ML20009A395

Draft Criteria for Preparation of Emergency Operating Procedures

ML20009A395
Person / Time
Issue date:	06/30/1981
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-0799, NUREG-0799-FC, NUREG-799, NUREG-799-FC, NUDOCS 8107100347
Download: ML20009A395 (50)

Text

m

/gpes 9s

$gf NUREG-0799 For comment

,3 Q g '2,

Draft Criteria for Preparation of Emergency Operating Procedures

)

1 U.S. Nuclear Regulatory i

Commission Office of Nuclear Reactor Regulation y nicoq Qfh) s...../ RWA 88287" 0799 R PDR

p- _ '~ Q -- ,.,f _,9 . r. f&; ~ 3 o ( - :r. r> 1 a .4 F w w J~+ f 'Available from GPO-Sales Program sDivision.of Technical Information and Document' Control ~ U.S. Nuclear Regulatory Commission . Washington, DC 20555' + w. a m

o NUREG-0799 For Comment =::- ::.__ r -_ T = : T = 2. Draft Criteria for Preparation of Emergency Operating Procedures 2.~ ::::TE:_ ^ :_:7' T.T ___.

_I:_ - - -._~ __. _-_'__ - __ _ - ___ -____ ~_-__ __-- _^

Mantscript Completed: April 1981 Date Published: June 1981 i Division of Human Factors Safety Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ga.,,, 4 l l l

~ 'TO: All Interested Parties

Gentlemen

SUBJECT:

REQUEST FOR PUBLIC COMMENTS ON ORAFT CRITERIA FOR PREPARATION OF EMERGENCY OPERATING PROCEDURES This report contains the work done to date by the staff in developing a program for preparation of Emergency Operating Procedures for nuclear power plants. It is being released early in the development process to encourage public participation and comments on the methods considered by the staff. The program is still in the development stages and is expected to be revised as the result of public comments and ongoing programs. For example, the-Institute for Nuclear Power Operations (INP0) is preparing guidelines for writing procedures. When these guidelines are available, the staff will consider them for input to the program. Also, some of the revised technical guidelines being developed by the Nuclear Steam Supply System (NSSS) vendors and associated Owners' Groups have not been submitted for staff review. These submittals may result in further modifications if other acceptable programs are described. The thrust of the program described in this report is threefold.

First, we encourage a thorough, systematic reanalysis of transients and accidents

' to provide a sound technical basis for the Emergency Operating Procedures. This coordinated analysis should prevent the " single issue" analysis that requires the operator _ to diagnose a specific event in order to take appropriate action. Second, personnel with experience in all aspects i of: design, construction, operations, and management should participate in the program for preparing technical guidelines and plant-specific Emergency Operating Procedures. This process should be well documented i l t i 1

- - - - - - 1 to ensure that the bases for the procedural steps are available to the operating staffs for training and for facilitating future changes that may be necessary because of plant modifications or operating experience. Third, since the concept of procedures accommodating multiple failures is a significant departure from past practice, we recommend an initial training program and upgradir.g of the requalification program to ensure operator familiarity with the new procedures. Implementation of the program, as establish'ed in NUREG-0737, Clarificatior. of. the TMI Action Plan, and discussed in the Introduction of this document, is currently the subject of rulemaking. In these proceedings, 10 CFR 50.34 ( paragraph (e)(2)(ii) applies to construction permit applications,10 CFR 50.34 paragraph (f)(1)(li) applies to operating license applications and 10 CFR 50.43a - applies to operating reactors. These proposed rules call for implementation as outlined in NUREG-0737. In Section 3, Preparation of Technical Guidelines, the staff has provided information on functional analysis and task analysis as part of the preparation of technical guidelines. These analyses are also intended to fulfill a major portion of the function and task analysis necessary to conduct the control room design review. Section 3 incorporates, as appropriate, portions of the systems review identified in NUREG-0659, f Staff Supplement to the Draft Report on Human Engineering Guide to Control Room Design Review, modified to reflect bot 1 written public comments, l ) 4 I. N A and those received orally at the April 22 and 24,1981, public meetings in Bethesda, Maryland. The staff anticipates that NUREG-0700, Guidelines l for Control Room Design Reviews, will contain a similar section. To further clarify the scope of the function and task analysis necessary for the control o room design review, Section 3 of this document will be modified to reflect any differences between the information needed for the control room design reviews and preparation of Emergency Operating Procedure Guidelines. The published Criteria for Preparation of Emergency Operating Procedures, which incorporates public comments, will be used by the staff in evaluating whether an applicant / licensee meets the requirements of the Commission's regulations as stated in the Foreword. This document is not intended to replace the regulations, and compliance with the criteria of this document will not be a requirement. However, use of criteria different from those contained in the document that incorporates the resolution of public comments will be acceptable only if the substitute criteria meet the requirements of the regulations for Emergency Operating Procedures. / 7 ,\\ a,,,..... i /n ,,<,u. Dennis L. Ziemann, Chief Procedures and Test Review Branch Division of Human Factors Safety

ABSTRACT -This document, NUREG-0799, is being issued for public comment on draft criteria for the preparation of Emergency Operating Procedures, developed in support of items I.C.1, I.C.8, and I.C.9 of the Task Action Plan (NUREG-0660 and NUREG-0737). These criteria were developed from information contained in contractor reports (NUREG/CR-2005, NUREG/CR-1970, NUREG/CR-1977, NUREG/CR-1999, and NUREG/CR-1875), staff review of the literature, and staff experience.in the pilot monitoring of Emergency Operating Procedures for near-term operating licensees. i 1 l l iii

CONTENTS Pagg ABSTRACT-................................ iii FOREWORD................................ ix 1-1 l' -INTRODUCTION........................... 1.1 Implementation........................ 1-2 2 DEFINITIONS............................ 2-1 Emergency Operating Procedures................' 2-1 2.1 ' 2. 2 Technical Guidelines..................... 2-1 2.3 Emergency Operating Procedures Guidelines 2-1 2.4 Implementation Plan 2-1 2.5 Shall,.Should, and May.................... 2-1 2.6 Automatic Actions 2-1 2.7 Immediate Operator Actions.................. 2-1 2.8 Subsequent Operator Actions 2-1 3 PREPARATION OF-TECHNICAL GUIDELINES................ 3-1 3.1 Analysis Supporting Preparation of Technical Guidelines 3-1 3.2 Documentation 3-1 3.3 Referencing Generic Guidelines................ 3-2 3.4 Coordination of Efforts 3-2 3.5 Validation of Generic Technical Guidelines.......... 3-2 3.6 Configuration Control and Changes 3-2 4 CRITERIA FOR THE PREPARATION OF PLANT-SPECIFIC EMERGENCY OPERATING PROCEDURES 4-1 4.1 development of Plant-Specific Emergency Operating Proce..ures. 4-1 4-1 4.2 Assumptions 4.3 General Requirements and Guidance 4-? 4.3.1 Procedure Orientation................. 4-2 i l 4.3.2 Document Control Procedure 4-2 4.3.3 Consistency Between Staffing and Procedures...... 4-2 4.3.4 Division of Responsibility 4-2 4.3.4.1 Staffing of the Control Room and Availability of Other Qualified Personnel 4-3 l 1 4.3.4.2 Training and Experience of Personnel..... 4-3 4.3.4.3 Layout of the Control Room.... 4-3 4.3.4.4 Specification of Areas of Responsibility... 4-3 4.3.5 Procedure' Availability and Accessibility 4-4 i v

CONTENTS (Continued) Page 4.3.5.1 General Availability............. 4-4 4.3.5.2 Hard Copy Availability............ 4-4 4.3.5.3 Accessibility 4-4 4.3.6 Consistency Among the Procedures............ 4-5 4.3.7 Replacement of "Used" Procedures............ 4-5 4.3.8 Reproduction of Emergency Operating Procedures. '4-5 4.4 Presentation of Information 4-5 4.4.1 Organization of Procedures 4-6 4.4.1.1 Cover Page. 4-6 4.4.1.2 Tabic of Contents 4-8 -4.4.1.3 Scope 4-8

4. 4.1. 4 Initiating Syniptoms or Entry Conditions 4-8 4.4.1.5 Immediate Operator Actions..

4-8 4.4.1.6 Subsequent Operator Actions 4-9 4.4.1.7 Appended Material (Attachments) 4-9 4.4.2 Format. 4-9 4.4.2.1 General Approach............... 4-10 4.4.2.2 Specific-Requirements and Guidance...... 4-10 4.4.3 Style of Expression and Presentation 4-14 4.4.3.1 Vocabul a ry.......... 4-14 4.4.3.2 Use of Abbreviations and Acronyms 4-15 4.4.3.3 Sentence Structure.......... 4-15 4.4.3.4 Punctuation and Grammar 4-15 4.4.3.5 Capitalization................ 4-15 4.4.3.6 Use of Symbols................ 4-16 4.4.3.7 Use of Units................. 4-16 4.4.3.8 Use of Numerals 4-16 4.4.3.9 Tolerances.................. 4-16 4.4.3.10 Use of Logic Terms.............. 4-16 4.4.4 Content of Procedures... 4-19 4.4.4.1 Sequencing. 4-19 4.4.4.2-Individual Steps... 4-20 4.4.4.3 Additional Information............ 4-22 5 VALIDATION AND VERIFICATION OF PLANT-SPECIFIC EMERGENCY OPERATING PROCEDURES 5-1 5.1 Validation of Plant-Specific Emergency Operating Procedures 5-1 5.1.1 Background 5-1 5.1.2 Method 5-1 vi

2 s CONTENTS (continued) P, age 5.1.3 Corrective Actions 5-1 5.1.4 ' Validation on a Simulator............... 5-2 5.2 Verification of the Emergency Operating Procedures...... 5-2 5-2 -5.2.1 Program for Verification 5.2.2 Documentation..................... 5-2 5-2 5.2.3 Reporting Requirements 6 OPERATOR FAMILIARIZATION AND TRAINING............... 6-1 6-1 6.1 Description 6-1 6.2 Training for Initial Implementation 6-1 6.2.1 Lectures....................... 6.2.2 Simulators and Control Room Walk-Throughs....... 6-1 6.2.2.1 Simulators.................. 6-1 6.2.2.2 Control Room Wal k-Throughs.......... 6-1 .6.3 Refresher. Training...................... 6-2 6-2

6. 4 Training on Revisions Appendix 1.

Notes........................... Al Appendix 2. References and Bibliography................ A2-1 Appendix 3. Sample Emergency Operating Procedures............ A3-1 I L vii t

i l FOREWORD NUREG-0799 is being issued to present for public comments the criteria that the U.S. Nuclear Regulatory Commission (NRC) staff intends to use in evaluating whether an applicant / licensee meets the requirements of 10 CFR 50.34(b)(6)(v) for Emergency Operating Procedures. A revised set of criteria, incorporating staff evaluation of public comments will be issued in a later document. Neither NUREG-0799 nor the revised document will replace 10 CFR 50.34(b)(6)(v), and compliance with the criteria will not be a requirement. However, use of criteria different from those incorporating the resolution of public comments on-NUREG-0799 will be accepted only if the substitute criteria provide a basis for determining that the requirements of 10 CFR 50.34(b)(6)(v) for Emergency Operating Procedures have been met. In developing _this document the NRC staff has considered information available from a broad range of inputs as indicated in Appendix 2. (See also Appendix 1, Note 1.) This included recently published documents that report the results of the work of several contractors related to development of Emergency Operat-ing Procedures. These reports included NUREG/CR-1999, " Human Engineering ' Guidelines for Use in Preparing Emergency Operating Procedures for Nuclear Power Plants;" NUREG/CR-1977, " Guidelines for Preparing Emergency Procedures for Nuclear Power Plants;" NUREG/CR-1875, " Evaluation of Emergency Operating Procedures for Nuclear Power Plants;" NUREG/CR-2005, " Checklist for Evaluating Emergency Procedures Used in Nuclear Power Plants;" and NUREG/CR-1970, " Develop-ment of a Checklist for Evaluating Emergency Procedures Used in Nuclear Power Plants." The availability of these reports is being highlighted to ensure that all applicable information is considered. However, comments on the contractor documents should be limited to their impact on ti.- criteria in this report. Mr. Don Beckham is the NRC Task Manager for the criteria for development of Emergency Operating Procedures. Should there be specific questions regarding the criteria, Mr. Beckham may be contacted by calling (301) 492-4958 or by writing to the following address: Division of Human Factors Safety Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: D. H. Beckham All comments for consideration specifically in connection with NUREG-0799, should be sent to the following address: Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch ix

c i 1 INTRODUCTION As required by the "TMI Task Action Plan," NUREG-0660, and "TMI-Related Require-ments for New Operating Licenses," NUREG-0694, Item I.C.8, the U.S. Nuclear .. Regulatory Commission (NRC) staff has been conducting pilot monitoring of emergency-procedures for near-term operating license (NT0L) applicants. In these reviews the staff has surveyed existing methods of developing and imple-menting Emergency Operating Procedures at nuclear power plants. In this document NRC staff has coordinated: (1) information gained from the pilot monitoring program and from the reanalysis of transients and accidents that was required by Task Action Plan Item I.C.1.(3) and clarified in NUREG-0737, " Clarification of the TMI Action Plan Requirements," Item I.C.1, (2) the NRC survey of human factors criteria applicable to Emergency Operating Procedures, and (3) the application of these criteria to the near-term operating license reviews. .The purpose of'this document is to identify the elements necessary to prepare and implement a program of Emergency Operating Procedures that will mitigate the consequences of a broad range of initiating events and multiple equipment failures. Although all of the events and conditions identified in Appendix A of Regulatory Guide 1.33 should be covered by appropriate procedures, only those that fall within the definition included in this document should be designated Emergency Operating Procedures. This document applies only to Emergency Operating Procedures so designated, and specifically does not address emergency preparedness or emergency planning. The staff recognizes that the development of Emergency Operating Procedures is, by necessity, a dynamic process and that new information should always be incorporated, as appropriate, into the Emergency Operating Procedures. How-ever, the reanalysis of Item I.C.1 and the criteria of this document are inteaded to reduce the frequency and extent of revisions to Emergency Operat-ing Procedures to ensure that the operators are not constantly being required to adjust to new procedures. This document has drawn upon a wide range of expertise and literature to identify the best available information related to preparation of procedures in general and to Emergency Operating Procedures in particular. This review also identified a large body of information that was not directly applicable because of the difference in technologies involved or the difference in con-straining factors, such as time response. This information, as well as the applicable information, has been included in Appendix 2, References and Bib!iography. (See Appendix 1, Note 1.) Any additional information, particu-larly information available from experimental data applicable to this document, should be called to our attention or forwarded to the NRC with a description ) of its potential usefulness. Comments on this document should be supported by ] references and field experience to the greatest extent possible and additional alternatives should be identified. In this document the staff attempted to accommodate a broad range of acceptable programs being developed in response to NUREG-0737, Item I.C.1. Although we I recognize that there are necessary differences dictated by variations in plant designs, we encourage the ' approaches taken to be made as similar as possible. i 1-1 l

This is intended to facilitate the most efficient development of Emergency Operating Procedures at utilities with multiple reactor sites and to reduce the impact on operators transferring from one station to another. NUREG-0799 represents the first step in developing a plan for upgrading of plant procedures, as required by TMI Action Plan, Item I.C.9. Future staff actions related to normal and abnormal operating procedures, maintenance and test procedures, and surveillance procedures will be addressed as new regulatory guides, revisions to existing regulatory guides, or revisions to the Standard Review Plan (5RP). 1.1 IMPLEMENTATION This document is being made available for public comment. The criteria that result, following necessary revisions to incorporate the public comments received, will be applied to operating reactors, applicants for operating licenses, plants under construction, and applicants for construction permits as appropriate to their stage of review. For operating reactors, NRC review of the plan for development and implementation of Emergency Operating Procedures is not required before implementation. However, a program plan including Technical Guidelines containing all necessary plant-specific data shall be submitted for staff review. The staff will document their review of the program. For applicants for operating licenses, the staff anticipates continuing the Pilot Monitoring of Emerge cy Procedures, as identified in Task Action Plan, Item I.C.8 for all applicants with expreted operating license issuance dates earlier than January 1, 1982. However, an applicant may request the staff to review the program developed in accordance with this document. For all other plants under construction and applicants for construction permits, a program plan for development of Emergency Operating Procedures, containing all necessary plant-specific Technical Guidelines, shall be developed. For plants applying for operating licenses, a description of the plan, as identi-fied in this document, shall be submitted in Section 13.5 of the Final Safety Analysis Report (FSAR). For plants applying for construction permits, a commitment to develop a plan shall be included in Section 13.5 of the Preliminary Safety Analysis Report (PSAR). The staff review will be docu-mented in the Safety Evaluation Report (SER). i l-2

2 DEFINITIONS 2.1 EMERGENCY OPERATING PROCEDURES Plant procedures that direct actions necessary to mitigate the consequences of transients and accidents developed from the reanalysis _of transients and accidents, as clarified in NUREG-0737, Item I.C.1. The transients and acci-dents involved are those that cause plant parameters to exceed reactor protec-tion _ system setpoints or engineered safety feature setpoints. 2.2 TECHNICAL GUIDELINES Documents that identify the equipment or systems to be operated and that list the steps necessary to mitigate the consequences of transients and accidents.

2. 3 EMERGENCY OPERATING PROCEDURES GUIDELINES The directions for preparing Emergency Operating Procedures included in both the Technical Guidelines and this document.

2.4 IMPLEMENTATION PLAN A' description of the program for implementing the Emergency Operating Procedure Guidelines (including analysis), Technical Guidelines, preparation of plant-specific Emergency Operating Procedures, validation and verification, approvals of the plant-specific Emergency Operating Procedures, and training. ~ 2.5 SHALL, SHOULD, AND MAY The word "shall" is used to denote that-the item is essential for successful program development; the word "should" denotes a recommendation; and the word "may" denotes permission. 2.6 AUTOMATIC ACTIONS Actions that are expected to occur as a result of a transient or accident, and without operator involvement. 2.7 IMMEDIATE OPERATOR ACTIONS Actions taken by the operator that are essential to mitigate the initiating symptoms and to place the plant in a condition that allows the operator time to refer to the Emergency Operating Procedures. 2.8 SUBSEQUENT OPERATOR ACTIONS Actions that are to be taken by the operator to take the reactor to a normal condition or to provide for a safe extended shutdown period, i 1 2-1

3 PREPARATION OF TECHNICAL GUIDELINES 3.1 ANALYSIS SUPPORTING PREPARATION OF TECHNICAL GUIDELINES Technical Guidelines identifying the functions, operator tasks, indications, and controls necessary for developing Emergency Operating Procedures shall be prepared. The orientation of the Technical Guidelines shall allow the operator to mitigate the consequences of the event, based on its symptoms, without prior diagnosis of the particular event. This may be done for a single plant or for a group of plants with similar designs. If the guidelines are prepared for similar plants, differences between the plants shall be identified and alternate methods that result from these differences clearly referenced to the applicable designs. Preparation of Technical Guidelines shall be based on a systematic evaluation of plant operation using realistic, best estimate analysis of plant response under normal and abnormal conditions. This analysis should concentrate on identifying plant functions that prevent core damage and radio-activity release to the environment. The analysis should then also identify the systems and subsystems that are available or required to provide these functions. Following this systems identification, an analysis should be conducted to identify the operator tasks that are necessary to support the functions identified in the analysis. This task analysis should consider component failures and operator errors that would threaten the accomplishment of the necessary ft actions. Part of this review should be to specify the characteristics of the instrumentation and controls necessary to accomplish these tasks. The analysis may be incorporated into the systems review described in NUREG-0700, " Guidelines for Control Room Design Review." Information from the task analysis should be used to identify human factors deficiencies in the control room. These deficiencies will be evaluated as described in NUREG-0700. In defining the scope of the system review, each licensee may consider the consequences of the failures and errors and their relative contribution to the overall risk. The analysis and guidelines should include mitigating actions for all failure paths that can contr bute appreciably to the overall risk. i 3.2 DOCUMENTATION The process used in developing the Te-hnical Guidelines shall be documented in sufficient detail to allow engineers and human factors analysts to follow the flow of information from its analytical base to the development of the Technical Guidelines, thereby providing an adequate description of the process involved. The development process should include documentation of the assumptions upon which the analysis was based; a reference to the results of the analysis; a description of the actual process used to generate the Technical Guidelines; the information necessary to interpret the Technical Guidelines and apply them to plant-specific cases; and a description of the intended use of the Technical Guidelines and the procedures prepared from the Technical Guidelines. The Emergency Operating Procedure Guidelines should include the method of use, initial and subsequent training of operators, administrative controls to be applied to configuration control, verification and validation, and the proposed implementation methods. 3-1

3.3 REFERENCING GENERIC GUIDELINES If the generic development approach is used, each plant to which the General Technical Guidelines are applicable may incorporate these Technical Guidelines into its submittal by reference. If generic Technical Guidelines, such as those prepared by owners' groups are referenced, plant-specific differences should be identified in both the technical information and the anticipated use of the Technical Guidelines and Emergency Operating Procedures. 3.4 COORDINATION OF EFFORTS ' Development of the Technical Guidelines should 'be coordinated with other ongoing efforts to ensure that best use is made of resources without duplication of affort, and that the programs are compatible. Examples of other programs that impact the development of Emergency Operating Procedure Guidelines are the control room design reviews (NUREG/CR-1580, NUREG/CR-0659, and NUREG/CR-0700), ' development of a Safety Parameter Display System (NUREG-0696), changes in instrumentation and indications (Regulatory Guides 1.47 and 1.97, individual items in NUREG-0660 and NUREG-0737), and changes in requirements for training and staffing (NUREG-0731). In the development of Technical Suidelines, the applicability or adaptability to known or anticipated control room improvements should be considered. Examples are the control room design review as outlined in NUREG-0700, the Safety Parameter Display System, and possible display of procedures and other information on interactive video display systems. 3.5 VALIDATION OF GENERIC TECHNICAL GUIDELINES The Technical Guidelines developed sSall be validated to ensure that the technical information is correct and that the actions specified would result in the anticipated plant response. Methods for performing this validation may include independent verification of calculotioas and methodology, review of actual operational experience, or others. The guiaelines should be reviewed by a broad range of professionals, including operating personnel and licensed operators. Finally, the guidelines ihall be exercised on dynamic simulators appropriate to the plant designs addressed in the Technical Guidelines. Deficiencies i;r problems noted in the simulator exercises shall be investigated to determine if they are due to simulator modeling problems or deficiencies in the Technical Guidelines. Deficiencies in the Technical Guidelines shall be corrected. The simulator exercises should extend to the limits of the capability of the simulator to respond. When significant advancements are made to simula-tors, revalidation of the appropriate Emergency Operating Procedures should be t performed. 3.6 CONFIGURATION CONTROL AND CHANGES A program for controlling changes to the Technical Guidelines shall be developed. This may include agreement with applicable vendors, contractors, and Owners' Groups. The program shall include a mechanism for approving and promulgating these changes and for ensuring that approved changes are incorporated into the Emergency Operating Procedures. The staff will not extend the requirement of NUREG-0660, Item I.C.7, Vendor Review of Procedures, to operating reactors. 3-2

b-Existing commitments to NRC Regulatory Guides, particularly_ Regulatory Guide 1.33, - shall be reviewed to ensure that the existing commitmants are consistent with the program developed in response to the criteria in this report.. Safety Analysis Report commitments or Technical Specification requirements shall be reviewed before implementation, to preclude conflicts. Implementation of the revised Energency 0perating Procedures shall proceed in accordance with the schedule provided in NUREG-0737, Item I.C.1. _NRC staff review is not required before implementation, except for technical specification changes. 'l fl e I l 3-3

4 CRITERIA FOR THE PREPARATION OF PLANT-SPECIFIC EMERGENCY OPERATIM3 PROCEDURES 4.1 DEVELOPMENT OF PLANT-SPECIFIC EMERGENCY OPERATING PROCEDURES Following completion of the implementation plan, licensees should initiate- . development of the plant-specific Emergency Operating Procedures using the criteria presented below. These criteria are intended to provide a minimum basis for preparing acceptable Emergency Operating Procedures. It is impor-tant to recognize that significant improvements in existing Emergency Operating Procedures beyond those achievable with the criteria of this docu-ment are possible and desirable. In this regard, it is recommended that the utilities monitor the work of industry-sponsored groups and participate in their programs to refine and improve the utilities' Emergency Operating Procedures. In developing the criteria that follow, the staff considered the role of Emergency Operating Procedures in promoting plant safety. This is not only a function of their technical adequacy, but also of their utility. Utility means that the procedure _ should be usable by, and acceptable to, control room personnel. Usability includes aspects such as completeness, accuracy, conven-ience, and readability. Acceptability is a function of both usability (a procedure that is usable is more likely to be acceptable) and the degree to which the users have provided input into the development of the procedure. The criteria specified in this section were developed by the staff within the above framework by assessing tho'se aspects of procedure preparation which are believed to optimize the usability and acceptability of Emergency Operating Procedures. The basis of the specific criteria was the data collection and evaluation described in Section 1 of this document. The task of developing plant-specific Emergency Operating Procedures falls into two general categories, technical content and presentation of informa-tion. The first category, technical content, is primarily supported by Technical L.idelincs with additional sources of input based on plant-specific design characteristics, operator experience, engineering judgment, reference plant analyses, and plant-specific transient and accident analysis, as des-cribed in Section 3.0. The criteria presented in this section discuss the second category, the presentation of information in Emergency Operating Pro-cedures, regardless of the reactor type or vendor. The specific approach adopted by a given plant should reflect the individual characteristics of the plant, input from the operators, and personal preference. 4.2 ASSbMPTIONS In developing the criteria, the staff made the following assumptions: There is a specific hierarchy of operator activities that define the priority and sequencing of steps. 4-1

The' Emergency Operating Procedures will 'be incorporated into i. raining -e twhere they will be supplemented by additional documentation and information. e All personnel using the Emergency Operating Procedures to direct plant ~ operations will.be qualified as recommended in Regulatory Guide _1.8 and -l .will be either operators licensed under the' requirements set forth in. ^10 CFR 55, or under the direction of licensed operators. Other advisory personnel ~,.such_as the shift' technical advisor, will conform to appli-cable' administrative-procedures. The-illumination provided at the procedures-work station.under normal and e . abnormal conditions (e.g... loss of offsite power) will be adequate for the. operators to read the procedures. 4,3'.. GENERAL REQUIREMENTS AND GUIDANCE 4.3.1 . Procedure Orientation Each plant shall have~a single Emergency 09erating Procedures document. Ihis document' may be a ' set of procedures:in a single binder or location, or a single Emergency Operating Procedure with component subprocedures. The pro-cedures'shall be written so that they can be entered without requiring diagnosis of the specific initiating event. 4.3.2 Document Control Procedure Emergency.0perating Procedures shall be controlled within the Document Control ~ System consistent with the requirements set forth in the Standard Review Plan, Section 17.2.6. Where operational experience or other information indicates that incomplete or. incorrect procedures are in place, a program shall be avail-able to quickly prepare and implement the required changes including the neces-sary reviews and approvals. Changes to the Emergency Operating Procedures and the Technical-Guidelines shall~be reviewed in accordance with the plant Technical Spa-ifications. The review method shall include a determination of whether the proposed changes are minor-(e.g., editorial or nomenclature), significant (changes that affect the sequence of actions or actions themselves), or repre- .sent unreviewed safety questions in accordance with 10 CFR 50.59. 4.3.3 Consistency Between Staffing and Procedures The licensee shall ensure that the Emergency Operating Procedures are struc-tured so that the manpower required to carry out concurrent actions does not exceed the minimum shift staffing required by the Technical Specifications. This'may be accomplished by any combination of changes to staff manning in the Technical Specifications or restricting the number of concurrent actions. 4.3.4 Division of Responsibility During an emergency, it' is vital that the actions of the control room staff be carried out efficiently and accurately. This, in large part, will be deter- ' mined by the quality of Emergency Operating Procedures and the training of the operators. For the benefits of good procedures and training to be realized, it is important that during an emergency, control room pervnnel operate as'a team, with pre established leadership and divisions of responsi-bility.. The specifics of team organization and divisions of responsibility 4-2

will clearly depend upon plant characteristics, staffing, and control room design. Licensees and applicants shall establish a program to define divisions of responsibility in the control room. 4.3.4.1 Staffing of the Control Room and Availability of Other Qualified Personnel The number and qualifications of personnel available in the control room will in large part determine the number of concurrent activities that can be carried out and the efficiency with which they are carried out. In determining the division of responsibilities, the following should be considered: Operator activities during an emergency should be planned to minimize e physical conflicts, such as requiring personnel to carry out actions at the same locations at the same time, or minimizing situations where personnel will frequently cross paths in moving from one location to another. This activity should be coordinated with the control room design review. The opportunity for personnel to unintentionally duplicate the action e steps of a given procedure should be minimized. The control room supervisor should be able to keep up with staff actions and plant status. 4.3.4.2 Training and Experience of Personnel The division of responsibility should reflect the training and experience of control room personnel. In this regard the licensee shall ensure that all assigned responsibilities are within the capabilities and training of respon-sible personnel consistent with Technical Specification qualifications. 4.3.4.3 Layout of the Control Room The licensee should ensure that the layout of the control room is considered in planning actions and in developing of the Emergency Operating Procedures to facilitate information transfer and to minimize conflicts in performing the various actions necessary. 4.3.4.4 Specification of Areas of Responsibility Specification of given areas of responsbility for the control room crew during applicaton of Emergency Operating Procedures should consider: Decision making and diagnostics, e Procedures sign-off, e Verification of actions and of systems or plant response, Communications within the control room, o Communications outside the control room, o Panel / function / system responsibilities, and o Actions that must be taken outside of the control room area or on back e panels. 4-3

The variable and unpredictable nature of control room events and the lack of specific emergency experience data make conformance with the criteria in Section 4.3.4 difficult in many instances. To the extent possible these considerations should be incorporated into the licensee's plan of action during emergencies. The licensee should maintain the flexibility of shifting responsibilities during an accident to account for changing conditions. For additional information on division of responsibility see ANSI /ANS 3.2-1980 (Draft 7, March 1981).1 (See Appendix 1, Note 1.) 4.3.5 Procedure Availability and Accessibility Procedures that are difficult to retrieve are less likely to be used. It is recognized that no single approach for locating, accessing, and using emergency . procedures is optimal for all plants. Regardless of the approach adopted, the following criteria shall apply: -4.3.5.1 General Avai1 ability The location of Emergency Operating Procedures within the control room is primarily dictated by control room layout. The procedures shall be located so that the operators have convenient access without being obstructed in carrying out their duties. Provision shall be made to permit laying down one or more Emergency Operating Procedures in a manner that will not interfere with work station activities. The licensee should prohibit operators from placing procedures over controls or displays. Acceptable approaches that may be used are slideout shelves, appropriately placed tables or desks, or movable carts. The working height of the procedures work station should be convenient for all control room personnel to use. 4.3.5.2 Hard Copy Availability All operating plants shall have at least one paper copy of emergency procedures available in the control room. Where two or more control rooms share a common area, each unit shall have a dedicated set of Emergency Operating Procedures that contain only the Emergency Operating Procedures for only that particular unit.8'8 4.3.5.3 Accessit ility Accessibility refers to the ease with which the operator can identify and access the relevant Emergency Operating Procedures. The Emergency Operating Procedures shall be labeled to facilitate rapid identification and access. Where the Emergency Operating Procedures are located with other procedures (e.g., normal operating and maintenance) they shall be set off from the other procedures with a distinctive marking of the binder or location. This may be accomplished by distinctively coloring the binders, using large letter labeling on the binders, or designating a specific, well-marked location for the procedures. Such marking will also facilitate returning the Emergency Operating Procedures to their proper location. 4-4

i Each part or subset of Emergency Operating Procedures that is referenced shall be indexed or partitioned so that the operator can easily identify the needed materials. Regardless of the approach adopted it shall be maintained in good condition. Experience has i.ndicated that common paper tabbing and inserts will wear with time and use.84 4.3.6 Consistency Among the Procedures In developing the Emergency Operating Procedures from the criteria that follow, the particular approach that is selected shall be used consistently throughout the procedures document. Specifically, all procedures and subprocedures shall be consistent with regard to organization, format, style, and content. 4.3.7 Replacement of "Used" Procedures Where the check-off or sign-off provision on the operational copy of the Emergency Operating Procedure or any part of that procedure has been used, the involved pages shall be replaced within 24 hours or when use of the Emergency Operating Procedures is no longer required, whichever is later. 4.3.8 Reproduction of Emergency Operating Procedures The operational copy of the Emergency Operating Procedures shall be of a readable quality. Under certain conditions it may become necessary to replace the entire procedure or parts of the procedure (due to revisions, use, wear, etc.). Where replacements are necessary, the quality of the copy shall not be discernibly less than that of the original. Particular care should be taken in ensuring that when copies are made, the entire page is reproduced (i.e., no instructions or parts of instructions are omitted). This may be accomplished by placing identifying marks around the page to delineate procedure boundaries. Where colored paper is used (see Section 4.4.2.2 (g)(7)), all replacements should be in the same color as the original. 4.4 PRESENTATION OF INFORMATION Presentation of the information in the Emergency Operating Procedures deter-mines their readability. Readability, as it is used here, is that characteristic of written material that determines how easily, rapidly, and precisely the material can be read and understood. In the criteria that follow, readability is primarily considered from the standpoint of legibility and intelligibility. (See Appendix 1, Note 3.) Legibility refers to the typographical characteristics of the symbols and their arrangement. A procedure may be considered legible if the written material can be identified and read rapidly, reliably, and easily.5 Intelligibility refers to the way in which the written material is presented. A procedure may be considered intelligible if: It can be easily read, e It can be read rapidly without interruption, e It can be precisely understood, e It can be understood without the aid of additional material, e 4-5

r e The reader accepts the information presented, e It can be learned well, It can be retained, e It can be used easily as an instruction, e It is simple, ordered, and pertinent, and e e The content is familiar.5 The remainder of this section is divided into four parts: Organization of Procedures, e Format and Typological Design, e Style of Expression and Presentation, and e e Content of Procedures. In these sections some-specific apper.nes for upgrading the readability of Emergency Operating Procedures will be provided. Where sufficient data exist to support adopting a single approach, use of that approach is identified by use of the word "shall." Where insufficient, inconsistent, or incomplete data exist to identify a single approach, but where some approaches appear superior to others, these approaches are identified by use of the word "should." Where a number of alternative approaches would be equally acceptable, they are identified by use of word "may." Performance-shaping factors such as the characteristics of the environment (e.g., illumination and control room layout), the particular emergency situ-ation (e.g., time pressures and stress level imposed), and the operator (e.g. training and experience) may also affect the usability and acceptability of the procedure.S 4.4.1 Organization of Procedures The basic organization of emergency procedures should be in accordance with Exhibit 1. Procedures that are written as a single procedure should follow this format. For plants that adopt 'a multiple procedure approach, the format of Exhibit 1, Sections 5.2, 5.3, and 5.4, etc. may be modified to allow for delineation of action steps. 4.4.1.1 Cover Page The cover page shall contain: Title and procedure number, e Current revision number and date, e Number of pages, and e Review and approval signatures. j e i 4-6

Exhibit 1. Organizational Format'for Emergency Procedures LCover Page Table of Contents (Optional) i-1.0 ~ Scope 2.0 Initiating Symptoms or Entry Conditions 3.0 Automatic System Actions (Optional) 3.1 Automatic Action 3.2 Automatic Action (etc.) 4.0 Immediate Operator Actions 4.1-Verify Automatic Actions 4.2 First Operator Action 4.3 Second Operator Action (etc.). 5.0 Subsequent Operator Actions 5.1 Verify Immediate Operator Actions 5.1.1 First action step 5.1.2 Second action step (etc.) 5.2 Diagnostics 5.2.1 First action step 3 5.2.2 Second action step (etc.) 5.3 Subprocedure 1 - Title of subprocedure 5.3.1 Title of first task 5.3.1.1 First action step 5.3.1.2 Second action step (etc.) 5.3.1.n - Final conditions 5.3.2 Title of second task (etc.) 5.3.2.n - Final conditions 5.4 Subprocedure 2 - Title of Subprocedure (Organized as Above) 6.0 Appended Material - 7

4.4.1.2 fable of Cont.nts e Although it is desirable to minimize clutter in the Emergency Operating Proce-dures, it may be advantageous when a single Emergency Operating Procedures document is used to include a Table of Contents at the front of the procedures document. Where the' control room capies of the Emergency Operating Procedures - are often referenced, used for training and review, or simply accessed to insert revisions, a Table of Contents would minimize wear on the documents caused by " thumbing through," facilitating the search for specific sections or informa-tion. A Table of Contents may, therefore, be included at the discretion of the licensee. 4.4.1.3 Scope The emergency procedure shall have a brief statement of scope that describes what the procedure is intended to accomplish. 4.4.1.4 Initiating Symptoms or Entry Conditions This section shall list the initiating' symptoms or entry conditions that would require the operator to perform the actions in the Emergency Operating Procedure. They should include Llarms, indications, operating conditions, automatic system actions, and probable magnitudes of parameter changes. Where a condition is specific to the emergency under consideration, it should be listed first. 4.4.1.5 Immediate Operator Actions This section shall list the operator actions that are essential for the opera-tor to take to stop the degradation of conditions, mitigate their consequences, and allow the operators time to evaluate the situation. The immediate opera-tor actions shall be memorized. The number of actions included in this section should be minimized, but should include the following. (a) Verification of Automatic Actions: This step is based on equipment operating as designed and symptoms developing as anticipated in the-Technical Guidelines. Since variation from the expected course may occur, operators should be alert to the failure of expected automatic actions, as well as the occurrence of inappropriate automatic actions, and be prepared to manipulate controls as necessary to cope with the actual event. However, the procedure should caution the operator not to place systems in " manual" unless misoper-ation in " automatic" is apparent, and should require the operator to make frequent checks for proper operation of systems placed in manual control. (b) Assurance That the Reactor Is.n a Safe Condition: This step usually means shutdown of the reactor with sufficient reactivity margin and establish-ment of required core cooling. (c) Verification of Power: Confirm the availability of adequate power sources. (d) Radioactivity Release: Confirm that containment and exhaust systems are operating properly in order to prevent uncontrolled released of radioactivity. 4-8

4.4.1.6 Subsequent Operator Actions This section shall provide the operator with all the action steps necessary to facilitate the diagnostic effort and take the reactor to a normal condition or to take the plant to a safe steady-state condition from which it can be taken to an extended shutdown condition. (a) Verify Imix:;'iate Operator Actions: The first action steps in Subsequent Operator Actions shall be the verification of Immediate Operator etions. Included in these steps shall be the indications needed to positively deter-mine that the Immediate Operator Actions have been performed. Alternatives to the Immediate Operator Actions, to account for systems that are not operable, shall be included in these steps if they were not included in the Immediate Operator Actions. (b) Plant Notification: Notify the plant perso.inei of the nature of the emergency. (c) Diagnostic Steps: This section shall present the diagnostic steps necessary to lead the operators to the correct subprocedures or follow-on procedures. (d) Subprocedures: Each subprocedure or follow-on procedure is a collection of action steps required to treat a specific set of symptoms or to perform a specific function. Their titles shall describe the objective of the task (e.g., " Restore feedwater Flow"). Each task consists of action steps. The title of the task shall describe its objective (e.g., start auxiliary feed-water pump and align flow to the. steam generator). The plant conditions that should exist at the end of each task should be identified. 4.4.1.7 Appended Material (Attachments) This section shall contain all operational documents which are used to support the Emergency Operating Procedures but are not included within the body of the procedures. These documents include graphs, tables, worksheets, and lists of abbreviations. Definitions of terms, reference or background material that was used in developing the procedures, and any supplementary material which may be required at a particular plant should also be included. Material included in this section that does not have any operational significance (necessary to carry out the procedure) should be bound separately from the Emergency Operating Procedures. Each attachment should be numbered indi-vidually and indicate the total number of pages contained in the attachment.88 4.4.2 Format The format of procedures can contribute significantly their compre sibility and minimize operator confusion and errors. Specifically, format helps to determine how well and quickly information can be located and acted upon by the operator. The format should be designed to minimize the time required to read and respond to procedure instructions by considering the following: 4-9

4.4.2.1 General Approach General approach refers to the overall layout and structure of the Emergency Operating Procedures do a ment, and includes the physical layout of information, narrative style, and "levd s" of information presentation. Physical layout refers to the physical arrangement of the action steps and supporting information (if any) on a given page. Typically this is a distinc-tion between using the full width of the page for an instruction or using what has been termed a " columnar" approach, in which specific types of information are partitioned across the page in designated columns. These columns may simply separate the action steps from the notes, or may distribute information such as " items to be manipulated," " action," and " consequences of the action" across the page. Also included in physical layout is the use of indentation to set off different levels cf instructions or a hierarchy of related actions steps. Narrative style refers to the manner in which the action statements are pre-sented, that is, are they written in complete sentences. short phrases, or some combination of the two. Level of information presentation refers to the degree of detail that is included in an instruction and should reflect the particular experience and training of the user population. A particular general approach, then, is represented by some combination of physical layout, narrative style, and level of information presentation. In most instances, the choice of one approach for a given structural element (layout, style, or level) will dictate the characteristics of one or both of the remaining elements. For example, use of a three-column approach will require the use of phrases or short sentences. In some instances it may be desirable to more efficiently accommodate the wide range of experience and training common to control room staffs.103 This may be accomplished using a two-level or " layered" approach. These approaches present the action steps in two levels of detail, making more-detailed information available to the operator if he needs it. The structure of this format may use a combination of short phrases and full sentences, the latter of which may be indented or placed in a separate column to set them off from the primary action phrases. Examples of two approaches are given in Appendix 3. Regardless of the approach used, it shall conform to the criteria set forth below. 4.4.2.2 Specific Requirements and Guidance (a) Cover Page: The specific format of the cover page is left to the dis-cretion of the licensee. The content of the cover page, however, shall conform to the requirements of Section 4.4.1.1. (b) Identifying Information Each page of the Emergency Operating Procedures shall contain identifying information which includes a shortened form of its title, the procedure number, revision number, date of revision, and "page of ." -This information should be single spaced and appear in the upper right-hand corner of the page.83 4-10

_(c) Page Layout.: If a two column format is used, the left-hand column shall be used only for ection steps. The right-hand column should be used for notes and explanations. The binding approach as such shall not interfere with the ability of the operator to read the material. All pages of the procedure shall open flat, and the binding side margin nall be wide enough so that every step can be easily read. Clutter should be avoided in page content at well as in figures and tables.sa As a general rule a left-hand and bottom margin of 1 inch, and right-hand and bottom margin of 3/4 or 1 inch should be used. Space between -lines shall be at least 1 spaces.38 The Emergency Operating Procedures should not be bound at the top. Each procedure or subprocedure shall begin on a new page and be adequately parti-tioned from preceding material using the guidance provided in Section 4.3.5.3. Each action step shall be wholly contained on a single page and not continued on the next page. (d) Placement of WARNING, CAUTION, and NOTE: For the purposes of Emergency Operating Procedure, WARNING and CAUTION are assumed to be synonymous. The licensee should select one term and use it consistently throughout the Emer-gency Operating Procedures. Where WARNING, CAUTION, or NOTE statements are included in the Emergency Operating Procedures, their placement shall be consistent with the following:101 For all formats, WARNING and CAUTION statements shall be placed in a box that extends from margin to margin. WARNING and CAUTION statements shall precede the task or action steps to which they apply. Any WARNING'or CAUTION that is general enough to apply to an entire procedure or subprocedure shall be placed before the first action step in the procedure or subprocedure. All WARNING or CAUTION statements shall be placed on the same page as the actions steps to which they apply, unless space does not allow for each placement. . All the lines of text for WARNING and CAUTION statement shall appear on one page, The words " WARNING" and " CAUTION" should be typed or printed in all e capital letters and centered inside the top of the box. WARNING or CAUTION statements consisting of two or more paragraphs should e be avoided. When multiple paragraphs are required for clarity, the heading (i.e., WARNING or CAUTION) shouid not be repeated above each paragraph, and all paragraphs should be to contained in one box. For the columnar format, NOTE state' ents shall begin next to the action e m steps to which they apply. For the narrative format, NOTE statements should immediately precede the ac'. ion steps to which they apply. 4-11

.o. NOTE statements.may-be continued from one page to the next. (e) Check-off-or Sign-of f Provisions: Some type of check-off or sign-off shall be incorporated in the Emergency Operating Procedures so that the For operator can readily keep-track of the current step in the procedure. both the columnar and narrative formats this should be placed immediately next to the. action step to which it refers. Check-of f or sign-of f provisions 'should not be applied to Immediate_0perator Actions. Check-of f or sign-of f-provisions are supplied for the convenience of the operators and shauld not be c considered administrative controls requiring completion. (f) Divisions, Headings, and Numbering: The divisions or organization of the text shall be evident through the use of headings and a numbering system. .Each action step shall be identified by its complete designation. For the ~ colamnar format, when a NOTE is continued on the next page, the page shall start with the step number (e.g., " step 6.5.4.1 cantinued"). An acceptable method of placing and standardizing headings is illustrated in the examples included in Appendix 3. ~(g) Emphasis: In a number of instances it may be desirable to emphasize (i.~e., focus attention, set off, or differentiate) specific information con-tained in the Emergency Operating Procerures. They may be accomplished in a number of ways as follows:5 (1) Underlining: For typewritten material, underlining represents the optimal method.for emphasis. (2) Capitalization: Capitalization may be used to draw attention to one or a few important works in text and to set off or call attention to headings or titles (see Section 4.4.3.5 of these criteria). In general, capitalization is not as effective as other methods for emphasis since it is less easily read. (3) Italics: As with capitalization, use of italics ic not as effective for emphasis as other methods. (4) Bold Print: for printed material bold print represents an excellent method for emphasis. (5) Indentation: Indentation is a method of emphasizing which sets off subordinate items or stages or importance. (6) Framing: The use of framing should be restricted to WARNING and CAUTION statements as specified in Section 4.4.2.2(d) of these criteria. (7) Colored Paper: Major' sections of the procedures may be differ-entiated by printing the material on pale-colored backgrounds. Care must be taken, however, that contrast not be reduced significantly in such a way that readability is impaired. If colored paper is used its reflectance should be at least 70 percent. If colored paper is used, all revisions or replacements should maintain the color coding. 4-12

(h) Letter Size: For typewritten material, characters shall be 10 pitch (10 ^ characters per inch). For printed material characters shall be 12 point type. (i) Letter Style: Roman style type shall be used throughout the Emergency Operating Procedures. Standard upper and lower case letters shall be used except as required for emphasis.5 (j) Line Size: Where the general format of the Emergency Operating Procedures . permits, line length should correspond to between 39 and 65 spaces (k) Identification of Sections Within a Procedure or Subprocedures: To assist the operator in locating specific sections of a procedura or sub-procedure (e.g., Immediate Operator Actions, Subsequent Operator Actions), the licensee should use some means of partitioning other than that used to distin-guish between procedures or subprocedures. Distinctive tabbing or printing sections on pale-colored paper are possible ways of setting off the various sections. (1) Figures and Tables: Text with related figures and tables should be arranged so that they can be viewed at the same time. (See Appendix 1, Note 2.) If this is not feasible, the figure or table should be placed as close to its first reference as'possible. M Figures and tables that are used as general operator aids, may be plat.ed at the end of the section to which they apply. Each figure and table should contain only that informtion related to a speci-fi: task or step. The intent is to provide several simple figures or tables rather than single, large, complex ones containing information not relevant to the immediate task. -(1) Titles of Figures and Tables: Each figure and table shall be referenced in the text and each shall have a title that disti.1-guishes the contents or purpose of the figure or table from others in the procedure. Table titles should be centered above the table. Figure titles should be centered below the figure.sa (2) Figure Format: For flowcharts, all inputs and outputs should be clearly identified, with inputs at the left or top, and outputs on the right or bottom. The direction of flow shall be indicated by arrows; signal or pres-sure flow should be from lef t to right or top to bottom, and feedback or return flow should be from right to left or bottom to top.los I.ine graphs should depict a maximum of four relationships between axis variables. Line depicting relationships shall be coded for easy discrimination. Graph scales may be linear or nonlinear as required for optimal comprehension or use. The axes shall be labeled to indicate the variables and units of measurement.: a The number of grid lines that enable the operator to read values to the required degree of precision shall be used. The grid line shall' be easily distinguished from the graph lines, and shall not obscure detail necessary for proper use of the graph. The grid lines shM1 be no less than 0.1 inch apart.ios 4-13

(3) Table Format: To avoid clutter, at least 25 percent of the area within the table shall be clear space between columns and goups of 1 rows. Entries-should be al.igned with columns as follows: For decimal dat( decimal points should be aligned. e For scientific notation, multiplication signs should be aligned, e e All other numeric data should be aligned flush right. Alphabetic or alphanumeric data should be aligned flush left. e Units of measurement shall be specified in row or column headings, ' as appropriate. Interpolation should be minimized by. expanding the table or by presenting the data in a graph. 4.4.3 Style of Expression and Presentation In order to achieve a high level of intelligibility, it is important that Emergency Operating Procedures be written in a style that presents informat..,,a in a simple, familiar, specific, and unambiguous manner. 4.4.3.1-Vocabulary The simplest, most familiar, and most specific words that accurately convey the intended meaning should be used. Short words and words that are commonly used_ in ordinary conversation are recommended. The nomenclature and idioms that the operator is trained te use should be incorporated in the procedures wherever it makes the materiai casier to understand. Concrete and specific words should be used to avoid vagueness (e.g., " Slowly depressurize and cool RPV,"_is vague. "Depressurize and cool RPV at a rate not to exceed 100 F/hr" is more precise).63 (a) Consistent Usage: If there are synonyms for a concept, object, or opera-tion, only one of them shall be selected and used consistently throughout the - procedures (e.g., do r.ot interchange the terms " unit," " assembly," " equipment," and " component" to refer to the same item).63 (b) Use of Standardized Nomenclature and Idioms: The Emergency Operating Pro-cedure shall be written using standardized nomenclature and idioms familiar to plant operators in the nuclear industry. Equipment nomenclature shall be identical to that on the control board. Vague words, slang, local jargon, or abbreviations that might be mis-understood should be avoided. In addition, words that are ambiguous or difficult to define should be avoided. Two common examples of such words, with preferred alternatives, are illustrated below.63 l f-P00R PREFERRED Secure Stop or shut P.,nitor Check level of RWST RWST every 30 minutes l 4-14 c 6-r e s,-. - v

4.4.3.2 Use of Abbreviations and Acronyms Every attempt should be made to use simple and short words; there are, however, many technical expressions that are used in nuclear plants that have well-est5tlished abbreviations or acronyms associated with them. Abbreviations and acronyms used should be those for which there is no need for any licensed operator to consult a glossary of abbreviations or acronyms. When abbrevia-tions and acronyms are used in labeling equipment, the same abbreviations and acronyms shall be used in the procedures. 4.4.3.3 Sentence Structure Sentences and clauses shall be written using simple word order (i.e., subject, verb, object) except for action steps. Sentencec directing the actions shall be in the active voice and imperative mode (e.g., " Shut Valve V21B"). All action steps sh311 be in the positive form (e.g., " Shut the valve") rather than the negative form (e.g., "Do not leave the valve open"). Modifiers, l including prepositional phrases, shall be as close as possible to the word modified. These word-order requirements may be relaxed only to the extent necessary to avoid ambiguity or distortion of meaning.ca There should be only one main thought per sentence. If a sentence has more than one clause and is more than 30 words long, it should be rewritten as one or more simple sentences, not to exceed 30 words each. Action steps should be as brief as possible.63 4.4.3.4 Punctuation and Grammar Punctuation is used to reveal the precise relationship of thoughts, and can thus be used to prevent misreading. The word order used should require a 3 minimum of punctuation. When extensive punctuation is necessary for clarity, l the sentence should be rewritten to improve clarity. Rules of grammar and punctuation for standard American English shall be used.s3 4.4.3.5 Capitalization Capitalization shall conform to standard English usage, or as follows, and shall be consistent throughout the Emergency Operating Procedures. The first letter of the first word of each sentence or phrase is capitalized. All letters of the title and headings of procedures or subprocedures are capitalized. All letters of words CAUTION and WARNING are capitalized. e All letters of the words AND, OR, NOT, IF, IF NOT, WHEN, and THEN are capitalized when they are used In logic 7tatements. The first letter in each word of the titles of alarms, indicators, panels, e and equipment is capitalized. 4-15

All letters of acronyms are capitalized. e All references to control board material, including equipment names (e.g., PORV), control designatiors (e.g., STBY, 0FF), annunciator labels, and other panel labels, shall use.;apitalization consistent with that snown on the control board.63 4.4.3.6 Use of Symbols Symbols commonly used in the nuclear industry (e.g., f, %, =) may t e used in the Emergency Operating Procedures. Symbols not in common industry or every-day use should be avoided. The use of symbols should be such that there is no need for licensed operators to consult. a glossary of symbols. 4.4.3.7 Use of Units Where the Emergency Operating Procedures reference instrumentation, the units shall be included. Procedures shall use units of measurement that maf.ch the units written on the referenced equipment. 4.4.3.8 Use of Numerals for numbers, Arabic numerals, rather than the spelled-out form or Roman numerals, shall be used (e.g., "4" instead of "four" or "IV"), consistent with panel designations. The numr,er of significant digits should correspond to the precision of the display (a.g., do not use "22.23 psig" in the procedure if the display is marked to the nearest whole digit, as with "22" or "23 psig").63 4.4.3.9 Tolerances Whenever exact values are not given, allowable tolerances shall be provided rather than vaguely worded specifications (e.g., use "1000 psig 110 psig" or "990 to 1010 psig" rather than "approximately 1000 psig"). If tolerance data are not available, then comparative information may he helpful (e.g., "the pressurizer level starts to drop at a faster rate"). When tolerances are given, they shall be in the same units as those used on the display (s) and ccntrol(s) where they are read (e.g., do not use "13 f" if the display is marked in 20 F increments). 4.4.3.10 Use of Logic Terms The logic terms AND, OR, NOT, IF, If NOT, WHEN, and THEN are often necessary to precisely describe a set of conditions or sequence of actions. When logic statements are used it is important that the logic terms be highlighted so that all the contingencies are clear to the operator, liighlighting or empha-sis can be achieved using capitalization, underlining, spatial isolation, or some combination of the three. Regardless of the overall approach used, all letters of the logic terms shall be capitalized. The following examples illustrate some acceptable methods for setting up logic statements. 4-16 m

Example 1: IF RPS scram has not initiated, TI1EN initiate SLC and isolate RWCU Example 2: IF RPS scram has not initiated THEN Initiate SLC and isolate RWCU Example 3: IF RPS scram has not initiated, THEN initiste SLC and isolate RWCU The specialized use of each logic term is discussed below. (a) Use of AND: Action steps will normally be performed in sequence so that a conjunction such as "and" is not required between the steps. When attention does need to 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 rnore than four conditions. If more than four conditions need to be joined, a list format shall be used. When used as a simple or compound conjunctian, the word "and" may be emphasizelf (e.g., to connect actions in a step: "o; q valves A and 0"). (b) Use of OR: The word OR shall be used when calling attention to alterna-tive combinations of conditions. The use of the word OR shall always be in the inclusive sense. To specify the exclusive "or" thTfollowing may be used: "either A OR 8 but not both". (c) Use of IF, IF NOT, WHEN, and THEN: When action steps are contingent upon certain conditions or combinations of conditions, the step shall begin with the words IF, IF NOT, or WHEN followed by a description of the condition or cor.ditions7the antecedent), a comma, the word THEN, followed by the action to be'taken (the consequent). For example: LF RCS pressure is increasing A_gD Pressurizer level is increasing, THEN Go to subprocedure 6.1 Use of IF NOT should be limited to those cases where the operator must respond I to the Te'cond of two possible conditions. -IF should be used to specify the first condition. For example: 4-17

E pressure is increasing, THEN stop the injection pump g NOT, start an additional injection pump. 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. Actions which are imbedded in this way (1) may be overlooked and not be performed, (2) make it difficult to verify the performance of each action step when a check-off or sign-off is used, and (3) can be confused with a logic statement. (d) Combinations of Logic Terms: The use of AND and OR within the same action should be avoided. When AND and OR are used together, the logic state-ment can be very ambiguous. For example: "IF condition A AND condition B OR condition C occurs, THEN go to step 5.3.6" .This statement has two possible meanings: J E both condition A AND Condition B occur, e THEN go to step 5.3.6 IF Condition C occurs THEN Go to step 5.3.6. or E both condition A AND condition B occur, e THEN go to step 5.3.6 i E If both condition A AND condition C occur, THEN go to step 5.3.6. l In either case, the use of OR results in going to step 5.3.6 if A, B, and C all occur, but the correct combination of conditions may be unclear to the

operator, If b use of AND and OR within the same action step ca.nnot be avoided, the more explicit form (ai illustrated in the preceding examples)

~ shall be used. (e) Other Antecedents: Action steps may be contingent upon other antecedents, such as elapsed time..In such cases, the step shall begin with the antecedent conditions, followed by a comma, and the action to be taken. For example: i 4-18

WHEN. [ The pressurizer temperature reaches 500 F, THEN stop the charging pump. (f) Use of "will," "can," "may," and "all": The following rules apply to the use of "will," "can," "may," and "all": e "Will" should be used when referring to the response of the equipment (e.g., "The AF and RC Pumps will start," or "A reactor trip will occur). e "Can" should be used when referring to a possible response of equipment (e.g., "The RN and KC Pumps can start"). e "May" should be used to refer to an operation which is possible, but which may or may not be necessary (e.g., "The RN and KC pumps may be started"). e Use of the word "all" shall be avoided when it can lead to confusion. Instead, list the individual components being referred to. That is, rather than stating " Turn off all charging pumps," the procedure shall state " Turn off Centrifugal Charging Pumps A and B. Turn off the Positive Displacement Charging Pump." (g) Use of Pronouns, Articles, and Adverbs: The following criteria'shall be followed in the use of pronouns, articles, and adverbs. The Emergency Operating Procedures shall be written without the use of personal pronouns, that is, use the imperative mode and active voice (e.g., " Terminate RCS } charging no sooner than 1.5 hours nor later than 2 hours post-LOCA") i Articles shall be used in textual material, but their use shall be minimized to describe action and diagnostic-steps. Adverbs that cannot be reliably and consistently defined should be avoided where possible. For example, " Periodically check the radiation monitors..." should be changed to " Check the radiation monitors at least every 30 minutes...."63 (h) Use of Footnotes: Footnotes shall not be uc.ed. 4.4.4 Content of Procedures This section provides detailed criteria for presenting the content of Emergency Operating Procedures. 4.4.4.1 Sequencing Tasks and action steps shall be sequenced according to technical necessity, which shall be the overriding consideration. The physical layout and organiza-tion of the control room is an important consideration in preparing Emergency 4-19 1 - ~ ~ -

Operating Procedures. Emergency Operating Procedure and Control Room Design Review shall be coordinated to enhance operator effectiveness and efficiency. Actions should be completed at one control board location before the procedure requires the operator to change locations. While at that one location, the operator's actions should flow in one direction, preferably from left to right and from top to bottom on the control board, in a logical fashion. Actions that require the operator to move from one control board location to another, should be sequenced so that the operator moves in one direction, preferably from lef t to right along the control boards.ca The objective of a sequence of actions shall be conveyed to the operator through descriptively written task headings (e.g., " Emergency Plant Shutdown"). If there are special conditions under which the action step is or is not performed they shall be included in the step. With regard to sequencing, action steps can be broken dezvn into the following categories: (a) Immediate Operator Actions: Immediate Operator Action steps shall be brief and shall include only the action step, and not its verification. Verification of automatic system actions, however, shall be included in immedi-ate operator actions. Immediate operator actions shall be limited to steps that cannot be delayed and included in Subsequent Operator Actions. (b) Subsequent Operator Actions: Subsequent Operator Actions shall contain all the action steps necessary to verify the 1mmediate Operator Actions and to diagnose and mitigate the emergency situation. The first set of actions in Subsequent Operator Actions shall ba to verify the Immediate Operator Actions. 4.4.4.2 Individual Steps (a) Basic Steps: A basic step is a step t',t simply directs operator actions. (b) Verification Steps: Verification steps verify that the objective of a task or sequence of ac'. ion steps has been achieved. Three types of verification are possible. The f'.rst type only checks that an action has resulted in a command signal to some piece of equipment. The operator shall not be directed to rely on such verification where other, more positive indications are available. The second type of verification is a positive indication to the operator that the equipment has responded to a command. This second type of verification is preferred, and when aveilable, shall be included (e.g., " Verify auxiliary feedwater flow on feedwater flow indicator FI-8"). The use of multiple indica-tions may be provided. The third type applies to those circumstances when it may be desirable to verify that an operator has correctly taken an action or carried out a series of steps. For example, in aligning critical systems, -equiring independent verification may be advantageous. (c) Nonsequential Steps: Nonsequential steps are steps that appear in the procedures where they may first be required, but may need to be performed later in the sequence of actions. Any nonsequential steps shall be identified in some manner that facilitates the operator findina it and should clearly identify the conditions or time sequence requiring its performance. 4-20

(d) Conditional Steps: Conditional steps are those that have an implicit contingency, for example, that Step A is required if one condition holds j and Step B is required if another condition holds. In these cases, the implicit condition shall be made explicit. The following example illustrates explicit action steps:ca 6.3.4 IF Eevel is greater than Letdown storage tank 50 inches. Indicator LI-31 VB-6. THEN Open LTDN ORFC VLV 12. IF NOT Letdown orifice Open LTDN ORFC VLV 13. valve 12 VB-6. Letdown orifice valve 13 VB-6. (3) Equally Preferable Steps: Equally preferable steps are those for which any one of several alternative steps or sequence of steps is equally correct. In such a case, only one of these steps or sequence of steps should be stated. For example, "Open one 75 gom letdown orifice valve" does not specify any par-ticular valve, and thereby can lead to operator error. Tha :n:,t. : tion as stated may result in two operators each opening a different 75 gpi letdow' orifice valve making changes to lineups more difficult are subject to error later in the pro-cedure. "Open letdown orifice valve LOV 12" is preferable. (f) Recurrent Steps: Recurrent steps are steps that require the operator to repeatedly perform a given action. These steps usually require the operator to monitor or control some plant parameter. Examples of bad practice are, " Monitor the RWST level throughout this procedure," or " Periodically check the auxiliary building radiation monitors for indication of ECCS leakage." Steps such as these shall be written in accord with the following:83 (1) State the Frequency: State the frequency with which the step should be repeated (e.g., " Check the RWST level at least every 30 minutes). (2) Method for Reminding Operators of Recurring Actions: A method for reminding the operator of required monitoring or controlling actions should be provided (e.g., use of notes). (3) State Consequential Actions: Recurrent actions should state the 1 action the operator must take once the plant parameter reaches a given condition (e.g., " Monitor the RWST level [LI-431] at least every 5 minutes. WHEN CVCS Tank Level reaches low level alarm (15 inches), THEN shift charging pump suction to RWST"). (4) Time-Dependent Steps: When steps are time dependent (e.g., " Terminate RCS charging no sooner than 1.5 hours after....."), some means shall be available to help the operator perform the step within the required time frame. Forward referencing should be 4-21

provided from the step that starts the clock" or on a separate data sheet, to those steps that are based on elapsed time. The forward referencing may be in the form of a listing of-time dependent steps in a note associated with the initiating steps. As shall be p'rovided in the procedure next to the step that " pace starts the clock so that the time can be recorded for later reference. The position of this time reference in the procedure may tiien be indicated in the step requiring the time-dependent action. (g) Concurrent Steps: Procedures often include steps or tasks that have to be undertaken at the same time. Use of concurrent tasks shall conform to Section 4.3.4, Division of Responsibility. The procedure shall explicitly state which tasks are to be performed concurrently. All tasks to be performed concurrently shall be located continguously in the same procedure or subprocedure. This minimizes the need for the operator to flip back and forth in the procedure.e3 (h) Diagnostics Steps: Diagnostics should contain information with the steps necessary to lead the operator to the appropriate subprocedure or section of the Emergency Operating Procedures. Diagnostic information may include references to tables, figures, or diagnostic flowcharts. 4.4.4.3 Additional Information (a) WARNING, CAUTION, and NOTE Statements: WARNING, CAUTION, and NOTE state-ments shall be used in the Emergency Operating Procedures to attract attention % essential or critical information, and should be worded and placed as follows (see Appendix 1, Note 2): (1) WARNING or CAUTION: WARNING or CAUTION statements shall be used to describe those conditions, practices, or procedures which must be observed _to avoid injury, loss of life, or long-term health hazard to the general public or plant personnel, and plant damage or destruction of equipment. The use of WARNING and CAUTION statements shall be restricted to those situations that pose a recognized threat to per-sonnel, public health and safety, or equipment. WARNING and CAUTION statements shall not contain action steps. The following information should be contained in WARNING and CAUTION statements, ordinarily in the order indicated:t i e The specific nature of the hazard, The precautions necessary to avoid or minimize the hazard, e e The location of the source of the hazard, The consequences of failing to heed the warning or caution, and o e Time consideration, when critical. The information should be presented as briefly as possible in clear, straightforward sentences. It should be self-contained: the operator shall not be referred elsewhere. However, when the location of a hazard and its consequences are clearly implied by the type of hazard, .or have appeared elsewhere on the same page, such information may be omitted. 4-22

(2) NOTE: A NOTE is a statement that describes information of special importance or interest, or that aids in job performance. This is information that should enhance the understaniing of the procedure, will facilitate decisions, and would otherwise be difficult to find and incorporate in the procedure. NOTE statements depend upon the material being presented and, do not have special content requirements. (b) Operator Aids: Decision aids or diagnostic decision aids should be used to the maximum extent possible. A decision aid is a decision t.'.ble (Exhibit 2), l a flow chart (Exhibit 3) or other device which can be used to decide which step to take next. The decision aid should identify the next step to be i taken. A diagnostic decision aid is used tJ assist the operator is identifying the specific cause of the symptons to which he is responding and directs him to the appropriate subprocedure or section. The manner in which the decision aid is used and the conditions under which it is used shall be apparent to the operator by the design of the aid. (c) Cross-Referencing of Procedures, of Subprocedures, or Sections: All infor-mation necessary to carry out a task should be consolidated in one place. Once the sequence of actions is begun, there should ordinarily be no need to refer to other parts of the Emergency Operating Procedure for information necessary to continue the task. Where referenced procedures, subprocedures or tasks are not described elsewhere or do not involve an excessive number of steps, they should be ncluded directly in the Emergency Operating Procedure, and reference may be made to the source in the notes. A task made up of an excessive number of steps shou'Id be cross-referenced. Exhibit 2. Decision Table Example RPV LEVEL RPV LEVEL INCREASING DECREASING OR STABLE 4 RCS PRESSURE SUBPROCEDURE SUBPROCEDURE INCREASING 6.3.1 6.3.2 OR STABLE LEVEL CONTROL RAPID DEPRESSURIZATION SUBPROCEDURE SUBPROCEDURE RCS PRESSURE 6.2.1 6.4.3 DECREASING CORE COOLING CORE COOLING WITHOUT WITHOUT RESTORATION INJECTION 4-23

Exhibit 3. Example Diagnostic Flowchart 83 Safety sniectat l upes atu wJ YES E' "$*"'

• NO u d6 cation awtat,le Pesturm actui atep YES Preswre NU 6 7 5 of subsequent

<1950 psi 9 operator actes A YES P essure f40 Perfc,em ar.tmn step g decreony b 3 2.1 of wtweeni operatae.sct6ons Verif y PO RV '"'",t e stat 1, 2, 3, 4 Clu*'l E tc. E tc. Heset safety ugettion Vesif y 134 dup awlation valve VLV 72 3 clowd \\ YES Pr essure NO <1350 psig g E tc E tc. d

4 e 5 VALIDATION AND VERIFICATION OF PLANT-SPECIFIC EMERGENCY OPERATING PROCEDURES i Following development of the Emergency Operating Procedures it.is impurtant that the procedures be validated to ensure that they properly reflect the existing plant design and control room design. A continuing prograin of verifica-tion is also necessary to ensure that the approach taken proves to be adequate and to ensure-that'the Emergency Operating Procedures are updated as necessary -to reflect changes in plant design, changes to the control room, and changes dictated by training and operating experience. 5.1 VA'IDATION OF PLANT-SPECIFIC EMERGENCY OPERATING PROCEDURES 5.1.1 Background Validation shall be performed to ensure the technical adequacy of the plant-specific Emergency Operating Procedures that were developed from the Technicai Guidelines. The validation process is intended to demonstrate that the steps included in the plant-specific Emergency Operating Procedures are sufficient to mitigate trar.sients and accidents at the plant. D 5.1.2 Method The licensee or applicant shall walk through all Emergency Operating Procedures in the control room. This walk-through shall consist nf a static verification I of the Emergency Operating Procedures that checks the compatibility of the procedures with the control room design, shift staffing, and the level of training of the staff. Items to be checked should include the following: All indications and annunicators referenced in the procedures are available to the operator, the Emergency Operation Procedures have the same units as the indicators and annunciatorr, and the procedure 4 identifies the indications and annuncia es as they are marked in the control room. All controls referenced in the Emergency Operating Procedures are avail-e able to the operator, function as specified or implied in the procedure, and the procedure identifies the controls as they are marked in the control room. All operator actions required by the procedure are within the capability o of the minimum control room staff required to be available by the Technical Specifications. Decisions and actions that the procedures require to be performed by the operators are consistent with the training and experience of control room i personnel. 5.1.3 Corrective Actions The licensee or applicant shall correct any discrepancies discovered in the l walk-throughs by changing the control room, the procedures, the staf fing, the 5-1

training, or some combination of these. For sites with multiple plants, an evaluation of the procedures for all plants at the site should be conducted to determine the relevance of the changes to each plant and to make the changes if necessary. 5.1. 4 Validation on a Simulator A dynamic validation of the plant-specific Emergency Operating Procedures should be conducted by exercising them on a plant-specific simulator, if available. 5.2 VERIFICATION OF THE EMERGENCY OPERATING PROCEDURES A program shall be implemented by the lices.see to provide for continuing evaluation of the Emergency Operating Procedures. The program should include evaluation of the initial Eh.argency Operating Procedures and revisions to the procedures. The program should include the following: Evaluation of the technical adequacy of the Emergency Operating Procedures in light of operational experience, Evaluation of the organization, format, style and content, Evaluation of the training program supporting the Emergency Operating Procedures, and Evaluation of staffing relevant to Emergency Operating Procedures. 5.2.1 Program For Verification The program for verifying the Emergency Operating Procedures should use existing reporting and analysis systems, such as the Licensee Event Reports, Nuclear Plant Reliability Data System, Nuclear Safety Assessment Center reports, Institute for Nuclear Power Operations reports, and Electric Power Research Institute Reports. In preparing inputs to existing reporting schemes, licensees she 'd carefully consider the contribution of the Emergency Operating Procedures tc the event and the implications of the event for the Emergency Operating Procedures. Strengths and weaknesses of the Emergency Operating Procedures should be described in the report as completely as allowed by the format. 5.2.2 Documentation When training is conducted on dynamic simulators, a system to record on-line data that can later be analyzed should be used. If a system of this types is available, some portion of the training may be tailored to verify that modifica-j tions in organization, format, style, or content of the Emergency Operating Procedures do improve performance. 5.2.3 Reporting Requirements No additional reports are required to implement the verification process. However, the validation and verification processes may indicate that changes should be made to the Emergency Operating Procedures that conflict with the criteria of this document. In these cases, the results of the process, 5-2

i.. ~ supporting information 'and a description of the change should be forwarded to ' the NRC.' The staff will consider this information in evaluating the necessity-to modify the criteria in this document. 4 N f 4 e i l P 4 5 '; ., ~

6 OPERATOR FAMILIARIZATION AND TRAINING

6.1 DESCRIPTION

This section outlines the means to improve the proficiency of licensed operators on Emergency Operating Procedures and to ensure the operators are informed of, and knowledgeable of, changes to Emergency Operating Procedures. 6.2 TRAINING FOR INITIAL IMPLEMENTATION A training program shall be established to instruct operators in the Emergency Operating Procedures. 6.2.1 Lectures A series of lectures shall be conducted. Included in the information presented during the lectures shall be: The philosophy behind the development of Emergency Operating Procedures, e The process used to develop the Emergency Operating Procedures, and e The Emergency Operating Procedures themselves, including supporting e technical and human-factors information. 6.2.2 Simulators and Control Room Walk-Throughs An important part of the instruction on Emergency Operating Procedures is practical experience gained through the use of simulators and walk-throughs of the procedures in the (.ontrol room. During this aspect of the instruction, the training program should stress a team approach to the use of Emergency Operating Procedures. 6.2.2.1 Simulators Training on the Emergency Operating Procedures shall be conducted for all licensed operators using practical exercises on a control room simulator. The members of each operating shift crew should be trained as a unit. Training shall be conducted with all operator performing their normal control room functions. Additional training should be conducted where the members of a shift crew alternate responsibilities. This additional training is important to promote understanding of other operators' responsibilities in the overall conduct of the actions, and leads to enhanced communications within the control room. 6.2.2.2 Control Room Walk-Throughs Training on the Emergency Operating Procedures shall be conducted for all licensed operators by conducting walk-throughs of the Emergency Operating Procedures in the control room or on a plant-specific simulator. This training should concentrate on information flow, interactions of the operators in the 6-1

p control room to minimize interference, and differences between the simulator and the actual control room. 6.3 REFRESHER TRAINING All licensees and applicants for operating licenses shall develop a program to ensure that all licensed operators conduct walk-throughs semiannually of all Emergency Operating Procedures. The walk-throughs shall be conducted either in the control room or'as evtnts conducted on plant-specific simulators. Realistic scenarios shall be developed by the licensee / applicant to ensure that all Emergency Operating Procedures are exercised semiannually. Training on Emergency Operating Procedures shall be conducted in such a. manner that each shift crew conducts the walk-throughs as a unit, with each operator performing the actions that he would normally be' responsible for during tr,e event. Licensed operators not assigned to a shift shall participate in the walk-throughs as part of a control room shift crew. The plant training staff shall actively participatr in the development and execution of the refresher training program. The training staff shall be responsible for developing the scenarios, obseeting and evaluating the walk-throughs, and critiquing the results. Commuqications outside the control room such as Emergency Plan Implementation Notifications should not be required during the walk-throughs. Any additional training shall be determined from the performance of the shift crew. Close coordination of this program with the plant operations staff should be an integral part of the overall program, both in development and execution. The scenarios shall be sufficiently varied to ensure the operators do not develop a set pattern of responses to events, but are able to respond to and mitigate the symptoms as they develop. 6.4 TRAINING ON REVISIONS -All licensees and applicants for operating licenses shall develop a program to ensure that all licensed operators are familiar with changes to the Emergency Operating Procedures prior to using the amended Emergency Operating Proceuures in the control room. The program shall address minor (e.g., editorial or nomenclature) changes, and significant changes that affect the sequence of actions or the actions themselves. L Training-on minor procedural changes should be conducted through a program of required readings (. elf-taught), preshift briefings, or lectures in the requali-fication program. Training on significant changes shall be conducted by the use of walk-throughs in the control room or on plant-specific simulators. If operational considerations do not allow control room walk-throughs and no -plant-specific simulator is available, the training on significant procedural changes may be conducted in seminars or briefings of shift personnel, f i 6-2

APPENDIX 1 NOTES 1. The criteria presented in this document were based upon staff review of the literature, the results of U.S. NRC contracts related to Emergency Operating Procedures (NUREG/CR-1999, NUREG/CR-1977, NUREG/CR-1875, NUREG/CR-2005, and NUREG/CR-1970), and -staff experience in the NTOL pilot monitoring program. In many instances the proposed criteria represent a composite, based upon a variety of sources of information or data. Only in those instances where text or criteria were based on information from a specific source, is.a reference cited. 2. In an effort to facilitate access to graphs, tables, warnings and cautions, it has been suggested that this information be placed on the left-hand page (back of previous page) opposite to where it is called out or needed in the Emergency Operating Procedure. In the case of graphs and tables, this would provide information to the operator where he needs it, and avoid the need to interrupt the flow of action steps, the need to turn the page, or the need to reference an appendix at the back of a procedure or sub-procedure. Where a large number of warnings or cautions are required, placement on the left-hand page would provide easy access while avoiding clutter.within the procedural steps. While use of the left-ha,d page, as described above, does provide certain advantages, the staff is concerned that during an emergency, parts of the procedure would be removed from the binder, with the possible loss of vital information on the preceding left-hand page. Furthermore, in the case of warn ngs and cautions, the staff is concerned that removing i warnings and cau; ions from the flow of the action steps would increase the' likelihood that they would not be read or would be inadvertently missed. In order to assist the staff in resolving this issue, public comment is requested specifically on the approach described above. Where possible, comments should be supported by experimental data or field experience. 3. In the staff discussion of readability, there was a deliberate lack of information'provided on how readability may be measured. While there is an abundance of literature which identifies numerous approaches (formulas) for evaluating readability, the applicability of these approaches to Emergency Operating Procedures may be questionable on the following grounds:5 o The reliability of most formulas has not been evaluated, Readability formulas do not consider certain design characteristics o such as division, ordering, style, and familiarity of the reader with the contents or subject. Those characteristics that are Al-1

v . measured may contribute little to the understanding of the text. Furthermore, different formulas mLy produce contradictory readability scores for the same material.

• High readibility scores can be obtained with trivial manipulations of the text.

Furthermore, it is not clear that readability measures would be valid for Emergency Operating Procedures considering the conditions under which the procedures would be used, the extensive training of the operators, and the use of nonstandard formats incorporating short phrases or columns. The staff has identified a wide range of literature in Appendix 2, Refer-ences and Bibliography, which both describe methods for measuring read-ability, and evaluate the shortcomings of these methods. Where it is desired to use a measure of readability, it is suggested that caution be exercised in' applying the results. In light of the desire by some to have an empirical measure of the quality of Emergency Operating Procedures, the staff requests public comments on the above concerns. Where possible, comments should be supported with experimental data or field experience. Al-2

APPENDIX 2 REFERENCES AND BIBLIOGRAPHY 1. American Nuclear Society, " Administrative Controls and Quality Assurance for. the Operational Phase of Nuclear Power Plants," ANSI /ANS-3.2-1980 -(Draft 7, March 1981). Available from American National Standards Institute,1430 Broadway, New York, NY 10018, Copyrighted. 2. D. Becker, J. Heinrich, R. V. Sichowsky, and D. Wendt, " Reader Preferences for Typeface and Leading," Journal of Topographic Research IV(1), 61-G (1970). 3. A. S. Blaiwes, " Formats for Presenting Procedural Instructions," Journal of Applied Psychology 59(6),683-686,(1974). 4. J. B. Blankenheim,, "Tectnical Manuals, Human Factors, and System Effective-ness," Paper presented to the System Performance-Effectiveness Ccaference (Specon-5) on May 22, 1969 (AD-691-418).** 5. E. Bohr, W. Preuss, G. Reinartz, and G. Thau, " Design of Operations . Manuals for Nuclear Power Plants," NRC translation 791, Technical Control Union Rheinland e.V., Institute for Accident Research, Cologne, W. Germany (March 1977). Not available to the public. '6. H. R. Booher, " Relative Comprehensibility of Pictorial Information and Printed Words in Proceduralized Instructions," Human Factors 17(3), 266-277 (1975). 7. R. L. Brune, and M. Weinstein, Sandia National Laboratories, " Procedures Evaluations Checklist for Maintenance, Test and Calibration Procedures," USNRC Report NUREG/CR-1368 (SAND-80-7053), May 1980.* 8. R. L. Brune and M. Weinstein, Sandia National Laboratories, " Development of a Checklist for Evaluating Maintenance, Test and Calibration Procedures-Used in Nuclear Power Plants," USNRC Report NUREG/CR-1369 (SAND-80-7054), i May 1980.* 9. R. L. Brune and M. Weinstein, Sandia National Laboratories, " Development .of a Checklist for Evaluating Emergency Procedures Used in Nuclear Power Plants," USNRC Report NUREG/CR-1970 (SAND-81-7070), March 1981.* 10.- R..L. Brune and M. Weinstein, Sandia National Laboratories, " Checklist for Evaluating Emergency Procedures Used in Nuclear Power Plants," USNRC Report NUREG/CR-2005 (SAND-81-7074), March 1981.* 11. BS 4884: Part 1: Specification for Technical Manuals. Part 1. Content. London: British Standards Institution, April 1973. 12. BS 4884: Part 2: Specification for Technical Manuals. Part 2. Presentation. London: British Standards Institution, January 1974. A2-1

i I I I 13. P. Burnhill, J. Hartley, and M. Young, " Tables in Text," Applied Ergonomics 7(1),13-18(1976).

14. -

R. P. Carver, American Institutes for Research, " Improving Reading -Comprehension: Measuring Readability," Office of Naval Research report,.May 14, 1974_(AD-780-448).** i 15.- W. B. Cheney III, " Nuclear Procedural System Design Based on Nuclear Human Factors Principles," Proceedings of the American Nuclear Society Winter Meeting,-Washington, D.C., November 16-21, 1980. l 16. E. B. Coleman, " Improving Comprehensibility by Shortening Sentences, Journal of Applied Psychology 46(2), 131-134 (1962). 17. T. E. Curran, " Survey of Technical Manual Readability and Comprehensibil-ity," San ~Diego, CA: Navy Personnel Research and Development Center, NPRDC Report TR 77-37, June 1977. 18. E. Dale and J. S. Chall, "A Formula for Predicting Readability: Instructions," Educational Research Bulletin 27, Feb.18,1948, 37-54, (b). 19. J. S. Davenport and S. A. Smith, " Effects of Hyphenation, Justification and Type Size on Readability," Journalism Quarterly XLII, 382-388 (1965). l 20. W. F.

Dearborn,

P. W. Johnston, and L. Carmichael, " Improving the Readability of Typewritten Manuscripts," Proceedings of the National Academy of Sciences 37(10), 670-672 (1951).- l 21. R. Fabrizio, I. Kaplan, and G. Teal, " Readability, as a Function of the Straightness of Right-Hand Margins, Journal of Typographic Research I(1),-90-95 (1967). 22. M. L. Fleming, " Perceptual Principles for the Design of Instructional Materials," Viewpoints 46(4), 69-200 (1970). l l

23. 'J. P. Foley, Jr., " Job Performance Aids Research:

Summary and Recommenda-l tions" Wright-Patterson Air Force Base, OH: Air Force Systems Command, April 1969 (AD-697034).** 24. J. P. Foley, Jr., " Task Analysis for Job Performance Aids and Related Training" (AFHRL-TR-72-73), Wright-Patterson Air Force Base, OH: Air Force Human Resources Laboratory, October 1973 (AD-771001).** 25. J. D. Folley and S. J. Munger, "A Review of the Literature on Design of l' Information Job Performance Aids, (ASD-TR-61-549), Wright-Patterson Air Force Base, OH: Aeronautical Systems Division, October 1961 (AD-270 867).** 26. J. J. ~ Foster, " Legibility Research - The Ergonomics of Print," Icographic -6, 20-24 (1973). 27. J. Foster and P. Coles, "An Experimental Study of Typographic Cueing in Printed Text," Ergonomics 20, 57-66 (1977). A2-2 l.

f 28. R. L. Fowler and A. S. Barker, " Effectiveness of Highlighting for Retention of Text Material," Journal of Applied Psychology 39(3), 358-364 (1974). 29. F. Fuchs, J. Engelschall, and G. Imloy, Xyzyx Information Corporation, Canoga Park, CA, " Human Engineering Guidelines for Use in Preparing l Emergency Operating Procedures for Nuclear Power Plants," USNRC Report i NUREG/CR-1999, April 1981.* 30. F. Fuchs, J. Engelschall, and G. Imlay, Xyzyx Information Corporation, Canoga Park, CA., " Human Engineering Guidelines for Use in Preparing Emergency Operating Procedures for Nuclear Power Plants," USNRC Report NUREG/CR-1999, April 1981.* 31. A. I.-Gates, "What Do We Know About Optimum Lengths of Lines in Reading?" Journal of Educational Research XXIII(1), 1-7 (1931). 32. J. Gilliland, Readability, London: University of London Press, 1972. 33. M. Gregory and E. C. Poulton, "Even Versus Uneven Right-Hand Margins and the Rate of Comprehension in Reading," Ergonomics 13(4), 427-343 (1970). 34. J. Hartley, and P. Burnhill, " Experiments with Unjustified Text," Visible Language 5(3), 256-278 (1971). 35. J. Hartley, S. Fraser, and P. Burnhill, "A Selected Bibliography of Typographical Research Relevant to the Production of Instructional Materials," Audio Visual Communication Review 22(2), 181-190 (1974). 36. T. G. Hicks, Successful Technical Writing, New York: McGraw-Hill Book ~ Company, 1959. L 37. A. J. Hoen and A.A. Lumsdaine, " Design and Use of Job Aids for Communicat-ing Technical Information," Lowry AFB, 00: Air Force Personnel and Training Research Center, Technical Report 58-7, 1958. 38. Institute of Nuclear Power Operations. " Procedures Writing Guide for General Format," Draft 1, August 1980. 39. W.~A. Jablonski, " Improving the Readability of Maintenance Manuals," Applied Behavorial Sciences, Inc., Report ABS-TP-1,~1971 (from Dec. 8-10, 1970 presentation). 40. F. W. James, " Job Performance Aid Methods," DSPD Report No. 75-1. Springfield, VA.: National Technical Information Service, October 2, 1975.** 41. R. C. Johnson, D. L. Thomas and D. J. Martin, " User Accep'tance and Usability of the C-141 Job Guide Technical Order System, ( AFHRL-TR-77-31). Wright-Patterson Air Force Base, OH: Advanced Systems Division, Air Force Human Resources Laboratory, June 1977 (AD-A044 001).** A2-3 i ~

42. K. H. Johnson, R. P. Relova, Jr., and J. P. Staf ford, "An Analysis of the Relationship Between Readability of Air Force Procedural Manuals and Discrepancies Involving Non-Compliance with the Procedures," Air Force Institute of Technology, Report AFR 80-45, Sept. 15, 1972 (AD-750-917).** 43. R. P. Joyce, A. P. Chenzoff, J. R. Mulligan, and W. J. Mallory, " Fully Proceduralized Job Performance Aids," Vol. I, Draft Specification for Organizational and Intermediate Maintenance (AFHRL-TR-73-43(I)). Wright-Patterson Air Force Base, OH: Air Force Human Resources Laboratory, December 1973 (AD-775 702).** 44. R. P. Joyce, A.P. Chenzoff, J. R. Mulligan and W. J. Mallory, " Fully Proceduralized Job Performance Aids," Vol. II, Handbook for JPA Developers, (AFHRL-TR-73-43(II)). Wright-Patterson Air Force Base, OH: Air Force Human Resources Laboratory, December 1973 (AD-775 705).** 45. R. P. Joyce and A.P. Chenzoff, " Improving Job Performance Aids Through Condensation, Dual-Level Presentation, Promotion of Learning, and Entry by Malfunction Symptoms," (AFHRL-TR-74-12). Wright-Patterson Air Force Base, OH: Advance Systems Division, Air Force Human Resources Laboratory, March 1974. 46. R. Kammann, "The Comprehensibility of Printed Instructions :nd the Flc'.. Chart Alternative," Human Factors 17(2), 183-191 (1975). 47. J. P. Kincaid and L. J. Delionbach, " Validation of the Automated Readabil-ity Index: A Follow-Up," Human Factors 15(1), 17-20 (1973). 48. Kinton, Inc., " Human Factors Criteria for Procedures," Report prepared for Babcock and Wilcox, Lynchburg, VA., July 16, 1980. 49. G. R. Klare, The Measurement of Readibility, Ames, IA: Iowa State University Press, 1963. 50. G. R. Klare, "Some Empirical Predictors of Readability," pp 241-254 in Rothkopf & Johnson (eds.), Verbal Learning Research and the Technology of Written Instruction, Washington, DC: Teachers College Press, 1971. 51. G. R. Klare, " Assessing Readability," Reading Research Quarterly 10(1), 62-102 (1974). 52. G. R. Klare, J. E. Mabry, and L. M. Gustafson, "The Relationship of Style Difficulty to Immediate Retention and to Acceptability of Technical Material," Journal of Educational Ps k. ology 46(5), 287-295 (1955). 53. G. R. Klare, W. H. Nichols, and F. H. Shuford, "The Relationship of Typographic Arrangement to tha 8. earning of Technical Training Materials," Journal of Applied Psychology C (1), 41-45 (1957). 54. G. R. Klare, H. W. Sinaiko, and L. M. Stolurow, "The Cloze Procedure: A Convenient Readability Test for Training Materials and Translations," Paper P-660, Institute for Defense Analysis, January 1971. A2-4 s

I 55. H. Krueger, "Ergonomical Aspects of the Legibility of Various Sized Letters." 343(76), Pflugers Archiv R 38 (1973). 56. E. R. Long, L. S. Reid, and R. W. Queal, " Factors Determining the Legibility of Letters and Words Derived from Elemental Printers," Third report on the "Informax" principle. Charlottesville, VA.: University of Virginia, August 1951. 57. E. J. McCormick, Human Factors Engineerin_g, 3rd edition, New York: McGraw-Hill Book Co., 1970. 58. G. H. McLaugulin, " Comparing Styles of Presenting Technical Information," Ergonomics 9(3), 257-259 (1966). 59. G. H. Mclaughlin, "SM0G _ Grading: A New Readability Formula," Journal of Reading'12, 639-646 (1969). 60. G. H. McLaughlin, " Temptations of the Flesch," Instructional Science 2(4), 367-383 (1974). 61. E. E. Miller, " Designing Printed Instructional Materials: Content and Format," Human Resources Research Organization, Alexandria, VA, Report HumRR0 RP-WD (TX)-75-4, October 1975. 62. R. ". Miller, American Institute for Research, "A Suggested Guide to the Preparation of Handbooks of Job Instructions," Air Force Personnel and Training Research Center report MC-TM-56-15, May 1956. 63. M. H. Morgenstern, M. J. Clausen, L. O. Foley, G. W. Levy, L. B. Myers, W. L. Rankin, and R. Shiklar, Pacific Northwest Laboratory, " Guidelines for Preparing Emergency Procedures for Nuclear Power Plants," USNRC Report NUREG/CR-1977 (PNL-3713), April 1981.* 64. J. F. Mulligan, Management and Technical Services Co., " Logic Tree Trouble-shooting Aids: Organizational and Intermediate Maintenance," Air Force Systems Command, Advanced Systems Division report AFHRL-TR-79-49, January 1979. 65. Navy Personnel Research and Development Center (EPICS), " Guidelines for the Development of Enriched Partially Proceduralized Job Performance Aids," EPICS Project Memorandum No. 80-51, July 1980. 66. W. R. Nelson, M. T. Clark, and W. W. Banks, U.S. Department of Energy, " Applications of Functional Analysis to Nuclear Reactor Operations," USNRC Report NUREG/CR-1995 (EGG-2087), March 1981.* 67. A. J. North and L. B. Jenkins, " Reading Speed and Comprehension as a Function of Typography," Journal of Applied Psychology 35(4), 225-228 (1951). 68. D. G. Paterson and M. A. Tinker, How To Make Type Readable, New York: Harper & Bros., 1940. A2-5

69. L. V. Peterson and W. Schramm, "How Accurately Are Different Kinds of Graphs Read?" Audio Visual Communication Review 2(2), 178-199 (1955). 70. T. J. Post and H. E. Price, " Requirements and Criteria for Improving Reading Comprehension of Technical Manuals," Falls Church, VA: Bio-Technology, Inc., November 1974. 71. T. J. Post, H. E. Price, and G. Diffley, "A Guide for Selecting Formats and Media for Presenting Maintenance Information. Falls Church, VA: Bio-Technology, Inc., April 1976. 72. E. C. Poulton, " Effects of Printing Types and Formats on the Comprehen-sion of Scient', tic Journals," Nature 184, 1824-1825 (1959). 73. E. C. Poultan, "A Note on Printing To Make Comprehension Easier," Ergonomics 3(3), 245-248 (1960). 74. E.C Poulton, "The Measurement of Legibility," Printing Technology 12(2), 72-76 (1978). 75. E. C. Poulton, " Size, Style and Vertical Spacing in the Legibility of Small Typefaces," Journal of Applied Psychology 56(2), 156-161 (1972). 76. H. E. Price, Bio-Technology, Inc, " Development of a Draf t Specification for Technical Manual Quality Assurance," Naval Ship Research and Develop-ment Center report, December 1975. 77. H. E. Price, T. J. Post, and G. Kolsrud, Bio-Technology, Inc., " Develop-ment of Information Measurement Techniques for Quality Assurance of Navy Aircraft Maintenance Job Aids," Naval Air Systems Command report, June 1971 (AD-725-815).** 78. D. W. Rees and W. N. Kama, " Size of Tabs: A Factor in Handling of Guides and Checklists" (WADC-TR-59-154), Wright-Patterson Air Force Base, OH: Wright Air Development Center, March 1959 (AD-213 595).** 79. D. O. Robinson, M. Abbamonte, and S. H. Evans, "Why Serifs Are Important: The Perception of Small Print," Visible Language, 5(4), 353-359 (1971). 80. D. A. Ross, " Comprehensibility Evaluation of Technical Manuals," WADC Technical Note 59-442, Wright-Patterson Air Force Base, OH: Wright Air Development Center, July 1959 ( AD-228-235).** 81. E. V. Saul and others, "A Review of the Literature Pertinent to the Design and Use of Effective Graphic Training Aids," SPECDEVCEN Technical Report 494-08-1, October 1954.. 82. H. G. Schutz, "An Evaluation of Formats for Graphic Trend Displays - Experiment II," Human Factors 3(2)., 99-107 (1961). 83. H. G. Schutz, "An Evaluation of Me thods for Presentation of Graphic Multiple Trends - Experiment III," liuman Factors 3(2), 108-119 (1961). A2-6

84. J. L. Seminara, W. R. Gonzalez, and S. O.' Parsons, Lockheed Missiles & Space Co., Inc., " Human Factors Review of Nuclear Power Plant Control Room Design," Electric Power Research Institute Report EPRI-NP-309, March 1977. 85. A. I. Siegel and others, Applied Psychological Services, Inc., " Increasing and Evaluating the Readability of Air Force Written Materials," Human Resources Laboratory Report AFHRL-TR-74-28, August 1974 (AD-786-820).** 86. A. I. Siegel and others, Applied Psychological Services, Inc., "Techni-ques for Making Written Material More Readable / Comprehensible," Air Force Human Resources Laboratory Report AFHRL-TR-74-47, August 1974 (AD-786-820) ** 87. R. J. Smillie, " Specification for the Production of Fully Proceduralized Job Performance Aids," Navy Personnel Research and Development Center, EPICS Project Memorandum No. 80-20R, May 1980. 88. E. A. Smith and J. P. Kincaid,'" Deviation and Validation of the Automated Readability Index for Use with Technical Materials," Human Factors 12(5), 457-464 (1970). 89. H.- Spencer, The Visible Word, New York: Hastings House, 1969. 90. H. Spencer, L. Reynolds, and B. Coe, A Preliminary Study of the Effects of Image Degradation on the Legibility of Printed Text and Numerals, London: Readability of Print Research Unit, Royal College of Art, March 1975. 91. H. Spencer, L. Reynolds, and B. Coe, The Effects of Image Degradation and Background Noise'on the Legibility of Text and Numerals in Four Different Typefaces, London: Readability of Print Research Unit, Royal College of Art, November 1975. 92. H. Spencer and A. Shaw, " Letter Spacing and Legibility," British Printer 84, 84-86, March 1971. i 93. B. M. Strong, "The Cloze Test as a Procedure for Establishing Objective German Prose Readability Standards," Ohio State University, 1978 (AD-A065489).** 94. W. Strunk, Jr., and E. 8. White, The Elements of Style, New York: Macmillan Publishing Co., 1978. 95. W. L. Taylor, "Cloze Procedure: A New Tool for Measuring Readability," Journalism Quarterly 30(Fall), 415-433 (1953). 96. M. A. Tinker, Legibility of Print, Ames, IW: Iowa State University Press, 1963. Second printing, 1964. A2-7

2 97. M. A. Tinker, " Experimental Studies in the Legibility of Print - An Annotated Bibliography," Reading Research Qusrterly 1(4), 68-118 (1966). 98. U.S. Department of Defense, " Military Specification - Manuals, Technical: Operator's, Preparation of," U.S. Department of Defense Report MIL-M-63036A (TM), April 1, 1980.

99. ' U.S. Department of Defense, " Military Specification Materials, Technical:

Organizational, Direct Support and General Support Maintenance," (ITDT-Flow Chart), U.S. Departmer t of Defense Report MIL-M-C3037 (TM), May 1, 1977. 100. U.S. Department of Defense, " Military Sepcification - Manuals, Technical: Organizational or Aviation Unit, Direct Support or Aviation Intermediate, and General Support Maintenance," U.S. Department of Defense. Report MIL-M-C3083B (TM), April 1,1980. 101. U.S. Department of Defense, " Technical Manual Writing Handbook," U.S. Department of Defense Report MIL.-HDBK-63038-1 (TM), May 1,1977. 102. U.S. Department of Defense, " Military Specification - Manuals, Technical: General Style and Format Requirements," U.S. Department of Defense Report l MIL-M-38784A, Amendment 4, May 1,1977. 103. U.S. Department of Defense, " Military Standard: Comprehensibility Stand-ards for Technical Manuals (Metric)," U.S. Department of Defense Report 00D-STD-1685 (SH), October 10, 1978. 104. T. G. Weidman and F. W. Ireland, "A New Look at Procedures Manuals," Human Factors 7(4), 371-377 (1965). 105. R. H. Wiggins, " Effects of Three Typographicai Variables on Speed of Reading," Journal of Typographic Research I(.1), 5-18 (1967). 106. A. R. Williams, Jr., A. I. Siegel, and J. R. Surkett, Applied Psycholoyiral Services, " Readability of Textual Materials - A Survey of the Literature," Air Force Human Resources Laboratory Report AFHRL-TR-74-29 July 1974 (AD-785-140).** 107. P. Wright, " Writing To Be Understood: Why Use Sentences," Applied Ergono-mics 2(4), 207-209 (19/1). 108. P. Wright and F. Reid, " Written Information: Some Alternatives to Prose l for Expressing the Outcomes of Complex Contingencies," Journal of Applied l Psychology 57(2), 160-166 (1973). A2-8

109. E. Yourdon, Techniques of Program Structure and Design, Englewood Cliffs, NJ: Prentice-Hall, Inc., 1975. 110. S. E. Zach, " Control Room Operating Procedures: Content and Format," 125-127 in Proceedings of the Human Factors Society 24th Annual Meeting, p 1980. 111. B. Zachrisson, " Studies in the Legibility of Printed Text," Acta Universitatis Stockholmiensis, Stockholm Studies in Educational Psychology II. Uppsala: Almqvist & Wiksell, 1965. "Available for purchase from the NRC/GPO Sales Program, USNRC, Washington, DC 20555.

• • Available for purchase from the National Technical Information Service, Springfield, VA 22161.

1 i 1 A2-9

APPENDIX 3 SAMPLE EMERGENCY OPERATING PROCEDURE 5 The sample Emergency Operating Pro edures contained in this appendix are intended to illustrate two acceptable general approaches for format. \\ wide range of other general approaches are acceptable as specified in Section 4.4.2 of the criteria. The procedural steps contained in the sample procedures are not intended to be technically accurate, correct, or complete. They should be viewed strictly as examples of two formats. The first example illustrates a two-column, multiple-level approach using a combination of short phrases and short sentences. The second example uses the full width of the page with complete sentences and a single level of information presentation. Any resemblance of the sample procedures to existing Emergency Operating Procedures is purely coincidental. A3-1

-~ .~. / r. i Page'l of 11 r TRANSSYLVESTER POWER & LIGHT COMPANY' SKUNKY-HOLLOW #2 Immediate Actions and Diagnostics E0P-0-0001 Revision'3 3 March 1981 e f REVIEWED date . CONCURRED date APPROVED date 4 i Total Number of Pages 11 a A3-3

'c Page 2 of 11 Immediate Actions and Diagnostics E0P-0-0001 Revision 1 February 27, 1981 -1.0 SCOPE 1.1 The purpose of this procedure.is to provide the actions necessary to shut.down the reactor following an initiating condition and to provide i diagnostic steps to determine a subsequent course of action. 2.0 INITIATING SYMPTOMS 2.1 ' Scram signal present, and scram 2.1 Indications, with scram signal has not occurred. present, of any of the following: 2.1.1 All control rods not fully inserted on full core display. 2.1.2 Neutron flux does not decrease rapidly. 2.1.3 CRD DISCHARGE V0L HI annunciator does not alarm following scram caused by another signal. 2.1.4 RPV pressure increasing following scram signal.

2. 2 Scram condition exists, but 2.2 indications, without scram signal, scram signal not received.

of any of the following: 2.2.1 Scram discharge volume high water level. (CRD DISCHARGE VOL HI). A3-5

'Page 3 of 11 Immediate Actions'and Diagnostics E0P-0-0001 Revision 3 March 3, 1981 2.2.2 Main steam line radiation. (MS HI RAD). 2.2.3 MSIV closure (MSIV lights panel 604). 2.2.4 Peactor high pressure (RPV PRESS HI). 1 2.2.5 Reactor low-low water level (RPV LEVEL). 2.2.6 Turbine stop valve closure (TSV lights on panel 612). 2.2.7 Neutron monitoring system trip (diagram on panel 103). L I 2.2.8 Drywell high pressure (DRYWELL PRESS HI). 2.3 Reactor trip. 2.3 Indications. 2.3.1 Neutron flux decreasing. 2.3.2 Reactor Trip alarm (RXT). 2.3.3 All control rods inserted on full core display. 2.3.4 CRD DISCHARGE V0L HI Trip annunciator. A3-7

I Page44 of 11 Immediate Actions and Diagnostics E0P-0-0001 Revision 2 February 28, 1981 3.0 AUTOMATIC ACTIONS 3.1 FOR ATWS, one of the following 3.1 NOTE will occur: ATWS covers conditions 2.1 and 2.2 of INITIATING SYMPTOMS. 3.1.1 Reactor Recirculation 3.1.1 Shift on RPT signal. Pumps shift to slow speed. 3.1.2 Reactor Recirculation 3.1.2 RPV Low Level Pumps trip (RPV LVL LO) OR RPV High Pressure (RX PRESS HI). 3.2 FOR Reactor Trip (RTX), all of the following will occur: 3.2.1 Control rods fully inserted. 3.2.2 HPSI initates. 3.2.2 RPV water level controlled at 18.75". A3-9

t Page_5 of 11-Immediate Actions and Diagnostics E0P-0-0001 Revision 2 February 28, 1981 l ?- 3.2.3 EHC operates 3.2.3 Reactor pressure con-trolled at-1000 psig. 0R SRV opens. T 4.0 IMMEDIATE OPERATOR ACTION 4.1 Verify automatic actions occurred. 4.2 IF a scram signal is present AND all rods are not fully inserted. i THEN fully insert all rods. 2 4.2.1 Manually trip RRPs A and B. 4.2.2 Manually scram the reactor. 4.2.2.1 Arm and depress the manual scram pushbuttons. 4.2.2.2 Place the mode switch in SHUTDOWN. A3-11

L L Page 6 of 11 Immediate Actions and Diagnostics E0P-0-0001 Revision 3 March 3, 1981 4.2.3 Vecify Main _ Turbine trip. 4.2.4 Verify Main Turbine Generator Output Breaker.is open. 4.2.5 IF reactor has tripped 4.2.5 NOTE with all control rods Do not perform any fully inserted, steps between 4.2.5 and 4.4 if a scram THEN go to Step 4.4. has occurred. 4.2.6 Start the second CRD pump. 4.6.2.1 Place CRD flow controller in MANUAL. 4.2.6.2 Fully open flow 4.2.6.2 Valve control valve. 1-37-FCV-YZ0138. 4.2.6.3 Fully open CRD 4.2.6.3 Valve water presure 1-39-CRD-3Y041A. control valve. 4.2.7 Open RPS Trip System A 4.2.7 Panel Z4218. supply breaker and open RPS Trip System B Panel Z421A. supply breaker. A3-13 i

I - Page 7 of 11 Ime?diate Actions and Diagnostics E0P-0-0001 Revision 3 March 3,.1981' 4.'2.8 ' Isolate and bleed afr from the scram air header. 4.2.8.1 Close 1-04-7Z431. Open 1-04-7Z901. 4.2.) Individually scram each 4.2.9 NOTE control rod at tF.e HCU There are 2 test by placing the test switches at each HCU. switches in TEST. 4.2.10 IF all control rods are not fully inserted THEN inject boron: 4.2.10.1 Initiate SLC. 4.2.10. 2 Isolate the RWCU system. 4.3 IF a scram condition exists, AND a scram signal has-NOT been received THEN fully insert all rods. 4.3.1 Manually scrani the reactor. A3-15 -~w er r==w r---

1 - Page 8 of 11 Immediate Actions and Diagnostics E0P-0-0001 Revision 3 March 3,.1981 '4.3.1.1 ' Arm and depress the 4 manual scram push-buttons. -4.3~1.2 Place mode switch in SHUTDOWN. 4.3.2 Manually trip Reactor ' Recirculation Pumps A and B. 4.3.3 Verify Main Turbine Trip. 4.3.4 Verify Main Turbine Generator Output Breaker Trip. 4.3.5 Open RPS. Trip ~ System A Output Breaker and open RPS Trip System B Output Breaker. 4.3.6 IF RPS scram has not initiated, THEN inject boron: i 4.3.6.1 Initiate 'SLC. 2 A3-17'

p -: Page 9 of 11' Immediate Actions and Diagnostics E0P-0-0001 Revision 1 i February 27, 1981 4.3.6.2 Isolate RWCU. 4.4.IF reactor trip.(RTX) AND all rods fully inserted THEN 4.4.1 Place Reactor Mode Switch in SHUTDOWN. 4.4.2 Insert IRMs and SRMs. 4.4.3 Shift IRM Recorders to IRM position 5.0 SUB5EQUENT ACTIONS j 5.1-Verify that all immediate operator actions are com-plete. Perform any actions not completed. 5.2 Inform plant personnel of 5.2 Use the site announcing symptoms of reactor trip system. 5.3 -Maintain RPV water level between 13" and 58". A3-19 -m-3

M Page ]LO of 11 Immediate Actions and Diagnostics E0P-0-0001 Revision 1 February 27, 1981 5.3.1 Use RPI in single element control. 5.4 IF RPV water level cannot-5.4 Level Control Procedure i be maintained above 13" E0P-0-0003. THEN~ follow the Level Control Procedure simultaneously with 1 the remainder of this procedure. 5.5 Monitor containment parameters 5.5 NOTE .every 5 minutes. Normal ranges of containment parameters: Suppression Pool Temperature: 70-95 F Drywell Temperature 70-95 F. Drywell Pressure 0.5-1.69 psig. i Suppression Pool Water Level 22-24 feet. 5.5.1 If any containment 5.5.1 Containment Control parameters get outside Procedure is E0P-0-0004. normal ranges THEN follow Containment control procedure simultaneously with the remainder of this procedure. A3-21

Page 11 of 11-Immediate Actions and Diagnostics E0P-0-0001 Revision'1 February 27, 1981 5.6 Determine the cause of the 5.6 Use troubleshooting procedure scram or ATWS and attempt to in TM-379 (RPS INSTRUMENTATION). clear condition. 5.7_ Carry out Emergency Plan 5.7 Emergency Plan, EP-1 actions. -(blue binder). 5.8 Direct CHEM / RAD Assistant to obtain a sample'of RPV water j and analyze for Dose Equivalent Iodine Activity. 5.9 Record Scram Report data. 5.9 File A, third drawer. 5.10 Notify Operations Supervisor of plant conditions. 5 A3-23

EP0-0-0001/3 IDA March 3, 1981 l t. ~ E0P-0-0001 Immediate and Diagonistic Actions s (IDA) i I Transsylvester Power and Light Company " Bringing Power to the People" March 3, 1981 Revision 3 ~ Reviewed: Date: Approved: Date: page 1 of 5 A3-25

EP0-0-0001/3 IDA March 3, 1981

1. 0 Scope:

i The purpose of this procedure is to provide the immediate actions necessary to - shut down the reactor following an initiating condition and to provide the diagnostic steps to determine a subsequent course of action. 2.0 Initiating Symptoms: 2.1 Scram signal present and the scram has not occurred. This is indicated by a Reactor Protection System scram signal with any of the following: 2.1.1 All control rods are not fully inserted. 2.1.2 Neutron flux does not decrease rapidly. 2.1.3 CRD DISCHARGE V0L HI annunciator does not alarm following a scram caused by another signal. 2.1.4 Reactor Pressure Vessel pressure is increasing. 2.2 A scram condition exists and the scram signal is not present. This is indicated by any of the scram conditions of Table 2.2 existing without a scram signal present. 2.3 A reactor trip as indicated by: J 2.3.1 Neutron flux is decreasing. 2.3.2 Reactor Trip alarm (RXT) occurs. 2.3.3 All control rods are fully inserted on full core display. 2.3.4 CRD DISCHARGE VOL HI Trip is present. Table 2.2 Scram Conditions Control Rod Scram Discharge High Level (CRD DISCHARGE V0L HI) Main Steam Line High Radiation (MS HI RAD) Main Steam Isolation Valve Closure (MSIV lights pane,1 604) Reactor High Pressure (RPV PRESS HI) Reactor Low-Low Water Level (RPV LO-LO LVL) j Turbir.e stop Valve Closure (TSV lights on panel 612) Neutron Flux Monitoring System Trip (diagram on panel 103) Drywell High Pressure (DW PRESS HI) page 2 of 5 A?-27

EP0-0-0001/3 IDA March 3, 1981 3.0 Automatic Actions NOTE: The term ATWS includes'the initiating symptons in paragraphs 2.1 and 2.2 3.1 For an Anticipated Transient Without Scram (ATWS) condition, either the Reactor Recirculation Pumps will shift to slow speed due to the Reactor Protection Trip Signal OR they will trip due to Reactor Pressure Vessel level (RPV LVL LO) or a Reactor Pressure Vessel high pressure (RX PRES HI) signal. 3.2 For a Reactor Trip (RTX) all of the following will occur:

3. 2.- 1 Control rods are fully inserted.

3.2.2 The reactor water level is being controlled at 18.75 inches. 3.2.3 Electro-Hydralic Control is operating or Safety Relief Valves are cycling, controlling reactor pressure at 1000 psig. 4.0 Immediate Operator Actions: 4.1 Verify that all automatic actions have occurred. 4.2 IF a scram signal is present AND all of the control rods are not fully Inserted, THEN perform all of the following steps: 4.2.1 Manually trip both Reactor Recirculation Pumps A and B. 4.2.2 Arm and depress the manual scram pushbuttons. 4.2.3 Place the Scram Mode Switch in SHUTDOWN. ,4.2.4 Verify that the Main Turbine has tripped. 4.2.5 Verify that the Main Turbine Generator Output breaker is open. 4.2.6 IF the reactor has tripped with all control rods fully inserted, THEN continue this procedure at Step 4.4. NOTE: The rest of the steps in paragrap 4.2 are not necessary if the reactor has tripped. 4.2.7 Place the Control Rod Drive flow controller in MANUAL. 4.2.8 Fully open the flow control valve 1-37-FCV-4Z0138. 4.2.9 Fully open the Control Rod Drive water pressure control valve 1-39-CRD-3Y041A. page 3 of 5 A3-29

N y h; EP0-0-0001/3 c ~ IDA a, March 3, 1981~ .y 4.2.10-Open the Reactor / Protection System Supply Breaker A on panel Z4218 and Supply; Breaker 8 on pansl-Z421A. 4.2.11. Close valve 1-04-7Z431, the scram header-isolation. valve.

4.2.12-Open 1-04-7Z901, the scram header bleed valve.

. 4.~ 2.13 At 'each Hy'draulic Control Unit place' both of the test switches in TEST. ' 4.2.14 IF all control rods are'not fully inserted,.THEN initiate the 3tandby Liquid Control System and isolate the Reactor Water Cleanup system. I '4.3 IF a scram condition exists AND a scram signal has NOT been received, t THEN perform the.following steps: '4.3.1 Arm and depress the manual scram pushbuttons. 4.3.2 ' Place the Scram Mode Switch in SHUTDOWN. 4.3.3' Manually trip both Reactor Recirculation Pumps A and B.

4. 3. 4 ~

Verify that the Main Turbine has tripped. 4.3.5' Verify that the Main Turbine Generator Output Breaker has tripped. 4.3.6 Open the Reactor Protection System Trip System A and B Output Breakers. 4.3.7 IF the Reactor Protection System scram has not initiated THEN liittiate the Standby Liquid Control system and isolate-the 3 I Reactor Water Cleanup system. ( 4.4 ~IF a reactor trip has occurred AND all control rods have been j, Inserted, THEN perform the following steps: 4.4.1 Place the Reactor Mode Switch in SHUTDOWN. 4.4.2 Insert the Intermediate Range Monitors and the Source Range Monitors. I 4.4.3 Shift the Intermediate Range Monitor Recorders to the Inter- ~ c ' mediate Range position (IRM). 5.0 Subsequent Actions 5.1 Verify that all of the immediate operator actions have been completed. Perform any actions that are not completed. 5.2 Inform the plant personnel of the symptoms of the reactor trip using the site announcing system. page 4 of 5 A3-31

EP0-0-0001/3 IDA March 3, 1981 5.3 Maintain Reactor Pressure Vessel water level between 13 inches and 58 inches using the Reactor Plant Feedwater system in single element control. 5.4 If the Reactor Pressure Vessel water level cannot be maintained a50ve 13 inches, THEN follow the Level Control Procedure (E0P-0-0003) simultaneously with this procedure.

5. 5 Monitor containment parameters every 5 minutes.

5.6 IF any containment parameters get outside their normal ranges In Table 5.6 THEN follow the Containment Control procedure E0P-0-0004 simultaneously with this procedure. Table 5.6 Containment Parameter Normal Ranges Suppression Pool temperature: 70-95 F Drywell Temperature: 70-95 F Drywell Pressure: 0.5-1.69 psig Suppression Pool Water Level: 22-24 feet 5.7 Determine the probable cause of the trip or transient without scram and attempt to clear the condition using RPS Instrumen-tation Procedure TM-379. 5.8 Carry out the Emergency Plan, EP-1 (blue binder). 5.9 Direct the Chemistry / Radiation Control (CHEM / RAD) Assistant to obtain a sample of the Reactor Vessel Water and analyze for Dose Equivalent Iodine Activity. 5.10 Record the data specified in the Scram Report. Blank copies of the report are in File A, third drawer. 5.11 Notify the Operations Supervisor of the plant conditions, page 5 of 5 A3-33

U.S. NUCLEf.3 f.EGUL ATORY COMMsSSION. h g BIBLIOGRAPHIC DATA SHEET ,4 TITLE ANO SUBTITLE / Add Vo/usrn No,,f eprmr are) 2, ft.,,, m.n a j Draft' Criteria for Preparation of Emergency Operating Procedures ~ 3 Pt d PIENT3 ACCESSION NO. 7, AUTHORIS!

5. DATE' REPORT COMPLE TED l Y1 AR MONTs April 1981

9. PERFORMING ORGANIZATION NAME AND M AILING ADDRESS //nclude 2,p Code /

DATE REPORT ISSUED U. S. Nuclear Regulatory Commission lvsAn uouTs - Division of Human Factors Safety. June 1981 Office of Nuclear Reactor Regulation

c. a,,,, u.na; Washington, D. C.

20555

8. fleave Nann)

12. SPONSORING OHGANIZ ATION NAME AND MAllING ADDRESS (inclutse 2,4 Codel 10 PROJECT / TASK / WORK UNIT NO.

H. G)NT R ACT NO. Same as 9, above.

13. TYPE OF REPORT Pt Hioo covt RE D linclus,re dates /

Technical 15 $UPPLEMENTARY NOTES

14. (t re<e plaaAl

16. ABSTR ACT /200 wo,as or / css /

This document, NUREG-0799, is a request for public comment on draft criteria for the preparation of Emergency Operating Procedures, developed in support of items I.C.1, I.C.8, and I.C.9 of the Task Action Plan (NUREG-0660 and NUREG-0737). These criteria were developed from information contained in contractor reports (NUREG/CR-2005, NUREG/CR-1970, NUREG/CR-1977, NUREG/CR-1999, and NUREG/CR-1875), staff review of the literature, and staff experience in the pilot monitoring of Emergency Operating Procedures for near-term operating 1icenses. 17 KE Y WORDS AND DOCUME NT AN ALYSiS 17.s DL SC rip T O kS l t 170 IDE NTIF 6E RS OPE N EN DE D TE RMS 18 LV AIL ABILIT) ST ATEMENT 19 SE CURiTY CLASS (Tnes scoorts 21 NO OF PAGE S Unclassified ".1imited n PRICE ,gsg,ggs ,7,,,, pa,./ .s C, o.o m,,,,,

UNITED STATES 2 NUCLE AQ C4EXULATOQY COMMISSl!N f ] r} C W ATHIN 3 TON, D. C. 20555 M py,vassaNnragspaso O Ei u 5. NUCLE A R REGU L A TOR Y Obgl OF FICI AL SUSINESS COMMISSION FEN ALTY FOR PRIVATE USE, $300 3 O' j k J gel -w\\ C1 c> n H O

D_

Hm' 2 nO'

D Ul "Um' 0,>

m>l H O. Z! On m m, T, O-m 2-O' =< ! 01 "O l m' %;>dz O 7 "UO Om OC

D m

Ch c_ C2m .a 03 .}}