Validation Method of validation whereby data developed in common EOP validation program is referenced by similar plants.

4.7 Scenario A structural plan of parameter and pla'nt symptom changes that provide operating cues for the conduct of assessment.

4.8 Table-To Validation Method of validation whereby personnel explain and/or discuss procedure actions steps for an observerireviewer in response to a scenario or as part of an actual industry operating experience review.

4.9 Walk-Throu h Validation Method of validation whereby Control Room operators conduct a step-by-step enactment of their actions during a scenario for an observer/review team without carrying out the actual control functions.

'0 AOM l t 1

App'ovd oc) ap 0-A I) bt-111 Emergency Operating Procedure Validation Plan 9/26/84 5.0 INSTRUCTIONS 5.1 Table To /Walk-Throu h Methodsof Validation 0 ~ ~~ ~ \W ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~

f NOTE I I Regardless of the validation method, the EOP validation process can be described by I the three phases of preparation, assessment, and resolution. I l ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

P~i

~ ~ ~ ~ ~ ~ ~ ~ ~ e ~ ~ ~ ~ ~ ~

5.1.1

1. Table top/walk-through validation method shall use the applicable evaluation criteria presented in Enclosure k, Evaluation Criteria:

2. The designated reviewer shall be responsible for the following:

a. Using and completing Attachment 2, EOP Validation Form.

b. Reviewing the scope of the validation designated by the Procedure Upgrade Supervisor or his representative.

c. Developing or modifying scenarios to support the scope of validation and filling out" Attachment 3, Table-Top/Walk-Through Scenario Form.

d. Modifying/selecting the developed evaluation criteria to support the scope of validation.

e. Selecting operators that are representative of the training level expected of all the operators.

f. Scheduling the needed resources for table-top:

(1) Observer/reviewer (2) Operator(s) involved (3) Conference Room (4) Sets of EOPs and support procedures

g. Scheduling the needed resources for walk-through (1) Observer/reviewer(s)

(2) Operator(s) involved (3) Control Room or Control Room mock-up (4) Set of EOPs and support procedures

I 0

At>p'Oval Date 0-A DM-111 Emergency Operating Procedure Validation Plan 9/26I84 5.1 Table To /Walk-Throu h Methods of Validation (Cont'd) 5.1.2 - Assessmen t

1. Specific guidance for assessment using each validation methodis presented on Enclosure 1, Evaluation Criteria.

2. The designated reviewer shall perform the following duties:

a. Brief the operator on the scope of validation and how the assessment will be conducted.

b. Follow the developed or modified scenario by first giving the plant initial conditions and then give the changing plant parameters as talking or walking through the procedures.

c. Stop the talk-through or walk-through assessment for discussion of any identified discrepancies.

d. Conduct a debriefing with the operators as soon as possible after each walk-through assessment, using the following sequence:

(1) Brief the participants on the purpose and objectives for debriefing.

(2) Have operators present problems and discrepancies which they had identified during assessment.

(3) Have operators provide possible reasons for problems.

(4) Present other problems and discrepancies identified during assessment.

(5) Have operators describe possible reasons for the other problems.

(6) Summarize the findings of the debriefing for the operators.

e. Record discrepancies and comments on Attachment 1, Discrepancy Sheet.

'0 ADM > I l

4 App5OVa Dale 0-ADM-) l 1 F.mergency Operating Procedure Validation Plan 9/26/84 5.1 Table To /Walk-Throu h Methodsof Validation (Cont'd) 5.1.3'esolution I. The designated observer/reviewer shall perform the following duties:

Review comments and discrepancies.

b. Propose resolutions on Attachment ), Discrepancy Sheet, for the Procedure Upgrade Supervisor.

c. Submit the validation package to the Procedure Upgrade Supervisor.

2. The Procedure Upgrade Supervisor shall perform the following duties:

a. Review proposed resolutions with appropriate staff.

b. Select resolutions for incorporation in the EOPs.

c. Present the revised EOPs to the Plant Manager for approval.

3. The following documentation shall be submitted as a validation package:

a. Completed Attachmen t 1, Discrepancy Sheet

b. Completed Attachment 2, EOP Validation Form

c. Completed Attachment 3, Table Top/W'alk-Through Scenario Form

d. Evaluation criteria used 5.2 Referenced Method of Validation 5.2.1 P~t'.

The designated reviewer shall be responsible for the following:

a. 'sing and completing Attachment 2, EOP Validation Form.

b. Identifying all differences in hardware and shift manpower between the Turkey Point Plant Unit 3 or 4 and the referenced plant.

c. Identifying the differences in the format and the level of detail between the EOP to be validated and the referenced EOP.

d. Selecting the applicable data from the referenced validation.

'O.AoM.111

App ave os'.E.

0-AI)M-1]1 Emergency Operating Procedure Validation Plan 9/26/84

, 5.2.2 Assessment

1. The designated reviewer shall be responsible for the following:

a. Evaluation the differences in hardware and shift manpower.

b. Evaluation the differences in the format and the level of detail.

c. Recording discrepancies and comments on Attachment 1, Discrepancy Sheet, with the applicable data selected from the referenced validation.

5.2.3 Resolution

1. The designated reviewer shall perform the following duties:

a. Review comments and discrepancies.

b. Evaluate the potential impact of any differences between the EOP to be validated and the referenced validation.

Propose resolution on completed Attachment 1, Discrepancy Sheet for the Procedures Upgrade Supervisor.

d, Recommend EOP validation by table-top/walk-through method to confirm reference validation results.

2. The Procedures Upgrade Supervisor shall perform the following duties:

a. Review the validation package.

b. Determine the scope of validation needed to confirm the resolutions and initiate an Attachment 2, EOP Validation Form, ifnecessary.

c. Present the revised EOPs to the Plant Manager for approval ifsubsequent validation is not required.

3. The following documentation shall be submitted with the validation package:

a. Completed Attachment 1, Discrepancy Sheet b, Completed Attachment 2, EOP Validation Form used

c. Reference validation package

d. Selected reference data

App ova Da'e 0-A l) M-111 Emergency Operating Procedure Validation Plan 9/26/84 5.3 Documentation The documented items needed to provide a history of the validation program are specified on each validation method. These items shall be mainta>ned as a validation package in the document control storage area in accordance with AP 0190.14, Document Control and Quality Assurnce Records.

'O ADM.111

P

~ ~ ~

~ ~ ~ ~ ~ ~

~

~

~ ~ ~ ~

~ J ~ ~ ~ ~ ~

~ ' ~ ~ ~, ~ ~ ~

~ ~ ~ ~ ~ ~

0 I

~

' ~ ~ ~

~ ~

~ ~ ~ ~

~ ~ ~ ~ ~ ~

' ~ e e ~

~ ~ ~ ~ ~ ~ e ~ ~ ~

~ ~ ~

' ' ~

~ ~ ~

~ ~ ~

~ ~

e ~ ~

~ ~

' e ~ ~ ~ ~

~ e ~

~

0 '

~ ' ~

~

' ~

~ ~ e I

'e

~ ~ ~ ~ ~ ~ ~

~ .ee ~ e ~

(

4 0

ADi> Ovd Db 0-AI)M-I) 1 Emer gency Operating Procedure Validation I'lan 9/26/84 I".NCI.OSU RE l (Page 2 of 3)

E VAI.U ATION C RITE Rl A TT WT 2.0 OPERATIONAL CORRECTNESS 2.1 PLANT COMPATIBILITY 0 X 2.1.1 Can the actions specified in the procedure be performed in the designated sequence?

X X 2.1.2 Are there alternate success paths that are not included in the EOPs?

0 X 2.1.3 Can the information from the plant instrumentation be obtained, as specified by the EOP?

0 0 2.1.4 Are the plant symptoms specified by the EOP adequate to enable the operator to select the applicable EOP?

0 0 2.1.5 Are the EOP entry conditions appropriate for the plant symptoms displayed to the operator?

0 X 2.1.6 Is information or equipment not specified in -the EOP required to accomplish the task.

0 x 2.1.7 Do the plant responses agree with the EOP basis?

0 X Are the instrument readings and tolerances stated in the EOP consistent with the instrument values displayed on the instruments?

0 X Is the EOP physically compatible with the work situation (too bulky to hold, binding would not allow them to lay flat in work space, no place to lay the EOPs down to use)?

0 X 2.1.10 Are the instrument readings and tolerances specified by the EOP for remotely located instruments accurate?

'0 Aohf.1 i 1

4 0

A~<'Ova Ds! p 0-A DM-111 Emergency Operating Procedure Validation I'lan 9/26IS4 ENCLOSURE 1 (Page 3 of 3)

EVAI.UATIONCRITERIA T-T W-T 2.2 OPERATOR COMPATIBILITY 0 X 2.2.1 If time intervals are specified, can the procedure action steps be performed on the plant within or at the designated time intervals?

0 X 2.2.2 Can the procedure action steps be performed by the operating shift?

0 X 2.2.3 If specific actions are assigned to individual shift personnel, does the EOP adequately aid in the coordination of actions among shift personnel where necessary?

0 X 2.2.4 Can the operating shift follow the designated action step sequences?

0 X 2.2.5 Can the p'articular steps or sets of steps be readily located when required?

0 X 2.2.6 Can proce'dure exit point be returned to without omitting steps when required?

X X 2.2.7 Can procedure branches be entered at the correct point?

X Y 2.2.8 Are EOP exit points specified adequately?

0

~ . ~

~ e- ~ ~ ~ '. ~

~ ~

~ ~

~ ~ ~

~ ~ - . ~

~ 4 I e:

~ e o . ~ .

~ ~

' 0 ' 0

~ o

~ I ~

~ ~ ' ~ ~

~ . ~ ~ ~

~ ~ 1 ~

~ ~ ' ~ ~

~ ~ .. ~ ~ ~ ~ ' ~

~ ~ ' ~ ~

~ ~ ~ ~ ~

' ~

I ~

~ ' ~

~ ~

~ ~ . ~ ~

~ ~ ~

~ ~

~ ' '

(

t) tg/

0

PROCEDURES GENERATION PACKAGE Turkey Point Plant Unit3 and Unit4

PROCEDURES GENERATION PACKAGE TABLE OF CONTENTS SECTION PAGE

1.0 INTRODUCTION

1.1 PURPOSE 4 1.2 SCOPE ~ ~ ~ ~ ~ ~ 4 1.3 ORGANIZATION 4 2.0, PLANT-SPECIFIC TECHNICALGUIDELINES 2.1 GENERAL ~ ~ ~ ~ ~ ~ 5 2.2 PROGRAM DESCRIPTION ..........;.......... 6 3.0 WRITERS GUIDE FOR EOPs 3.1 GENERAL ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 7 3.2 DOCUMENT DESCRIPTION ~ ~, ~ ~ ~ ~ 7 4.0 EOP VERIFICATIONPROGRAM 4.1 GENERAL ~ ~ ~ ~ ~ 8 4.2 PROGRAM DESCRIPTION ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 8 5.0 EOP VALIDATIONPROGRAM 5.1 GENERAL 9 5.2 PROGRAM DESCRIPTION ..................... 9 6.0 EO P TRAINING P ROG RAM 6.1 GENERAL ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 10 6.2 PROGRAM DESCRIPTION ..................... 10 6.3 TRAININGPROGRAM GOALS ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 10

~

PG-><PGP<sr:9/26l84 2 of 13

PROCEDURES GENERATION PACKAGE TABLE OF CONTENTS SECTION PAGE 6.0 EOP TRAININGPROGRAM (Cont'd) 6.4 INITIALEOP TRAININGMETHODS 6.5 REQUALIFICATIONTRAINING .................. 12 6.6 TRAININGON REVISIONS TO EOPs ............... 12 6.7 INPUTS INTO TRAININGPROGRAM CHANGES ~ ~ ~ ~ ~

=

~ ~ 12 6.8 EVALUATION ~ ~ ~ ~ ~ ~ 12 Attachment 1 Turkey Point Plant Writers Guide for Emergency Operating Procedures 13

'P G. S/P G P/sr;9/26'S4 3of13

0 PROCEDURES GENERATION PACKAGE

1.0 INTRODUCTION

1.1 PURPOSE The purpose of this Procedures Generation Package (PGP) is to describe the Emergency Operating Procedures (EOPs) development at Turkey Point Plant Units 3 and 4 which are Westinghouse 3 - loop pressurized water reactors.

1.2 SCOPE This document was developed in response to Supplement 1 to NUREG-0737, Item 7.2b, Page 15.

1.3 ORGANIZATION This document consists of the following six parts:

Section 1.0 Introduction Section 2.0 Plant Specific Technical Guidelines Section 3.0 Writers Guide for EOPs Section 4.0 EOP Verification Program Section 5.0 EOP Validation Program Section 6.0 EOP Training Program Each part describes the approach taken as part of the overall EOP Implementation Plan for Turkey Point Plant Unit 3 and Unit 4.

'PG-1(PGP'Sr;9i2644 4of 13

PROCEDURES GENERATION PACKAGE 2.0 PLANT-SPECIFIC TECHNICALGUIDELINES 2.1 GENERAL 2.1.1 The following program for convertinq the Westinghouse Owners Group Emergency Response Guidelines (ERGs) into EOPs has been developed and will be used by Turkey Point Plant Unit 3 and Unit4.

2.1.2 The Westinghouse Owners Group Emergency Response Guidelines, Revision 1, dated September 1, 1983, will be used for the implemented EOPs.

2.1.3 The following major items were considered in the methodology to be used:

1. Mechanics of conversion

2. Location of the plant-specific technical information

3. How the plant-specific technical information willbe used

4. The use of existing EOP's

5. Documentation requirements

6. Use of the background information supplied with technical guidelines

'PG.1/PGP/sr:9/26/84 5of13

PROCEDURES GENERATION PACKAGE 2.2 PROGRAM DESCRIPTION 2.2.1 Mechanics of Conversion

1. P~i The 'designated EOP writing team will obtain and review the following Plant-specific Technical Information (EOP source documents):

a. Westinghouse Owners Group Emergency Response Guidelines (ERGs), Revision 1, with background information

b. FSAR Unit 3 and Unit 4

c. Turkey Point Plant Writers Guide for Emergency Operating Procedures

d. Technical Specifications for Unit 3 and Unit 4

e. The most current revision of existing EOPs

f. As-built plant drawings

2. Writin Plant S ecific EOPs from Westin house ERGs The EOP writing team will follow the ERG's step-by-step, adding footnoted information where designated.

Concurrently, the writers will review appropriate EOP source documents. The use of plant specific technical information or analysis resulting from plant unique design will be included to the ERG format. The inclusion of these design requirements will be covered by two separate documents, the Basis Document, which outlines the logic used for inclusion of the step into the ERG, and the Transition Document, which delineates the flow of information from the ERGs to the plant specific EOPs. The Basis Document is described in O-ADM-109, Writers Guide for EOPs, for Turkey Point.

3. Transition from Existin EOPs to the U raded Plant eci lcE Ps The EOP writing team will ensure that required information in the existing EOPs is properly incorporated into the upgraded plant specific EOPs which'are derived from the Westinghouse ERGs. This will be accomplished by means of a Transition Document, detailed in the Turkey Point EOP Writers Guide, O-ADM-109.

2.2.2 Documentation The completed Transition Documents will be provided as a source document to assist in the EOP verification process and in the revision, review and approval process.

'PG.1/PGPisr:9(26/84 6 of 13

PROCEDURES GENERATION PACKAGE 3.0 WRITERS GUIDE FOR EOPs 3.1 GENERAL 3.1.1 A writers guide. for EOPs is a plant-specific document that provides instructions for writing EOPs. In addition to establishing sound writing principles, the guide helps to promote consistency among all EOPs and their revisions, independent of the number of EOP writers.

3.1.2 The writers guide will be revised, as necessary, based on feedback from operator training, experience, and procedure validation, 3.2 DOCUMENT DESCRIPTION 3.2.1 Information on the following major items is included in the plant-specific writers guide for EOPs.

l. EOP format

2. EOP organization

3. EOP content

4. Mechanics of style 3.2.2 The Turkey Point Plant Writers Guide for Emergency Operating Procedures, is based on both the industry document Emergency Operating Procedures Writing Guideline (INPO 82-017), and the Writers Guide for Emergency Response Guidelines dated September 1, 1983, developed by the Westinghouse Owners Group.

'PG.1/PGPisr:9/26/84 7of 13

PROCEDURES GENERATION PACKAGE 4.0 EOP VERIFICATIONPROGRAM 4.1 GENERAL EOP verification is the evaluation performed to confirm the written correctness of the procedure and to ensure that applicable generic and lant-specific technical information has been incorporated properly.

~ ~ ~

his evaluation also checks that the human factors aspects presented in

~ ~

~

the writers guide for EOPs have been applied.

~

4.2 PROGRAM DESCRIPTION 4.2.1 When developing this EOP verification program, the following major items were considered:

1. How EOP verification willbe performed

2. How completion of the EOP verification process will be documented

3. What process willbe used in resolving discrepancies

,4.2.2 The verification program is based on the industry document Emergency Operating Procedures Verification Guideline (INPO 83-004), developed by the EOPIA Review Group and published by INPO.

. 4.2.3 The Turkey Point Plant verification procedure for emergency operating procedures is provided in Administrative Procedure 0-ADM-110 and addresses the following objectives:

1. EOPs are technically correct, i.e, they accurately reflect the technical guidelines and other EOP source documents

2. EOPs are written correctly, i.e they accurately reflect the Plant-specific Writers Guide

3. A correspondence exists between the procedures and the control room/plant hardware

4. The language and level of information presented in the EOPs are compatible with the qualifications, training, and experience of the operating staK

'PG-1/PGP/srs9/26/84 8 of 13

i

. PROCEDURES GENERATION PACKAGE 5.0 EOP VALIDATIONPROGRAM 5.1 GENERAL EOP validation is the evaluation performed to determine that the actions specified in the procedure can be performed by the operator to manage the emergency conditions effectively. The methodology for EOP validation utilizes present, available methods at the Turkey Point Plant while recognizing and allowing for future improvements. The EOP validation will evaluate the operators'bility to manage emergency conditions using the EOPs. It will validate that part of the EOP not covered by any technical validation of generic technical guidelines.

5.2 PROGRAM DESCRIPTION 5.2.1 When developing this EOP validation program, the following major items were considered:

1. How EOP validation willbe performed

2. How to appropriately use walk-throughs or table-top methods of validation

3. How operating and training experience will be integrated into the program evaluation

4. The evaluation criteria to be applied and the methods to be followed in resolving discrepancies

5. How completion of the EOP validation process will be documented 5.2.2 The program is based on the industry document Emergency Operating Procedures Validation Guideline, ('INPO83-006),

developed by the EOPIA Review Group and published by INFO.

The Turkey Point Plant validation procedure for emergency operating procedures is provided in Administrative Procedure 0-ADM-111 and addresses the following objectives:

1. EOPs are usable, i.e., they can be understood and followed without confusion, delays, and errors

2. A correspondence exists between the procedures and the control room/plant hardware

3. The instructions presented in the EOPs are compatible with the shift manpower, qualifications, training, and experience of the operating staff

4. A high level of assurance exists that the procedures will work, i.e., the procedures guide the operator in mitigating transients and accidents

'PG-)/PGPlsr:9(26/84 9 of 13

V 0

PROCEDURES GENERATION PACKAGE 6.0 EOP TRAININGPROGRAM 6.1 GENERAL The EOP training program was developed to support implementation of the EOPs. The EOP writer interfaces with the Training Department to ensure a supportive program.

6.2 PROGRAM DESCRIPMON I

6.2.1 When developing the EOP training program, the following major items were considered:

1. What type of operator training should be provided (initial, requalification)

2. What method of operator training should be followed

3. What operator knowledge and skill level is desired

4. What training material is needed to support EOP training requirements

5. What current operator licensing requirements exist

6. What method should be provided for operator feedback into the training program and EOP development 6.3 TRAINING PROGRAM GOALS 6.3.1 The initial, overall training goals for the EOP training program are as follows:

1. To enable the operators to understand the structure of the EOPs

2. To enable the operators to understand the technical basis of the EOPs

3. To 'enable the operators to use the EOPs under operational conditions 6.3.2 Training program objectives to support these goals will be developed for each lesson plan.

PG-1/PGP/sr.9<26/84 10 of 13

PROCEDURES GENERATION PACKAGE 6.4 INITIALEOP TRAININGMETHODS The EOP training program is established to instruct operators in the EOPs. The program consists of classroom instruction and procedure walk-throughs. Non-plant specific simulator exercises willbe conducted when available but is not considered a requirement for EOP implementation.

6.4.1 Classroom Instruction Classroom instruction sessions will be conducted. Included in the information presented during this method will be the following:

1. The logic behind the development of EOPs

2. The process used to develop the EOPs

3. The EOPs themselves, including supporting technical and human-factors information 6.4.2 Procedure Walk-Throu hs An important part of the instruction on EOPs will be the practical experience gained through procedure walk-throughs.

This walk-through training will also concentrate on information flow and interaction with the physical plant.

6.4.3 Similator Exercises Training on the EOPs will be conducted for all licensed operators using scenarios on a non-plant specific simulator.

Training will be conducted with all operators performing their normal control room functions. Until the plant-specific simulator is completed, complicated scenarios will be discussed during classroom instruction and procedure walk-throughs.

'PG.1/PGP/Sr:9/26.'84 11 of 13

PROCEDURES GENERATION PACKAGE 6.5 RE UALIFICATIONTRAINING All licensed operators will conduct procedural walk-throughs for refresher training. The walk-throughs may be conducted either in the plant control room or at a simulator. Simulator scenarios will be as described in Section 6.4.3. Simulator exercises will be evaluated by the Nuclear Training Department or Operations Department Supervision.

Evaluation results will be critiqued for feedback to the operators and to determine additional training needs.

6.6 TRAININGON REVISIONS TO EOPs Training on revisions to EOPs will be accomplished through a program of required readings (self taught), pre-shift briefings, or lectures in the requalification program. Determination of appropriate methods will be made by the Nuclear Training Department.

6.7 INPUTS INTO TRAININGPROGRAM CHANGES 6.7.1 Su ortin Trainin Material Chan es Changes to supporting training material will be factored into updated lesson plans and operator memos. Some of the supporting material identified to date is as follows:

1. ERGs

2. Background Information 1

3. Associated WCAPs 6.7.2 0 erator Feedback Operator feedback resulting from EOP verification, EOP validation, and training critique forms will be used to keep the training program and EOPs current and relevant.

6.8 EVALUATION An evaluation will be performed to ensure that the. training program goals have been accomplished.

'PG. 1 /PGP/sr:9/26/84 12 of 13

1 PROCEDURES GENERATlON PACKAGE ATTACHMENT1 TURKEY POINT PLANT WRITERS GUIDE FOR EMERGENCY OPERATING PROCEDURES

'PG-1IPGP.sr:9/26i84 13 of 13

Florida Power 8r, Light Company Turkey Point Nuclear Plant 0-ADM-109

Title:

Writers Guide for Emergency Operating Procedures Safe Related Procedure Responsible Department: Procedure Upgrade Reviewed by PNSC: 84-165 Approved by Plant Manager-N: 9/26/84

Writers Guide for App'eve Da't 0-A DM-109 Emergency Operating Procedures 9/26'84 LIST OY F.FFECTI VF. PAGF.S Revisioa

~Pa e Date 1-35 9/26/84 0-ADM-109

Writers Guide for r >~ a.a Da'e 0-ADM-)09 Emergency Operating Procedures 9/26/84 TABI.F. OF CONTENTS Section ~Pa a l..0 nv~nn PIJ RPOSE ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 'I ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 4

2.0 REFERENCES

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 4 3.0 RESPONSIBILITIES 4 4.0 DEFI NITIONS ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 5 5.0 PROCEDURE 5.1 EOP Identification ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 9 5.2 Format 5.3 Writing Instructional Steps.... ~ ~ ~ ~ ~ ~ ~ ~ ~ 13 5.4 Mechanics of Style 23 5.5 Reproduction 27 5.6 Basis Document 27 5.7 Transi tion Document ~ ~ ~ ~ ~ ~ ~ o 28 ENCLOSURES/ATTACHMENTS:

Enclosure 1 Example Instruction Steps........... ~ ~ ~ ~ ~ ~ ~ ~ ~ 31 Enclosure 2 Formats For Status Trees ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 32 Enclosure 3 Action Verbs ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 33 0 ADM-109

e Writers Guide for 4>> ov~ oa'e 0-A I) M-109 Emergency Operating Procedures 9/26/84 1.0 P U R POSE This procedure provides administrative and technical guidance on the preparation of Emergency Operating Procedures. This guide applies to Optimal Recovery Guidelines, Function Restoration Guidelines, and Cntical Safety Function Status Trees.

2.0 REFERENCES

2.1 Administrative Procedure 0103.37, Standard Acronyms and Abbreviations 2.2 ADM-100, Procedure Preparation, Review and Approval.

2.3 ADM-101, Writers Guide for Administrative and Normal Operating Procedures 2.4 NUREG-0899 Guidelines for the Preparation of Emergency Operating Procedures.

2.5 INPO 82-017 Emergency Operating Procedures Writing Guideline 2.6 INPO 83-007 Emergency Operating Procedures Generation Package Guideline 2.7 Westinghouse Owners Group Emergency Response Guidelines 3.0 RES I'ON SI 8 I I.ITIES 3.1 Ori nator The originator of any Emergency Operating Procedure is responsible for researching reference sources, verifying the accuracy of technical information, and confirming the usability of new or revised procedures.

Writers Guide for <wD~ovb Db'tP 0-A I) M-109 Emergency Operating Procedures 9/26/84 4.0. I) E I'IN ITION S 4.1 Caution A procedure element containing information about potential danger to equipment or personnel.

4.2 C~hallen e A condition which is expected to jeopardize the plant safety state (in reference to a Critical Safety Function).

'.3 Critical Safet Function a

An activity which serves to protect the integrity of one or more of the physical barriers against radiation release.

4.4 ~Dia osis The process of identifying a particular plant state by examining the existing symptoms. In symptom-based procedures, diagnosis is the process used to direct the operator to the appropriate procedure steps to address the existing plant state (symptoms) and does not require identification of the cause (event) of the symptoms.

4.5 Emer enc 0 eratin Procedures(EOPs)

Plant procedures that specify the operator actions required to mitigate the consequences of transients and accidents that cause plant parameters to exceed reactor protection system setpoints, engineered safety feautres setpoints, or other appropriate technical limits.

4.6 EQP Source Documents Documents or records upon which EOPs are based.

4.7 Emer enc Res onse Guidelines ERGs The detailed and complete network of generic emergency response guidance developed by the Westinghouse Owners Group for Westinghouse plants. The idance includes Optimal Recovery Guidehnes, Critical Safety Function tatus Trees and Function Restoration Guidelines.

0 AONi 'I09

ll

\

5'

b

%'riters Guide for  ! yp overt Date 0-A I) M-109 Emergency Operating Procedures 9/26/84 4.8 Event Tree A branching diagram which illustrates schematically the possible combinations of sequential or multiple events.

4.9 Function Restoration Procedures FRs Those procedures which respond to Critical Safety Function challenges.

Guidance is provided to restore the Critial Safety Function to a satisfied condition. Typically, actions are based on the severity of the challenge and may not correspond to "good operational practice".

4.10 Human Factors The elements of relationship between a human and his work, i.e., those things which effect how well a control room operator is able to use a procedure:

legibility, vocabulary, grammar, training, external stress, etc.

4.11 Immediate Actions (ste s Actions which can be performed from memory, i.e., without reference to the written procedure (typically verification of automatic actions).

4.12 ~Ma Used to denote permission; neither a requirement nor a recommendation.

4.13 b ote A procedure element conveying advisory or administrative information.

4.14 ~Otimal Most favorable or. best (response) for the particular situation.

4.15 0 timal Recover Procedures ORP)

Those procedures network which provide guidance to recover the plant in the most efficient manner to a safe and stable end state. Typically, actions correspond to "good operational practice".

4.16 ~coverCr The process of returning to a stable and safe condition. Recovery implies establishing operator control over plant processes and taking the plant to a stable and safe end state.

0 ADM.109

Writers Guide for Approval Date 0-A DM-109 Emergency Operating Procedures 9/26/84 4.17 Restoration The act of putting something into a prior state. Restoration implies establishing operator control over plant processes and returning the plant state to one in which the Critical Safety Functions are satisfied.

4.18 Shall Used to denote a requirement.

a 4.19 Should Used to denote a recommendation.

4.20 Status Tree A graphical device to quickly evaluate the condition of a Critical Safety Function. This identifies off-normal conditions and the appropriate procedure for restoration of the Critical Safety Function to a satisfied condition.

4.21 ~S)toms Process parameters used to identify and characterize a plant or condition.

4.22 Transition A change from one place to another in the EOPs, either from one step tc another step or from one procedure to another.

4.23 Tvt o-column format The manner of presenting operator instruction steps in the EOPs. Expected conditions and responses are listed in the left-hand column to facilitate normal usage. Contingency actions are separated by placement in the right-hand column.

4.24 Will Used to denote a requirement.

0 ADh,a 109

0 Writers Guide for apprOvs" Date 0-A DM.10S Emergency Operating Procedures 9/26/84 5.0 PROCEDURE 5.1 EOP Identification 5.1,1 Desi ation and Numberin

1. The emergency operating procedures (EOPs) shall specify operator actions'to be taken during plant 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. Every separate EOP shall have its own descriptive name which summarizes the scope of that procedure, or states the event(s) which it is intended to mitigate.

3. Every separate EOP shall have its own alpha-numeric designation to supplement the descriptive title. Letter designators are to be assigned according to the definitions as follows:

a. E a procedure for diagnosis and recovery from design basis events.

b. ES a procedure which supplements the recovery actions of an E procedure.

C. ECA a procedure which supplements both the E and ES procedures by providing recovery actions for lo~

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.

d. F a procedure for diagnosis of challenges to a Critical Safety Function -represented in tree format.

e. FR a procedure for restoration of a Critical Safety Function (CSF) to a satisfied condition.

f. S designator for SUBCRITICALITYCSF

g. C designator for CORE COOLING CSF

h. H designator for HEATSINKCSF

i. P designator forINTEGRITYCSF

j. Z designator for CONTAINMENTCSF

k. I designator for INVENTORYCSF 0 AOM 109

Writers Guide for Approve oats 0-A I)M-109 Emergency Operating Procedures 9/26!84 5.1 EOP Iden ti fica tion 5.1.1 Desi nation and Numberin (Cont'd) 4, Optimal recovery procedures shall be designated by the letters E, ES or ECA plus a sequentially assigned number designator.

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 sequentially assigned decimal integer.

5. ECA procedures shall each have a number designator consisting of an integer plus a decimal integer. Related procedures shall be ass>gned sequential decimal integers.

6. Letter and number designators shall be separated by a hyphen.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ IQ EXAMPLE E-0 ES-O. 1 E5-1.2 E5-1.3 ECA-O.O ECA-1. 1 ECA-2. 1

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

e ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

Critical Safety Function Status Trees shall be designated by the letter F plus a number designator. Number designators shall consist of the sequentially assigned number zero plus a decimal integer.

8. Letter and number designators shall be separated by a hyphen.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 EXAMPLE F-0.2

~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

0 ADM-109

l0 W ri ters Guide for AOP<O>b Dh 0-A DM-109 Emergency Operating Procedures 9/26/84 5.1 EOP Identification 5.1.1 Desi nation and Numberin (Cont'd)

9. Function Restoration Procedures shall be designated by the letters FR plus additional letter which corresponds to the respective Critical Safety Function. All the separate procedures related to a particular Critical Safety Funct>on are assigned decimal integers in increasing order.

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

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE FR-S. t FR-S.Z 5.1.2 Revision Numberin Every separate procedure shall have an assigned revision date to identify its time of origin.

5.1.3 Pa e Numberin and Identification Each page of the procedure shall be identified by the procedure title.

alpha-numeric designator, and revision date in a title block at the top of the page. Each page number shall be specified as" of located at the top of the page. The last page of instructions shall have the word "END OF TEXT" following the last instruction step.

0 AOM >09

0 ll

ii Writers Guide for 499~0vJ DJtt 0-A DM-109 Emergency Operating Procedures 9/26/84 5.2 Forma t

~ ~ ~

~ ~ ~ ~

NOTE l I I

~ This section describes the format that is to be applied consistently to all Emergency Operating Procedures. I

~ ~ ~t~ ~ ~ ~

~ ~ ~ ~ ~ M ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ )

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 5.2.1 Procedure Or anization 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

[ NOTE I I

~

Any individual procedure might contain only the three required elements, or ~

addhtional elements as necessary to present the intent of the procedure. I l ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ o J

1. All EOP's are to employ a common structure as required consisting of five elements as follows:

a. COVER SHEET (all procedures) - identifies procedures by title, number, revision, applicable unit, etc.

b. INSTRUCTION STEPS (all procedures) - presents the stepwise operator instructions.

c. FIGURES (as required) -presents usually graphical data to supplement action steps.

d. ATTACHMENTS (as required) - presents non-graphical information to supplement action steps.

e. FOLDOUT PAGE (as required) - presents information which is applicable throughout the guideline(s) that it follows.

2. The sequence of procedure elements is always in the order specified. Page numbering is sequential through all the elements comprising any procedure.

0 ADMi109

~ '

IR

%'riters Guide for App(QVA Db'-P 0-A I) M-109 Emergency Operating Procedures 9!26'S4 5.2 Format (Cont'd) 5.2.2 Pa e Formats

1. All pages of the Emergency Operating Procedures shall use the same page structure. This page structure employs a pre-printed border to assure all margins are correctly maintained, and pre-printed designator and page boxes to verify completeness and consistency.

2. The pages for presentation of operator action steps shall use a two-column format within the pre-printed border. The left-hand column is designated for expected operator actions and response, and the right-hand column is designated for contingency actions when the expected response is not obtained.

These pages shall use pre-printe'd title blocks above the separate columns (including the "step" column) for uniformity See Enclosure 1.

3. 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".

5.2'.3 Instructional Ste Numberin

1. Procedures steps shall be numbered as follows:

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE

1. High-level step

a. Sobstep (ifnecessary)

1) Detailed instroctions (i f necessary)

2. 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 ( ~ ). 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.

O.ADM.109

rage 13 Writers Guide for apprOva< Date 0-ADM-109 Emergency Operating Procedures 9/26/84 5.2 Format 5.2.3 Instructional Ste Num berin (Cont'd)

For those procedures which are the entry procedures into the ERG 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, ifpossible. Immediate action steps are identified by a NOTE prior to the first action step.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

NOTE l

I Steps 1 through 10 are IMMEDIATEACTION steps.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

Many'of 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.

5.3 Writin the Procedure 5.3.1 Pur ose and S tom The first section shall be titled PURPOSE and should 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 shall be titled SYMPTOMS OR ENTRY CONDITIONS. For procedures that are entry ORPs, a symptom summary is sufficient. For other procedures, which can only be entered by transition from previous procedures, a summary of the entry conditions should be provided.

5.3.2 0 rator 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.

0 ADM 509

14

%writers Guide for App<Ovb Emergency Operating Procedures Ob1t'/26/84 0-A I) M-109 5.3 Writin the Procedure 5.3.2 0 erator Actions (Cont'd) 2." All steps are assumed to be performed in sequence unless stated otherwise in a preceding NOTE. 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.

3. Actions required in a particular step, should not be expected to be corn lete before the next step is begun. If assigned tasks are short, t en the expected action should 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 com leted prior to continuation, this condition must be state c ear in that step or substep.

Refer to Enclosure 1 as an example of the format for presenting operator actions in the following steps.

5. The left-hand column of the two-column format shall be used for operator instruction steps and expected responses. The following rules of construction apply:

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

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

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

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE Check Sl Accumulator Isolation Valve Status;

a. Power to isolation valves - AVAILABLE

b. Isolation valves - OPEN 0 ADM 109

Writers Guide for <Pg'Ovb Dd'0 0-A DM- I 09 Emergency Operating Procedures 9/26'S4 5.3 Kritin the Procedure 5.3.2 0 erator Actions (Cont'd)

5. d. Ifonly 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

e. Left-hand column tasks should be specified in sequence as ifthey 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.

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

g. All procedures should end with a transition to another procedure, or with direction to consult plant supervision for guidance.

6. 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:

a. Contingency actions should identify directions to override automatic controls and to initiate manually what is norm"ally initiated automatically.

b. 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.

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

O.ADM 109

0

%'riters Guide for 4~p~ova Qs'.e 0-A DM-109 Emergency Operating Procedures 9/26/84 5.3 W~ii t F 'd 5.3.2 0 erator Actions (Cont'd)

6. d. 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.

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

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE Establish Letdown: Establish excess letdown:

a. 1)

b. 2) 3)

0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

As a general rule, all contin ent transitions to other procedures take place out o t e right-hand column.

(Deliberate transitions may be made from the left-hand column.)

If a contingency action cannot be com leted. the user is expected to proceed to the next step or su step in the left-hand column unless specifically instructed otherwise.

When writing Hie procedure, this rule of usage should be considered in wording subsequent left-hand column instructions.

h. If a contingency action must be completed prior to continuing, that instruction must appear explicitly in the right-hand column step or substep.

0 ADM.109

'J l7 Writers Guide for I<DI<<Oebt Oatp 0-A I) M- l 09 Emergency Operating Procedures 9/26/84 5.3 Writin the Procedure (Cont'd) 5.3.3 Use of Lo c Terms The logic terms AND, OR, NOT, IF NOT, WHEN, can NOT and THEN, are M6e use2 to descr<r>e prec>sely a set of cond<t<ons or a sequence of actions. Logic terms shall be highlighted for emphasis by capitalizing and underlining.

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

3. 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, ttte word THEN, and the action to be taken.

4. IF is used for an unexpected, but possible condition.

5. WHEN is used for an expected condition.

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

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

IF ... NOT or IF ... can NOT should be used when an operator must respond to the seconnno'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.)

5.3.4 Notes and Cautions Because the present action step wording is reduced to the minimum essential, certain additional information is sometimes desired, or necessary. This non-action information is presented as either a NOTE or a CAUTION.

0-AOM f09

e 18 IA'riters Guide for >Op'ovsi oat@

0-A DM-109 Emergency Operating Procedures 9/26/84 5.3 Writin the Procedure 5.3.4 Notes and Cautions (Cont'd)

2. To distinguish this information from action steps, it shall extend across the entire page and shall immediately recede the step to which it applies, Each category (NOTE or ON) shall be preceded by its descriptor in large, bold, letters.

Multiple statements included under a single heading shall be separately identified by noting them with bullets (o).

CAUTION When SI actuates, plant conditions exist which require actions not covered in this procedure. Therefore, a transition to E-O, Reactor Trip or Safety Injection, should be made.

~ The foldout page provides a list of important items that should be continuously monitored. If any of the parameters exceed their limits, the appropriate operations should be initiated.

3. 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.

4. As a general rule, neither a CAUTION or a NOTE shall contain an instruction/operator action; however, reference may be made to expected actions in progress.

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

5.3.5 Transitions to Other Procedures or Ste s

1. Certain conditions require the use of a different procedure or step sequence. Transitions are specified by using the words "go to" folIowed by the procedure designator, title {in ALL CAPITALLETTERS) and step number.

~ ~ e ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE Go to ES-0. 1, REACTOR TRIP RESPONSE, Step 1 0 ADM 'i09

Writers Guide for Ape~Ova Os<e 0-A I) M-109 Emergency Operating Procedures 9/26/84 5.3 Writin the Procedure (Cont'd) 5.3.6 Com onent Identification

1. Equipment, controls and displays shall be identified in "operator language" terms. Standard abbreviations which may be used throughout the procedures are listed alphabetically ia Administrative Procedure 0103.37, Standard Acronyms, and Abbreviations. Where similar components are used in both primary and secondary systems, it is always necessary to clarify the location, even ifthe wording appears redundant.

EXAMPLE PRZR PORV vs. SG Steam Dump to Atmosphere identifies the pressurizer power operated relief valve as distinct from a steam generator power operated rehef valve.

5.3.7 Level of Detail To allow an operator to eAiciently 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) shou not e inc uded. Many actuation devices (switches) in the control room are similar, even though the remotely performed functions are not, so certain action verbs listed he're are recommended.

n

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

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

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

d. Use "trip/close" for electrical breakers.

e, 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.

O.ADM 109

Writers Guide for 4oorova'- Date 0-A I) M-109 Emergency Operating Procedures 9/26/84 5.3 Writin the Procedure (Cont'd) 5.3.8 ~Fi ree

1. Ifneeded to clarify operator action instructions, figures shall be added to a procedure. Any figure used should be constructed to fit within the pre-printed page format. Certain rules of construction shall apply:

a. All wording on the figure should be at least as legible (type size and spacing) as the'instruction steps in the procedures.

b. Each figure should occupy a complete page and should be uniquely identified by a figure and title. The figure number should consist of the gui'deline designator, without unctuation, followed by a hyphen and an integer.

~

ultiple figures shall be assigned sequential integers.

~

~ ~ ~ ~ ~ ~ ~ ~ e ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE Figure ES-03-1 Figure FR- 13-1 C. Figure titles should explain the intent or content of the figure.

The figure number and title will be placed at the top of the page just above the pre-printed border.

e. Ifthe figure is a graph, all the numbers and wording should be horizontal and the independent variable should be lotted on the horizontal (X) axis. Grid line density should

~

e consistent with the resolution expected from the graph.

~ ~

Any labeling required on the graph should have a white

~ ~

(not graph) background.

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.

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

0 ADM.'l09

4' 8'riters Guide for ApPPQvd 0-A I) M -109 Emergency Operating Procedures Od'.I'/26/84 5.3 Wri tin the Procedure (Cont'd) 5.3.9 Tables Tables may be used within the text of a procedure to clearly present a large number of separate options. A,table shall immediately follow the step or substep which makes use of it.

Therefore, it-does not require a unique number and title. Any table should be completely enclosed by a distinct outline; if necessary, it may extend into the adjacent column because of this delineation.

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

3. All columns and,rows of information in a table should be defined by solid lines.

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

5.3.10 Attachments Supplementary information or detailed instructions which would unnecessarily complicate the fiow 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 should be the same as for the procedure. Attachments should use a single- column, full-page-width format.

3. Physically, Attachments should be located after any Figures belonging to the procedure. Attachment pages are numbered in sequence with normal procedure pages.

5.3.ll 3~15 3 Only a single foldout page should be supplied for each "E-series" and "ECA-series" of procedures. Its page number shall reflect its position in that procedure. The foldout page will be titled "FOLDOUT FOR E-X SERIES PROCEDURES", and should use a single-column, full- page-width, format.

2. Each set of operator information shall be numbered sequentially and have an explanatory title. The title shall be capitalized and underlined for emphasis. This page contains those important actions which can be performed at ~an step in the applicable procedure.

O.ADM.109

0 Writers Guide for 459<0>h DB'4 0-A DM-109 Emergency Operating Procedures 9/26/84 5.3 Writin the Procedure (Cont'd) 5.3.12 Status Tree Format

1. Critical Safety Function Status Trees may be presented in either the "branch" or "block" versions (see Enclosure 2, Status Tree Priority Identification Symbols), but all trees in the set must use the same format. Similarly, the trees may be oriented either vertically or horizontally on a page, so long as the orientation is consistent over the set.

2. Color-coding and/or line-pattern-coding shall be used from each last branch point to its terminus.

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

4. 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.

5. Statements shall be worded so that the favorable response is the downward branch (branch version) or yet exit (block version).

Termini shall be ordered so that REDs are uniformly at the top*

and GREENs at the bottom. Termini order should be RED-ORANGE - YELLOW -GREEN ifpossible.

5.4 Mechanics of St le 5.4.1 ~Sellin

1. Allspelling should be consistent with modern usage as specified in the Webster's Third New International Dictionar and Webster's ew o e ate Dictionar .

0 ADM-'09

0 54 Writers Guide for < pvt 3 rt v J D d 't p 0-AI)M-]09 Fmergency Operating Procedures 9/26l84 5.4 Mechanics of Style (Cont'd) 5.4.2 Punctuation

1. 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:

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

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE Stop the follovving equipment:

b. Use a comma after conditional phrases for ease of reading.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~

EXAMPLE IF level exceeds 50%, THEN ...

c. Use a period to indicate the end of complete sentences in right-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.

5.4.3 ~dit II*

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

a. Logic terms shall be capitalized and underlined.

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

c. Titles of procedures should be completely capitalized whenever referenced within any procedure.

d.

e.

Qp I tt I p Abbreviations are commonly capitalized.

yt ptt 5* dye f, Section headings on foldout pages are capitalized and underlined.

0 AON.-i09

~ ~ 9f KS

%'riters Guide for 4~p ova Da',w 0-A I) N -109 Emergency Operating Procedures 9/26/84 5.4 Mechanics of St le (Cont'd) 5.4 4 Vocabula I. 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.

2. 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 Enclosure 3, Action Verbs.

3. Some words have unique meanings as listed below:

a. Manual (manually) - an action performed by the operator in the control room. (The word is used in contrast to an automatic action, which takes place without operator intervention.)

b. 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.

4 Certain other words are to be avoided simply because they are not defined when used without modification'. These include:

approximately, rapidly and slowly. The same words become acceptable when some clarification is provided; clarification is provided; clarification normally is part of a lower-level substep.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

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

5. 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 flowrates. The words "above"and "below" should not be used in this context.

0 AD".i09

0 Writers Guide for Apr ova> Date 0-A I) M-l09 Emergency Operating Procedures 9/26I84 5.4 Mechanics of St le (Cont'd) 5.4.5 Numerical Values

1. 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).

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

3. 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.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ Q

~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE 250 psig maximum 350 F minimum between 450'F and 500'F

4. Tolerances can be expressed by stating the normal value followed by the acceptable range in parenthesis.

~ ~ ~ 4 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ t ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE 550'F (540'F to 560'F) - Correct 550'F + 10'F, Incorrect

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0

5. 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.

5.4.6 Abbreviations and Acron s

1. Abbreviations and acronyms should be limited to those commonly used by operators. Abbreviations and acronyms should be used whenever possible to simplify the procedures.

2. Abbreviations and acronyms from Administrative Procedure 0103.37, Standard Acronyms and Abbreviations should be uniformly capitalized whenever they are used.

0 ADNi 109

Writers Guide for ApprOva'a:e 0-A I) M -109 Emergency Operating Procedures 9/26/84 5.5 ~55 5.5.1 ualit ofRe roduction 1, Reproduction will be done on a standard copier, single- sided copy only.

2. All copies will be checked for readability.

3. All copies will be checked to insure that all four (4) borders are visible.

5.6 Basis Document BD 5.6.1 P~ur ose The purpose of this document is to provide the basis used in the preparation of plant emergency operating procedures and for the development of operator training programs.

5.6.2 Title and Desi nation Each basis document shall include in its title the same alpha-numeric designator and title of the procedure for which it is written.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE BD. E-0 Reactor Trip or Safety Injection 5.6.3 Revision Datin The basis document shall correspond in revision date to the procedure for which it is written. Ifa new revision of a procedure is approved, appropriate modifications shall be made to its basis document, both in technical content and descriptive material.

D.ADM >09

0 VSCKCourt NO <<OCOOLJ~C I lt>t ~ gaia Writers Guide for c pp ova Date 0-A I) M-109 Emergency Operating Procedures 9/26/84 5.6 Basis Document (BD) (Cont,'d) 5.6.4 Basis Justification The justification for the use of an instructional step will consist of, but not be limited to, the following information, as applicable.

1. Document used as a basis for developing the associated step.

2. A summary of the reason for the step.

3. Identification of regulatory commitments.

4. Management directives.

5. Plant practices.

6. Vendor recommendations.

5.6.5 Basis Content The basis for an instructional step should be as brief as possible without compromising the integrity of the document, 5.5.6 Basis Document Placement The Basis Document will be Attachment 1 for all EOPs.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE Left Page Right Page Document 'asis Procedure

1. To provide a system flowpath 1. Open TPCW Htx ICW Outlet Valve, (Number )

0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 5.7 Transistion Document 5.7.1 Use of Transition Documents

1. The Transition Document is used to indicate to the Plant Nuclear, Safety Committee where the information is located in the old procedure in respect to an upgrade procedure.

0 ADM.109

L i'toceduie eo wt~eggre iA<e "r" Zp Writers Guide for 0-AI)M-]09 Emergency Operating Procedures 5.7 Transistion Document 5.7.1 Use of Transition Documents (Cont'd)

2. Topics in the old procedure shall be enclosed in a block and a reference made to the location of the old information. If the information has been deleted, this shall be indicated and a general reason stated.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

EXAMPLE EMERGENCY OPERATING PROCEDURE 20000 (E-O), Page 4 IMMEDIATEACTIONS AND DIAGNOS TICS

NOTE 1

5. 1.3 Verify the following:

1. Safety Injection flow (FI-'-943) from at least one train is delivered on the reactor coolant system when the . .'eing Reactor Coolant System pressure is below the safety pump shutoff head (approximately 1400 psig.) If:.'njection not, at tempt to operate equipment manually or locally.

NOTE2 NOTE: Safety Inlection initiation with flow to the core is .

an UNUSUAL EVENT. Notify the Plant Supervisor- '.

Nuclear.

0

NOTE 3

2. Auxiliary Feed water flow from at least one trainis being '.

delivered to the steam generators. If not, attempt to .

operate equipment manually or locally.

TRANSITION DOCUMENT:

NOTE 1 Thisinformationis now presentedin E-0 Step 3.15.

NOTE2 This information is now presentedin Emergency Procedure 20101

NOTE3 This information is now presentedin E.O Step 3. 16

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

0 ADM 109

%'riters Guide for 0-ADM-109 Emergency Operating Proce'd ures 5.7 Transistion Document 5.7.1 Use of Transition Documents (Cont'd)

3. This transition document shall be included with the upgrade procedures generated from the Procedure Development Group.

END OF TEXT 0 ADA. >09

PCOCedure HO Pr OC ed uie Title 4vt 3I Writers Guide for App'ova Oatr.

0-A I) M-109 Emergency Operating Procedures 9/26r'84 KNCLOSURK I

~IPg l 1)

EOP SAMPLE PAGE FORMAT

>ciitdv'r ivy t ortrrvir tint 3EO Reactor Trip or Sa(ety lfklectiott X/XX/XX STEP ACTIONIEXPECTED RESPONSE RESPONSE NOT OBTAINED Check lf SGs Art Not Faulttd:

a CheCI p eSSuie S in al'GS ~ ~ Go to f ~

2 ~

F AULT ED STE Alit'EHE RAZOR ISOLATION, Step I

~ NO SG PRESSURf DECREASING IN AN UHCON ROLI.ED MANNER

~

NO SG COMPLETELY DEPRES ~

SURIZED Check lf SG Tubes Art Not Ruptured Go to f.3. STEAM GENERaTOR TUBf RUPTURE. Step I Condensti <<r eltctor rad ation-NORMAL SG blowdown radiation NORMaL ~

25 Check l(RCS ls Intact: Go to E t. LOSS OF REACTOR OR Sf CONDAftv COOLANT, Step I

~ Conta nmtnt rad ation NORMAE ~

trav

~ Conta nment piessuit ~ HORMa;

~ COntairlrntnt rt(il(ulatidri Sump leve'I ~ HORMAL CheCk If SI FIOw ShOuld Bt Terminated:

a ltCS subcoolinp based on ccvt e<<t TCs ~ ~ DO NOT STOP Sl PUMPS Go to Step GRf ATfR THAN 3P~F ZB b Secondary heal s nk b iF ntithe. COnditiOn SaUSfied, ~TH N DO NOT STOP SI PUMPS Go to Step

~ Total feed flow to SGs ~ GREaTER 28 THAN 390 GPM AR.

~ Narrow ranpe Fever in at Itast one SG ~ GIIEATER THAN c RCS pressure. c DO NOT STOP SI PUMPS Go to Step 2B

~ Pressure - GRfATER THAN I64 PSIG

~ PreSSuie ~ STABLE OR INCRE ASING d PRZR Level ~ I Sv DO NOT STOP SI PUMPS Try tO Stabilist RCS Pressure wdh normal PRZR spray Return to Step lfia 0 ADM.I09

9'riters Guide for Ape ova Da't 0-A I) M- I 09 Emergency Operating Procedures 9/26/84 KNCI.OSVRF. 2

~(Pg 1 STATVSTREE PRIORITY IDENTII'ICATIONSYMBOL Table 2 STATUS TREE PRIOR!TY IDENTIFICATION Symbol Color Line Code Code Status/Response Red The critical safety function is under extreme challen e; imme iate operator action is required.

Orange ~ N ~ 5 The critical safety function is under severe challen e; prompt operator action is required.

Yellow ~ ~ ~ ~ ~ ~ The critical safety function Dp taken.

t~v condition is off - normal.

Green The critical safety function is satisfied. No operator action is needed.

0 ADNl 109

U Writers Guide for 0-ADM-109 Emergency Operating I'rocedures ENCI.OSl'RK 3

~(P K 1 3)

ACTlON VERBS Actuate To put into action or motion; commonly used to refer to automated, multi-faceted operations Align To arrange components into a desired configuration Allow To permit a stated condition to be achieved prior to proceeding, for example, "allow discharge pressure to stabilize" Block To inhibit an automatic actuation Check To perform a comparison with a procedural requirement "Check ifSI can be termined" Close To change the physical position of a mechanical device so that it prevents physical access or flow or permits passage of electrical current, for example.

'close valve V2530" Complete To accomplish specified procedural requirements, for example, "complete valve checkoff list "A", 'complete data report QA-l," "complete steps 7 through 9 of Section III" Continue To go on with a particular process Control To manually opeerate equipment as necessary to satisfy guideline requirements on process parameters: pressure, temperature, level, flow, etc.

Decrease Avoid use because of oral communication problems. To cause a reduction in inventory.

Determine To calculate or evaluate using formulae or graphs Energize To supply electrical energy to (something); commonly used to describe an electrical bus or other dedicated electrical path Enter To insert into or add to; commonly used in reference to plant-specific additions Establish To make arra'ngementss for a stated condition, for example, "establish communication with control room" Evaluate To examine and decide; commonly used in reference to plant conditions and operations Equalize To make the value of a given parameter equal to the value of another parameter 0 aov.'Oe

noceavit WO Writers Guide for Ap~tOva'a'.e 0-AI)M-109 Emergency Operating I'rocedures 9/26/84 ENCI.OSURK 3

~IFg 2 3)

ACTION V E RH S Increase Do not use because of oral communication problems Initiate To begin a process Inspect To measure, observe, or evaluate a feature or characteristic for comparison with specified limits; method of inspection should be included, for example, "visually inspect for leaks" Load To connect an electrical component or unit to a source of electrical energy, may involve a "start" in certain cases.

Lower To decreasse, as in setpoint, flow, pressure, etc.

Maintain To control a given plant parameter to some guideline requirement continuously Minimize To make as small as possible Monitor Similar to "check", except implies a continuous activity Open To change the physical position of a mechanical device, such as valve or door to the unobstructed position that permits access or flow, for example, "open valve IFP143" Operate To turn on or turn off as necessary to achieve the stated objective Place To move a control to a stated position 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 Raise To increase, as in setpoint, flow, pressure, etc.

Record To document specified condition or characteristic, for example, "record discharge pressure" Reset To remove an active output signal from a retentive logic device even with the input signal still present; commony used in reference to rotection/safeguards logics in which the actuating signal. is "locked-in".

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

0 ADM'.09

wrCAgyy~ C'vV 3A 8'riters Guide for AQP'Ovh oalf 0-A l) M- I OS Emergency Operating Procedures 9/26/84 KNCI.OSURE 3

~IPg 3 3l AC'I'ION VERBS Sample To take a representative portion for the purpose of examination; commonly used to refer to chemical or radiological examination To physically adjust to a specified value an adjustable feature, for example, "set diesel speed to .. 'rpm'

~

Shut down To deenergize equipment and place in standby Start To originate motion of an electric or mechanical device directly or by remote control, for example, "start...pump" Stop To terminate operation, for example, "stop...pump" Throttle To operate a valve in an intermediate position to obtain a certain How rate, for example, "throttle valve V6550 to...

'o Trip manually activate a semi-automatic feature, for example, "trip breaker..."

Vent To permit a gas or liquid confined under pressure to escape at a vent, for example, "vent...pump" Verify To observe an expecteed condition or characteristic, for example, "verify discharge pressure is stable" FINALPAGE 0 ADA!09