ML20091J856

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Emergency Operating Procedure Verification Procedure
ML20091J856
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 02/21/1984
From: Falk R, Hann R
WISCONSIN ELECTRIC POWER CO.
To:
Shared Package
ML20091J821 List:
References
PROC-840221, TAC-56311, TAC-56312, TAC-56602, TAC-56603, NUDOCS 8406060226
Download: ML20091J856 (20)


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February 21, 1984 A

ATTACHMENT 3.1 EMERGENCY OPERATING PROCEDURES VERIFICATION PROCEDURE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Written By / [ .f/#[Ff Reviewed By ((s- Afo[M Approved By [A hS//e/iY PDR 0 2b F- PDR ,

.. Fcbruary 21, 1984 ,

l TABLE OF CONTENTS SECTION PAGE 1.0 OBJECTIVE. 3

2.0 REFERENCES

3 2.1 General 3 2.2 Implementation 4 3.0 RESPONSIBILITIES 4 3.1 Plant Manager 4 3.2 Manager's Supervisory Staff 4 3.3 Superintendent - Operations 4 3.4 Superintendent - Reactor Engineering 4 3.5 E0P Writer 4 3.6 Verification Team 4 4.0 EMERGENCY OPERATING PROCEDURE 5 VERIFICATION PROCESS 4.1 Preparation Phase 5 4.1.1 Designate Personnel 5 4.1.2 Obtain and Review the Source Documents 5 4.2 Assessment Phase 6 4.3 Resolution Phase 6 4.4 Documentation Phase 7 Attachment 1 - E0P Verification Forms 8 Attachment 2 - Evaluation Criteria Checklist 12 L

. February 21, 1984 1.0 OBJECTIVE The objective of the Emergency Operating Procedure (EOP) verification procedure is to determine and document that consistency has been maintained between E0P source documents and the PBNP E0P's and to assign responsibilities for conducting the verification process. The E0P source documents are the Emergency Response Guidelines (ERG) that were developed by the Westinghouse Owners Group (WOG) to aid utilities in the development of plant-specific E0P's, the PBNP E0P Writer's Guide, and previous PBNP emergency procedures. The verification is made by evaluating the E0P's for the characteristics of written correct-ness and technical accuracy.

- E0P Written Correctness - Addresses proper incorporation of infor-O mation from the plant-specific writer's guide for E0P's and other appropriate administrative policies.

- E0P Technical Accuracy - Addresses proper incorporation of generic and/or plant-specific technical information from E0P source docu-ments and plant hardware into the E0P's.

This verification guideline is interdependent with an E0P validation program. The validation program encompasses the efforts necessary to support a performance evaluation of the E0P's and will be covered in a separate guide.

2.0 REFERENCES

2.1 General

- NUREG 0899, " Guidelines for the Preparation of Emergency Operating Procedures", N.S. N.R.C. , August 1982.

- NRC Generic Letter 82-33, " Supplement 1 to NUREG-0737 - Requirements 1

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for Emergency Response Capability", December 17, 1982.

- C. W. Fay Letter to H. R. Denton, " Response to Generic Letter i

No. 82-33. . .", April 15,1983.

- PBNP Emergency Operating Procedures, current approved revisions.

- Institute of Nuclear Power Operations (INPO) Guideline, " Emergency Operating Procedures Verification Guideline",83-004, March 1983.

- Emergency Operating Procedure Writer's Guide, PBNP,1983.

- Westinghouse Owners Group, " Emergency Response Guidelines", Rev. 1, September 1, 1983.

2.2 Implementation Source documents, with proper revision numbers used in the compar-ative evaluation, should be noted on Form 1 of the E0P Verification Forms.

3.0 RESPONSIBILITIES 3.1 Manager-PBNP - The Manager PBNP shall approve all E0P's and revisions.

3.2 Manager's Supervisory Staff - Manager's Supervisory Staff, or a subcommittee thereof, shall have the responsibility of reviewing the E0P's after verification resolutions have been incorporated, and making a recommendation to the Manager.

3.3 Superintendent-0perations(PBNP) - The Superintendent Operations shall approve the verification resolutions.

3.4 General Superintendent (NSE&A) - The General Superintendent of NSE&A shall have overall responsibility for the E0P verifi-cation process.

3.5 E0P Writer - The E0P Writer shall review and comment on resolutions before they are forwarded to the Superintendent Operations for l l

approval. He shall incorporate approved resolutions into the E0P's. l l

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February 21, 1984 3.6 Verification Team - The verification team shall manage and execute the technical accuracy evaluation and the written correctness eval-uation portions of the process. They shall recommend verification resolutions for the Superintendent's Operations approval.

4.0 E0P VERIFICATION PROCESS 4.1 Preparation Phase i The preparation phase consists of the following activities:

- Designating personnel to conduct the comparative evaluation, and

- Obtaining and reviewing the E0P source documents.

4.1.1 Designate Personnel The verification team shall include two personnel from the NSE&A engineering staff, one person from PBNP operations, and one person from PBNP training. The General Superin-tendent (NSE&A) shall act as chairman of the verification team. The composition of the verification team shall be approved in writing by the Vice Presider.t, Nuclear Power Department. A summary of the qualifications of designated personnel shall be documented.

4.1.2 Obtain and Review the Source Documents E0P source documents will be listed on Form 1 of the E0P Verification Forms and shall be reviewed by the verifica-tion team member responsible for the particular E0P. These documents shall be reviewed to ensure they are complete, current, and applicable. These documents are to include, but not be restricted to, the following source documents:

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- PBNP Emergency Operating Procedure Writer's Guide

- W0G Low Pressure ERG's PBNP FSAR

- Existing PBNP.EOPs 4.2 Assessment Phase In the assessment phase, the evaluator shall:

- Hake a general review of the E0P using the procedure-general portion of the evaluation criteria checklist (Attachment 2) and source documents.

Indicate on Form 1 of the E0P Verification forms (Attachment 1) that the evaluation was performed, either by checking the acceptance column or by designating the appropriate discrepancy sheet number (s) for any discrepancies identified.

- Make a step-by-step review of the E0P using the step, caution, note-specific portion of the evaluation criteria checklist (Attachment 2) and source documents.

- Indicate (for each step, caution, and note) on Form 2 of the E0P Verification forms (Attachment 1) that the compara-tive evaluation was performed, either by checking the acceptable column or by designating the appropriate discrep-ancy sheet number for any discrepancies found.

- Describe the details of any discrepancy between the E0P and the source documents on a discrepancy sheet, Form 3 of the' EOP Verification forms (Attachment 1).

4.3 Resolution Phase In the resolution phase, the evaluator is to:

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- Determine a solution for each discrepancy and indicate this as the resolution on the discrepancy sheet (Attach [nent 1, Form 3).

- The Verification Team will then review the discrepancy resolution using the E0P and any applicable source document.

After Verification Team review, the discrepancy sheet with the E0P and any applicable source documents are sent to the procedure writer for review and comment.

- After review and coment by the procedure writer, the dis-crepancy sheet with the E0P and any applicable source docu-ments are sent to the Superintendent Operations for approval of the resolution.

- If the resolution is not approved, the evaluator is to deter-mine a. revised solution to the satisfaction of all reviewers.

A new discrepancy sheet is to be initiated and the full review and approval process completed.

- The procedure writer updates the E0P with all approved resolutions and returns the modified procedure to the Verification Team.

4.4 Documentation Phase E0P Verification Forms (Forms 1 and 2) and Discrepancy Sheets

' ' -(Form 3) shall be maintained per the Administration Procedure, PBNP 2.2.1, " Records Administration and Storage."

i The revised E0Ps are then submitted for approval per Administrati:n Procedure PBNP 2.1.1, " Classification, Review, and Approval of Procedures."

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February 21, 1984 The E0Ps are to be evaluated per the E0P Validation Procedure during operator training. Changes resulting from the Validation Procedure will be reviewed and approved per Administration Procedure PBNP 2.1.1, " Classification, Review, and Approval of Procedures."

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Attachrnent 1 E0P VERIFICATION FORMS e

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l February 21, 1984 l E0P VERIFICATION FORM #1 E0P TITLE:

E0P NUMBER: REVISION:

E0P SOURCE DOCUMENTS USED:

EVALUATOR: DATE s

PROCEDURE-GENERAL VERIFICATION A. WRITTEN CORRECTNESS AREAS ACCEPTABLE DISCREPANCY SHEET #(s)

LEGIBILITY a

E0P FORMAT CONSISTENCY IDENTIFICATION INFORMATION B. Technical Accuracy AREA ACCEPTABLE DISCREPANCY SHEET #(s)

Entry Conditions or Symptoms 8

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February 21, 1984 E0P VERIFICATION FORM #2 E0P Rev.

Page of  ;

STEP, CAUTION, NOTE-SPECIFIC VERIFICATION STEP NUMBER, WRITTEN CORRECTNESS TECHNICAL ACCURACY CAVTION, 0,R ACCEPTABLE DISCREPANCY ACCEPTABLE DISCREPANCY NOTE SHEET # SHEET #

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February 21, 1984 Form #3 DISCREPANCY SHEET NUMBER -

E0P: REV.:

PAGE NUMBER: STEP NUMBER:

DISCREPANCY:

RESOLUTION:

EVALUATOR: DATE:

VERIFICATION TEAM REVIEW AND COMMENTS:

BY: DATE:

E0P WRITER REVIEW AND COMMENTS:

i BY: DATE:

RESOLUTION APPROVED: YES N0 (circle one)

SUPERINTENDENT OPERATIONS: DATE:

, RESOLUTION INCORPORATED BY: DATE:

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, 1 l l Attachment 2 EVAlllATION CRITERIA CHECKLIST l

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February 21 0 1984 EVALUATION CRITERIA CHECKLIST =

l Area Reference PROCEDURE-GENERAL I.

A. Written Correctness )

1. Mechanics of Style
a. Are hyphens used appropriately? WG 6.2
b. Is punctuation used properly? WG 6.3
c. Is capitalization used properly? WG 6.4
d. Does the vocabulary used follow proper rules? WG 6.5
e. Are numerical values consistent with estabiished rules? WG 6.6
f. Is spelling correct?
2. Legibility
a. Are the text, tables, graphs, figures, WG 5.12 and charts legible to the evaluator?
b. Are the tables, graphs, figures, and WG 5.12 charts properly labeled and referenced?
3. E0F Format Consistency
a. Do the following sections exist in WG 4.1 the E0P:

Section 1 - COVER SHEET with purpose and entry condition Section 2 - OPERATOR ACTIONS with stepwise guidance Section 3 - FOLD 0VT PAGE with summarized information (not in CSP Series)

b. Is the operator actions section WG 4.2 presented in a dual-column format?
c. Is the pace layout consistent with WG the sample page format? Fig. 1 o
d. Is the foldout page titled " Foldout WG 4.2 l

For E0P-X Series"?

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e. Is the typing format consistent and . WG 7.0 correct?
4. Identification Information
a. Is the procedure title descriptive of the purpose of the procedure?
b. Does the cover sheet correctly WG 3.1, provide the following: 3.3 (1) procedure title (2) procedure designator (EOP or CSP) and number (3) revision number (4) number of pages (5) date of issue
c. Does each page correctly provide WG 3.3 (1) procedure designator and number (2) "Page of " numbers
d. Does the procedure have all its pages WG 3.3 in the correct order? Does the last page include the word "END" B. Technieal L 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 II. -STEP, CAUTION, NOTE-SPECIFIC A. Written Correctness

1. Information Presentation i

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a. Are instruction steps numbered WG 4.3 correctly? .
b. Are instruction steps constructed to comply with the following:

(1) Steps deal with only one idea. WG 5.1 (2) Sentences are short and simple. WG 5.1 (3) Operator actions are specifically WG 5.1 stated.

(4) Objects of operator actions are WG 5.1 specifically stated.

(5) If there are three or more objects, WG 5.1 they are listed (and space is pro-vided for operator check-off).

(6) Punctuation, spelling, and capitalization WG 6.3, are proper. WG 6.4 (7) Abbreviations are correct and WG 6.7 understandable to the operator.

c. Are system response and operator response times given where appropriate? WG 5.1
d. Do complex evolutions exist? They should WG 5.1 be prescribed in a series of steps.
e. Do instruction steps make proper use of WG 5.4 logic terms?
f. When an action instruction is based on receipt of an annunciator alarm, is the setpoint of the alarm identified in the setpoint document?
g. Are precautions and cautions used WG 5.5 appropriately?
h. Are precautions and cautions placed properly WG 5.5 and do they extend across the entire page?
g. Ate precautions and cautions constructed WG 5.5 tr comply with the following?

. (1) They do not contain operator actions.

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February 210 1984 (5) They do not use extensive punctuation for clarity.

(3) They make proper use of emphasis.

(4) They are written in full capitals.

j. Operator Actions Column (1) Are the expected indications located in WG 5.2 the left-hand column?

(2) Are operator actions appropriate for the expected indications? WG 5.2

k. Are the contingency actions located in the WG 5.3 right-hand column?
1. Is the level of detail such that only the WG 5.11 detail that a newly trained and licensed operator would desire during an emergency condition is provided,
m. Are appropriate action verbs used? WG 5.11
n. Are notes properly used? WG 5.6
o. Are notes properly placed? WG 5.6
p. Are notes worded so that they do not WG 5.6 contain operator actions?
q. Are numerical values properly written? WG 5.7
r. Are values specified in such a way that WG 5.7 mathematical operations are not . required of the user?
s. Is a chart or graph provided in the pro-cedure for necessary operator calculations?
t. Are units of measurement in the E0P the WG 5.12 same as those used on equipment?
u. Is underlining used for emphasis of high WG 5.8 level steps and some logic terms only?
2. Procedure Referencing and Branching

, a. Do the referenced and branched procedures WG 5.9 identified in the E0Ps exist for operator use? ,

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b. Is the use of referencing minimized? -

WG 5.9

c. Are referencing and branching instructions WG 5.9 correctly worded?

(1) "go to" (branching)

(2) " refer to" (referencing)

d. Do the instructions avoid routing users UG 5.9 past important information such as cautions preceding steps?
e. Are the exit conditions compatible with WG 5.9 entry conditions of the referenced or branched procedure?
3. Component Identification
a. Are equipment, controls and displays WG 5.10 identified in operator language?
b. If names and numbers on panel nameplates WG 5.10 and alarm windows are specifically the item of concern are they quoted verbatim and emphasized by using all capitals?
c. Are the names of plant system titles WG 5.10 emphasized by initial capitalization?
d. Are components seldom used or difficult to WG 5.10 find supplied with location information in parentheses?
4. Printed Operator Aids
a. Are charts, graphs, tables, and figures self-explanatory, legible, and readable? WG 5.12
b. Are the units of measure, titles, and numbering proper and consistent? WG 5.12 L i l
c. Is the foldout page format correct? WG 5.12  ;

l B. Tech.iical Accuracy e

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1. Are E0P/ ERG differences: .

(a) documented (b) explained 2.Is[theERGtechnicalfoundation(strategy) changed by the following changes in E0P steps, cautions, or notes: ,

(a) elimination (b) addition (c) sequence (d) alteration

3. Are correct, plant-specific adaptions incorporated per ERG and existing E0Ps:

(a) systems (b) instrumentation (c) limits (d) controls (e) indications

4. Have plant specific licensing commitments [e.g. , boron precipitation control or R. G. 1.97] applicable to the E0Ps been addressed and documented?
5. Quantitative Information
a. Do the quantitative valur.s, including tolerance bands, used ia the E0P comply with applicable E0P source document?
b. Where ERG values are not used in the i E0P, are the E0P values computed accurately?
c. When calculations are required by the WG 5.7 E0P, are equations presented with

! sufficient information for operator

! . use?

d. Are limits expressed quantitatively WG 5.1 I whenever possible?

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6. 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

b. Does the specified hardware meet appropriate requirements?

(1) QA?

(2) Environmental qualification?

(3) Redundancy?

(4) Power Supply?

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