ML20041A266
| ML20041A266 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 01/28/1982 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20041A267 | List: |
| References | |
| NUDOCS 8202190347 | |
| Download: ML20041A266 (6) | |
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JAN ? 81982
!D10RANDU?i FOR:
Atomic Safety and Licensing Board for Virgil C. Sumer Nuclear Station, Unit flo.1 FRO't:
Robert L. Tedesco, Assistant Director for Licensing, DL
SUBJECT:
BOARD HOTIFICATION - EtlERGEHCY OPERATING PROCEDURES (BN-82
)
Attached is a trip report dated December 22, 1981 which was prepared by fi. tiedeiros, Jr. of the NRC's Office of Regulatory Research. Also attached is a meiorandum fron J. Norberg of the same office identifying a typographical er or in the trip report. The trip report contains certain opinions regarding the adequacy of operating procedures at the Virgil C. Sumer fluclear Station, Unit No. I which we consider to be relevant and material to the Board's review s
of this application. However, it does not relate directly to specific conten-tions which the Board is presently considering.
It should be noted that the author of the trip report retired froq the HRC on Decenher 26, 1981 and is now employed by the Babcock A-Wilcox Ccripany.
The purpore of the trip as stated in the trio report (as corrected) ms to
" gain first-hand knowledge of ooerating procedure preparation and use so as to better scope and direct Agency research in support of NRC's human factors research progran for upgrading operating procedures".
It should also be noted that the Virgil C. Sumer Nuclear Station, Unit No. I was reportedly selected at random for this study.
We have reviewed each of the comments contained in the trip report and our preliminary conclusion is that they do not alter the favorable conclusions reached in our Safety Evaluation Report (HUREG-0717) and supplements thereto regarding the adequacy of emergency operating procedures (E0Ps). This conclusion is based on the following:
(1) the E0Ps that were reviewed before writing the Safety Evaluation Report are based on generic technical guidelines that had received staff review and interin approval and (2) the procedures are expected to be upgraded early in the life of the< plant based on additional work on the technical guidelines and on human factors guidance to be provided by the staff and by industry groups.
s During the week of January 18, 1962, representatives of the Offices of lluclear Reactor Regulatioq, and Inspection and Enforecaent will conduct an 3
inspection of the Virgil C. Su rier Nuclear Station procedures. It is exoected that editorial nodifications in the procedures will result from our review.
Ile will notify you if we find any discrepancies that change the favorable i'
conclusion of our initial Safety Evaluation Report.
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, Furthemore, the coments nade in !!r. Medeiros' trip report are beino considered in the development of fiRC's lona ter, program for uograding plant pracedures (NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accidents" Ite, I.C.9, "Lonq-Tern Proqran Plan for Upgradino of Procedures").
Original signed by
. ggt L. Tedesco Robert L. Tedesco, Assistant Director for Licensing Division of Licensinq
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?O!0RA!:301 FOR:
Atomic Safety and Licensinq Board for Virgil C. Sum 1er Nuclear Station, Unit Ho.1 FRut:
Robert L. Tedesco, Assistant Director for Licensinq, DL SU3 JECT:
BOARD NOTIFICATIO'l - EMERCE?lCY OPERATING PROCEDURES (8N-82
)
Attached is a trip report dated December 22, 1981 which was nrepared by
!!. 'tedeiros, Jr. of the HRC's Office of Regulatory Research. Also attached is a neaorandum from J. Morberg of the sa,e office identifying a typographical error in the trip report. The trip recort contains certain opinions regarding the Maquacy of operating orocedures at the Virgil C. Struer Nuclear Station, Unit No. I which we consider to be relevant and naterial to the Board's revimt of this apulication. liomver, it does not relate directly to specific conten-tions which the Board is present!y co.1siderinq.
It should be noted that the author of the trip report retired froa the IRC on December 26, 1931 and is now elployed by the Babcock '. Wilcox Company.
The purpose of the trip as stated in the trip report (as corrected) ms to
" gain first-hand kn)wledge of operatinq procedure preparation and use so as to better scone and direct Aqency research in su7 port of hRC's hu1an factors research proqraq for upgrading operatinq proceriores".
It should also be noted that the Virgil C. Sumer Nuclear Station, linit t!o. I as selected at random for this study.
We have revieted each of the coments contained in the trip report and have concluded that they do not alter our favorable conclusions reached in the Safety Evaluation Repart (NUREG-0717) and sucolements thereto regardinq the adequacy of e,ergency operatinq orocedures. ue do, n3 wever, deif eve tnat the infornation obtained durino the trio will he an inportant innut to the NCC's longer tern progran for upgrading mergency operating procedures as described in HU'tEG-0660, "U.C Action Plan Developed as a Resul t of the T'11-2 Accident", Ite1 1.C.9, Long-Tera Proqrara Plan for Upgrading of Procedures".
Robert L. Tedesco, Assistant Director for Licensing Olvision of Licensing Attach: Tent:
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4 EMORANDUM FOR:' Atomic Safety and Licensing Board for Virgil C. Sumer Nuclear Station, Unit No.1 FRO't:
Robert L.- Tedesco, Assistant Director for Licensing, DL i
SUBJECT:
BOARD HOTIFICATION - EftERGENCY OPERATING PROCEDURES (BN-82
-)
Attached is a trip report dated December 22, 1981 which was prepared by H. Nedefor, Jr. of the NRC's Office-of Regulatory Research. Also attached is a memorandum fron J. Norber of the same office identifying a typographical error in the trip report. The trip report contains certain opinions regarding the adequacy of operating procedures at the Virgil C. Sumer Nuclear Station, Unit No. I which we consider to be relevant and mterial to the Board's review i
of this application. Ho>ever, it does not relate directly to specific conton-tions which the Board is presently considering.
It should bs noted that the author of the trip report retired from the NRC.
on December 26, 1981 and is now enployed by the Gabcock & Wilcox C07pany.
Tne purpose of the trip as stated in the trip report (as corrected) vas to
" gain first-hand knowledge of operatir # procedure preparation and use so as to better scope and direct. Agency research in support of NRC's human factors research program for upgrading operating procedures".
It should also be noted!
that the Virgil C. Sumer !!uclear Station, Unit No. I was selected at randon for this study.
We have reviewed each of the cowents contained in the trip report and have-concluded that they do not alter our favorable conclusions reached in the Safety Evaluation Report (NUREG-0717) and supplements thereto regarding the adequacy of energency operating procedures. We do, however, believe that the information obrained during the trip will be an toportant input to the j
NRC's longer tern program for upgrading eacrgency operating procedures as -
described in !!UREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 l
Accident", Ites I.C.9, Long-Tern Progran Plan for Upgrading of Procedures".
,s Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
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1 DISTRIBUTION OF BOARD tiOTIFICATION V.C. Summer Docket No. 50-395 ACRS Members Dr. John 11. Buck Dr. Robert C. Axtmann fir. Brett Allen Bursey Mr. Myer Bender George Fischer Esq.
Dr. Max W. Carbon Herbert Grossman, Esq.
Mr. Jesse C. Ebersole Dr. Frank F. Hooper Mr. Harold Etherington Joseph B. Knotts, Jr., Esq.
Dr. William Kerr Christine N. Kohl, Esq.
Dr. Harold W. Lewis Mr. Gustave A. Linenberger Dr. J. Carson Mark Mr. Randolph R. Mahan Mr. William M. Mathis Alar. S. Rosenthal. Esq.
Dr. Dade W. Hoeller Richard P. Wilson, Esq.
Dr. David Okrent Atomic Safety and Licensing Board Dr. Milton S. Plesset Panel Mr. Jeremiah J. Ray Atomic Safety and Licensing Appeal Dr. Paul G. Shewmon Panel Dr. Chester P. Siess Docketing and Service Section Mr. David A. Ward Document Management Branch O
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Mr. T.
C.'
Nichols, Jr.
Vice President & Group Executive Nuclear Operations South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 cc:
Mr. Henry Cyrus Senior Vice President South Carolina Public Service Authority 223 North Live 0ak Drive Moncks-Corner', South Carolina 29461 J. B. Knotts, Jr., Esq.
Debevoise & Liberman 1200 17th Street" N. W.
Washington, D. C.
20036 Mr. Mark B. Whitaker, Jr.
Group Manager - Nuclear Engineering & Licensing South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 Mr. Brett ' Allen Bursey Route 1 Box'93C Little Mountain, South Carolina 29076 Resident Inspector / Summer NPS' c/o U. S. NRC Route 1, Box 64 Jenkinsville, South Carolina 29065 Dr. John Ruoff Post Office Box 96 Jenkinsville, South Carolina 29065 Mr. James P. O'Reilly U. S. NRC, Region II' 101 Marietta Street Suite 3100 Atlanta, Georgia 30303 e
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WASHINGTON, D. C. 20555 c
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0gC 3 0 M MEMORANDUM FOR: Distribution
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FROM:
James A. Norbergs: Chief Human Factors Br&6ch, DF0, RES
SUBJECT:
TYP0 GRAPHICAL CORRECTION TO M. S. MEDEIROS REPORT OF TRIP TO VIRGIL C. SUMMER NUCLEAR STATION DATED DECEMBER 22, 1981 With reference to the above' subject trip report, please correct the typo-graphical error in the third line of the Purpose by changing with pen and ink "NRR's" to "NRC's".
Tne Purposie_ should read as follows:
Purpose:
The purpose 5f this trip was to gain first-hand knowledge of operating procedure preparation and use so as to better scope and direct Agency research in support of NRC's human factors research program for upgrading operating procedures.
Cr James A. Norberg, Chief
/
Human Factors Branch, DF0, RES
' DISTRIBUTION H. L. Thompson, NRR J. Skolds, IE W. Kane, NRR V. Brownlee, IE Reg II K. Woodward, SCE&GC d a+h ph
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DEC 2 2 E81 ME'iORANDUM FOR:
James Norberg, Chief, HFB, DF0, RES Raymond DiSalvo, Section Leader, HFB, DF0,RES FROM:
M. S. Medeiros, Jr., HFB, DF0, RES
SUBJECT:
REPORT OF TRIP TO VIRGIL C. SUMMER NUCLEAR STATION Attached for your infomation and use as apptcpriate is a report of trip to Virgil C. Summer nuclear station on December 17 and 18,1981.
This plant contains a Westinghouse three-loop reactor which has just completed hot functional testing in preparation for core load in late winter or early spring 1982.
The operating procedures have been in preparation since 1976 and have gone through several revisions as more up-to-date information has become avail-abl e.
The procedures were first written to reflect system descriptions, piping and instrumentation diagrams, and the preliminary safety analysis report.
Subsequently, a contractor (NUS) was hired to rewrite the proca-dures to incorporate ccaponent technical manual information, Westinghouse generic procedure information, and comments resulting from procedure use during an earlier hot functional test program.
Also attached for your information is the latest copy of my " Operating Procedures Thinking Paper" (marked 7-23-81 Rev.) which contains an overall plan of action for upgrading operating procedures,of which first-hand observations of the sort made during this trip are a part.
M. S. Medeiros, Jr.
Human Factors Branch Division of Facility Operations Attachments: As stated cc:
H. L. Thompson, Jr., DHFS
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December 22,1981 r
Report of Trip Date:
December 17, and 18,1981 Place:
Virgil C. Sumer Site, Jenkinsville, South Carolina
Subject:
, Review of Operating Procedures Person Traveling:
M. S. Medeiros, Jr., Office of Nuclear Regulatory Research Persons X. W. Woodward, Supervisor of Operations, South Carolina Visited: -
Electric and Gas Company, Jenkinsville, South Carolina J. Skolds, NRC Resident Inspector, Sumer Site, Jenkinsville.
Purpose:
The purpose of this trip was to gain-first-hand knowledge of operating procedure preparation and use so as to better scope and direct Agency research in support of NRR's human factors research program for upgrading operating procedures.
Background:
After the Three Mile Island accident, the Nuclear Regulatory Comission published NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," to provide a comprehensive and integrated plan for all actions judged by the NRC to be necessary to correct or improve regula' tion and operation of nuclear facilities.
In particular NUREG-0660 action plan item I C.1 requires a short-term accident analysis and procedures revision program for emergency operating procedures, and action plan item I.C.9 re--
quires a long-term program for upgrading all operating procedures stating l
that "significant industry efforts will be required in the area of plant
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l procedures upgrading."
Activity reflecting action plan item I.C.1 is underway. For example, NUREG-0799, " Draft Criteria for Preparation of Emergency Operating Procedures",
published for public coment in June,1981, provides style and format guidance for preparing emergency operating procedures.
In parallel with NUREG-0799 activity, the Institute for Nuclear Power Operations (INPO) is writing more detailed style and format guidance, and the nuclear steam supply system (N5SS) vendors are writing technical quidelines to be used in conjunction with style and format guidance for preparing emergency operating procedures. However, at the present time, little activity is underway in connection with action plan item I.C.9 which addresses the large majority of a plant's operating procedures, the non-emergency operating procedures governing normal operation, maintenance,. testing, etc.
It was this area of non-emergency operating procedures that was-of primary interest during the trip.
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Sunmary The main observation made during the trip was that operating procedures are very crude from both a style-fomat-editorial standpoint and a technical J
standpoint. Procedure preparation and presentation are so inept that vague-ness, ambiguity, unintelligibility, and error-are coninon. As a result, these procedures appear to invite operator error.
Furthemore, the procedures are so poorly written that, without first per-fonning a major upgrading,, it appears the procedures would be as much a hindrance as a help in related work areas such as control room design review i
- and operator training. Although published management policies for procedure preparation, review, approval and use appear adequate, the actual products do not exhibit the results o'f management followup and attention to quality that must fann a basis for operating excellence.
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The observations made during this trip are particulacly disturbing because, even without a detailed knowledge of the plant's design and even without consulting system diagrams and descriptive text for thorough technical review, a significant number of deficiencies were evident to the reviewer. This suggest that an enormous amount of detailed technical and editorial direction, and upgrading must be accomplished before currently planned studies aimed toward procedure refinements and optimization have any p,ractical meaning.
Discussion Unless one can show that operating procedures are complied with to a high degree, one has little basis to claim that a plant is being operated safely.
A policy of compliance with procedures is an essential element of management which assures that a utility has the needed control of operations and is able to demonstrate it. Furthermore, operator attitude toward adherence to procedures reflects a utility management perspect e for safety of operations.
Current research activity in support of upgrading operating procedures is focused toward gathering sufficient information to draft a proposed regula-t l
tion and supporting regulatory guides having two aims. These aims are to assure that well-thought-out, step-by-step, approved and validated operating procedures exist in each operating plant, and that operating procedures are prepared so that specified evolutions can be perfonned in strict compliance with the procedures so as to prevent incidents that can lead to accidents.
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In addition, cost-benefit data based on quantifying reductions in operator error rate from use of the upgraded procedures, and based on risk assessment methods, will be developed to confinn the adequacy of these new regulatory requirements. However, to the extent that procedures reviewed during this trip are representative of procedures in use generally at operating plants, a considerable amount of ordinary technical writing must be accomplished before operating procedure improvement programs can profit from research.
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In view of the Agency emphasis on emergency operating procedures, Enclosures (1) and (,2) have been prepared to delineate examples of specific deficiencies found during in-plant review of two emergency operating procedures. Similar examples could be prepared from the in-plant review of non-emergency operating prccedures, which appeared to be even more in need of upgrading than the emergency operating procedures.
Enclosure (3), prepared from earlier work, provides a list of comonly observed deficiencies, many of which were evident during this review.
The following general observations were made during this trip:
The operating procedures are artless from both an editorial and a tech-nical standpoint.
. Sentence construction and punctuation shows little skill; sentence frag-ments compound the problem.
Abbreviations are used excessively and. inconsistently; capitalization is inconsistent.
Directions provided are often vague and ambiguous and sometimes un-intelligible.
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Procedure format is difficult to follow and does not permit rapid I
location of information.
Typical of the skill-less preparation is a glossary which attempts to guide the reader through the inordinate number of abbreviations but does this in a random order rather than in an alphabetical order.
There is little, if any, consistency in the meaning and use of "must",
"may not", "1hould", "must not", "shall* and "will".
Confusion abounds.
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corresponding Seemingly stringent elapsed time specifications have no time measuring requirements or specification tolerances.
A parameter was specified for observation in the control room that was not observable in the control room.
(deficiency, was being corrected.)
The operator is required to make calculations for which the input data is not available.
(deficiency was being corrected at time of this review)
Meaningless generalities such'as:
" care should be exercised", "if desired",
and "any significant change" are sprinkled throughout the procedures.
Within the same steps, different tenns (eg. card vs. tag and bumped vs.
started) are confusingly used to mean identical actions.
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random sequence (eg. 350 F,145 F, 200 F,160 F) instead of in the natural sequence of temperature change.
The word "will", meaning the result of an automatic system feature, is used interchangeably, and therefore confusingly, with "will", meaning the operator shall take action. The same deficiency exists with use of the word "should" and a similar inadequacy is evident in several instances where "should not exceed", is really meant to be "shall not be allowed to exceed", and "the maximum" is really meant to be "the maximum allowable".
The emergency operating procedures exhibit the same clumsy fonn and deficient content as the nonnal operating procedures.
i Enclosures (1) and (2) contain specific examples of the foregoing and
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other deficiencies observed during this trip.
Other:
The senior person contacted was J. W. Woodward, Supervisor of Operations, whc was apprised of the purpose and background of the trip and who was provided a detailed trip agenda prior to the start of procedure review.
M. S. Medeiros, Jr.
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Enclosures:
1.
Examples of Editorial and Technical Deficiencies (EOP-2) 2.
Examples of Editorial and Technical Deficiencies (EOP-5) 3.
Coninanly Observed Deficiencies in Operating Procedures cc:
J. Skolds, IE W. Kane, NRR V. Brownice, IE Reg. II K. Woodward, SCE&GC l
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.a Enclosure (1): Examples of Editorial and Technical Deficiencies Emergency Operating Procedu e E0P-2, Main Steam Line or Feedwater Line Break.
(Revision 1, Dated November 4,1980)
Editorial Deficiencies The first two pages of this emergency procedure have been devote [1 to the 1.
non-emergency matters of references, a glossary and a table of abbreviations.
2.
Section 2.1.8 makes little sense If sting the feedwater system as a reference.
3.
Section 2.2.1, which consists of a five-line phrase, is vague. Furthermore.
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the words "...line rupture - lower bounded by those signs...".make little sense.
4.
The procedure contains an inordinate' number of abbreviations especially in view of the ample blank space generally existing at the end of steps. Further-more, some abbreviations that are used in the text are not listed in the more-than-one-page list of abbreviations.
In related p'recedures, some abbreviations are listed in a manner different from that used in the text (e.g. SG vs. S/G). -
5.
There is little consistency.in the use of abbreviations and punctuations. For example, step 3.6 starts with "RB" while step 3.7 starts with " Reactor Build-ing"; step 4.7 uses both "S.I." and " Safety Injection".
6.
Writing is so cryptic an'd so artless that many readings of an ' emergency step are necessary to even guess at the step's meaning. For example, "... low / low-low level alarm"; "... signal low block heaters isolate letdowr. alarm";
"...from 2/3 steam headers..."; "...from 2/3 RCS loops..."; ".. 25% S/G level in the narrow range."; ".. 25% narrow range span.";
I 7.
There is little consistency in using phrases in lieu of using sentences to i
specify symptoms and actions.
8.
The caution note accompanying step 5.6 should preceed the step, not follow it.
9.
The confusing " arid /or" connective is used where "or" is meant, where "and" is j
meant, and where "or both" is meant.
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- 10. Unexplained blank lines appear throughout the procedure, apparently for signatures. No statement is made in the procedure as to what such signatures might mean in terms of actual perfordance, observation, or hearsay.
- 11. A note between steps 6.4 and 6.4.1 concludes "...this step may be omitted" but the note is ambigious as to which step it applies to.
- 12. Step 6.4.1.8 starts with the unintelligible phrase: " Place all EF isolation..." and ends with a cryptic table of letters and numbers. A clear, easy-to-understand command could be given with the same amount of text or less..
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- 13. Step 6.4.3 mixes two separate actions into one step. Furthemore, because
" controller" should be " controllers," it is not clear that the cryptic table following step 6.4.3 is related to step 6.4.3.
- 14. A typical, poorly written, clumsy step that should be rewritten in plan English is step 6.5.2 which states: " Place all EF isolation from the turbine driven pump tor S/G's and EF isolation from motor driven pump to S/G's valves (6 valves),
to the respective S/G, in the MANUAL position."
2
- 15. The incorrectly-punctuated, two-line, sentence fragment (with undefined abbreviation), which comprises step 6.7.3, is unintelligible, technically.
- 16. Many steps have multi-line redundant headings which generate confusion and add an unnecessary layer of numbering to an already cumbersome presentation.
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- 17. Extraneous punctuation and missing punctuation make many steps ambigious or change their meanings antirely. Steps 6.8.2A and 6.9 are examples of this deficiency.
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Technical Deficiencies i
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The energency procedure contains a cumbersome list of 18 symptoms which appear to be ranked in no particular order. For example, symptom 2-mentions changes in feed pump speed and condensate pump flow which may or may not be observable if the operator happened to be looking at these instruments. Furthermore, one parameter is specified in gallons per minute but the panel meter is calibrated in pounds per hour. The list should be pared down to a more meaningful and manageable number.
2.
The first immediate action step, step 5.1, starts: " Evaluate plant para-4
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meters..." which appears to be of little value since the parameters of interest are not. mentioned.
3.
Similarly, the third immediate actiom step, step 5.3, starts: "If time and conditions pennit it..." but gives no clue as to what other duties, defined by procedure, training, management, etc., may be so important as-to preclude compliance with this step.
4.
Step 5.4 requires the operator to proceed to E0P-5, the Reactor Trip procedure, but does not state whether or not the remainder of E0p-2 is to be ignored or whether E0P-2 and E0P-5 should be performed in parallel.
5.
Action required by step 6.4.2 was already required by immediate action step 5.5.
6.
Alarm tile engravings unjustifiably suffer from the same subiguities and excessive abbreviations that aflict the procedures (e.g. low / low-low level alarm).
7.
In step 6.6, if feed flow is unavailable,it appears that the referenced procedure should be implemented by itself, not concurrently with E0P-2 as stated.
8.
Step 6.7.1 appears to identify a design deficiency; automatic control should preceed and prevent an alann,not be triggered at the alarm point.
9.
In step 6.8.10, two of the three valves have an incorrect compcnent designation.
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Enclosure (2):
Examples.of Editorial and Technical Deficiencies Emergency Operating procedure E0P-5, Reactor Trio, (Revision 3. Dated October 22, 1981 Editorial Deficiencies 1.
The first page of this energency procedure has been almost canpletely devoted to the non-emergency matters of references ar.d a glossary of
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abbreviations.
2.
The first listing under automatic actions,
- Reactor trip". makes little
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sense since the energency procedure is entitled " Reactor Trip". A more-meaningful statement, such as "all ads drop into the core", should be
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made.
3.'
Action specified by step 5.1 is redundant to action specified by steps 5.1.1 and 5.1.4 and therefore only adds confusion and an unnecessary layer of numbering. Furthermore, the meaning of the "/" mark is undefined and unclear in this step.
4.
Step 5.1.1.A is vague since it is not clear how the operator is to deter-mine that the reactor is not tripped.
It appears the writer means, "If the rods have not inserted:",. A similar deficiency exists in step 5.1.1.A2).
5.
Step 5.2 is awkwardly written to make ambiguous the intent of.IF NOT" (i.e. if not verify? or if not running?).
6.
In step 6.7.1, "IF NOT RESET..." is really meant to be "IF NOT, RESET...".
7.
Step 6.8 should identify the motor of interest and step 6.11 shorid specify what infonnation whould be given to the load dispatcher.
8.
The note with step 6.19, " Test performed by I & C Technicans", contains no verb and therefore it is unclear whether the test "may be", "should be",
"shall be" or "must be" performed by the I & C technicians.
9.
The setpoint column of Attachment I contains numerous ambiguities (e.g. +
Penalties; progranned; 4/4; +5%/2 Sec; etc) which detract from the usefuT-ness of the table.
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3 Technical Deficiencies 1.
The " symptoms" section refers the operator to an attachment I for "any one of the 23 reactor trip first out annunciators". Attachment I lists 24 reactor. trips.not 23.
Furthermore, the attachment contain* a distract-ing column of setpoints which are of little use in an emergency and which, in many cases, have oeen written unintelligibly.
2.
The symptoms section fails to mention a rapid decrease in reactor power, or rod bottom lights being energized, as plant-specific parameters and events that are key symptoms of a reactor trip.
3.
The command " Emergency borate 17 minutes (approximately 100 PPM)..." makes little sense technically since a differential rather than an absolute value is meant.
- 4. 'The; recorder specified in step 5.1.3 is the same one specified in step 6.7, yet the component designations are different in the two steps; step 6.7 is in error.
5.
Step 5.1.4 should specify what indication the operator should use to verify that the turbine has tripped.
6.
Immediate action step 5.3 makes little technical sense when it requires the operator to: " Verify RCS temperature.....by operation of staan dumps."
7.
Similarly, the apparent run-on-sentence of imediate action step 5.4:
" Verify pressurizer level and pressure causence recovery from transient." makes little sense technically. Any pressurizer level and any pressurizer pressure would satisfy this command, and almost any action would meet the recovery statement, when, in fact, what is meant is that the operator should verify that pressurizer level and pressurizer pressure are returning to normal.
8'.
Step 5.4.A is of little additional help with its generalities: "If not recovering, evaluate conditions for safety injection symptoms.
If necessary, safety inject...".
Step 6.3.2 is similarly deficient.
9.
Section 5.5 contains no contingency step similar to the contingency steps in sections 5.1.1 and 5.1.4 in spite of the fact that the likelihood of need is simil.ar in all three sections.
- 10. Step 6.2, " Verify feedwater isolation at Tavg 564 F." is too cryptic to be understood consistently and is too restrictive to be performed reliably.
The step should state clearly what automatic operations are to be observed, whatmanualacgionistobetaken,andwithwhatdegreeofprecision,(i.e.not at exactly 564 F) recognizing that a busy operator must tend multiple duties.
- 11. Similarly, step 6.3, " Verify Tavg a0 or approaching no-load.alue of 557 F.",
is technically unintelligible. What does the comand mean? Whatistge operator supposed to do? Why does it need to be done precisely at 557 F?
- 12. Step 6.3.1 starts: "If cooldown rate is uncontrolled..." but gives the operator no criteria or guidance to recognize this condition.
If the inten-tion is to prevent a restart accident in the event automatic steam dumping takes reactor temperature below a certain value, this fact should be stated rather than rely on the operator to guess.
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- 13. Step 6.4.2.A cannot be perfomed with the infomation given since the panel meter is not calibrated in psig. Either a meter value, an equation or a calibration chart reference should be provided if the panel meter design I
cannot be improved to obviate the need for these crutches.
- 14. Step 6.14 action should be based on direction by the senior reactor operator rather than on the desires of the operator.
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I Enclosure (3): Connonly Observed Deficiencies in Operating Procedures I
Commonly observed deficiencies in operating procedures are the following:
L too general; insufficient "what" and how" information is provided to provide meaningful aid.
1 2.
too verbose and cumbersome; narrative style is used in lieu of simple step-by-step format.
3.
too detailed; the procedure ties the operator in knots and generates excessive number of changes.
4.
incomplete technically.
5.
incorrect technically..
6.
steps are sequenced improperly.
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known, uncorrected errors exist---a reflection of poor management-8.
Informal, handwritten changes exist in the text.
9.
poor format; difficult to follow.
- 10. all"likely symptoms not identified.
- 11. does not state what to do if equipment is initially operating outside of the range specified in the procedure.
- 12. does not warn of likely conditions that could occur and should be avoided during procedure performance.
- 13. control actions seldom indicate the correct system response.
14.
insufficient provision of contingency steps.
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explanation embedded in instructional steps.
16.
instructions embedded in explanatory notes.
- 17. cautions not placed ahead of action steps and in bold type.
18.
specific control positions and indicator values not specified.
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- 19. procedure nomenclatura does not agree with equipment labels.
20.
acceptance criteria and tolerances ambiguous.
21.
no verification checks and signatures required.
- 22. too many abtireviations.
23.
text not written at low enough grada level; should be approximately grade S.
24.
immediate action steps are primarily for economics rather than safety.
25.
too many immediate action steps.
26.
immediate action steps are too verbose.
27.
too many actions specified per step.
28.
too much referencing to other phscadures.
- 29. poor readability of charts, graphs and figures.
- 30. work sheets are not provided or are inadequate.
- 31. apply to more than one unit at a site.
- 32. used for guidance only; no strict complianew.
- 33. the procedures have not been validated by actual performance or walk through before being adopted.
- 34. the procedures contain editorial deficiencies concerning items such as titling, page identification and typing.
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OPERATING PROCEDURES THINKING PAPER HAPOSE: This paper discusses the operating procedure portion of nuclear plant operating excellence; lists some attributas of a procerly designed operating
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procedures program, and identifies areas where action should be taken to expeditiously bring utility practice into line with a prcperly designed program.
SACKGROUNO: Since the Three Mile Island accident, several laboratory prepared /
contractor prepared reports have been published advising the agency of action that should be taken to upgrade operating quality. The value of this advice spans a broad range particularly in the operating procedures area. Perhaps the most useful of the operating procedure-related reports---useful because it shows a working familiarity with the relationships among operators, procedures, equipment, training, operational data gathering and management--is NUREG/CR-1970, " Development of a Checklist for Evaluating Emergency Procedures Used in Nuclear Power Plants," published in May 1981. This report is based on proce-dures from and visits to four operating plants and a simulator and summarizes operator performance with regard to the use of operating procedures. Other useful background information is contained in TEC Report R-81-004 " Analysis of the Operator's Role Ouring the Onset of an Emergency"; NUREG/CR-1999 " Human Engineering Guidelines for use in Preparing Emergency Operating Procedures for Nuclear Power Plants"; and NUREG/CR-1977 " Guidelines for Preparing Emergency Procedures for Nuclear Power Plants."
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DISCUSSION Ooeratino Procedure Tyoes Non-administrative-type operating procedures generally fall into one of the-1
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fo1 Towing four categories:
L emergency operating procedures 2.
alarm responsa procedures 3.
routine operating procedures 4.
saintenance and test procedures
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To date, upgrading efforts have been applied almost exclusively to the first category, emergency operating procedures.
Little effective work is being done in the other three areas, seemingly because the emergency operating procedures are considered the most seriously deficient; the belief that the most important procedures from a regulatory view are those that aid the operator in responding to a plant casualty (akin to the agency's degraded-cooling /new-design-basis focus on risk reduction by attigation of t.ccident consequences rather.than by accident prevention); and the judgement that upgrading routine operating proce-dures and maintenance procedures is an enormous task beyond the agency's current resource capability.
Without debating which procedures are the most important and therefore which should receive first attention, it is clear that the work being done for emergency operating procedures, as described in the various NUREG's, has applicability to the other types of operating procedures, including main-tenance procedures. For example, NUREG/CR-1970, provides a checkli.*t for
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evaluating emergency procedures used in nuclear power plants.
Persons experienced in preparation, review, approval, use and revision of nuclear power plant procedures will recognize many features of the NUREG/CR-19N checklist as applicable ta normal operating procedures and maintenance procedures as well. Using this common basis, we should be able to outline a model prograa
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of operating procedures; compare current NRC requirements and current utility practice to this model operating procedure program; and identify action
~ necessary to upgrade the entire operating procedure program to the necessary level.
Current Industry Practice Current industry practice varies from a policy of operating in strict literal compliance with procedures to a policy of operating with emergency procedures having known and uncorrec*.ed errors.
In some places, emergency procedures are viewed as not particularly relevant to coping with an emergency; the contents are regarded as unlikely to reflect the actual emergencies that are experienced and the procedures are used as guidelines only.
In other places, the policy of strict literal compliance is reported to be enforced for maintenance procedures as well as for operating procedures, even to the point of stopping maintenance to process a procedure change when an error is found.
Until procedures and actual practicis at each operating plant are examined in detail, the full extent of operating procedure deficiencies can not be deter-ained. However, sufficient information exists to supcort the need for a general upgrading of industrf practice and NRC requirements in this area. In this connection, the Scinto Task Force, which was established to determine whether O
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there was a sufficient regulatory base for the TMI Action Plan, recommended rulemaking for items related to procedures since these items have only a tenuous connection to existing regulations.
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3 Table 1 contains examples of deficiencies in currently used operating procedures.
Curfsnt NRC Activity As mentioned previously, current NRC activity in the operating procedure area is focused on emergency operating procedures.
Little effective upgrading activity j
is undenvay for alarm response procedures, routine operating procedures, or maintenance and test procedures even though TMI-2 Action Plan item I.C.9, Long Term Program for Upgrading of Procedures, is applicable to all these areas.
The emergency operating procedures work is attempting, in six steps, to replace as many as 50 event-oriented procadures now existing in some plants with approximately 10 symptom-oriented emergency operating procedures. The six steps are as follows:
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Step 1:
NUREG-0799, Criteria for Preparing Emergency Operating Procedures (tensed " guidelines"), has been prepared by NRR and contains primarily administrative and editorial guidelines to identify "...the elements necessary to prepare and. implement a program of emergency cperating procedures." Some parallel writing guide-type (format) work is being performed by INPO.
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In parallel with NUREG-0799 preparation, the four nuclear steam system suppliers (NSSS), General Electric, Westinghouse, combustion Engi-nearing and Babcock and Wilcox,. are preparing four more detailed E !
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technical guidelines, one for each reactor plant design. These guide-
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lines:will receive a NRR technica review in the areas of systems, i
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safety analysis and human factors.
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Using the appifcable NSSS guidelines, some utilities may prepare Step 3:
plant-specific guidelines tailored to the parameters and equipment of specific plants. AnysuchguidelinessiilbereviewedbyNRRhuman factors personnel.
Step 4:
Using NSSS guidelines or plant-specific guidelines, or both, and NUREG-0799, individual emergency operating procedures will be prepared for each plant. Although NRR approval cf the individual procedures is neither specified nor planned, some NRR review will take place in l
the course of review of an applicant's program.
l Step 5:
Utilities will verify the adequacy of individual procedures by per-formance, by walk-through, or by both, as appropriate.
IE may assist the utility, informally, as part of IE's normal observance of plant
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activities, and NRR say observe selected verifications for feedback to the procedure upgrading program and to the control room review program.
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6 Step 6:
The procedures will be issued for use and will then become subject to formal IE scrutiny, on an audit basis, using detailed checklists being developed by IE.
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7-From the foregoing, several observations can be made. For example, there is no specific requirement for NRC approval of the final product, the emergency h.
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operating procedures.
Instead, the NRC will employ the weaker historic approach i
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of reviewing generic guidelines and auditing the final product. Similarly, there is no stated intention to strengthen the regulations to avoid the weak position of trying to enforce " guidelines." Also, unti.1 the final product can be viewed, it is not clear that an adequate set of symptom-oriented procedures will be or can be much different from an adequate set of event-oriented procedures.
Attributes of a Properly Designed Goeratino Procedures Program In addition to the detailed checklist of NUREG/CR-1970 and the more general guidance contained in various reference documents concerning what is meant by a good procedure (e.g. see page 4 of NUREG/CR-1995 " Applications of Functional Analysis to Nuclear Reactor Operations"), a properly designed operating procedure program sust be based on several other practical considerations which, for various reasons, do not appear in the NUREGs that discuss operating procedures. Some of these other practical and fundamental considerations are the following:
1.
Plants must be operated and maintained in accordance with writcen, approved procedures which have been formally issued and distributed for use.
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Strict compliance with approved procedures is absolutely essential for the safe operation of the plant.
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Personnel should not be allowed. to give direction, guidance, recommenda-
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tions or clarifications which conflict with approved procedures.
4.
The responsibility for following approved procedures as they are written rests with the supervisor directing the work or evolution and with the individual performing the wrk or evolution.
5.
Any deviation from apprcved procedures must receive prior approval from the cognizant technical auth'ority. This policy is vital to the continued safe operation of the plant. It forces proper technical engineering evaluation to be applied toward the solution of all problems.
It also ensures that decisions to deviate from existing standards are made by proper authority.
6.
The foregoing policy of compliance with procedures is an essential element of management which assures that the utility has the needed control of operations and is able to demonstrate it.
7.
Unless one can show that operating procedures are complied with to a high degree, one has little basis to claim that plants are being operated safely.
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If any lengthy routine task is performed without step-by-step reference to written procedures, errors of omission are very likely.
9.
If properly prepared maintenance procedures and nomat operating proce-f dures are followed strictly, many incidents are preventec before they can
. lead to accidents.
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- 10. For strict compliance with procedures to be practical, there must exist a stringent, fomal and speedy correction mechanisa to rectify errors, omis-sions, ambiguities and vagueness promptly when these problems are uncovered in procedure use.
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- 11. Operator attitude toward procedure adherence reflects a util,ity sanagement perspective for safety of cperations.
- 12. Although no amount of instruction can compensate for deficient design, some procedures must be written to recognize design deficiencies that may be impractical to correct (e.g. a pressurizer that lacks sufficient volume to compensate for system shrinkage after a scram thus requiring use of a protection system for normal. operation).
- 13. Just as no amount of instruction can compensate for deficient design, a procedures upgrading program is meaningless 'f we do not concurrently raise the level of operator understanding of his plant, since procedures can not be written for every eventuality.
For safe operations, we must 9
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depend upon the operator to use his education and training to recognize when a procedure is not applicable, or is wrong for the evolution at iland.
1 See the short article " Operational Excellence: One Facet", Attachment
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- (1), for sort detailed discussion of this point as it relates to emer--
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~i gency operating procedures.
14~.' "Th'ere are no quick solutions or shortcuts to operating excellence, only
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~ painstaking, thorough, often inundane attention to detail. Intaresting and seemingly pertinent scientific studies by contractors not familiar with nuclear power pitnts should not be allowed ~to beccme distractions that waste rescurcas needed to upgrade today's primitive operating pro-
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cedures. The lure of producing scientific cost-benefit models for refined a
choices has little place in correcting a basi.cally managemen,t/ engineering deficiency where there are no choices to be made between upgrading groce-dures, upgrading operator training, and upgrading maintenance information--
they all sust be developed under tight formal control to improve quality.
- 15. Similarly, a one-time upgrading will have no lasting results. There must follow continual management reinforcement of operating excellence and con-tinual NRC auditing of utility management comeitsent to operating excel-1ence. Technical management in terms of generic " solutions" viewed com-plate when such " solutions" have been promulgated will not work.
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- 16. Based on review of the work to date of outside organizations, the agency can not depend upon outside organizations to set a standard of operating procedure excellence for the utilities; we must do it ourselves.
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- 17. In applying the foregoing considerations, one must recognize that operating i
excellence is the responsiblity of the utilities, not the Government, but f
that there is little reason to believe the utilities will accept the costs associated with operating excellence without tough regulatory requirements
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or without a demonstration that the benefits will outweigh the costs.
Procosed Action plan for Timely Mich-Quality Operatino Procedures 1.
As a necessary prerequisitt to a meaningful procedure upgrading program, obtain general agreement in the NRC on the following essential features:
(a) Well-thought-out, step-by-step, approved and validated operating pro-cadures (i.e., procedures for emergencies, abnormalities, normal operation, and maintenance) shall exist in each cperating plant.
(b) Operating procedures shall be prepared so that specified evolutions
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can be performed in strict compliance with the procedures.
l (c) Since adherence to normal operating and maintenance procedures pre-vents incidents that can lead to accidents, spgrading of normai e
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.e 11 operating and maintenance procedures should proceed in timely fashian in parallel with ongoing emergency operating procedure upgrading.
(d) The NRC aust. advance from the traditional guideline and audit type y
of regulatory approactt to more active, direct involvement with operating procedures including pubitcation of stringent regulations requiring high quality procedures and NRC review and approval of such procedures.
2.
Agree upon reasonable limits for a detailed NRC~ review and approval pro-gram. There is need for considerable imagination and flexibility in setting up and conducting a procedures review and approval program in view of the enormity of the task, resulting from the lack of standardization that has been allowed in power plant design and operation and the dearth of agency personnel experienced in conducting detailed procedure reviews.
Furthemore, some plants have thousands of operating procedures. There-fare, detailed and complete review and approval will be practical only for a small portion, of the total number of plant procedures-perhaps the emergency operating procedures (and the abnormal operating procedures where these are separate), the major normal operating procedures, and selected important maintenance procedures and alars response procedures.
Regulatory activity with regartt to the remainder of the operating pro-cedures would continue to center around the traditional guideline and audit approach.
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12 3.
From the numerous NUREGs that have been issued in the past year concerning operating procedures, assemble in the fors of a Regulatory Guide, a com-posite list. of necessary procedure attributes considered acceptable to
.J the staff and base preifsinary upgrading on this list.
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With NRC management committed to the foregoing realistic and practical
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path to operating procedure excellence, conduct a scoping study to identify the resources that will be nee.ed to upgrade operating procedures at all plants.
Resource estimates for this very costly program will be needed not to choose whether to conduct the program or not, because there is no choice if operating excellence is the goal, but rather to more properly and completely package and defend an adequate program. Also, the scoping study should address features of a follow-on pilot p' reject to review and approve a representative number of plan'ts' procedures; how a pilot program should be structured; and hcw pilot plants should be picked to demonstrate the necessity and practicality of more stringent control of procedures.
5.
Initiate-proposed rulemaking with the following objectives:
(a) Define our concern (b) Explain the problem to the public (c) Lay out a proposed solution (d) Provide the public and the regulated industry an opportunity to advise the NRC (e) Use the response to the proposed rule to shape a final regulation O
t 13 6.
Initiate a pilot program to demonstrate the necessity and practicality of a rigorous operating procedure program. The pilot program should:
(a) Se managed by a group that is experienced in reviewing and approving 3
procedures and cart demonstrate a practical understanding of operating excellence.
(b) Establish the composition of the minimum size technical group that can adequately review and approve operating procedures.
(c) Establish the time and cost to complete the review and approval of one plant's worth of-procedures, as defined in foregoing item 2.
7.
Based on the pilot study and a new regulation, commence a long ters (about five year) program of upgrading procedures, as defined in item 2, at all operating plants. Some considerations, in no particular order, might be:
(a) Attempt to understand the basis for each utility's historic manage-l ment policies with regard to operating procedures and use this infor-sation, in conjunction with management needs to tailor the program to individual sites.
(b) The final review and approval program may fit in well with the IE resident inspector program as a tool to do two jobs with little more work than that needed to do one. For example, at a site with a resident inspector greatly knowledgeable of plant systems, and e
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14 familiar with design documents, a one procedure-a week type of detailed review over a period of about five years could mostly cover a plant's worth of important procedures as defined in item 2.
(c) The program will probably evidence the need for more and better drawings, schematic diagrams, and technical manuals, especially for
~ :
understanding the systems and for maintenance.
(d) Research may be needed to optimize procedure improvements once correc-tion of known major deficiencies is underway. See Attachment (2) for a brief status of current user requests for operating procedure research.
(e) A new office, AE00, was born from eventually recognizing a similiar, but no more urgent, element of operating excellence, operational data gathering and analysis. Surely the element of stringent procedural control warrants a similarly independent organizational entity--an entity with independence of perspective as well as with independence from conf 1 feting priorities.
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Table 1 OPERATING PROCEDURES Soecific Deficiencies Needing Correction Commonly observed deficiencies in operating procedures are the following:
2 1.
too general; insufficient "what" and how" information is provided to provide meaningful aid.
i 2.
too verbose and cumbersome; narrative style is used in lieu of simple 7
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step-by-step format.
3.
too detailed; the procedure ties the operator in knots and generates excessive number of changes.
4.
incomplete technically.
5.
incorrect technically.
-o 6.
steps are sequenced improperly.
7.
known, uncorrected errors exist-a reflection of poor management.
1 8.
informal, handwritten changes exist in the text.
9.
poor format; difficult to follow.
L 10.' all likely symptoms not. identified. '
- 11. does not state what to do if equipment is initially operating outside of the range specified in the procedure.
- 12. does not warn of likely conditions that could occur and should be avoided l
during procedure performance.
13.'
control actions sel' dom indicate the correct system response.
14, insufficient provision of contingency steps.
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- 15. explanation embedded in instructional steps.
16.
instructions embedded in explanatory notes.
- 17. cautions not placed ahead of action steps and in bold type.
- 18. specific control positions and indicator values not'specified.
- 19. procedure nomenclature does not agree with equipment labels.
-j;
- 20. acceptance criteria and tolerances ambiguous.
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- 21. no verification checks and signatures required.
- 22. too many abbreviations.
- 23. text not written at low enough grade level; should be approximately grade 5.
24.
immediate action steps are primarily for economics rather than safety.
- 25. too many immediata action, steps.
- 26. immediate action steps are too vereose.
- 27. too many actions specified per step.
- 28. too much referencing to other procedures.
- 29. poor readability of charts, graphs and figures.
- 30. work sheets are not provided or are inadequate.
- 31. apply-to more than one unit at a site.
- 32. used for guidance only; no strict compliance.
- 33. the procedures have not been validated by actual performance or walk througtt before being adopted.
- 34. the procedures contain editorial deficiencies concerning i'ais sucn as
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titling, page identification and typing.
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OPERATING EXCELLENCE: ONc FACET various documents concerning operating excellence refer to a oractice of strict literal compliance with operating procedures. Critics almost always misunder-stand the practice and therefore misrepresent it; clearly there is need for better understanding of the practice. Accordingly, the following thoughts are offered as a basis for requiring strict literal cang11ance with procedures.
Safe reactor plant operation must be built on a foundation of preventing accidents from happening. This foundation has several cornerstones in-luding conservative 1
design, independent design veMfication, high cuality construction, thorough acceptance testing and comoetent coerstion. Lack of one or more of these corner-stones results in a low quality program. For example, unless independent engineering design review by technically competent personnel is the core of a technical agency's
~
business, the agency will not have the base needed to make the myriad of technical judgments necessary to assure that plants are being operated safety.
Competent operation has several facets including availability of detailed technical information, extensive and intensive operator training based on such detailed technical infonnation and aimed toward thorough understanding of plant operation, and rigorous adherence to carefully prepared, reviewed, and verified detailed operating procedures. Lack of one or more of these facets will result in poor operator perfannance and therefore a low quality program. For example,..
unless one can show that cperating procedures are complied with to a high degree, one has little basis to claim that plants are being opertted safely.
Strict literal compliance with procedures is part of an old-fashioned, connon sense policy, fed by expeMence, that when well-thought-out-and-prepared procedures are follcwed rigorously during plant testing, plant maintenance, and other routine plant operations, the the probabilities of abnonnalities and potential plant casualties are substantially reduced.
Implicit in such a program is the need to stop an operation, for fonnal correction of text, anytime that testing, maintenance, or other routine operating procedures are found vague, ambiguous, in error, or otherwise deficient. The operation is allowed to proceed only after appropriate changes are prtposed, reviewed, and approved for perfonnance. At first, this can be a very laborious, time-consuming process as verboseness, sloppiness, vagueness, ambiguity, errors, or omissions are replaced by step-by-step, clear, technically justified, procerly secuenced instruction. Furthermore, the process exacts a price for attention to technical detail, for monotonous and unglamorous engineering reviews, for midnight telephone calls, and the need for c. cadre of first class nuclear power plant engineers.
However, as mentioned earlier, this price must be paid anyhow if sound technical judgements are to be made in other matters affecting safety of coerating plants.
In addition, overall cost will diminish as a standard of ocerating excellence develops that is based on detailed understanding of plant operacion with atten-dant reduction in operator errors and operating incidents.
The program proposed must be based on a high level of coerator training since it is impossible to prepare detailed procedures for every accident secuence - -
no one can predict the course of accidents ahead of time. This is crecisely W
Attachment (1)
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why automatic computer control can be an imcediment to safety - - one cannot program a computer for all casualty and accident sequences in advance.
Instead, one must depend on highly knowledgeable ocerators to recognize when a casualty procedure no longer provides the detailed guidance for the situation at hand, and to use'their training, their ingenuity and intuition based on such training, and sound technical, judgment to handle the unthinkable, the unexpected, the accidental event that will inevitably occur in any complex system no matter how ingenious its design might be.
The operator and his excellence when compared to hardware is the final safety
^
assurance within the system, and the operator's adherence to detailed high quality procedures is one of his fundamental tools.
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Note: The foregoing is an editorial update of a January 8,1981 paper entitled
" Strict Literal Ccmpliance with Procedures, prepared as an enclosure to a February 2,1981 degraded cooling rulemaking memorandum.
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Status of Current User Recuests for Ocerating Procedure Research Pracosed Research Task 1: In coordination with DHFS, conduct a survey to identify tnose aspects related to plant procedures (other than emergency response
-q procedures) which are frequently deficient from a safety related standpoint and outline corrective actions needed.
Proposed Response: Recently published doc:ssents report the results of the work
- of several-contractors related to development of Emergency Operating Procedures.
These reports include NUREG/CR-1999, " Human Engineering Guldelines 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, "Develcpment of a Check 11st for Evaluating Emergency Procedures Used in Nuclear Power Plants." These reports are directly ar :icable to all plant procedures and thus provide the survey of deficiencies sad corrective action needed as proposed in Task 1.
'Prooosed Research Task 2: As indicated from Task 1. conduct supportive re-searen, witn involvemenc of human factors specialists, leading to the develop-ment of guidelines for upgrading ~of ncn-emergency plant procedures.
Proposed Resoonse: Response for Task 1 above is ap)licable here also. Guide-lines can ce prepared from infonnation already available.
Proposed Researctr Task 3: With initial emphasis on emergency response pro-cedures, but witn applications to procedures in general, explore.and test alter-nate ways of presenting prk edures to operators and other plant personnel to optimize comprehension and response. In particular, this should include studies related to computer based CRT displays.
Proposed Resoonse: In parallel with correcting the major fundamental operating procedura deficiencies with practical straightfonsard solutions, ongoing research, both domestic and foreign, will be monitored for infomation that might be used to optimize procedures once a fundamentally sound procedures program has been put in place.
Proposed Research Task 4: An effort is underway to provide guidelines for improving p.ocedures. At this point little data is available to validate the effects j
of the required changes on crew perfemance'or to judge the' potential eff~ects of various ways of presenting procedures. Such data are needed to evaluate future changes. Research is needed to develop methodologies for d.etennini.ng the effectiveness of changes that have been or may be made to olant procedures.
A series of simulator tests to ascertain the effects on crew perfomance of s
various changes in procedures femat should be conducted. -
1 Attachment (2)
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._.. j 2-Procosed Response: Similar to response 3, major fundamental operating proca-cure deficiencies must be corrected before a research program for " fine tuning" has meaning. Therefore, action on this item should commence once a fundamentally sound procedures program has been put in place.
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