ML20084G959

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Emergency Offnormal Procedures Verification & Validation Program
ML20084G959
Person / Time
Site: Clinton Constellation icon.png
Issue date: 04/26/1984
From: Hall D, Kant E
ILLINOIS POWER CO.
To:
Shared Package
ML20084G928 List:
References
PROC-840426, NUDOCS 8405070405
Download: ML20084G959 (27)
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CLINTON POWER STATION EMERGENCY OFFNORlfAL PROCEDURES VERIFICATION AND VALIDATION PROGRAM  ;

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Recommend Approval M9N V wdr PL it M nager ' '

O Date Recommend Approval j/ [

Manager uclear Station Engineering Dept. ( Dpte Approval J( //

Vice President '

D'a ts 1

i 8405070405 840501

! PDR ADOCK 05000461 F PDR L. j

TABLE OF CONTENTS l

I. Introduction  ;

II. Document Approval III. Personnel Designation IV. Verification A. Introduction B. Preparation

1. Personnel Designation
2. Emergency Offnormal Procedure (EOP) Source Documents C. Assessment
1. Table-Top Review
2. Control Room Walkthrough
3. Plant-Specific Calculations D. Resolution E. Documentation
1. Table-Top Review
2. Control Room Walkthrough
3. Plant-Specific Calculations V. Validation A. Introduction B. Preparation
1. Personnel Designation
2. Source Documents C. Validation Methods
1. Table-Top
a. Preparation
b. Assessment / Resolution
c. Documentation
2. Control Room Walkthrough
a. Preparation
b. Assessment
c. Resolution
d. Documentation
3. Simulator
a. Preparation
b. Assessment
c. Resolution
d. Documentation VI. Verification & Validation of Subsequent E0P Revisions A. Review of Source Documents Revisions B. Verification & Validation C. E0P Control Page 2 of 27

TABLE OF CONTENTS (Continued)

VII. Summary VIII. References : Verification Wor'* Sheets - : Evaluation Criteria Checklist : Discrepancy Sheet - Verification : Observation Guide : Debriefing Guide : Plant-Specific Calculation Verification Worksheet : CPS Control _ Room Walkthrough Checklist : CPS Simulator Checklist : EOP/ Emergency _ Procedure Guidelines (EPGs) Correspondence to Control Room / Plant Equipment E Page 3 of? 27' s

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1. Introduction This document shall be included as an element of the Procedures Generation Package, required by section 7.2b of Supplement 1 of NUREG-0737, " Requirements for Emergency Response Capability".

The Clinton Power Station (CPS) Plant Specific Emergency Procedure Guidelines (EPGs) and Emergency Offnormal Procedures (EOPs) are written to revision 3J of the generic Boiling Water

Reactor Owners' Group (BWROG) guidelines. It is the intent of t

this plan to critically review how effectively the guidelines have been implemented through a verification and validation process. This process shall identify procedural / human factors deficiencies, initiate resolution of those deficiencies, and provide auditable documentation of this review.

Verification of the EOPs shall provide due evidence that they i are correctly written and are technically accurate, while validation shall prove them useable and operationally correct.

NOTE All CPS EOPs shall be verified / validated by this program plan.

II. Document Approval All revisions of the Emergency Offnormal Procedures (EOP)

Verification and Validation (V&V) Program shall be a complete-reissue bearing a new title page. Each revision shall be reviewed by the Power Plant Manager and the Manager - Nuclear Station Engineering Department and approved by the Vice

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President.

III. Personnel Designation The V&V shall be performed by a consultant which has experience in performing E0P V&V.

! As many -Plant Operations personnel as possible shall be involved in both verification and validation. Their participation shall be coordinated by the Supervisor - Plant Operations.

NOTE The E0P V&V shall be. performed by people not involved in writing l the CPS EOPs.

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IV. Verification A. Introduction E0P verification evaluates the written correctness of the procedure and ensures that applicable generic and plant-specific technical information has been incorporated.

The E0P Writer's Guide should be reviewed to ensure that human factors are considered in writing the E0Ps.

The verification program is based on the INPO document, Emergency Operating Procedures Verification Guideline (INPO 83-044), developed by the Emergency Operating Procedures Implementation Assistance (EOPIA) Review Group.

B. Preparation d

1. Personnel Designation The consultant shall provide the necessary personnel as evaluators to conduct the comparative evaluation.
2. E0P Source Documents i

The listing of E0P source documents is provided on Form

  1. 1 of the EOP verification forms and shall be reviewed by personnel conducting the assessment phase. These documents shall be reviewed to ensure they are complete, current, and applicable. (See VI. A. - Review of Source-Documents Revisions.) Any additional source documents used shall be listed.

C. Assessment

1. Table-Top Review In the table-top review, the evaluator (s) shall:
a. Make a general review of the EOP using_the procedure-specific portion of the evaluation criteria (Attachment 2) and source documents.
b. Indicate on Form #1 of the E0P Verification Forms (Attachment 1) that the evaluation was_ performed, either by checking the acceptable column or by designating the appropriate discrepancy sheet for-any discrepancies identified.

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c. Make a step-by-step review of the E0P using the step, caution, note-specific portion of the evaluation criteria (Attachment 2) and source documents.
d. Indicate for each step on Form #2 of the EOP Verification Forms (Attachment 1) that the comparative evaluation was performed either by checking the acceptable column or by designating the appropriate discrepancy sheet for any discrepancies identified.
e. Upon completion of Form f3 of the EOP verification forms (Attachment 1), all verification forms including discrepancy sheets should be collected by the consultant.
2. Control Room Walkthrough In the walkthrough phase, the evaluator (s) shall:
a. Verify that the instrumentation required by postulated plant accidents is identified in the E0Ps and is available in the main control room.
b. Check to ensure that the instrumentation in the main control room meets the range and accuracy of the instrumentation required to carry out the EOPs.
3. Plant-Specific Calculations Evaluators shall review calculations of plant-specific parameters.

D. Resolution Independent of the type of verification performed, the evaluators shall:

1. Review all other evaluators' comments and resolve any conflicts between the E0P writer's and evaluators' comments. In the event of a disagreement, forward the identified concern to the Supervisor - Technical for review and comment.
2. Forward recommended solutions to Supervisor - Technical,

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Supervisor - Plant Operations, Assistant Power Plant Manager - Operations, and the Power Plant Manager for review and comment.

3. Have responsible department revise applicable documents and procedures with approved resolutions as directed by the Supervisor - Technical or justify why no revision is -

required.

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E. Documentation

1. Documentation of the table-top review shall consist of Forms 1-3 (Attachment 1) and all discrepancy sheets (Attachment 3).
2. Documentation of the control room walkthrough shall consist of the completed E0P/EPG Correspondence to Control Room / Plant Equipment Sheets (Attachment 9).
3. Documentation of the review of plant-specific calculations shall consist of completed CPS Plant Specific Parameter Calculation Worksheets (Attachment 6).

V. Validation A. Introduction E0P validation is the evaluation performed to determine that the actions specified in the procedure can be performed by the operator to effectively manage the emergency conditions.

The E0P validation will evaluate the operational correctness and useability provided by each E0P.

The validation program is based on the INPO document, Emergency Operating Procedures Validation Guidelines (INPO 83-006), developed by the EOPIA Review Group.

B. Preparation

1. Personnel Designation The consultant shall provide the personnel necessary to conduct the comparative evaluation.
2. Source Documents The following shall constitute a minimum list of source documents:
a. Generic EPGs, Rev. 3J
b. CPS FSAR
c. SERs, SOERs
d. INPO Guidance Documents (see section VIII -

References) l Page 7 of 27-

C. Validation Methods Some combination of the following methods shall be employed by Illinois Power Company to validate all CPS E0Ps.

1. Table-Top Review
a. Preparation Arrangements shall be made prior to the review to have the required EOPs, specifications, related technical documentation, SERs and SOERs available along with a room equipped with adequate surface area to lay out E0Ps and related documentation. A blackboard, an overhead, transparencies, and pens should also be available.
b. Assessment / Resolution *
1. Assessment In this method, personnel explain and/or discuss procedure action steps in response to a proposed scenario or as part of an actual industry operating experience review. Evaluators should use the observation guide (Attachment 4) for.

evaluation criteria.

2. Resolution
  • Recommended resolutions shall be produced in the same session and forwarded to Supervisor -

Technical for review and approval. Upon approval, cognizant department (s) shall revise applicable source documents and' procedures, as directed by the Supervisor - Technical.

c. Documentation Documentation of the table-top validation effort-shall be achieved by a summary memo or letter from the consultant to all cognizant departments.
2. Control Room Walkthrough
a. Preparation Arrangements shall be made to have access to the main control room for the walkthrough. To. minimize-impact on normal operations and to more easily involve all rotating shifts, it is recommended that the walkthrough be accomplished in stages. To help maintain continuity in the overall validation, each stage _should' include one scenario.

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b. Assessment In this method, control room operators shall conduct a step-by-step enactment of their actions during a proposed scenario for the evaluators without carrying out actual control functions. Evaluators should use the observation guide (Attachment 4) for evaluation criteria during the review. Evaluators shall note operator errors on the Control Room Walkthrough Checklist (Attachment 7).
c. Resolution The evaluators shall:
1. Review all other evaluators' checklists / comments and resolve any conflicts between the writer's and evaluators' comments. In the event of a disagreement, forward identified concern to Supervisor - Technical for review and comment.
2. Forward recommended solutions to the Supervisor

- Technical for review and comment.

3. Have responsible department revise applicable source documents and procedures with approved resolutions as directed by the Supervisor -

Technical or justify why no revision is necessary.

d. Documentation Evaluators shall use the debriefing guide (Attachment 5) in interviewing the operators following each scenario. All aroblems or concerns identified during assessment should be documented on CPS Control Room Walkthrough Checklist (Attachment 7).
3. Simulator
a. Preparation Arrangements shall be made to have access to the CPS simulator and sufficient classroom space for support purposes.

Selection of appropriate transients and subsequent scenario development shall be completed by the consultant prior to commencement of this phase of the validation. Multiple failures, both simultaneous and sequential, shall be addressed.

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b. Assessment In this method, control room operators shall perform actual control functions on simulated equipment, during a proposed scenario for evaluators.

Evaluators shall note operator errors on the CPS Simulator Checklist (Attachment 8).

c. Resolution Evaluators shall:
1. Review all other evaluators' checklists / comments and resolve any conflicts between the writer's and evaluators' comments. In the event of a disagreement, forward identified concern to Supervisor - Technical for review and comment.
2. Forward the recommended solutions to the Supervisor - Technical for review and comment.
3. Have responsible department revise applicable source documents and procedures with approved resolutions as directed by the Supervisor -

Technical.

d. Documentation Evaluators shall use the debriefing guide (Attachment 5) to interview operators following each scenario. All problems / concerns identified shall be documented on CPS Simulator Checklists (Attachment 8).

VI. Verification / Validation of Subsequent E0P Revisions A. Review of Source Document Revisions All revisions to E0P source documents shall be reviewed for impact on the E0Ps.

B. Verification / Validation All revisions to E0Ps shall be verified and validated according to this plan. The scope of the V&V performed shall be continge upon the type of changes.

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C. EOP Control All EOPs shall be distributed in accordance with CPS Procedure 1005.04, Distribution and Control of Station Procedures and Revisions.

VII. Summary Upon completion of the V&V effort, Illinois Power Company shall have a high level of assurance that the content of the E0Ps is sufficient, (i.e., that the E0Ps are technically accurate, correctly written, useable, and operationally correct.) .

VIII. References A. EOP Writing Guideline, INP0 82-017, dated July 1982 B. E0P Verification Guideline, INPO 83-004, dated March 1983 C. E0P Validation Guideline, INPO 83-006, dated April 5, 1983 D. E0P Implementation Guideline, INPO 82-016, Rev. 1, dated i July 1983 E. E0P Procedures Generation Package Guideline, INPO 83-007, dated February 1983 a

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ATTACHMENT 1 E0P VERIFICATION FORM #1 Page of.

E0P TITLE:

CPS NUMBER: REVISION:

SCOPE OF VERIFICATION:

EOP SOURCE DOCUMENTS USED:

1. EPGs, Rev. 3J
2. CPS FSAR 3.

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5.

6.

6.

EVALUATOR (S):

PROCEDURE-GENERAL VERIFICATION

1. WRITTEN CORRECTNESS AREAS ACCEPTABLE DISCREPANCY SHEET f(s)

LEGIBILITY E0P FORMAT CONSISTENCY IDENTIFICATION INFORMATION _

2. TECHNICAL ACCURACY -

AREAS ACCEPTABLE DISCREPANCY SHEET f(s)

ADDRESSED IN FORM #2 AS PART OF STEP, CAUTION, NOTE-SPECIFIC '

VERIFICATION.  ;

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ATTACHMENT 1 l E0P VERIFICATION '

FORM #2

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STEP, CAUTION, NOTE-SPECIFIC VERIFICATION i

STEP NUMBER, WRITTEN CORRECTNESS TECHNICAL ACCURACY l CAUTION, OR ACCEPTABLE DISCREPANCY ACCEPTABLE DISCREPANCY NOTE SHEET f SHEET f 4 i i

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ATTACHMENT 1 E0P VERIFICATION FORM i3 E0P Rev.

Page of Verification Completion Date:

Performed by:

Reviewed by:

All actions required by the verification have been completed and approved.

Date Consultant l

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ATTACHMENT 2

1. PROCEDURE-GENERAL A. Written Correctness
1. Legibility Are the text, tables, graphs, and figures legible to the evaluator?
2. EOP Format Consistency
a. Do the following sections exist in each EOP:

Section 1.0 - SYMPTOMS Section 2.0 - AUTOMATIC ACTIONS Section 3.0 - OPERATOR ACTIONS Section 4.0 - CONTINGENCIES Section 5.0 - FINAL CONDITIONS Section 6.0 - DISCUSSION

b. Is the page layout consistent with the' sample page format given in FSAR Table 13.5-7 Emergency Offnormal Procedure Format?
3. Identification Information
a. Is the procedure title descriptive of the purpose of the procedure?
b. Does the cover sheet correctly provide the following:
1. procedure title
2. procedure number
3. revision number'
4. number of pages
c. Does each page correctly provide the following:
1. procedure designator
2. revision number
3. Page of numbers-d.

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Does the procedure have all:its.pages_.in the correct order?

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II. STEP, CAUTION, NOTE-SPECIFIC A. Written Correctness

1. Information Presentation
a. Are instruction steps numbered correctly?
b. Are instruction steps constructed to comply with the following:
1. Steps deal with only one idea.
2. Sentences are short and simple.
3. Operator actions are specifically stated.
4. Objects of operator actions are specifically stated.
5. Objects of operator actions are adequately i stated.

l 6. If there are three or more objects, they are l listed (and space is provided for operator check-off).

7. Punctuation and capitalization-are proper.
8. Abbreviations are correct and understandable to the operator.
c. Do instruction steps make proper use of logic structure?

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

c. Are cautions used appropriately?
f. Are cautions _placed properly?
g. Are cautions constructed to comply with the following: l
1. They do not contain operator actions.
2. They do not use extensive punctuation for clarification.
3. They make proper use of emphasis.
h. Are notes properly used?
1. Are notes properly placed?
j. Are notes worded so that they do not'centain.

operator actions?

k. Are numerical values-properly written?

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1. Are values specified in such a way that mathematical operations are not required of the user?
m. Is a table or graph provided in the procedure for necessary operator calculations?
n. Are units of measurement in the E0P the same as those used on equipment.
2. Procedure Referencing and Branching
a. Do the refere.nced and branched procedures identified in the E0Ps exist for operator use?
b. Is the use of referencing minimized?
c. Are referencing and branching instructions correctly worded?
1. "go to" (branching)
2. " refer to" (referencing)
d. Do the instructions avoid routing users past important information such as cautions preceding steps?
e. Are the exit conditions compatible with the entry conditions of the referenced or branched procedure?

B. Technical Accuracy

1. Entry Conditions or Symptoms Information
a. Are the entry conditions of the EPG listed correctly?
b. If additional entry conditions have been added, do they comply with the following:

' 1. appropriate entry conditions for which'the E0P should be used

2. not-excessive
2. Instructional Step, Caution, and Note Information
a. Are E0P/EPG differences:

-1. documented

2. explained i

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b. Is the EPG technical foundation (strategy). changed.

. by the following changes in.EOP steps,-cautions, or notes:

! 1. elimination

2. addition
3. sequence i 4. alteration
c. Are correct, plant-specific adaptations incorporated per EPG
1. systems
2. instrumentation

, 3. limits

5. controls
5. indications-
d. Have licensing commitments applicable to E0Ps been addressed?

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e. Are differences between the licensing commitments and the E0Ps or EPGs documented?

l j 3. Quantitative Information l a .- Do the quantitative values,. including tolerance bands, used in the EOF comply with applicable E0P source document?

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b. Where EPG values are not usedlin the EOP, are the-

, E0P values computed accurately?

! c. When calculations are -required by the EOP, ~ are

equations presented with sufficient information for j operator use?
4. Plant Hardware Information
a. Is the following plant hardware specified in'the E0P

[ available for operator use:

1. equipment

-2. controls-

3. indicators '
4. -instrumentation lPage 18' of '27

ATTACHMENT 3 EOP DISCREPANCY FORM EOP: REV.: STEP NUMBER: _

DISCREPANCY:

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RESOLUTION:

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SUPERVISOR - TECHNICAL: DATE:

APPROVED: YES NO (circle one)

RESOLUTION INCORPORATED BY: DATE:

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ATTACHMENT 4 OBSERVATION GUIDE I. USEABILITY A. LEVEL OF DETAIL

1. Did the operator appear to have sufficient information to perform the specified actions at each stop?
2. Did the operator seem uncertain at any decision point?
3. Was the operator able to find needed equipment with the labels, abbreviations, symbols, and location information provided him in the E0Ps?
4. Was the operator able to manage the emergency condition with the information provided him?
5. Were the operator's contingency actions sufficient to address the symptoms?
6. Was the operator able to find referenced and branched procedures?

B. UNDERSTANDABILITY

1. Did the operator appear to have problems with any of the following?
a. reading the E0P
b. reading figures and tables
c. determining values on figures and graphs
d. complying with EOP step
e. complying with caution and note statements
f. understanding the organization of the E0Ps II. OPERATIONAL CORRECTNESS A. PLANT COMPATIBILITY l 1. Were the actions specified in the E0Ps able to be l performed in the designated sequence?
2. Were alternate success paths found which were not

-included in the E0Ps?

3. Was the operator able to obtain the necessary information from plant instrumentation as specified in the procedure?

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4. Did the plant symptoms provide adequate information for the operator to select the applicable E0P?
5. Were the E0P entry conditions appropriate for the plant symptoms seen by the operator?
6. Did the operator have to use information or equipment not specified in the E0Ps to accomplish his task?
7. Did the plant responses agree with the E0P basis?
8. Were the instrument readings and tolerances consistent with the instrument values stated in the E0P?
9. Were the EOPs physically compatible with the work situation (too bulky to hold, binding wouldn't allow them to lay flat on the work space, no place to lay the E0Ps down to use)?

B. OPERATOR COMPATIBILITY

1. If time intervals were specified, were the procedure action steps able to be performed on the plant within or at the designated time intervals?
2. Could the procedure action steps be performed by the operating shift?
3. If specific actions were assigned to individual shift

, personnel, did the E0Ps appear to help coordinate the l

actions where necessary?

4. Was the operating shift able to follow the designated action step sequences?
5. Was the operator able to do the following?

I a. find the particular step or set of steps when required

b. return to the procedure exit point without omitting steps when required
c. enter the branched procedure at the correct point I
d. exit from the given E0P at the correct branch Page 21 of 27

ATTACHMENT 5 DEBRIEFING GUIDE l

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1. USEABILITY A. LEVEL OF DETAIL
1. Was there sufficient information to perform the specified actions at each step?
2. Were the alternatives adequately described at each j decision point?

i 3. Could the operator use labeling, abbreviations, and location information as provided in the E0Ps to find the needed equipment?

4. Were the E0Ps missing information needed to manage the I- emergency condition?
5. Were the contingency actions sufficient to address the t

symptoms?

6. Could the operator use the titles and numbers to find referenced and branched procedures?

B. UNDERSTANDABILITY t

1. Was the E0P easy to read? <
2. Were the figures and tables casily and accurately read?
3. Were the values on figures and graphs easily determined?

! 4 Were caution and note statements complied with?

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! 5. Were the E0P steps complied with?

l II. OPERATIONAL CORRECTNESS A. PLANT COMPATIBILITY i

1. Were the actions specified in the procedure able to be performed in the designated sequence?
2. Did the operator find alternate success paths not included in the E0Ps?

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3. As specified in the E0Ps, could the operator obtain the necessary information from the plant instrumentation that is provided?
4. Did the plant symptoms provide adequate information from the operator select the applicable E0P?
5. Were the E0P entry conditions appropriate for the plant symptoms seen by the operator?
6. Did the operator have to use information or equipment not specified in the E0Ps to accomplish his task?
7. Did the plant responses agree with the E0P hasis?
8. Were the instrument readings and tolerances consistent with the instrument values stated in the E0P7
9. Were the E0Ps physically compatibic with the work situation (too bulky to hold, binding wouldn't allow them to lay flat in work space, no place to lay the E0Ps down to use)?

B. OPERATOR COMPATIBILITY

1. If time intervals were specified, were the procedure action steps able to be performed on the plant within or at the designated time intervals?
2. Could the procedure action steps be performed by the operating shift?
3. If specific actions were assigned to individual shift personnel, did the E0Ps appear to help coordinate the actions where necessary?
4. Was the operating shift abic to follow the designated action step sequences?
5. Could the operator find the particular step or set of steps when required?
6. Could the operator return to the procedure exit point without omitting steps when required?
7. Could the operator enter the branched procedure at the j correct point?
8. Could the operator exit from a given E0P at the correct branch?

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ATTACHMENT 6 CPS PLANT-SPECIFIC PARAMETER VERIFICATION Parameter Name E0P

Title:

Calculated Value:

Attached calculations have been reviewed.

Evaluator Date 1

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ATTACHMENT 7 CPS CONTROL ROOM WALKTHROUGH CHECKLIST EOP

Title:

CPS Number:

Date:

List any step for which:

1. Level of detail inadequate or instruction unclear
2. Equipment label /

identification ambiguous or nonexistent

3. Required motion / travel is awkward or impossible in reasonable / required time.
4. Required action has no monitoring device.

Comments:

Evaluator Shift Supervisor l

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ATTACHMENT 8 CPS SIMULATOR CHECKLIST Transient (s)

Procedure (s) Used Date

1. List any step (s) resulting in immediate unexpected simulator response Describe unexpected response
2. List any step (s) difficult to performed in required time interval.

Why?

3. List any step (s) being performed when management of the emergency was judged a failure.

How did failure (s) transpire?

Recommendations Evaluator Shift Supervisor l

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ATTACHMENT 9 E0P/EPG CORRESPONDENCE TO CONTROL ROOM / PLANT EQUIPMENT Subject Panel / Equipment Briefly explain discrepancy below:

Evaluator

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