ML18051A991

Forwards Milestone Commitments on Suppl 1 to NUREG-0737, Procedures Generation Package,Function & Task Analysis Methodology & Reg Guide 1.97 Milestone Activity Schedule Change

ML18051A991
Person / Time
Site:	Palisades
Issue date:	06/29/1984
From:	Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8407100422
Download: ML18051A991 (58)

Text

consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 June 29, 1984 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR

• PALISADES PLANT - SUPPLEMENT 1 TO NUREG-0737 - PROCEDURE GENERATION PACKAGE, FUNCTION AND TASK ANALYSIS METHODOLOGY AND REGULATORY GUIDE 1.97 MILESTONE ACTIVITY SCHEDULE CHANGE Consumers Power Company letter dated April 2, 1984 provided commitment dates for completing milestone activities in the Supplement 1 to NUREG-0737 Program.

The NRC, June 12, 1984 Confirmatory Order is based on these commitments.

The purposes of this submittal are as follows:

a.

Summarize status on milestone commitments (Attachment 1)

b.

Provide a flow chart (Attachment 2) which displays the primary interfaces between Emergency Operating Procedure (EOP), Detailed Control Room Design Review (DCRDR),

Sa~ety Parameter Display System (SPDS), and Regulatory Guide 1.97 Projects.

The flow chart includes function and task analysis.

The flow chart is consistent with information provided by the NRC Staff to Consumers Power Company at February 9, 1984 and May 2, 1984 meetings.

The meetings are summarized by NRC letters dated February 29, 1984 and May 16, 1984.

c.

Fulfill EOP and DCRDR commitments

d.

Reschedule RG 1.97 commitments in accordance with the flow chart described in item b EOP Commitments The Procedures Generation Package is provided as Attachment 3.

(Attachment 3 has two enclosures.)

Consistent with Section 7.2.b of Supplement 1 to NUREG-0737, the Procedures Generation Package is hereby submitted at least 3 months prior to formal operator training on the upgraded procedures and includes the following information:

OC0684-0014A-NL02 8407100422 840629 PDR ADOCK 05000255 F

PDR

DMCrutchf ield, Chief Palisades Plant 0737 - MILESTONE ACTIVITIES June 29, 1984 2

a.

A description of the planned method for developing plant specific EOPs from generic guidelines, including plant specific information.

The method includes consideration of function and task analysis. of Attachment 3 provides the function and task analysis methodology.

b.

A Writer's Guide that details the specific methods to be used in preparing EOPs based on the Technical Guidelines. of provides the The Writer's Guide.

c.

A description of the program for EOP validation is provided in.

d.

A brief description of the training program for the upgraded EOPs is provided in Attachment 3.

The upgraded EOPs will be implemented by February 1986.

This schedule is consistent with the Attachment 2 flow chart.

DCRDR Commitments A DCRDR summary report including a schedule for implementation will be provided by May 1985.

This schedule is consistent with the Attachment 2 flow chart.

Regulatory Guide 1.97 Consumers Power Company has reevaluated RG 1.97 commitments to be consistent with the appropriate sequence of activites outlined in the Attachment 2 flow chart.

NRC Staff representatives at the May 2, 1984 meeting advised the following:

a.

NRC Staff does not recommend adding instrumentation to satisfy RG 1.97 without first, performing a function and task analysis and giving adequate consideration to human factors criteria.

b.

The function and task analysis may demonstrate that certain RG 1.97 variables are not essential for a particular plant.

(Each RG 1.97 variable must be addressed, however.)

c.

The function and task analysis should be an input to identify RG 1.97 Type A variables.

A report describing how the requirements of Supplement 1 to NUREG-0737 have or will be met and an implementation schedule will be provided by May 1986. This schedule is consistent with the Attachment 2 flow chart.

Previous Consumers Power Company commitments and subsequent NRC Confirmatory Order dated June 12, 1984 are not consistent with the NRC Staff guidance.

The Confirmatory Order OC0684-0014A-NL02

r. ~

\\1.

DMCrutchfield, Chief Palisades Plant 0737 - MILESTONE ACTIVITIES June 29, 1984 3

requires a response, by August 1984, that will not consider Reg Guide 1.97 work resulting from completion of EOP and DCRDR project work.

It is clear that EOP and DCRDR project work drives the RG 1.97 response and not vice versa.

Consumers Power Company hereby withdraws the Regulatory Guide 1.97 Phase I, II, III, and IV commitments as stated on page 3 of our September 13, 1983 submittal.

Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC.Resident Inspector - Palisades Attachment OC0684-0014A-NL02

f ATTACHMENT 1 Consumers Power Company Palisades Plant - Docket 50;...255 MILESTONE COMMITMENTS ON SUPPLEMENT 1 TO NUREG-0737 REVISION 2 June 29, 1984 3 Pages MI0684-0018A-NL02

Revision Number 0

1 2

e Consumers Power Company Palisades Plant MILESTONE COMMITMENTS ON SUPPLEMENT 1 TO NUREG-0737 REVISION

SUMMARY

Consumsers Power Company Submittal September 16, 1983

. April 2, 1984

. June 29, 1984 REVIS ION

SUMMARY

Original Submittal Modify Emergency Operating Procedure and Detailed Control Room Design Review schedules to accomodate increased scope for function and task analysis.

The increased scope addresses NRC letters of February 29, 1984 and May 16, 1984.

a)

Revise wording to be consistent with NRC Confirmatory Order.dated June 12, 1984.

b)

I c) d)

e)

Document EOP Procedure Generation Package submittal Provide EOP implementation schedule Provide date for DCRDR report and implementation schedule Revise Regulatory Guide 1.97 commitment dates to accomodate increased scope of function and task analysis and a resequencing of activities MI0684-0018B-NL02

CONSUMERS POWER COMPANY PALISADES PLANT

• MILESTONE COMMITMENTS ON SUPPLEMENT 1 TO NUREG-0737 REVISION 2 TITLE

1.

Safety Parameter Display System (SPDS)

2.

Detailed Control Room Design Review (DCRDR)

3.

Regulatory Guide 1.97 -

Application to Emergency Response Facilities MI0684-0018B-NL02 la.

lb.

2a.

2b.

3a.

3b.

JUNE 29, 1984 REQUIREMENT Submit a safety analysis and an implementation plan to the NRC.

SPDS fully operational and operators trained.

Submit a program plan to the NRC.

Submit a summary report to the NRC including a proposed schedule for implementation.

COMPLETION SCHEDULE (Or Status)

July 1984 Date to be provided with implementation plan in July 1984 Complete (Consumers Power Company letter-s dated March 16, 1982 & June 7, 1983.)

May 1985 Submit a report to the NRC May 1986 describing how the require-ments of Supplement 1 to NUREG-0737 have been or will be met.

Implement (installation or upgrade) requirements.

Plan and schedule to be provided with report in May 1986

CONSUMERS POWER COMPANY PALISADES PLANT MILESTONE COMMITMENTS ON SUPPLEMENT 1 TO NUREG-0737 REVISION 2 TITLE

4.

Upgrade Emergency* Operating Procedures (EOPs)

S.

Emergency Response Facilities 4a.

4b.

Sa.

Sb.

Sc.

JUNE 29, 1984

'REQUIREMENT Submit a Procedures Generation Package to the NRC.

Implement the upgraded EOPs.

Technical Support Center full functional.

Operational Support Center fully functional.

Emergency Operations Facility fully functional.

COMPLETION SCHEDULE (Or Status)

Complete (Consumers Power Company letter June 29, 1984)

February 1986 End of refueling outage which commenced August 1983*

Complete*

Complete*

Except for any additional changes that may be required as a result of the other items in this order.

MI0684-0018B-NL02

MI0684-0018A-NL02 ATTACHMENT 2 Consumers Power Company Palisades Plant - Docket 50-255 Flow Chart PRIMARY INTERFACE BETWEEN EOP, DCRDR, SPDS, AND REG GUIDE 1.97 PROJECTS June 29, 1984 1 Page

CONSUMERS POWER COMPANY PALISADES PLANT WRITERS GUIDE EOP PLANT SPECIFIC TECHNICAL GUIDELINES PROCEDURE VALIDATION (SIMULATOR WALKTHAOUGH)

TRAINING IMPLEMENTATION FUTURE EOP UPGRADES (BASED ON MODS. ETC)

DCRDR INFORMATION & CONTROL NEEDS VERIFICATION INFORMATION SHOAT YES TERM

)-....,....,,__ _____

RESOL

?

NO SHORT TERM RESOL

?

NO YES HED

?

YES SHORT TERM RE SOL

?

NO JUSTIFY OR SCHEDULE &

RESOLVE DISCREPANCIES WITH PLANT NO YES A

I I

I I

I I

I I

I I

I I

I NUREG-0737 SUPPLEMENT 1 EMERGENCY PROCEDURE GUIDELINES (CEN-152)

PLANT SPECIFIC FUNCTION & TASK ANALYSIS INFORMATION & CONTROL NEEDS INCLUDING THOSE REQUIRED TO IDENTIFY INITIATE MANUAL ACTION SPDS VERIFY DESIGN BASES VERIFY SAFETY ANALYSIS AND IMPLEMENTATION SCHEDULE NO RG 1.97 R.G.197 REVIEW OF A,8,C,O,E VARIABLES NO JUSTIFY OR SCHEDULE &

RESOLVE DISCREPANCIES WITH PLANT TYPE (B,C,D,E)

REVISE TYPE B,C,O,E REVIEW LIST (TO BE SUBMITTED AS TYPE A)

AG 1.97 MET

?

NO JUSTIFY OR SCHEDULE &

RESOLVE DISCREPANCIES WITH PLANT (TYP( A)

TRAINING DEPARTMENT I

MI0684-0018A-NL02 ATTACHMENT 3 Consumers Power Company Palisades Plant - Docket 50-255 PALISADES NUCLEAR PLANT PROCEDURES GENERATION PACKAGE June 29, 1984 9 Pages

Page 1 of 9 1

INTRODUCTION 1.1 PURPOSE The purpose of this Procedures Generation Package (PGP) is to describe the emergency operating procedures (EOPs) upgrade project at the Palisades Nuclear Plant.

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 five major parts:

0 Plant-Specific Technical Guidelines 0

Writers Guide for EOPs 0

EOP Verification Program 0

EOP Validation Program 0

EOP Training Program Each pa~t describes the approach taken as part of the overall EOP Development and Implementation Plan for the Palisades Nuclear Plant.

1.4

SUMMARY

DESCRIPTION OF PROGRAM

a.

Project Team The new EOP's will be developed and implemented by a project team designated by the Palisades Plant Operations Superintendent.

The project team will consist primarily of Shift Engineers who are SRO qualified with additional support from other individuals in the Operations Department.

b.

Interfacing Procedures EOP's are only one of the many types of instructions within the plant's procedure system.

Their relationship to each other and other plant procedures will be considered during EOP upgrade to ensure continuity of the EOP's with the supporting plant and system procedures.

Where necessary, changes to existing procedures will be recommended an~ processed as part of this program.

MI0684-0016-NL02

Page 2 of 9 For ~urposes of EOP's, an emergency event is distinguished from other plant operations by virtue of its severity in that it is sufficiently severe that a reactor trip is either activated or required immediately to properly mitigate the event.

Other less severe events for which a reactor trip is not required, but if left unattended could eventually challenge $afety functions will be addressed as offnormal procedures.

2. PLANT SPECIFIC TECHNICAL GUIDELINES 2.1 GENERAL Because of the similarity between Palisades and the generic plant used in the Combustion Engineering Owner's Group (GEOG) generic Emergency Procedure guidelines (EPG's), Palisades will use the CEOG EPG's (CEN-152, Revision 2, Dated 05/15/84) to upgrade existing plant emergency procedures.

This section describes the process that will be used.

The CEOG EPGs and the other source documents indicated below constitute the plant specific technical guidelines required by Reference 7.1.

Future approved revisions to the CEN-152 will be incorporated using the established revision, review; and approval process.

2.2 PROGRAM DESCRIPTION

a.

Source Documents EOP writers will use the.following source documents to prepare upgraded EOPs.

0 EOP Writers Guide 0

GEOG Emergency Procedure Guidelines 0

Plant Specific Technical Guidelines (See Enclosure 2) 0 Technical Specifications 0

Existing Emergency Procedures 0

FSAR 0

Licensing Commitment Letters Related to EOPs 0

Administrative Procedures 0

As Built Plant Drawings MI0684-0016-NL02

Page 3 of 9

b.

EOP Development The EOP writer will review the source documents and then develop the EOP using the following additional guidance.

0 0

0 0

0 0

0 If it is,determined that a generic step is compatible with Palisades, then the step will be incorporated into the EOPs using the appropriate format instruction.

When a generic step requires a plant specific value, it will be determined and put into the EOP.

When a generic step indicates the need for plant-specific details, then the information will be added to the EOP's.

When the generic guidelines fail to address systems or actions that are unique to Palisades, then step~ will be included to encompass the necessary actions.

If a generic step specifies an action that cannot be performed at Palisades, then the step will be deleted or modified.

Generic steps will be reworded to conform to Palisades standard terminology.

Generic steps may be rearranged to streamline the procedure provided the technical intent remains unchanged.

NOTE:

Most of the above concerns should be resolved by the Fuction and Task Analysis (See Enclosure 2)

c.

EOP Basis Document Each EOP writer will prepare a basic document which will provide specific reference and/or additional technical justification for each step contained in the EOP.

This basis document will be technically reviewed and approved as part of the EOP implementation process.

Specific Deviations from the CEOG EPG's will also be addressed and justified.

3. WRITERS GUIDE FOR EOP's 3.1 GENERAL A plant specific writers guide for EOP's has been prepared to provide instructions on writing EOPs, using good writing principals.

In addition, the guide helps to promote consistency among all EOP's and subsequent revisions, independent of the number of EOP writers.

The writers guide will be revised as necessary, based on feedba~k from operator training, experience and validation.

MI0684-0016-NL02

e Page 4 of 9 3.2 DOCUMENT DESCRIPTION Information on the following major items is included in the plant specific writers guide for EOP's:

0 Introduction 0

Numbering, Headings, Format 0

Writing Instructional Steps 0

Mechanics of Style 0

General Appearance The Palisades Plant Writers Guide for Emergency Operating Procedure is based primarily on the industry document Emergency Operating Procedures Writing Guideline (INPO 82-017), developed by the Emergency Operating Procedures Implementation Assistance (EOPIA) Review Group and published by INPO.

The Palisades Guide is provided as Enclosure 1.

3.3 DOCUMENT REVIEWS The writers guide has been reviewed by the Plant Operations Department, Plant Manager, Quality Assurance Department and Reactor Engineering Department and will be incorporated into the Plant Administrative Procedures.

4 EOP VERIFICATION PROGRAM 4.1 GENERAL EOP verification is the evaluation performed to confirm the written correctness of the procedure and to ensure that applicable generic and plant-specific technical information has been incorporated properly.

This evaluation also checks that the human factors aspects presented in the writers guide for EOP's have been applied.

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

0 How EOP verification will be performed 0

How completion of the EOP verification process will be documented 0

What process will be*used in resolving discrepancies MI0684-0016-NL02

e Page 5 of 9 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.

The Palisades Plant Administrative Procedure for Emergency Operating Procedure Development and Implementation will include a verification section that addresses the following objectives:

0 0

0 0

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

EOP's are written correctly, i.e., they accurately reflect the plant-specific writers guide.

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

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

EOP verification will be accomplished by completing all the elements described below.

a.

Operations Review The EOP's will be made available to each operations shift for review.

A review/comment sheet will be provided to collect and respond* to comments.

b.

EOP Verification Checklist An EOP verification checklist will be used to ensure that the EOP's conform to certain human factors principles and represent a degree of consistency in presentation of the written material.

c *. Table Top Review Each EOP will be discussed by a group of operators, engineers, and trainers.

d.

Control Room Walkthrough Each EOP will be walked through the control room to ensure compatibility with existing control room indications.

MI0684-0016-NL02

Page 6 of 9 5

EOP VALIDATION PROGRAM 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 will consist of performing selected scenarios at the-Palisades Plant specific simulator for each EOP.

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

0 0

0 0

How EOP validation will be performed How to appropriately use the simulator as a method of validation The evaluation criteria to be applied and the methods to be followed in resolving discrepancies How completion of the EOP validation process will be documented-The program is based on the industry document Emergency Operating Procedures Validation Guideline (INPO 83-006), developed by the EOPIA Review Group and published by INPO.

The Palisades Plant Administrative Procedure for Emergency Operating Procedures Development and Implementation will include a validation section that addresses the following objectives:

0 0

0 0

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

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

The instructions presented in the EOP's are compatible with the shift manpower, qualifications, training, and experience of the operating staff.

A high level of assurance exists that the procedure will work, i.e.,

the procedures guide the operator in mitigating transients and accidents.

MI0684-0016-NL02 j

e Page 7 of 9 The Validation Program will basically consist of the following activities:

a.

Designate Observer/Review Team and Operator Personnel The Operations Superintendent will designate personnel to participate in EOP validation. It is planned that the EOP's will be validated by an operations crew familiarized with the EOP's and observed by members of the EOP Project Team.

b.

Select Scenario~

The EOP Team with assistance from Simulator Training.Staff, will select appropriate scenarios for EOP validation.

c.

Conduct Simulator Validation Runs Selected scenarios will be run on each EOP to determine if the actions specified in the EOP can be performed by the operator to manage the emergency condition effectively.

d.

Debrief and Resolution of Discrepancies Personnel involved in the validation run will be debriefed.

Data assessment and debrief comments will be reviewed and revision requests generated as necessary.

Revalidation will be performed for significant revisions.

6 EOP TRAINING PROGRAM 6.1 GENERAL The EOP's format requires that the operator have a significant knowledge level based on experience and specific training on the use of the EOP's.

As part of the EOP Upgrade Project, a basis document will be developed for each EOP which includes specific justification for each step of the EOP.

The basis will be the primary reference for development of training materials.

Training will be conducted prior to initial implementation of the new EOP's.

6.2 PROGRAM DESCRIPTION The training program described herein is comprised of both classroom and simulator training.

MI0684-0016-NL02

e Page 7 of 9 The Validation Program will basically consist of the following activities:

a.

Designate Observer/Review Team and Operator Personnel The Operations Superintendent will designate personnel to participate in EOP validation. It is planned that the EOP's will be validated by an operations crew familiarized with the EOP's and observed by members of the EOP Project Team.

b.

Select Scenarios The EOP Team with assistance from Simulator Training Staff, will select appropriate scenarios for EOP validation,

c.

Conduct Simulator Validation Runs I

Selected scenarios will be run on each EOP to determine if the actions specified in the EOP can be performed by the operator to manage the emergency condition effectively.

d.

Debrief and Resolution of Discrepancies Person~el involved in the validation run will be debriefed.

Data assessment and debrief comments *will be reviewed and revision requests generated as necessary.

Revalidation will be performed for significant revisions.

6 EOP TRAINING PROGRAM 6.1 GENERAL The EOP's format requires that the operator have a significant knowledge level based on experience and specific training on the use of the EOP's.

As part of the EOP Upgrade Project, a basis document will be developed for each* EOP which includes specific justification for each step of the EOP.

The basis will be the primary reference for development of training materials.

Training will be conducted prior to initial implementation of the new EOP's.

6.2 PROGRAM DESCRIPTION The training program described herein is comprised of both classroom and simulator training.

MI0684-0016-NL02 J

Page 8 of 9 The training program has four major objectives:

0 0

0 0

To enable the operator to understand the structure and format of EOP's.

To enable the operator to understand the technical basis of the EOP's.

To enable the operator to have a working knowledge of the technical content of the EOP's.

To give the operator experience in using the EOP under simulated control room conditions.

The Training Process can be divided into these areas:

a.

Awareness and Involvement in the Upgrade Process" During operator requalification training in 1984/1985 the EOP upgrade program progress will be discussed and draft procedures will be reviewed and critiqued as time permits.

b.

Classroom Presentation and Discussion Instruction will be given on:

a.

Use of the new format

b.

Standard post trip actions

c.

Each event specific EOP

d.

When and how to use the functional recovery EOP

c.

Simulator Instruction Use of the Palisades Plant specific simulator will provide each operator the "hands on" experience of using the EOP under control room operating conditions.

This allows the operator to observe the effects, of various actions and non-actions.

d.

Examination Test will be administered to check that the necessary information has been learned.

This will include:

i. Written examination at the conclusion of classroom presentation.

MI0684-0016-NL02

e Page 9 of 9 ii. Operating evaluation at the conclusion of the simulator instruction.

6.3 TRAINING ON REVISIONS (AFTER INITIAL IMPLEMENTATION)

Training on minor procedure revisions will be conducted through a program of required readings (self-taught), preshift briefings, or lectures in the requalification program and will occur coincidental with implementation.

Training on major revisions will be conducted by the use of classroom instruction and walk-throughs in the control room or on the Palisades plant-specific simulator.

If operational considerations do not allow control room walk-throughs, and the plant-specific simulator is not available, training on major revisions will be conducted during classroom instruction.

In any event, training on major revisions will be completed prior to implementation.

7 REFERENCE 7.1 NUREG-0737, Supplement 1, Item 7.2b, page 15.

7.2 Combustion Engineering Emergency Procedure Guidelines, CEN-152, Revision 1.

8 ENCLOSURES 8.1 Palisades Nuclear Plant Writers Guide for Emergency Operating Procedures, May 1983.

8.2

• Fuction and Task Analysis Methodology MI0684-0016-NL02

ENCLOSURE 1 OF ATTACHMENT 3 Consumers Power Company Palisades Plant - Docket 50-255 WRITERS GUIDE FOR EMERGENCY OPERATING PROCEDURES June 29, 1984 23 Pages MI0684-0018A-NL02

Table of Contents

1.0 INTRODUCTION

i.1 PURPOSE

1. 2 SCOPE 1.3 DEFINITION 2.0 NUMBERING, HEADI'NGS AND FORMAT 2.1 TITLE BLOCK INFORMATION 2. 2 NUMBERING 2.3 SECTION AND SUBSECTION HEADINGS 2.4 FORMAT...........

3.0 WRITING INSTRUCTIONAL STEPS 3.1 INSTRUCTION STEP LENGTH AND CONTENT 3.2 USE OF LOGIC TERMS.........

3.3 USE OF CAUTIONARY INFORMATION AND NOTES 3.4 CALCULATIONS...

3.5 USE OF UNDERLINING 3.6 REFERENCING AND BRANCHING TO OTHER PROCEDURES OR STEPS 3.7 COMPONENT IDENTIFICATION 3.8 LEVEL OF DETAIL 3.9 PRINTED OPERATOR AIDS 3.9.1 Units of Measure..

3.9.2 Titles and Headings 4.0 MECHANICS OF STYLE.

mi0483-0008d-89 Page 1

1 1

1 1

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1 1

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4 4

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Table of Contents 4.1 HYPHENATION 4.2 PUNCTUATION 4.2.1 Brackets 4.2.2 Colon 4.2.3-Comma 4.2.4 Parenthesis 4.2.5 Period..

4.2.6 Slant Line 4.3 VOCABULARY 4.4 NUMERICAL VALUES 4.5 ABBREVIATIONS, LETTER SYMBOLS AND ACRONYMS 5.0 GENERAL APPEARANCE 5.1 BREAKING OF WORDS 5.2 PRINTED OPERATOR AIDS 5.3 CAUTIONS, WARNINGS AND NOTES 5.4 USE OF FOLDOUT PAGES.

5.5 USE OF OVERSIZED PAGES 5.6 USE OF REDUCED PAGES.

Attachments, Component Identification, Action Verbs mi0483-0008d-89 Page 6

6 7

7 7

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8 8

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9 10 10 10 10

1.0 INTRODUCTION

1.1 PURPOSE The purpose of this document is to provide administrative guidance on the preparation of Emergency Operating Procedures (EOPs).

1. 2 SCOPE This writers' guide applies to the development and revision of all EOPs.

1.3 DEFINITION 2.0

. 2.1 EOPs are procedures that direct operator actions necessary to mitigate consequences of transients and accidents which cause plant parameters to exceed reactor protection setpoints, engineered safety feature setpoints, or other appropriate technical limits.

. NUMBERING, HEADINGS AND FORMAT TITLE BLOCK INFORMATION Title block information shall be in accordance with Administrative

• procedure 10.41.

2.2 NUMBERING Alpha-Numeric designation shall be in accordance with Administrative Procedures 10.41 and 10.42.

2.3 SECTION AND SUBSECTION HEADINGS Headings shall be in accordance with Administrative Procedure 10.41.

2.4.

FORMAT Format shall be as specified in Administrative Procedure 10.41,.

3.0 WRITING_INSTRUCTIONAL STEPS 3.1 INSTRUCTION STEP LENGTH AND CONTENT Instruction steps shall be short and exact.

General rules to be used in meeting these objectives are as follows:

Instruction steps should deal with only one idea.

Short, simple sentences should be used in preference to long, compound or complex sentences.

mi0483-0008a-89

Page 2 Complex evolutions should be prescribed in a series of steps.

Objects of operator actions should be specifically stated.

Instructional steps that involve an action verb shall be listed with space provided for operator checkoff in the left hand margin, except for those steps which require continuous or rep_eated operator actions.

Mandatory sequence of steps is assumed unless otherwise stated.

Instruction content should be written to communicate to the minimum expected operator experience and knowledge level.

Expected results of routine tasks need not be stated.

Minimize use of articles (the, a, an) unless they are needed for clarity.

This practice helps reduce the length of instructions, and thus increases reading speed.

When actions are required based upon receipt of an annunciated alarm, list the setpoint of the alarm.

When requiring resetting or restoration of an alarm or trip, list the expected results immediately following the resetting or restoration if it would be beneficial to the operator.

When considered beneficial to the user for proper understanding and performance, describe the system response time associated with performance of the instruction.

When system response dictates a time frame within which the instruction must be accomplished, prescribe such time frame.

If possible, however, avoid using time to initiate operator actions.

Operator actions should be related to Plant parameters.

When anticipated system response may adversely affect instrument indications, describe the conditions that will likely introduce instrument error and means of determining if instrument error has occurred by using a NOTE.

When additional confirmation of system response is considered necessary, prescribe tqe backup readings to be made.

3.2 USE OF LOGIC TERMS The logic terms AND, OR, NOT, IF, IF NOT, WHEN, and THEN are.often necessary to describe----PreciselY-a set of conditions or sequence of actions.

When logic statements are used, logic terms shall be highlighted.

The use of AND and OR within the same action shall be avoided.

When AND and OR----are usecr-together, the logic can be very ambiguous.

mi0483-0008a-89

Page 3 Use other logic terms as follows:

When attention should be called to combinations of conditions, the word AND shall be placed between the description of each condition.

The word AND shall not be used to join more than three conditions.

If four or more conditions need to be joined, a list format shall be used..

The word OR shall be used when calling attention to alternative combinations of conditions.

The use of the word OR shall always be in the inclusive sense.

To specify the exclusive-"OR", the following may be used:

"either A ORB, but not both".

When action steps are contingent upon certain conditions or combinations of conditions, the step shall begin with the words IF or WHEN followed by a description of the condition or conditions (the antecedent), a comma, the word THEN, followed by the action to be taken (the consequent).

WHEN is used for an expected condition.

IF is used for an unexpected but possible condition.

Use of IF NOT should be limited to those cases in which the operator must respond to the second of two possible conditions.

IF should be used to specify the first condition.

THEN shall not be used at the end of an action step to instruct the operator to perform the next step, because it runs actions together.

3.3 USE OF CAUTIONARY INFORMATION AND NOTES Cautionary information can be considered in two fundamental categories:

those that apply to the entire procedure and those that apply to a portion or a specific step of the procedure.

Those that apply to the entire procedure are called "PRECAUTIONS" and are covered in operator training.

Those that apply to a portion of a procedure are called "CAUTIONS" and are placed immediately before the procedural steps to which they apply.

A caution cannot be used instead of an instructional step.

If additional information other than cautions is necessary to support an action instruction, a. NOTE should be used.

A* NOTE should present information only, not instructions, and should be located as close to the applicable instruction as possible.

3.4 CALCULATIONS Mathematical calculations should be avoided in EOPs.

If a value has to be determined in order to perform a procedural step, a chart or graph should be used whenever possible.

mi0483-0008a-89

3.5 USE OF UNDERLINING Underlining shall be used for emphasis of logic terms, CAUTIONS, WARNINGS AND NOTES.

3.6 REFERENCING AND BRANCHING TO OTHER PROCEDURES OR STEPS Page 4 Referencing implies that an additional procedure or additional steps shall be used as a supplement to the procedure presently being used.

Referencing other steps within the procedure being used, either future steps or completed steps, should be minimized.

When only a few steps are involved in the referencing, the steps should be stated in the procedure wherever they are needed.

To minimize potential operator confusion, branching should be used when the operator is to leave one procedure or step and use another procedure or step.

Use the key words "go to" so the operator will know to leave the present step and not return until directed.

• Use quotation marks to emphasize the title of the referenced or branched procedure; examples:

Go to Step 10 of EOP-1, "Reactor Trip".

3.7 COMPONENT IDENTIFICATION Component identification shall be in accordance with Administrative Procedure 10.41 and the following requirements:

Equipment, controls, and displays shall be identified in operator language (common usage) terms as listed on Attachment 1.

When the engraved names and numbers on panel placards and alarm windows are specifically the item of concern in the procedure, the engraving should be quoted verbatim and emphasized by using all capitals.

The names of Plant system titles shall be emphasized by initial capitalization.

If the component is seldom used or it is felt that the component would be difficult to find, location information should be given in parenthesis following the identification.

3.8 LEVEL OF DETAIL Too much detail in EOPs should be avoided in the interest of being able to effectively execute the instruction in a timely manner.

The level of detail required should be the detail that a newly trained and licensed operator would desire during an emergency ~ondition.

mi0483-0008a-89

Page 5 To assist in determining the level of detail, the following general rules apply.

For control circuitry that executes an entire function upon actuation of the control switch, the action verb appropriate to the component suffices without further amplification of how to manipulate the control device; -for example, "Open SHU'l'DOWN COOLING RETURN (;';;'*M0-3016)".

Recommended action verbs are as follows:

a.

For power-driven rotating equipment, use Start, Stop.

b.

For valves, use Open, Close, Throttle Open, Throttle Close, Throttle.

c.

For power distribution breakers, use Synchronize and Close, Trip.

For control switches with a positional placement that establishes a standby readiness condition, the verb "Set" should be used, along with the engraved name of the desired position.

Positional placements are typically associated with establishing readiness of automatic functions and are typically named AUTO or NORMAL; for example, "Set PRESSURIZER SPRAY (;';;\\*CV-105 7) in AUTO".

Standard practices for observing for abnormal results need not be prescribed within procedural steps.

For example, observation of noise, vibration, erratic flow, or discharge pressure need not be specified by steps that start pumps.

3.9 PRINTED OPERATOR AIDS 3.9.l When information is presented using graphs, charts, tables and figures, these aids must be self-explanatory, legible, and readable under the expected conditions of use and within the reading precision of the operator.

In addition they must:

Be easily located when referenced to in the text.

Be easily identified from the text information.

Contain only the relevant information needed to accomplish the purpose referred to in the text.

Units of Measure Units of measure used in plotted values should be compatible with divisions shown on the graph.

That is, if plotted values progress in units of five (5, 10, 15) it is better to separate the values by five lines than by four lines.

mi0483-0008a-89

-i

3.9.2 Page 6 Titles and Headings Initial capitalization should be used for references to tables and figures, titles of tables and figures within text material, and column headings within a table.

4.0 MECHANICS OF STYLE 4.1 HYPHENATION Hyphens are used between elements of a compound word when usage calls for it.

The _following rules should be followed for hyphenation.

When doubt exists, the compound word should be restructured to avoid hyphenation.

Hyphens should be used in the following circumstances:

a.

In compound numerals from twenty-one to ninety-nine; example:

one hundred thirty-four.

b.

In fractions; examples:

one-half, two-thirds.

c.

In compounds with "self"; examples:

self-contained, self-lubricated.

d.

When the last letter of the first word is the same vowel as the first letter of the second word - ag an alternative, two words may be used; example:

fire-escape or fire escape.

e.

When misleading or awkward consonants would result by joining the words; example:

bell-like.

f.

To avoid confusion with another word; examples:

re-cover to prevent confusion with recover, pre-position to avoid confusion with preposition.

g.

When a letter is linked with a noun; examples:

X-ray, 0-ring, U-bolt, I-beam

h.

To separate chemical elements and their atomic weight; examples:

Uranium-235, U-235.

4.2 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.

When extensive punctuation is necessary for clarity, the sentence should be rewritten and possibly made into several sentences~ Punctuation should be in accordance with the following rules.

mi0483-0008a-89

4.2.1 4.2.2 4.2.3 4.2.4 4.2.5 4.2.6 Brackets Do not use brackets.

Colon Use a colon to indicate that a list of items is to follow, for example:

Restore cooling flow as follows:

Comma Page 7 Use of many commas is a sign the instruction is too complex and needs to be rewritten.

Therefore, evaluate the number of commas to ensure the instruction is not too complex.

Use a comma after conditional phrases for clarity and ease of reading.

Example: WHEN level decreases to 60 inches, THEN start pump.

Parentheses Parentheses shall be used to indicate alternative items in a procedure, instruction, or equipment numbers.

Period Use a period at the end of complete sentences and for indicating the decimal place in numbers.

Slant Line Use a slant line to indicate an "either-or" situation and as a substitute for "per" in units of measure; examples:

ft/sec, lbs/hr, gal/min.

4.3 VOCABULARY Words used in procedures should convey precise understanding to the trained person.

The following rules apply~

Use simple words.

Simple words are usually short words of few syllables.

Simple words are generally common words.

Use common usage if it makes the procedure easier to understand.

Use words that are concrete rather than vague, specific rather than general, familiar rather than formal, precise rather than blanket.

Define key words that may be understood in more than one sense.

Verbs with specific meaning should be used.

Examples are listed in.

mi0483-0008a-89

Page 8 Equipment status should be denoted as follows:

a.

Operable/Operability - These words mean that a system, subsystem, train, component, or device is capable of performing its specified function(s) in the intended manner.

Implicit in this definition is the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing related support function(s).

b.

Operating - This word means that a system, subsystem, train, component, or device is in operation and is performing its specified function(s).

c.

Available - This word means that a system, subsystem, train, component, or device is operable and can be used as desired; however, it need not be operating.

4.4 NUMERICAL VALUES The use of numerical values should be consistent with the following rules:

For numbers less than unity, the decim?l point should be preceeded by a zero; for example:* 0.1.

The number of significant digits should be consistent with the reading precision of the operator.

Acceptance values should be specified by stating acceptance values as limits.

Example:

580° to 600°F.

For calibration points, statement of the midpoint and its lower and upper limits for each data cell would accomplish the same purpose; for example, 10 milli-amperes (9.5 to 10.5).

Avoid using+/-.

Engineering units should always be those used on the Control Room displays.

4.5 ABBREVIATIONS, LETTER SYMBOLS AND ACRONYMS The use of abbreviations should be minimized because they may be confusing to those who are not thoroughly familiar with them.

Abbreviations may be used where necessary to save time and space, and when their.meaning is unquestionably clear to the intended reader.

The full meaning of the abbreviation should be written in before the first use of the abbreviation and whenever in doubt.

Consistency should be maintained throughout the procedure.

Capitalization of abbreviations should be uniform.

If the abbreviation is comprised of lowercase letters, it should appear in mi0483-0008a~89

Page 9 lowercase in a title or heading.

The period should be omitted in abbreviations except in those cases where the omission would result in confusion.

• Letter symbols may be use*d to represent operations, quantities, elements, relations and qualities.

An acronym is a type of symbol formed by the initial letter or letters of each of the successive parts or major parts of a compound term.

Acronyms may be used if they are defined or commonly used.

Abbreviations, symbols and acronyms should not be overused.

Their use should be for the benefit of the reader.

They can be beneficial by saving reading time, ensuring clarity when space is limited, and communicating mathematical ideas.

5.0 GENERAL APPEARANCE 5.1 BREAKING OF WORDS Breaking of words shall be avoided to facilitate operator reading.

5.2 PRINTED OPERATOR AIDS Figures include graphs, drawings, diagrams, and illustrations.

The following rules are established.

The figure field should be of sufficient size to offer good readability.

The essential message should be clear; simple presentations are preferred.

Grid lines of graphs should be at least l/8 11 apart; numbered grid lines should be bolder than unnumbered grid lines.

Labeling of items within the figure should be accompanied by arrows pointing to the item.

The items within the figure should be oriented naturally insofar as possible.

For example, height on a graph should be along the vertical axis.

Tables should be typed using the following rules:

Type style and size should be the same as that for the rest of the procedure.

A heading should be entered for each column.

There should not be a vacant cell in the table.

If no entry is necessary, "N/A" should be entered to indicate not applicable.

mi0483-0008a-89

Page 10 5.3 CAUTIONS, WARNINGS AND NOTES All notes and cautions shall be distinguishable from the rest of the text by using the format required by Administrative Procedure 10.41.

In addition all of the text of a CAUTION or WARNING shall appear on one page, along with the first step of the instruction to which it applies.

5.4 USE OF FOLDOUT PAGES When used, a foldout page is treated as a single page.

It should follow the same format as a standard page except the width is different.

The page should be folded so that a small margin exists between the fold and the right-hand edge of standard pages.

This will reduce wear of the fold.

5.5 USE OF OVERSIZED PAGES Oversize pages should not be used.

They should be reorganized or

'reduced to a standard page.

If this cannot be done, a foldout page should be used.

5.6 USE OF REDUCED PAGES Reduced pages should be avoided whenever possible.

Final size of reduced pages should be standard page size.

Reduced pages should be readable.

mi0483-0008a-89

COMPONENT fl AE-0203 C-2A C-2B C-2C CV-1048 CV-0152 CV-0155 CV-0437A CV-0437B CV-0501 CV-0510 CV-Q511 CV-0521 CV-0522A CV-0522B CV-0569 CV-0571.

CV-0573 CV-0575 CV-0594 CV-0595 CV-0596 CV-0597 CV-0701 CV-0703 CV-0710 CV-0711 CV-0729 CV-0730 CV-0731 CV-0732 CV-0734 CV-0735 CV-0736A CV-0737A CV-0738 CV-0739 CV-0742 CV-0744 CV-0767 CV-0768 CV-0770 CV-0771 CV-0779 CV-0780 CV-0781 CV-0782 CV-0824 COMPONENT IDENTIFICATION DESCRIPTION Boronometer *k Instr Air Compressor Instr Air Compressor Instr Air Compressor Quench Tk Dr Vlv

• Quench Tk Vent Vlv

• Quench Tk Spray Vlv

• r-102 Outlet Vlv

• T-102 Outlet Vlv

• MSIV For S/G B

• MSIV For S/G A

• Turbine Bypass Valve

• Alt Stm Supply to P-8B From S/G "B" Alt Stm Supply to P-8B From S/G 11B 11 Norm Stm supply.to P-8B From S/G 11A11 Ill Stop Valve -/;

112 Stop Valve ;';

113 Stop Valve ;'*

114 Stop Valve -/;

Reheat Stm to MSR 11A11 Reheat Stm to MSR "B" ;'*

Reheat Stm to MSR "C" ;'*

Reheat Stm to MSR "D" ;'*

Feed Reg Vlv to S/G A

• Feed Reg Vlv to S/G B *

"B" Feed Pump Recirc Vlv ;'*

11A11 Feed Pump Recirc Vlv ;'*

Hotwell 6 11 Makeup Vlv ;'*

.Attachment 1 Page 1 of 9 Condensate Recirc From Gland Stm Condenser Condensate Reject Vlv Hotwell 3 11 Makeup Vlv Feed Reg Vlv Bypass to S/G B

• Feed Reg Vlv Bypass to S/G A

• Aux Feed Flow to S/G B

• Aux Feed Flow to S/G "A" ;'*

S/G "B" Blowdown to Blowdown Tk S/G "A" Blowdown to Blowdown Tk Feed Reg Block Vlv to S/G A Feed Reg Block Vlv to S/G B S/G A Bottom Blowdown Vlv S/G B Bottom Blowdown Vlv S/G B Bottom Blowdown Vlv S/G A Bottom Blowdown Vlv Atmospheric Dump From S/G B Atmospheric Dump From S/G B Atmospheric Dump From S/G A Atmospheric Dump from S/G A Containment Air Coolers Serv Water Return

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

COMPONENT II CV-0825 CV-0847 CV-0861 CV-0864 CV-0867 CV-0873 CV-0878 CV-0879 CV-0880 CV-0910 CV-0911 CV-0913 CV-0937 CV-0938 CV-0939 CV-0940 cv-0944*

CV-0944A CV-0945 CV-0946 CV-0947 CV-0948 CV-0949 CV-0950 CV-0951 CV-0977B CV-1001 CV-1002 CV-1004 CV-1007 CV-1036 CV-1037 CV-1038 CV-1044 CV-1045 CV-1049 CV-1051 CV-1057 CV-1059 CV-1064 CV-1065 CV-1101 CV-1102 CV-1103 CV-1104 CV-1113 CV-1123 CV-1211 COMPONENT IDENTIFICATION DESCRIPTION Attachment Page 2 of 9 East ESG Room Cooler Serv Wtr Outlet Containment Air Coolers Serv Wtr Supply Containment Air Cooler VHX-1 Serv Wtr Outlet Containment Air Cooler VHX-2 Serv Wtr Outlet Containment Air Cooler VHX-4 Serv Wtr Outlet Containment Air Cooler VHX-3 Serv Wtr Outlet West ESG Room Cooler Serv Wtr Inlet ESG Pump Seal Cooling Serv Wtr Supply ESG Pump Seal Cooling Serv Wtr Supply CCW Inlet Isol CCW Return Isol ESG Pumps Seal Cooling CCW Supply SDC HX CCW Inlet SDC HX CCW Inlet Shield Cooling Surge Tk Isol CCW Return Isol CCW Supply to Evaporators Spent Fuel Pool CCW Shutoff CCW HX "A" Inlet CCW HX "B" Inlet West ESG Pumps CCW Supply East ESG Pumps CCW Supply ESG Pumps Seal Cooling Isol ESG Pumps CCW Return ESG Pumps Cooling Serv Wtr Return CCW Return From Evaporators Primary Sys Dr Tk Recirc Isol Primary System DR Tk Outlet Isol CWRT Inlet Isol Primary Sys Tk Outlet Isol CWRT Recirc Isol CWRT Recirc Isol CWRT Recirc Isol CWRT Outlet Isol CWRT Outlet Isol 3" RW Disch to Mixing Basin l" RW Disch to Mixing Basin Pzr Spray Vlv from Loop 2A Pzr Spray Vlv From Loop lB CWRT Vent Isol CWRT Vent Isol Containment Vent Hdr Isol Containment Vent Hdr Isol Containment Sump Dr Isol Containment Sump Dr Isol Waste Gas Surge Tk to Stack Waste Gas Decay Tk to Stack Instr Air Isol

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

COMPONENT ff CV-1212 CV-1358 CV-1359 CV-1501,

CV-1502 CV-1503 CV-1805 CV-1806 CV-1807 CV-1808 CV-1813 CV-1814 CV-1910 CV-1911 CV-2001 CV-2002 cv-2003*

CV-2004 CV-2005 CV-2009 CV-2083 CV-2111 CV-2113 CV-2115 CV-2117 CV-2130 CV-2136 CV-2155 CV-2165 CV-3001 CV-3002 CV-3006 CV-3025 CV-3027 CV-3029 CV-3030 CV-3031 CV-3037 CV-3038 CV-3042 CV-3046 CV-3047 CV-3051 CV-3055 CV-3056 CV-3057 CV-3059 CV-3063 COMPONENT IDENTIFICATION DESCRIPTION Serv Air Isol Nitrogen Supply Isol Non Critical Serv Wtr Isol Containment Htg Stm Return Isol Containment Htg Stm Return Isol Containment Htg Stm Supply

, Containment Purge Exhaust Isol Containment Purge Exhaust Isol Containment Purge Exhaust Isol Containment Purge Exhaust Isol Air Room Supply Isol Air Room Supply Isol Primary Sys Sampling Isol Primary Sys Sampling Isol Letdown Stop Valve Letdown Orifice Bypass Valve Letdown Orifice Stop Vlv Letdown Orifice Stop Vlv Letdown Orifice Stop Valve Letdown Containment Isol Controlled Bleedoff Containment Isol Charging Line Stop Vlv Charging Loop IA Stop Vlv Charging Loop 2A Stop Vlv Aux Spray Vlv BAST "B" Recirc BAST "A" Recirc Makeup Stop Vlv PMW Makeup Control Containment Spray Hdr Isol Containment Spray Hdr Isol SDC HX Bypass Vlv SDC HX Outlet Vlv SIRWT Recirc Vlv Containment Sump I sol Contai_Jlffient Sump I sol SIRWT Outlet HPSI P-66A Discharge Hdr T-82D Press Control T-82A Press Control T-82B Press Control T-82C Press Control T-82D Vent LPSI Pump Disch Crossover SIRWT Recirc Vlv SIRWT Outlet HPSI P-66B Disch HDR T-82C Vent Attachment I Page 3 of 9

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

COMPONENT fl CV-3065 CV-3067 CV;;.3069 CV-3070 CV-3071 CV-8206 CV-8207 CV-8208 E-50A E-50B EA-11 EA-I2 EC-2 EC-I3 EC-33 EC-5I EC-105

• EC-I26 EX-I5 EY-IO EY-20 EY-30 EY-40 F-I4 FI-030IA FI-0301B FI-0302A FI-0302B FI-0307A FI-0307B FI-0308A FI-0308B FI-0309A FI-0309B FI-03IOA FI-03IOB FI-0311A FI-0311B FI-03I2A FI'-03I2B FI-03I6A FI-03I7A FIC-0306 FIC-0736A FIC-0736B FIC-0737A

.FIC-0737B HIC-0526 COMPONENT IDENTIFICATION DESCRIPTION T-82B Vent T-82A Vent SIT Di. to Primary Sys Dr Tk HPSI P-66B Subcooling HPSI P-66A Subcooling Condensate Dem~n Bypass Condensate Demin Outlet Condensate Demin Inlet S/G A ir S/G B ;'(

Bus IC ;'(

Bus ID ;'r C-2 Panel ;'(

C-13 Panel ;'r C-33 Panel 'fr C-5 l Panel ;'r C-I05 Panel ;'r.

C-I26 Panel ;'r Pzr Htr Transformer I5 Pref AC Bus I *'*

Pref AC Bus 2 *'*

Pref AC Bus f13 ir Pref AC Bus 4 *'*

"i'\\

Blowdown Filter Containment Spray Hdr Flow Containment Spray Hdr Flow Containment Spray Hdr Flow Containment Spray Hdr Flow LPSI Flow to Loop IA LPSI Flow to Loop IA HPSI Flow to Loop IA HPSI Flow to Loop lA LPSI Flow to Loop IB LPSI Flow to Loop lB HPSI Flow to Loop lB HPSI Flow to Loop lB LPSI Flow to Loop 2A LPSI Flow to Loop 2A HPSI Flow to Loop 2A HPSI Flow to Loop 2A HPSI Train 2 Cold Leg Flow HPSI Train I Cold Leg Flow SDC HX Bypass Control Flow S/G B Aux FW Control S/G B Aux FW Control S/G A Aux FW Control S/G A Aux FW Control "A" Feed Pump Speed Control Attachment I Page 4 of 9

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

COMPONENT fl HIC-0529 HIC-0701 HIC-0703 HIC-0736A HIC-0780A HIC-0780B HIC-078IB HIC-0881 HIC-0882 HIC-3003 HIC-3004 HIC-3039 HIC-3043 HS-1221 HS-1801 K-2 K-6A K-6B K-7A K-7B K-8 LI-0702 LI-0704 LI-0757A LI-0757B LI-0758A LI-0758B LI-1107A LI-1107B LI-lllOA LI-lllOB LIA-0116 LIA-:0331 LIA-0358 LIA-0359 LIA-0365 LIA-0368 LIA-0372 LIA-0374 LIA-1400 LIA-1416 LIA-1417 LIA-2021 LIA-2022 M0-0501 M0-0510 M0-1042A M0-1043A COMPONENT IDENTIFICATION DESCRIPTION "B" Feed Pump Speed Control S/G A FW Control S/G B FW Control S/G "B" Aux F\\j Control Atmospheric Dump Control S/G B Atmospheric Dump Control S/G A Atmospheric Dump Control CCW HX Serv Wtr Outlet CCW HX Serv Wtr Outlet T-82D Drain T-82C Drain T-82A Drain T-82B Drain Air Supply From FWP Control Room Isol Dampers Turbine Turning Gear *'*

D/G 1-1,._

D/G 1-2,._

Feedwater Pump Turbine Feedwater Pump Turbine Aux Feed Pump Turbine S/G A* Level,._

S/G B Level,._

S/G A Wide Range Level

• S/G A Wide Range Level '"

S/G B Wide Range Level

• S/G B Wide Range Level

• West ESG Rm Sump West ESG Rm Sump East ESG Rm Sump East ESG Rm Sump Quench Tank Level SIRWT Level Containment Sump Level Containment Sump Level T-82A Level i; T-82B Level *'*

T-82C Level '"

T-82D Level *'*

T-10 Level D/G 1-1 Day Tk Level D/G 1-2 Day Tk Level T-2 Level T-2 Level S/G B MSIV Bypass Vlv,._

S/G A MSIV Bypass Vlv

• PORV Isol Vlv PORV Isol Vlv Page 5 of 9

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

COMPONENT ff M0-2087 M0-2140 M0-2160 M0-2169 M0-2170 M0-3007 M0-3008 M0-3009 M0-3010 M0-3011 M0-3012 M0-3013

• M0-3014 M0-3015 M0-3016 M0-3041 M0-3045 M0-3049 M0-3052 M0-3062 M0-3064 M0-3066 M0-3068 M0-3080 M0-3081 M0-3082 M0-3083 M0-3189 M0-3190 M0-3198 M0-3199 M0-5301 M0-5302 M0-5326A M0-5326B P-lA P-lB P-2A P-2B P-5 P-7A P-7B P-7C P-8A P-IOA P-lOB P-39A P-39B COMPONENT IDENTIFICATION DESCRIPTION VCT Outlet Boric Acid Pumped Feed SIRWT to Charging Pump Suction Boric Acid Gravity Feed Boric Acid Gravity Feed HPSI Loop lA LPSI Loop lA HPSI Loop lB LPSI Loop lB HPSI Loop 2A LPSI Loop 2A HPSI Loop 2B LPSI Loop 2B Shutdown Cooling Wtr Return Shutdown Cooling Wtr Return T-82A Outlet T-82B Outlet T-82C Outlet T-82D Outlet HPSI Loop 2B Train 2 HPSI Loop 2A Train 2 HPSI Loop lB Train 2 HPSI Loop lA Train 2 HPSI Train 2 Cold Leg HPSI Train 1 Cold Leg HPSI Train 2 Hot Leg HPSI Train 1 Hot Leg P-67B Inlet, LPSI P-67B Inlet, Shutdown Cooling P-67A Inlet, LPSI P-67A Inlet, Shutdown Cooling West Water Box Inlet Vlv East Water Box Inlet Vlv Basin "A" Blowdown Line Vlv Basin "B" Blowdown Line Vlv Main Feed Pump

• Main Feed Pump

• Condensate Pump

• Condensate Pump

• Warm Wtr Recirc Pump Serv Wtr Pump ;';

Serv Wtr Pump ;';

Serv Wtr Pump ;';

Motor Driven Aux Feed Pump

• Heater Dr Pump ;';

Heater Dr Pump

• Cooling Tower Pump ;';

Cooling Tower Pump ;';

Page 6 of 9

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

COMPONENT fl P-40A P-40B P-45A P-45B P-SOA P-SOB P-SOC P-SOD P-51A P-51B P-52A P-52B P-52C P-54A P-54B P-54C P-55A P-55B P-55C P-56A.

P-56B P-66A P-66B P-67A P-67B PI-0783 PI-1106 PI-1108 PI-1805 PIA-0116 PIA-1814 PIA-1815 PIC-OlOlA PIC-OIOIB PIC-0202 PIC-0338 PIC-0342 PIC-0346 PIC-0347 PIC-0511 PCV-0521A PCV-6003 PCV-6004 PRC-OlOlA PRC-0101B PRV-1042B PRV-1043B PRV-1067 COMPONENT IDENTIFICATION DESCRIPTION Dilution Wtr Pump

• Dilution Wtr Pump

• Turbine Bldg Sump Pump Turbine Bldg Sump Pump Primary Coolant Pump

• Primary Coolant Pump

• Primary Coolant Pump Primary Coolant Pump Fuel Pool Cooling Pump Fuel Pool Cooling Pump CCW Pump '"

CCW Pump "'

CCW Pump '"

Containment Spray Pump '"

Containment Spray Pump

• Containment.Spray Pump*

Charging Pump "'

Charging Pump '"

Charging Pump,.,

Boric Acid Pump

• Boric Acid Pump

• HPSI Pump *:.

HPSI Pump "'

LPSI Pump,.,

LPSI Pump "'

Aux Feed Pump Disch Press ESG Rm Sump Pumps Disch Press ESG Rm Sump Pumps Disch Press Containment Press Quench Tk Press Containment Press Containment Press Pzr Press Control Pzr Press Control Intermediate Letdown Press Control T-82D Press Control T-82A Press Control T-82B Press Control T-82C Press Control Turbine Bypass Vlv Control Aux Feed Pump Stm Supply Control Blowdown Tk Relief Control Blowdown Tk Outlet Control Pzr Press Control Pzr Press Control PORV PORV Reactor Vent Vlv Page 7 of 9

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

COMPONENT II PRV-1068 PRV-1069 PRV-1070 PRV-1071 PRV-1072 PS-0104 RIA-0202 RIA-0631 RIA-0707 RIA-1113 RIA-1805 RIA-1806 RIA-1807 RIA-1808 RIA-2319 RIA-5710 RV-1039 RV-1040 RV-1041 SMM-0114 SMM-0124 SV-0505A SV-0505B SV-0507A SV-0507B T-2 T-3 T-10 T-26A T-26B T*29 T-58 T-60 T-64A-D T-81 T-82A T-82B T-82C T-82D T-90 T-92A T-92B T-92C T-102 T-104 T-939 TI-0115C TI-0125C COMPONENT IDENTIFICATION DESCRIPTION Reactor Vent Vlv Pzr Vent Vlv Pzr Vent Vlv Vent Vlv to Containment Atmosphere Vent Vlv to Quench Tk Pzr Press Failed Fuel Monitor Off Gas Monitor Radwaste Liquid Disch Monitor Waste Gas Disch Monitor Containment Isol Monitor Containment Isol Monitor Containment Isol Monitor Containment Isol Monitor Stack Gas Monitor Penetration & Fan Room Monitor Pzr Code Safety Vlv Pzr Code Safety Vlv Pzr Code Safety Vlv Subcooling Margin Monitor Subcooling Margin Monitor S/G B MSIV S/G A MSIV S/G B MSIV S/G A MSIV Condensate Storage Tk CCW Surge Tk Diesel Oil Storage Tk Feedwater Turbine Dr Tk Feedwater Turbine Dr Tk Blowdown Tk SIRWT ;'o:

Dirty Waste Drain Tk Clean Waste Receiver Tk ;';

Primary Sys Makeup~Tk Safety Injection Tk

• Safety Injection Tk

• Safety Injection Tk

• Safety Injection Tk

• Primary Makeup Wtr Storage Tk Misc Waste Hold-up Tk Misc Waste Hold-up Tk Misc Waste Hold-up Tk Sodium Hydroxide Tk Blowdown Deroin Demineralized Wtr Storage Tk Loop 1 Cold Leg Temp Loop 2 Cold Leg Temp Attachment Page 8 of 9

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

COMPONENT ff TI-0912 TI-0913 TIA-0106 TIA-0107 TIA-0108 TIA-0109 TIA-0116 V-lA V-lB V-2A V-2B V-3A V-3B V-4A.

V-4B V-69 V-70A V-70B 042-1 RPS 042-2 RPS 152-010"2CS COMPONENT IDENTIFICATION DESCRIPTION SDC HX "A" Outlet Temp ;'>

SDC HX "B" Outlet. Temp ;'>

Relief & Safety Vlv Disch Temp Relief & Safety Vlv Disch Temp Relief & Safety Vlv Disch Temp Relief & Safety Vlv Disch Temp Quench Tk Temp Containment Recirc Fan Containment Recirc Fan Containment Recirc Fan Containment Recirc Fan Containment Recirc Fan Containment Recirc Fan Containment Recirc Fan Containment Recirc Fan Attacrunent 1 Page 9 of 9 Aux Bldg Addition Fuel Handling Area Supply Fan Aux Bldg Addition Fuel Handling Area Exhaust Fan Aux Bldg Addition Fuel Handling Area Exhaust Fan RPS Clutch Power Supply RPS Clutch Power Supply P-40A Dilution Pump Control Switch *

• Component Numbers need not be used in conjunction with these component descriptions mi0483-0008b-89

Verb Allow Check Close Complete Establish Inspect Open

-1 Page 1 of 2 ACTION VERBS Application To permit a stated condition to be achieved prior to proceeding To perform a comparison with a procedural requirement To change the physical position of a mechanical device so that it prevents physical access or flow or permits passage of electrical current To accomplish specified procedural requirements To make arrangements for a stated condition To measure, observe, or evaluate a feature or characteristic for comparison with specified limits; method of inspection should be included To change the physical position of a mechanical device, such as valve or door to the unobstructed position that permits access or flow mi0483-0008c-89

Verb Record Set Shut Start Stop Throttle Trip Vent Verify ACTION VERBS Application To document specified condition or characteristic Page 2 of 2 To physically adjust to a specified value on adjustable feature Do not use.

The verb "close" shall be used instead To originate motion of an electric or mechanical device directly or by remote control To terminate operation To operate a valve in an intermediate position to obtain a certain flow rate To manually activate a semi-automatic feature To permit a gas or liquid confined under pressure to escape at a vent To observe an expected condition or characteristic mi0483-0008c-89

MI0684-0018A-NL02 ENCLOSURE 2 OF ~TTACHMENT 3 Consumers Power Company Palisades Plant - Docket 50-255 FUNCTION AND TASK ANALYSIS METHODOLOGY June 29, 1984 12 Pages

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1.0 General CPCo will use an interdisciplinary team of individuals to perform the Palisades function and task analysis.

This team will involve individuals experienced in the areas of:

a.

Transient analysis of emergency events,

b.

Probabilistic risk assessment,

c.

Systems interactions and system design,

d.

Human factors engineering,

e.

Emergency response procedures,

f.

Instrumentation and control, and

g.

Palisades Plant operations.

The CPCo departments that will participate in the process are Reactor Engineering Dept (RED), Nuclear Activities Plant ORG (NAPO), Nuclear Plant Projects (NPP), Nuclear Plant Support (NPS) and Plant Operations. In the area of the DCRDR an external contractor may participate in the process.

During the scopirig study the following guidelines were established:

a. It is important to utilize all of the CEOG documentation that has been developed in support of Supplement 1 to NUREG-0737.

b. The critical safety functions contained in the EPGs (CEN-152) provide a basis for the function analysis.

The resource trees found in this document will be independently developed in a plant specific fashion to identify:

1.

Success criteria for each safety function,

2.

Modes of control for each success p~th,

3.

Transient characteristics,

4.

Operator actions,

5.

Operator information and control needs,

6.

Equipment requirements,

7.

Key SPDS parameters,

8.

Critical Function Monitoring System (CFMS) alarm algorithm design, and

9.

RG 1.97 instrumentation requirements.

These items constitute the task analysis effort.

MI0684-0016A-NL02

2.0 Function Analysis The function analysis consists of three parts:

a.

Identification and definition of critical safety functions (CSF) that encompass the requirements of section 4.1.f of Supplement 1 to NUREG-0737.

b.

Identification of modes of control for each CSF based on the transient status of key parameters, plant equipment availability and plant response characteristics.

These modes of control will be referenced as "success paths" following the terminology of CEN-152.

c.

Identification of success criteria of the success paths for each CSF.

The use of the term critical safety function (as opposed to "safety function") was chosen to coincide with the terminology used in the CFMS.

The term safety function is used in CEN-152.

For this report both terms are synonymous.

"A critical safety function is any condition or action needed to either prevent core damage or minimize radiation releases to the general public.

If all CSFs are fulfilled, the safety.of the public is preserved."

To accomplish CSFs the operator does not have to know what event has occurred.

He needs to know what CSFs need to be accomplished, how to accomplish the CSFs and what criteria show that the CSF is being accomplished.

2.1 Classification of CSFs For the Palisades Plant, Consumers Power Company has identified eight CSFs that must be fulfilled.

All are directed at mitigating an event or containing and/or controlling radioactivity releases, These CSFs can be grouped into four major classes as follows:

1.

Anti-core melt CSFs,

2.

Containment integrity CSFs,

3.

Indirect radioactivity release CSF, and

4.

Maintenance of vital auxiliaries needed to support other CSFs.

The anti-cor.e melt class contains four CSFs:

1.

Reactivity control,

2.

Primary coolant system (PCS) inventory control,

3.

PCS pressure control, and

4.

PCS temperature control.

MI0684-0016A-NL02

Note that Consumers Power Company has reduced the number of CSFs in this class to four, down from the five contained in CEN-152.

Consumers Power Company has combined two CEN-152 safety functions, namely core heat removal and reactor coolant system heat removal*, into a single CSF named PCS temperature control.

This CSF terminology describes the operators control functions, actions, and instrumentation cues more closely than "heat removal" does.

CEN-152 considers temperature control as two safety functions that (1) remove decay heat generated in the core to a location where (2) it can be removed from the PCS to another heat sink.

The control of these two processes involve the same equipment and instrumentation and therefore are only considered as one CSF.

2.2 Definitions of CSFs The definitions of the anti-core melt CSFs follow:

CSF-1, Reactivity Control The purpose of reactivity control is to achieve and maintain a

• shutdown condition in the reactor.

CSF-2, PCS Inventory Control The purpose of maintaining PCS inventory control is to provide a medium for the removal of decay heat.

CSF-3, PCS Pressure Control The purpose of PCS pressure control is to maintain the PCS subcooled and prevent the loss of inventory through the pres-surizer power operated relief valves (PORVs) and/or safety valves thereby preventing release of radioactive liquid to the contain-ment and possibly the atmosphere.

The control of the maximum PCS pressure within Technical Specification limits is important to minimize the potential for pressurized thermal shock.

CSF-4, PCS Temperature Control The purpose of the PCS temperature control function is to remove decay heat and cool the PCS to a stable heat removal condition.

The containment integrity class contains two CSFs:

1.

Containment isolation, and

2.

Containment atmosphere control.

Consumers Power Company has reduced the number of CSFs in this class to two, down from the three contained in CEN-152.

Consumers Power Company has combined (1) the containment temperature and pressure control safety function and (2)* the containment combustible gas control safety function into the single containment atmosphere control CSF.

MI0684-0016A-NL02

The definitions of the containment integrity class follow:

CSF-5, Containment Isolation The purpose of the containment isolation function is to maintain closure/blockage of those flow paths required to isolate the containment following_ an event characterized by an increase in containment pressure and/or radioactivity levels or an increased risk of release of activity through a steam generator with leaking tubes.

CSF-6, Containment Atmosphere Control The purpose of the containment atmosphere control function is to maintain the containment temperature, pressure,* and combustible gas concentration within their design limits.

This will provide a barrier to fission product release and prevent damage to vital equipment.

Definitions of the remaining two CSFs follow:

CSF-7, Indirect Radioactivity Release Control The purpose of indirect radioactivity release control is to prevent radioactive releases to the environment from sources outside the containment such as the spent fuel pool and the radioactive waste storage and handling facilities.

CSF-8, Maintenance of Vital Auxiliaries The purpose of maintaining vital auxiliaries is to assure that support systems used to accomplish CSFs 1 through 6 (described above) are kept in service.

Support systems provide service such as instrument air needed in valve operation, AC and DC power needed for valve operation, pump motors, and operating instruments, *and an ultimate heat sink for PCS and core heat removal.

2.3 CSF Hierarchy The CSF concept incorporates a principle of CSF hierarchy.

Some CSFs have precedence over others as far as their sequence of implementation during an event.

Figure 1 summarizes the CSF hierarchy based on tran-sient response characteristics of Palisades.

The hierarchy concept is important in the design of systems used to fulfill each function and was also employed in developing CEN-152.

MI0684-0016A-NL02

FIGURE 1

-1 CSF Hierarchy Reactivity Control Maintenance of Vital Auxiliaries PCS Inventory Control PCS Pressure Control PCS *Temperature Control Containment Isolation Containment Atmosphere Control Indirect Radioactivity Release Control MI0684-0016A-NL02

3.0 Task Analysis Task analysis effort is a detailed extension of the function analysis effort.

Once the CSFs have been identified, a set of "success paths, 11 or modes of CSF control, must be determined.

The Palisades Plant is designed such that each CSF has multiple means of fulfillment.

Each method of fulfillment (mode of CSF control) is called a success path.

During any emergency event, the ~perator needs information on the plant state. This monitoring of the plant state leads to identification of systems available to satisfy the CSFs and the preferred success paths.

CEN-152 presents three principles to use the document:

1.

Principles of Standard Post Trip Actions (SPTA),

2.

Principles of Optimal Recovery Guidelines (ORG), and

3.

Principles of Functional Recovery Guidelines (FRG).

It is expected that the principles of CEN-152 will generally be adhered to by CPCo.

Some of the details may differ.

3.1 Standard Post Trip Actions The purpose of the SPTAs is to provide an entry point for all EPGs.

The emergency is defined as any off-normal event which actuates or requires a reactor trip (RT) to properly mitigate the event.

This definition is consistent with the NUREG 0899 definition and with industry practice.

The SPTA guideline contains, as its first operator action, a check of CSFs against acceptance criteria, followed by,standard actions and alternative actions which can be taken easily and quickly to restore those functions in jeopardy.

SPTAs contain the only immediate actions in the entire system of EPGs.

The purposes for this are to acknowledge the standard post trip actions which are performed by operators following an RT; and to standardize a*

safety function approach to any event which causes an RT.

SPTAs differ from the ORGs and FRGs in the task analysis area in that the level of technical information required extends only to the system level.

Action statements are sufficiently detailed to indicate the systems to be used, including important supporting systems, but detailed step-by-step guidance is not provided for operating (starting or stopping) ~ystems or components.

MI0684-0016A-NL02

3.2 Optimal Recovery Guidelines ORGs are written to cover specific symptom sets.

ORGs are grouped into classes of events which are difficult to distinguish from each other in the short term or which have similar effects on the NSSS over time.

The classes of events considered by CEN-152 are:

1.

Reactor Trip (RT),

2.

Loss of Coolant Accident (LOCA),

3.

Steam Generator Tube Rupture (SGTR),

4.

Excess Steam Demand Event (ESDE),

S.

Loss of Feedwater (LOF), and

6.

Loss of Forced Circulation (LOFC).

Consumers Power Company has not yet concluded that the above list is the best arrangement of ORGs.

Consumers Power Company will determine the specific classes of events to be included in the ORGs during the remainder of the function and task analysis project.

The RT event autom~tically leads the operator to the SPTAs which in turn will lead the operator to the FRGs if the details of the event are uncertain.

The tasks that an *operator performs and the operator instrumentation, decision, and information needs will not be addressed for the ORGs.

The details of this effort will be adequately covered during the task analysis associated with the FRGs.

The operator actions of the ORGs will refer the EOP writer to tasks and task analyses which are grouped according to specific systems or operations and commonly used by the FRGs and the ORGs.

The task analyses performed for the EOP update effort differs signifi-cantly from the task analysis effort which Consumers Power Company normally conducts for the training department.

The task analysis per-formed for training is based on the INPO catalogue of tasks which include_

details of all the actions, jnformation, instrumentation, and system performance associated with the operation of individual components or systems.

This information is used to train the operators how the equipment operates.

MI0684-0016A-NL02

It is assumed for the function and task analysis of the EOP upgrade effort that the operator is fully trained and experienced in the details of component operation provided in the training task analysis.

However, the individual operations used by the EOP upgrade task analysis will refer to the operator actions using the same terminology and catalogued action identification as provided by the Training Department task analysis when referring to specific operator actions.

The specific step-by-step details will not be restated in the EOP upgrade analysis.

Information cues and operator needs will be obtained from the training task analysis where appropriate.

3.3 Functional Recovery Guidelines FRGs are used to combat off-normal symptom pictures which result in a reactor trip and cannot be quickly-or easily diagnosed by the operators.

They may also be used to mitigate symptoms for which the operators have initially selected an ORG but subsequently discovered that they had misdiagnosed or that the ORG was not adequately treating symptoms as anticipated.

The Palisades task analysis will be conducted while developing the FRGs.

FRGs consist of the following sections in CEN-152:

a)

Safety function status check, b)

Resource assessment trees, c)

Op.erator action guidelines, d)

Long term actions, and e)

Bases.

The Palisades task analysis will cover all of these sections in order to provide _plant specific EPGs for the procedure writer.

In addition the task analysis will include sections that provide information for:

a)

Detailed control room design review, b)

Identification of RG 1.97 instrumentation, c)

Key SPDS* parameters, and d)

Critical function monitor system (CFMS) alarm algorithms.

For Palisades the Safety Parameter Display System (SPDS) presents CRT displays of the key parameters used by operators to evaluate the status of the CSFs.

In addition to the CRT which presents the SPDS displays, an additional CRT is avaialble to present the CFMS displays.

The CFMS was developed independently of the SPDS and provides.several key operator aids:

MI0684-0016A-NL02

a)

The alarm algorithms of the CFMS alarm if the success criteria for each CSF are not satisified.

Thus the CFMS is equivalent to the safety function status check (SFSC).

A concise SFSC is provided as the primary CFMS display.

The primary SPDS display contains a SFSC alarm indicator in the lower left hand corner to provide the operator information as to whether or not CSFs are satisified.

b)

The CFMS provides an historical data retrieval system (HDRS) for all SPDS parameters and parameters used by the CFMS.

Trend information can be displayed oh the CFMS CRT or printed in hardcopy form.

c)

The CFMS provides secondary displays for each CSF that show the status of safety function equipment needed for CSF success paths.

This aids the operator in selecting the correct success path and success criteria for the CSF.

NOTE:

One computer is used for the SPDS and the CFMS displays.

However, the CRT for the SPDS displays only the key CSF parameters.

A discussion of each of the task analysis operations is provided in the following sections:

3.3.l Safety Function Status Check The SFSC is the entry point for the FRG.

It is used to assess the status of each CSF.

The SFSC is structured to facilitate the selection of appropriate operator actions which will restore CSFs in jeopardy. Since CSFs are a complete set of the actions or conditions which will provide for plant and public safety, an EPG-which fulfills all of the CSFs preserves plant safety.

The SFSC lists the CSFs which must be checked in an emergency.

For Palisades the.CFMS provides a continuous computerized check of the SFSC items and displays and alarms when any CSF is unful-filled.

The SFSC lists the success paths associated with each CSF.

Listing the success paths permits the operator to select the CSF criteria appropriate to the success path in use.

For any given CSF, the appropriate criteria to use are those associated with the lowest success path on the list. After performing the SFSC and attempting to diagnos~ the plant condition, the operator will be generally aware of what equipment is operating.

Secondary displays of the Palisades CFMS will provide this equipment status for most success paths. If the CFMS is not operable, the Resource Assessment Tree charts for the CSF will assist in surveying the plant status.

Success paths are shown on the resource assessment trees in left to right orientation.

Moving to the right, the p~ths correspond to progressively more degraded plant conditions.

MI0684-0016A-NL02

The SFSC also contains the success criteria for each CSF.

The success criteria are organized in the SFSC such that each success path has its respective success criteria next to it. These are the success criteria used in the CFMS alarm algorithms.

Each CSF listed in the SFSC also contains reference to its respective resource assessment tree.

3.3.2 Resource Assessment Trees Resource assessment trees are pictorial representations of plant resources available to fulfill each CSF.

The trees are intended to assist the operator in evaluating plant resources available to fulfill CSFs.

A pictorial representation provides simplicity and clarity and is compatible with CRT displays.

Each limb of a tree starts at the top with the name of the CSF, then (working down) the name of the success path (mode), then the plant conditions and equipment used in that path (conditions, source, motive, power), then the su~cess criteria for that path, and finally, the number of the recovery guideline associated with that path.

3.3.3 Operator Action Guidelines Each success path in each resource assessment tree has a corres-ponding set of operator action (recovery) guidelines for imple-mentation of that success path.

Because different success paths may utilize the same quipment, more than one success path may reference the same guideline.

Guidelines are numbered according to the CSFs they serve.

For example, PC-2 is the second operator action guideline associated with PCS pressure control.

Each operator action guideline has the following structure:

1.

Name and number of the guideline,

2.

The recovery action steps for that path,

3.

The task numbers, using the INPO training nomenclature, associated with each recovery action step,

4.

The instrumentation information such as range, accuracy, speed of response, and setpoints used in the DCRDR,

5.

The key parameters that must be observed to satisfy the success

. path and displayed on the SPDS,

6.

The success criteria for that path used in the SFSC and the CFMS alarm algorithms, and

7.

Supplementary information for use of that path which should be considered when preparing the Palisades EOPs.

The items included should be precautions, cautions, notes, or information to be placed in the EOP training program.

MI0684-0016A-NL02 J

It should be clear that the above items constitute the basic task analysis effort.

3.3.4 Long Term Actions The long term actions section of the FRG is designed to ensure that the operator continues to periodically verify the adequate maintenance of safety functions, assesses the status of the plant, implements the appropriate ORG if conditions warrent, and determines the necessity, feasibility and/or urgency to perform a cooldown to cold shutdown conditions.

3.3.5 Bases The bases section for the FRG is a dialogue between 'the guideline preparer (function and task analysis team) and the procedure writer.

It is not intended that the bases appear in the_ de-tailed, plant specific EOP but rather it appears in preparing EOPs and in operator training.

The bases include information such as plant data, licensing analysis, realistic transient analysis, incident reports, sequence of events diagrams, and operating experience.

The bases presents a condensed form of this information for the DCRDR, RG 1.97 instrumentation team, the SPDS designer, the EOP writer, operators, and training personnel.

The bases section provides technical information that increases the operator's ability to identify the FRG that is appropriate and understand corrective actions expected.

The following points are addressed in the bases section:

1.

Overview of the FRGs for a given CSF,

2.

Potential events that could require the FRG to be required,

3.

General characteristics of the transients,

4.

Equipment required for the fulfillment of the FRG, and

5.

A detailed discussion of the range and trend of key parameters that exercise the FRG for a given CSF.

The following list contains examples of the significant plant parameters that are considered:

MI0684-0016A-NL02 Reactor Power PCS.Temperature Pressurizer Pressure Pressurizer Level Steam Generator Level Steam Generator Pressure Reactor Vessel Inventory

6.

Description of the operator action (tasks) objectives in satisfying the FRG for a given CSF and why these actions are

taken,

7.

The intermediate and long range goals of the actions for each CSF success path,

8.

The alternate success paths for each CSF, and

9.

How the success criteria for each CSF success path are established.

4.0 Validation and Verification When the function and task analysis effort is complete for Palisades the resulting information will be verified and validated prior to final implementation of the EOPs.

4.1 Verification Verification is the process by which the technical information in the EOPs is demonstrated to be accurate and complete.

The verification of the function and task analysis for Palisades will consist of:

a)

Technical review by Reactor Engineering Department (RED),

b)

Technical Review by Operations Department c)

Technical review by Nuclear Activities Plant Organization (NAPO).

The outcome of this verification process is a function and task analysis which is technically sound and complete.

4.2 Validation Validation is the process by which the function and task analysis information is demonstrated to be useable by the operators.

Validation will be accomplished by demonstration of the information on the Palisades simulator.

MI0684-0016A-NL02