ML20115G524
| ML20115G524 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/30/1985 |
| From: | MISSISSIPPI POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20115G517 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 PROC-850430, NUDOCS 8504220237 | |
| Download: ML20115G524 (84) | |
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I GRAND GULF NUCLEAR STATION-UNIT 1 EMERGENCY PROCEDURES UPGRADE PROGRAM '
4 PROCEDURES GENERATION PACKAGE g
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l Prepared for l
i U.S. Nuclear Regulatory Commission April 1985 i
1 F
PDR 1
MISSISSIPPI POWER & LIGHT COMPANY
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GRAND GULF NUCLEAR STATION - UNIT 1 EMERGENCY PROCEDURES UPGRADE PROGRAM PROCEDURES GENERATION PACKAGE Prepared for U.S. NUCLEAR REGULATORY COMMISSION -
APRIL 1985 MISSISSIPPI POWER & LIGHT COMPANY
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s MISSISSIPPI POWER & LIGHT COMPANY 1 1-
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TABLE OF CONTEATS Page 1-1 1.
INTRODUCTION..............................................
1-1 1.1 Purpose.............................................
1-1 1.2 Scope...............................................
1-1 1.3 Organization........................................
1-1 1.4 Acronyms............................................
1.5 References..........................................
1-2 2.
PSTG PREPARATION GUIDE....................................
2-1 2.1 Introduction........................................
2-1 2.2 Me tho do l o gy.........................................
2-1 2.2.1 Mechanics of Conversion.....................
2-1 2.2.2 Documentation Requirements..................
2-1 2.2.3 Reference Material..........................
2-2 2.2.4 Qualification Requirements..................
2-2 2-3 2.3 Appendices..........................................
.3.
EP W RI TE R ' S GU I D E.........................................
3-1 3.1 Introduction........................................
3-1 3-1 3 1.1 Purpose.....................................
3.1.2' Relationship of EPs to Other Plant Procedures............................
3-1 3.1.3 How to Use This Guide.......................
3-1 3.2 EP Designation System...............................
3-1 3.2.1 Numbe rin g S cheme............................
3-1 3.2.2 Title.......................................
3-3 3.2.3 Revision Numbering Scheme...................
3-3 3-3 3.3 EP Structure........................................
3.3.1 Introductory Section........................
3-3 3.3.2 Body of the Procedure.......................
3-4 3.4 Flowchart Preparation Guidelines....................
3-5 3.4.1 Ide ntification and Numbe ring................
3-5 3.4.2 Logic Symbols...............................
3-5 3.4.3 Entry Conditions............................
3-5 3.4.4 Action and Ve rification Steps...............
3-7 3.4.5 Retainment Steps............................
3-7 3.4.6 Decision Steps..............................
3-8 3.4.7 Concurrent Steps............................
3-8 3.4.8 Entry and Exit Points.......................
3-9 3.4.9 Cautions and Notes..........................
3-9 3.4.10 Functional Flow and Branching...............
3-10 3.4.11 Step Numbering Scheme.......................
3-10 3.4.12 Placekeeping Aid............................
3-11 3.4.13 Readability Guidelines......................
3-11 3.4.14 Printed Operator Aids.......................
3-11 3.5 Step construction...................................
3-12 3.5.1 Level of Detai1.............................
3-12 3.5.2 Step Sequencing.............................
3-12 i
M 6-MISSISSIPPI POWER & LIGHT COMPANY TABLE OF CONTENTS (Continued)
Page
-3.5.3 Step Le ngth an d Conte nt.....................
3-13 3.5.4 Types of Steps..............................
3 - 14 3.5.5 Logic Terms.................................
3-15 3.5.6 Conditional Statements......................
3-16 3.5.7 Re ferencing and Branching...................
3-17 3.5.8 Safety Parameter Display System References..
3-18 3.5.9 Component I dentification....................
3-18 3.5.10 Word Choice.................................
3-18 3.5.11 Me tho ds o f Empha s i s.........................
3-19 3.6 Mechanics of Style..................................
3 - 19 3.6.1 Spelling....................................
3-19 3.6.2 Abbreviations and Acronyms..................
3-19 3.6.3 Hyphenation.................................
3-20 3.6.4 Punctuation.................................
3-21 3.6.5 ^
Acceptance Criteria and Calculations........
3-22 3.6.6 Numerical Values............................
3-22 3.7 EP Revi s io ns a n d Up dat e s............................
3-23 3.7.1 Review Requirements.........................
3-23 3.7.2 Revision Process............................
3-23 3.8 Personnel Utilization to Accomplish EPs.............
3-23 3.8.1 Personnel Responsibilities..................
3-23 3.8.2 Training....................................
3-24 3.9 Use of Procedures to Combat Emergencies.............
3-24 3.9.1 Use of EPs..................................
3-24 3.9.2 Use of EPPs.................................
3-24 3.9.3 Use of SOIs and IOIs........................
3-24 3.10 Guidelines on Equipment Use during Emergencies......
3-24 3.10.1 Emergency Use of' Equipment..................
3-24 3.10.2 Documentation...............................
3-24
~3.10.3 Return to Service...........................
3-25 3.11 Appendices..........................................
3-25 4.
VERIFICATION AND VALIDATION PLAN..........................
4-1 4.1 Introduction........................................
4-1 4.2 PSTG and EP Verification............................
4-2 4.2.1 Verification Preparation Phase..............
4-4 4.2.2 PSTG Verification Assessment Phase..........
4-4 4.2.3 EP Verification Assessment Phase............
4-4 4.2.4 Verification Resolution Phase...............
4-5 4.2.5 Verification Documentation Phase............
4-6 4.3 EP Validation.......................................
4-6 4.3.1 Validation Preparation Phase................
4-6 4.3.2 Validation Assessment Phase.................
4 - 15 4.3.3 Validation Re solution Phase.................
4-18 4.3.4 Validation Documentation Phase..............
4-20 4.4 Appe n d ice s..........................................
4-20
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MISSISSIPPI POWER & LIGHT COMPANY TABLE OF CONTENTS (Continued)
Page 5.
EP T RAINING PROG RAM DESCRIPTI ON........................... '
5-1 5.1 Introduction........................................
5-1 5.2 Training Pro gram Development........................
5-1 5.3 Training Program Objectives.........................
5-1 5.4 Training Methods....................................
5-2 5.4.1 Classroom Instruction.......................
5-2 5.4.2 Simulator Exe rci se s.........................
5-2 5.4.3 Control Room Walk-Throughs..................
5-2 5.5 Requalification Training............................
5-2 5.6 Training on Revisions...............................
5-3 5.7 operator reedback...................................
5-3 4w
7 MISSISSIPPI POWER & LIGHT COMPANY 1.
INTRODUCTION 1.1 Purpose This Procedures Generation Package (PGP) describes the process by which Mississippi Power & Light Company (MP&L) will develop, implement, and maintain the Emergency Procedures (EPs)' for Grand Gulf Nuclear Station -
Unit 1 (GGNS-1).
1.2 Scope This document was developed in response to NUREG-0737 Supplement 1, Item 7.2b, and deals only with those procedures to be used by operations personnel to mitigate the consequences of transients and accidents.
1.3 Organization The remaining sections of this document are o
PSTG Preparation Guide e
EP Writer's Guide e
Verification and Validation Plan e
EP Training Program Description Each section describes the approach taken for a significant part of the overall EP Upgrade Program for GGNS-1.
1.4 Acronyms The following acronyms are used in this PGPr Boiling Water Reactor BWR BWROG BWR Owners Group Control Function CF Control Room CR Detailed Control Room Design Review DCRDR Emergency Procedure EP Emergency Procedure Guidelines EPGs Final Safety Analysis Report FSAR Grand Gulf Nuclear Station - Unit 1 GGNS-1 Instrumentation and Controls I&C Mississippi Power & Light Company MP&L U.S. Nuclear Regulatory Commission NRC Procedures Generation Package PGP 1-1
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MISSISSIPPI POWER & LIGHT COMPANY Plant Specific Technical Guidelines PSTGs Safety Parameter Display System SPDS Senior Reactor Operator SRO Task Analysis Worksheet TAW TMI Three Mile Island Verification and Validation V&V 1.5 References
- 1.5.1
" Boiling Water Reactor Owners Group - Emergency Procedure Guideline, Revision 3."
.1 '. 5. 2 INPO 82-017, " Emergency Operating Procedures Writing Guideline s. "
1.5. 3 INPO 83-004, " Emergency Operating Procedures Verification Guidelines."
1.5. 4 INPO 83-006, " Emergency Operating Procedures validation Guidelines."
1.5.5 NUREG-0737, " Clarification of TMI Action Plan Requirements."
1.5. 6 NUREG-0737 Supplement 1, " Requirements for Emergency Response Capability."
1.5.7 NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures."
.5.8 NUREG/CR-2005, " Checklist for Evaluating Emergency Operating Procedures Used in Nuclear Power Plants."
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e MISSISSIPPI POWER & LIGHT COMPANY 2.
PSTG PREPARATION GUIDE 2.1 Introduction This guide provides the administrative and technical requirements for the preparation of the Plant Specific Technical Guidelines (PSTG) to be used in developing the GGNS-1 Emergency Procedures. These guidelines identify the equipment or systems to be operated, and list the steps necessary to mitigate the consequences of trannients and accidents.
They will be based on the Boiling Water Reactor Owners Group (BWROG)
Emergency Procedure Guidelines (EPG), Revision 3.
These generic guidelines have been validated by the BWROG and approved by the U.S.
Nuclear Regulatory Commission (NRC) (Letter LS05-83-11-045).
2.2 Methodology 2.2.1 Mechanics of Conversion Each step of the BWROG EPG will be assessed to verify a.
applicability to GGNS-1.
Revision 3 of the EPG will be used as the primary source document; however, all current and pertinent information supplied by the BWROG will be reviewed for this assessment.
4 b.
Where applicability is verified, the generic EPG will be converted to a plant specific guideline. This will require the inclusion of GGNS-1 specific information and the deletion of nonapplicable information.
c.
For all deviations from Revision 3 of the generic EPG that are not readily apparent, written calculations and/or decision processes will be documented.
d.
Documentation of the conversion process will be performed as described in Section 2.2.2.
i 2.2.2 Documentation Requirements As each step of the BWROG EPG is converted to a GGNS-1 PSTG step, the documentation requirements will be satisfied by completing a copy of Appendix 2A, using the guidance listed
- below, a.
Column 1, "BWR Owners Group - Emergency Procedure Guideline," will contain a duplication of each of the EPG Revision 3 steps. This information will be used as the basis for the creation of the PSTG step.
2-1
MISSISSIPPI POWER & LIGHT COMPANY
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b.
Column 2, "GGNS - Plant Specific Technical Guideline," will contain a guideline step that incorporates the intent of j
l the corresponding generic step and includes GGNS-1 plant specific information, values, and limits. Column 2 will also be used to incorporate additional plant specific information not required by the generic EPG.
Thesa items may include Technical Specification requirements, licensing commitments, or operational techniques.
Column 3, " Deviation / Justification," will be used to c.
document and explain all deviations between Column 1 and Column 2, and provide explanations for additional PSTG j
steps. For each plant specific value given in Column 2, column 3 will list, as a minimum, the reference from which the value was obtained (i.e., FSAR tables, EPG Appendix C calculation, Technical Specification, etc.), including title, revision number, and location.
i 2.2.3 Reference Material The basic plant specific technical information to be re-a.
viewed for the production of the PSTGs will be the material gathered as part of the GGNS-1 Detailed Control Room Design Review (DCRDR), and as documented in Appendix 2B.
b.
In addition to this information, EPG Appendices A and B will be used to clarify the intent of the EPG.
EPG Appendix C provides the plant specific calculations and curves necessary to convert the EPGs to plant specific guidelln'es.
Should additional plant specific calculations be required c.
to support the PSTGs, they will be performed by personnel using the Calculation Sheet shown as Appendix 2C (or similar).
Independent verification of all calculations l
will be in accordance with the verification and validation Plan.
d.
The PSTG writing team will ensure that GGNS-1 licensing commitments are incorporatsd into the PSTGs.
l 2.2.4 Qualification Requirements Those personnel selected for the conversion of the EPGs to a.
the PSTGs will have, as a minimum, the following experience l
level:
' Currently hold a Senior Reactor Operator (SRO) e Certification on a Boiling Water Reactor l
l 2-2 1
1
MISSISSIPPI POWER & LIGHT COMPANY Demonstrate'd previous experience in symptom-based EP e
development Have at least 8 years of nuclear experience e
b.
As proof of meeting the above requirements, resumes of personnel actually performing this activity will be included as part of the PSTG documentation package.
23 Appendices 231 Appendix 2A - EPG to PSTG Conversion Documentation 2 3.2 Appendix 2B - Documentation List 2.3.3 Appendix 2C - Sample Calculation Sheet i
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MISSISSIPPI POWER & LIGHT COMPANY APPENDIX' 2B - DOCUMENTATION LIST PROJECT FILE NUMBER DESCRIPTION MPL-120-03 System Lesson Plan (SLP) LPRMs C51-3 MPL-120-04 SLP IRMs C51-2 MPL-120-05 SLP Fuel Pool Cooling & Cleanup Sys G41/G46 MPL-120-06 SLP RWCU System G33/G36 MPL-120-07 SLP Liquid Radwaste System G17 MPL-120-08 SLP Recirculation B33-1 MPL-120-09 SLP Vessel Instrumentation B21 MPL-120-10 SLP Auxiliary Steam System MPL-120-11 SLP Condensate System N19 MPL-120-12 SLP Rod Control & Information Sys (RCIS) File C11-2 MPL-120-13 SLP. Control Rod Drive Mechanism C11-1B MPL-120-14 SLP CRD Hydraulic System C11-1A MPL-120- 15 SLP Heater Vents & Drains N23 MPL-120-16 SLP Feedwater System N21 MPL-120- 17
'SLP Main Turbine N30 MPL-120-19 SLP Circulating Water System N71 MPL-120-19 SLP Chlorination System N72 MPL-120-20 SLP CRWST P11 MPL-120-21 SLP' Makeup Water System P21 MPL-120-22 SLP Standby Service Water System M1 MPL-120-23 SLP Low Pressure Core Spray E21 MPL-120-24 SLP Area Radiation Monitoring System D21 MPL-120-25 SLP Process Radiation Monitoring System D17 MPL-120-26 SLP Reactor Protection System C71 MPL-120-27 SLP MSIV & FWLC System E32/E38 MPL-120-28 SLP RCIC System E51 MPL-120-29 SLP Combustible Gas Control System E61 MPL-120-30 SLP Refuel & Vessel Service F11/F17 I
MPL-120-31
'SLP Division III (HPCS) Diesel Generator P81 MPL-120-32 SLP RHR System E12 MPL-120-33 SLP Service Air System MPL-120-34 SLP Instrument Air System PS3 MPL-120-35 SLP Fire Protection System 2B-1
o MISSISSIPPI POWER & LIGHT COMPANY
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PROJECT FILE NUMBER DESCRIPTION MPL-120-36 SLP Plant Chilled Water P71 MPL-120-37 SLP Condenser Air Removal N62 MPL-120-38 SLP Hydrogen & Carbon Dioxide Bulk Storage System MPL-120-39 SLP Radweste Building Ventilation V41 MPL-120-40 SLP Turbine Building Ventilation U41 MP L-120-41 SLP Standby Gas Treatment T48
-MPL-120-42 SLP ESF Electrical Distribution R21 MPL-120-43 SLP Recirculation Flow Control System B33-2 MPLe120-44 SLP Standby Diesel Generators P75 MPL-120-45 SLP Component Cooling Water P42 MPL-120-46 SLP Turbine Building Cooling Water P43 MPL-123-47 SLP Plant Service Water / Radial Well Sys P44/P47 MPL-120-48 SLP Floor and Equipment Drains System P45 MPL-120-49 SLP HPCS E22-1 MPL-120-50 SLP Automatic Depressurization System E-22-2 MPL-120-51 SLP Nuclear Boiler & Vessel Internals B13/21 MPL-120-52 SLP Drywell Cooling System M51 MPLe120-53 SLP Containment Systems M41-1 MPL-120-54 SLP Containment Cooling System M41' MPL-120-55 SLP Nuclear Fuel MPL-120-56 SLP EHC Logic N32-2 MPle120-57 SLP Turbine Auxiliaries N30/31-2 i
MPL-120-58 SLP Condensate & Suppression Pool Cleanup Sys N22/P60 MPic120-59 SLP Radwaste Building Ventilation V41 MPL-120-60 SLP Generator N41/N51 1
MPLc120-61 SLP Extraction Steam N36 MPL-120-62 SLP Lube Oil Conditioning & Storage N34 l
MPL-120-63 SLP Seal Steam System N33 MPLe120-64 SLP EHC Control Oil System N32-1 l
MPL-120-65 SLP Source Range Monitors C51-1 MPL-120-66 SLP APRM C51 MPLe120-67 SLP Transversing Incore Probe System C51 MPL-120-68 SLP Standby Liquid Control System C41 MPLe120-69 SLP Feedwater Control System C34 f
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MISSISSIPPI POWER & LIGHT COMPANY PROJECT FILE NUMBER DESCRIPTION MPL-120-70 SLP Offgas System N64/55 MPL-120-71 SLP Supression. Pool Makeup E-30 MPL-120-72 SLP Leak Detection System E-31 MPle120-74 MP&L Plant Operations Manual Vol. 5 Section 2 MPLc120-75 MP&L Drawing J-0400 (Panel Location)
MPL-120--76 MP&L Technical Specifications MPL-120-77 MP&L DCRDR Program Plan GP-R-212123 MPLc120-79 MP&L Drawings, J-A0460A, J-A0460s, J-A0460C, J-A0460D, J-A0460E, J-A1470N, J-A1470U, J-B1470X MPL-120-81 MP&L BWR Emergency Procedure Guidelines, Appendix C, Calculated Procedures MPLc120-82 MP&L Author's Guide. Plant Operations Manual, Vol.1, Section 2 MPL-120-83 Grand Gulf FSAR Chapter 15, Accident Analysis MPL-120-86 MP&L Instrument Index MPLc120-87 Grand Gulf Preliminary Design Assessment Report MPL-120-88 Graphic Display Development Program MPL-120-90 MP&L Plant Procedures (EPs)
MPL-120-98 Letter from General Electric. BWR Emergency Procedure Guidelines (DRAFT)
MPL-12 0-99 Letter from General Electric. Distribution of Appendix B, Rev. 3 A to the Emergency Procedure Guidelines.
MPL-120- 10 0 MP&L Drawings MPL-120- 10 3 NPE Technical Specification / Standard MP&L ES-01 MPL-120- 104 Drawing Reference MPL-120-105 MP&L FSAR Section 3 MPL-120-107 US NRC Standard Review Plan MPL-120-110 MP&L BWROG-8452 Draf t MPL-120-111 MP&L DCRDR Program Plan MPL-120-131 MP&L Project Plan DCRDR (GP-R-212133) w
MISSISSIPPI POWER & LIGHT COMPANY s
APPENDIX 2C - SAMPLE CAI4ULATION SHEET CALCULATION SHEET Project Calculation No.
Title Calculated By Date Page of Checked By Date Reviewed By Date i
MISSISSIPPI POWER & LIGHT COMPANY 3.
EP WRITER' S GUIDE 3.1 Introduction 3.1.1 Purpose This document establishes format and content standards for GGNS-1 Emergency Procedures and gives guidance to the EP writer for the creation and revision of all EPs.
3.1.2 Relationship of EPs to Other Plant Procedures EPs are but one of many types of procedures within the plant procedure system. The relationship of EPs to other procedures is shown in Figure 3-1.
To ensure compatibility of the EPs with othsr plant procedures, all EP-referenced procedures will be verified: (1) to exist and (2) to contain instructions addressing the EP-required evolution.
3.1.3 How to Use This Guide This guide was prepared to give the EP writer complete guidance in preparing GGNS-1 EPs.
The following process is recommended:
a.
Review Appendix 3A, which contains references and other information that will help plan the procedures.
b.
Then review Sections 3.2 and 3.3, which give an overview of the EP system and the structure of the individual EPs.
Then use Sections 3.4, 3.5, and 3.6 and the remaining c.
appendices to draf t the procedures. These sections deal with general flowchart guidelines, then action step construction, then specific points of style.
Sections 3.7 through 3.10 contain information on when and how EPs are revised, and how they are used in an actual esorgency.
3.2 EP Designation System 3.2.1 Numbering Scheme Each EP has a unique number. The following scheme is used for all GGNS-1 Operations Procedures:
Procedure Sequential Volume (1)
Unit (2)
Section(3)
Type (4)
No. (5)
XXX XX X
X XX 3-1
MISSISSIPPI POWER & LIGHT COMPANY P
ADMINISTRATIVE PROCEDURES SOI,101 EPP EP ONEP
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L ARI Legin d ARI Alarm Response Instructions EP Emergency Procedures EPP Emergency Plan Procedures ONEP Off-Normal Event Procedures SOI,IOI System Operating Instructions, Integrated Operating Instructions Figure 3-1.
Relationship of EPs to Other Procedures f
3-2 i
J MISSISSIPPI POWER & LIGHT COMPANY
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KEY (1)
Operations Manual Volume Number (2)
Generating Unit:
1, 2, or S (shared)
(3)
Section Number within the Operations Manual volume. When there is only one section in a volume, this number may be deleted.
(4)
Procedure Types e.g., EP (5)
Sequential Number The sequential numbering scheme begins with 1 and can go to 999.
Appendix 3B is a list of GGNS-1 EPs with their assigned numbers.
3.2.2 Title The EP titles are to be brief, yet descriptive. The flowchart fornat of the EPs enforces brevity. Two principles are to be used in titling EPs:
a.
The title is to be 10 words or less.
b.
Important words are to be at or near the beginning of the title.
3.2.3 Revision Numbering Scheme Revisions of EPs are numbered sequentially with arabic numerals with the revision date shown on each procedure.
(See Section 3.4.1 for 'an example. )
3.3 EP Structure Each EP will consist of an introductory section and the flowchart (s) that contain(s) the action steps.
3.3.1 Introductory Section a.
Content Although the heart of the EP is the flowchart of action steps, additional information needed for a complete procedure cannot be accommodated in such a format without cluttering the chart. Therefore, each EP will have an introductory section consisting of a cover sheet and five sections in single-column, 8-1/2" X 11" format, separate from the flowcharts. The EP number will link this introductory section with the flowchart portion of the procedure.
3-3
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MISSISSIPPI POWER & LIGHT COMPANY The cover sheet contains the following identification informations e
EP title, number, and revision number e
volume and section of the Plant Operations Manual e
Plant and unit identification e
Signatures of the preparer, reviewers, and approvers e
List of Effective Pages A sample format is shown in Appendix 3C.
In addition to the cover sheet, the introductory section includes the following:
o Purpose e
Scope e
Definitions e
General Precautions e
Procedure (flowchart reference) e References The format and content of these headings are given in Appendix 3C.
b.
Page Identification and Layout Each page following the cover sheet is identified as follows:
GRAND GULF NUCLEAR STATION EERENCY PROCEDURE
Title:
No.:
Revision:
Pages Appendix 3C contains sample page layouts for the EP introductory section.
3.3.2 Body of the Procedure The body of the procedure consists of the flowchart (s).
Appendix 3C contains a sample flowchart format. The flowcharts contains a.
Entry conditions 3-4
MISSISSIPPI POWER & LIGHT COMPANY b.
Action steps (to bring the plant to a stable condition, or to branch to another procedure that will do so) c.
Exit conditions Section 3 4 below contains detailed guidelines on flowchart development.
34 Flowchart Preparation Guidelines 3 4.1 Identification and Numbering A title block in the lower right corner of each flowchart will contain the EP number, title, revision number, revision date, page numer, an3 plant name. See Figure 3-2.
PROCEDURE NO.
PAGE X OF X PROCEDURE TITLE REVISION NO.
REV DATE: XX/YY GRANO GULF NUCLEAR STATION UNIT 1 Figure 3-2 Sample Flowchart Title Block 3.4.2 Logic Sy m ols Figure 3-3 contains the standard flowchart symbols used in EPs.
343 Entry Conditions The entry conditions or synytons are generally brief noun phrases that initiate the EP actions. The entry conditions are located at the top of each flowchart within entry condition syeols. The positioning of the symbols indicates to the operator'.whether any one or all of the conditions are necessary before operator actions commence. See Figures 3-4 and 3-5 3-5
MISSISSIPPI POWER & LIGHT COMPANY v
ENTRY CONDITION C
Contains the condition requiring entry into and execution of this procedure.
ACTION STEP Contains the procedural actions. Also defines contingency action steps (IF...THEN).
RETAINMENT STEP Contains information or contingency action conditions the operator must remember while performing the steps that follow.
DECISION STEP Contains a question to which the answer determines the next step.
I
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EXECUTE CONCURRENTLY EF5
/
Requires the operator to enter the designated procedure and perform the stated actions while continuing in the existing flow path.
v ENTRY ARROW E P-5 Designates the entry point for this procedure when directed by the procedure step in the arrow.
XX.Y EXIT ARROW
)
Requires the operator to leave the flow path at that point.
EP 5 If required,it contains the procedure number and/or step XX Y that must then be entered.
OPERATOR CAUTION OR NOTE Indicates that a specific caution or note is applicable 8
6 to the step. The number in the symbol corresponds to a statement at the bottom of the procedure.
CAUTION NOTE Figure 3-3.
Flowchart Symbols 3-6
MISSISSIPPI POWER & LIGHT COMPANY (CONDITION ) (CONDITION) (CONDITION )
l I
ACTION Figure 3-4.
any.One Condition Initiates Action
( CONDITION )
I (CONDITION )
I
( CONDITION)
I ACTION Figure 3-5.
All Conditions Must Be Present to Initiate Action 3 4.4 Action and Verification Steps In the flowcharts, action steps and verification steps are not differentiated in that both are shown as actions in an action step symbol. See Figure 3-6.
I I
RESET...
VERIFY...
3 i
Figure 3-6.
Identical Symbols Used for Action and Verification 4
3.4.5 Retainment Steps A retainment step gives the operator information or contingency action conditions he must remember while executing the steps that follow. See Figure 3-7.
I i
3-7 w,
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,,,,mm..,-.,-_.,.._,---,,.,,,-,.nw.,,_
,,__._g.
- MISSISSIPPI POWER & LIGHT COMPANY
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g WHILE EXECUTING THE FOLLOWING STEPS THE SCRAM CAN BE RESET, THEN RESET THE SCRAM AND RETURN TO STEP AA/B CC Figure 3-7.
Sample Retainment Step 3.4.6 Decision Steps All decision steps require a choice between only two opposite possibilities, for example, yes/no or high/ low. These steps are phrased as questions. See Figure 3-B.
RESET THE SCR AM ACTION INSTRUCTION LEADING TO DECISION NO YES 4
THE SCR AM BE RESET 7 3g DECISION Figure 3-8.
Sample Decision Step 3.4.7 Concurrent Steps A concurrent step symbol is usea when an operator is to enter another procedure while at the same time continuing in the current flow path. The symbol contains the number of the additional procedure. See Figure 3-9.
I ACTION I )
EP 5 Y
ACTION I
Figure 3-9.
Sample Concurrent Step 3-8
MISSISSIPPI POWER & LIGMT COMPANY 3 4.8 Entry and Exit Points An entry arrow symbol is used to show where a procedure is entered from another procedure.
The symbol contains the procedure number that was exited, and is located to the lef t of the entry point.
See Figure 3-10.
EP 4 ACTION Figure 3-10.
Entry Arrow Symbol An exit arrow syr.bol requires the operator to leave the flow path at that point. If required, it contains the procedure number and/or step that must be entered. An exit arrow is located below and to the right of the step exited. See Figure 3-11.
ACTION
)
I EP 4 rigure 3-11.
Exit Arrow Symbol 3 4.9 Cautions and Notes cautions and notes give additional information to the operator. They are never used to convey an action step.
a.
Definitions 1)
Caution A caution statement gives the operator information needed to avoid equipment damage in executing the step.
2)
Note: A note gives the operator information to clarify the instruction. It never deals with equipment hasards.
3-9 l
l i
L
mississippi POWER & LIGHT COMPANY b.
Format A specific caution applicable to a step is indicated by a hexagon to the right of the step. A note is indicated by a circle to the right of the step. The statement is located at the bottom of the flowchart (similar to a footnote on a text page) and nanbered the same as the symbol. See rigure 3-12.
8 6
ACTION ACTION I
I CAUTION NOTE Figure 3-12.
Piacement of Caution and Note Symbols 3 4.10 runctional riow and Branching Sufficient spacing will be allowed between paths so that a.
the operator does not inadvertently enter an adjacent path.
Arrowheads will be used on connecting lines to clarify the b.
direction of the path.
3.4.11 Step Numbering Scheme a.
Multiple-3 ranch EPs Multiple-branch EPs use an AA/3-C format, where AA = the procedure desiTnator 3 = the branch of the procedure C = the sequential step number Tor example, peactor Control, Level tranch, Step 3 would be numbered RC/L-3.
b.
Single-3 ranch EPs Single-branch EPs use an AA-3 format, where AA = the procedure designator B = the sequential step number For exarnple, Level postoration, Step S would be numbered LR-5.
3-10
MISSISSIPPI POWER & LIGHT COMPANY 3.4.12 Placekeeping Aid A J is placed next to each step as a placekeeping aid to the operator.
3 4.13 Readability Guidelines The following apply The flewchart typeface will be a sans-seraph style, in full a.
caF ttis, at least 10 points in sise.
i b.
The spacing between letters, words, and 31nes will be distinct so that the flowcharte can be easily read lu emergency lighting.
c.
All EP lettering will be black type on white background for the highest possible contrast.
d.
Copies of flowcharts will be of high quality, i.e., without fussy type.
e.
The flowcharts will have a nonglare surface.
f.
The flowcharts will be no larger than 36" X 60" and no smaller than 0-1/2" X 11".
3.4.14 Printed Operator Aids Figures (such as graphs and charts) and tables may be used to aid the operator in performing the action steps.
For example, a table of values could be used so that a calculation is avoided.
a.
Labeling Scheme 1)
Figures and tables will be titled.
2)
They will be numbered in separate sequences within each Fi ure 1, Figure 2, Table 1, Table 2, etc.
flowcharts T
3)
A figure number and title will be placed below each figure.
4)
A table number and title will be placed above each table.
5)
Figures and tables will be referred to by number within the action steps a
" REFER To FIGURE 1..."
3-11
t MISSISSIPPI POWER & LIGHT COMPANY b.
Placepent operator aids will be placed directly on the flowcharts adjacent to the appropriate steps.
c.
Quality Operator aids will be self-explanatory and legible under the expected conditions of use. Specifically, 1)
The typeface will be a sans-seraph style, in full capitals, at least 5 points in size.
2)
The aid will be a high-quality reproduction (or reduction), i.e., not a blurry photocopy.
d.
Consistency The terms used in the aid will match those used in the procedure steps and in the control room itself. Units of measure and numerical values will be consistent with GGHS-1 Technical specifications and with actual control room indicators.
3.5 step Construction 3.5.1 Level of estail The detail required in the flowcharts is that required by the least trained operator expected to use the procedure, specifically a newly trained and licensed operator working under emergency (stressful) conditions. The flowchart format leaves little room for supporting instruction or information, and operators are trained on the procedures, so a cluttered flowchart will only hinder efficient performance.
3.5.2 step sequencing steps will be listed in the required sequence. The operator assumes the sequence is mandatory unless the procedure specifically states otherwise.
Other considerations in sequencing action steps are:
Structure the control room action steps to ensure that a.
minimum control room staff can perform the actions.
b.
Sequence the steps to minimise physical conflicts among operators.
Seqttence the steps to avoid unintentional duplication of c.
steps by dif ferent operators.
3-12
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MISSISSIPPI POWER & LIGHT COMPANY 3.5.3 Step Length and Content Instruction steps will be short and simple statements dealing f
with only one idea. The following specific guidelines apply Limit the number of action verbs per step to one, unless a.
the actions are closely related, in which case up to three J
action verbs are acceptable. Appendix 3D defines some of the action verbs anticipated to be used in the EPs.
4 b.
Describe complex evolutions in a series of steps.
Do not state the person performing the actions that is, do c.
not begin a step with "The operator shall..."
l d.
Do not use imprecise adverbs (for example, frequently or slowly).
i e.
Avoid double negatives.
f.
When an action has three or more objects, list them j
J vertically using bullets. For exag les CLOSE OR VERIFY CIDSED:
f e
RPV HEAD VElffS B21-F001 AND B21-Y002 i
e MSIVs e
MAIN STEAM LINE DRAINS j
e RCIC STEAM ISOLATION VALVES t
g.
When actions are required based on receipt of an annunciated alarm, state the alarm and its setpoint.
h.
If required for proper understanding, describe the system response time associated with step performance.
l 1.
When system response dictates a time frame within which the instruction mast be accomplished, state the time frame.
However, avoid using time to initiate operator actions because operator actions should be related to plant parameters.
j.
When anticipated system responses may adversely affect instrument indications, describe in a CAUTION:
(1) the conditions that will very likely introduce instrument error and.(2) a means of determining whether instrument error has occurred.
k.
When additional confirmation of system response is necessary, state the backup readings to be made.
3-13
o MISSISSIPPI POWER & LIGHT COMPANY 3.5.4 Types of Steps Guidance for different types of actions follows.
a.
Simple Action Step Begin this type of step with the action verb:
CLOSE.
OPEN.
POSITION.
b.
Verification Step Begin with an action verb that clearly indicates that verification is to be performed:
VERIFY.
As stated in the guidelines above, list three or more items to be verified vertically.
c.
Continuous Step Indicate clearly that an action is to be performed continuously:
CONTINUE TO SCAN...
MAINTAIN CO!ITINUOUSLY...
8 d.
Recurrent Step Indicate clearly (1) when or how often the step is to be performed and (2) under what conditions the step should no longer be carried out.
Remind the operator at a later point in the flow path to keep performing the step.
An example of a recurrent step ist CHECK TANK LEVEL EVERY 30 MINUTES e.
Alternative Step State specifically that the prescribed step may be performed in alternative ways (if any) by using the logic word OR.
3-14
MISSISSIPPI POWER & LIGHT COMPANY l
f.
Concurrent Steps
~
Indicate clearly whether any steps need to be performed concurrently with other steps by using such words as
" simultaneously," "at the same time," or " concurrently."
e If the actions are closely related, join the actions with "and" within the same step. However, "and" does not in itself imply simultaneous performance, so the need for simultaneous action still needs to be stated.
e If the actions are not closely related enough to be included in the same step, or if there are more than three closely related actions, list the steps with a lead-in instruction indicating the need for simul-taneity, such as " perform the following actions concurrently."
The number of concurrent steps should not be beyond the capability of the control room staff to perform them.
3.5.5 Logic Terms The following guidelines apply to the use of logic terms. Logic terms will be underlined for emphasis.
a.
AND/OR Avoid' the use of AND and OR within the same action. When AND and OR are used together, the logic can be very ambiguous. For example, the following instruction could be interpreted in more than one sense:
IF CONDITION 1 AND CONDITION 2 OR CONDITION 3 OCCURS, THEN GO TO STEP 3 b.
AND When attention should be called to combinations of conditions, use the word AND between the conditions. Do not use the word AND to join more than three conditions.
If four or tore conditions need to be joined, use a list format.
When used as a simple conjunction, "and" need not be emphasized:
STOP THE PUMP AND PLACE IT IN STANDBY c.
Ojt Use the word OR when calling attention to alternative combinations of conditions.
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MISSISSIPPI POWER & LIGNT COMPANY e
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i d.
IF or WHEN... THEN When action steps are contingent on certain conditions or combinations, begin the step with IF or WHEN followed by a description of the condition (s), a comma, and the word THEN followed by the action to be taken. WHEN is used for an expected condition. IF is used to determine the specific course of action based on plant conditions.
e.
IF NOT Use IF NOT only where the operator must respond to the second of two possible conditions. IF should be used for the first condition. For example:
IF PRESSURE IS INCREASING, THEN STOP THE INJECTION PUMP; IF NOT, 'liiEN START AN ADDITIONAL INJECTION PUMP Examples of conditional statements using logic words are given in Section 3.5.6 below.
3.5.6 Conditional Statements Conditional action steps must be constructed simply and clearly because of the often complex logic and ideas therein. The-following rules apply:
The IF or WHEN clause precedes the action a.
E SUPPRESSION POOL TEMPERATURE REACHES 110*F, THEN SCRAM THE REACTOR WHEN RPV PRESSURE DECREASES TO 800 PSIG, THEN OPEN ALL ADS VALVES AND GO TO EP-4 (LEVEL RESTORATION) b.
Where three or more conditions exist, a listing approach is preferable:
E THE FOLLONING THREE CONDITIONS ARE MET:
TEMPERATURE NEAR COLD REFERENCE LEG INSTRIMENT VERTICAL e
RUNS IS LESS THAN RPV SATURATION LIMIT AS DETERMINED BY FIGURE 1, AND
. CONTAINMENT PRESSURE IS MAINTAINED IESS THAN 15 PSIG, e
AND e
RPV WATER LEVEL CAN BE DEFERMINED, THEN ENTER EP-1 (LEVEL CONTROL) AT STEP X 3-16
MISSISSIPPI POWER & LIGHT COMPANY c.
Where only one of two conditions produces an action, use the following approach:
E AT ANY TIME THE RPV WATER LEVEL TREND REVERSES g RPV PRESSURE CHANGES REGION, THEN RETURN TO TABLE 1 If there were three or more conditions in the above example, a listing approach would be preferable, with each condition linked by OR.
Conditional statements are treated in further detail in NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures," Appendix B, and in INPO 82-017, " Emergency Operating Procedures Writing Guidelines," Section 2.3.18.
3.5.7 Referencing and Branching a.
Definitions The term " referencing" in connection with another procedure implies that the referenced procedure will be used as a supplement to the initial procedure. Referencing can also occur within a procedure, either forward or backward.
The term " branching" means that an operator exits the initial procedure and enters a new procedure, so that at any given time he is working with only one procedure.
b.
Guidelines Excessive referencing to other procedures or forward / backward within a procedure causes operator errors. The following guidelines apply:
1)
If the length or complexity of the flowchart will not be substantially increased, repeat the needed information rather than referencing.
2)
Reference complete procedures or sections of procedures if possible. Requiring an operator to use another procedure for just a few steps is to be avoided.
3)
Be sure to clearly direct the operator back to where he left off.
4)
Include references to GGNS-1 Emergency Plan Procedures (EPPs) as appropriate on the flowchart.
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6 MISSISSIPPI POWER & LIGHT COMPANY c.
Format 1)
When referencing another step, flow path, or procedure to be used as a supplement, use words such as " REFER TO" or "... USING PROCEDURE E-5."
For examples E SUPPRESSION POOL WATER LEVEL INCREASES' TO X FT, THEN RESTORE LEVEL WITH NORMAL SUPPRESSION POOL DRAIN USING PROCEDURE 04-1-01-P11-2 A procedure may also be referenced using the concurrent step symbol described earlier in Section 3.4.7.
2)
When branching to another procedure or flow path, use words such as "GO TO" or " EXIT / ENTER," and the entry and exit symbols described earlier in Section 3.4.S.
For example:
IF RCIC IS NCyr READY FOR OPERATION AND MPV PRESSURE IS INCREASING, THEN GO TO EP-5 (RAPID RPV DEPRESSURIZATION) 3.5.8 Safety Parameter Display System References An asterisk (* ) or other identifier will be placid on the flowchart at appropriate points to indicate that pertinent information is available on the Safety Parameter Display System (SPDS).
3.5.9 Component Identification Equipment, controls, and displays should be identified in operator language (common usage) terms without the location, with the following exceptions:
When the engraved names and numbers on legend plates and a.
alarm windows are specifically the item of concern in the procedure, the engraving should be quoted verbatim.
b.
If the component is seldom used or difficult to locate, location information such as the panel number should be given.
3.5.10 Word Choice The flowchart format requires brevity, so words must be selected carefully. The following guidelines apply:
a.
Use simple, short, familiar words commonly understood by the trained operator.
b.
Use concrete, specific words.
3-18
MISSISSIPPI POWER & LI!HT COMPANY c.
Use specific action verbs such as those listed in Appendix 3D.
For control circuitry that executes an entire function upon actuation of the control switch, use the action verb without further instructions on how to manipulate the control device. Recommended action verbs are e
For power-driven rotating equipment START, STOP e
For valves: OPEN, CLOSE, THROTTLE OPEd, THROTTLE CLOSE, THROSTLE e
For power distribution breakers: SYNCHRONIZE, CLOSE, TFGP For multiposition control switches that have more than one position for a similar function, placement to the desired position should be specified.
d.
Use Appendix 3E for recommended spellings and words to avoid.
e.
Use Appendix 3F for acceptable abbreviations and acronyms.
f.
Define any key words that may be understood in more than one sense.
3.5.11 Methods of Emphasis The following methods are to be used:
a.
All logic terms underlining (E, WHEN, THEN, AND, OR, NOT) b.
Other types of informations underlining when appropriate for special emphasis.
3.6 Mechanics of style 3.6.1 spelling Use spelling consistent with a current dictionary. When a choice of spellings is of fered, use the first listed.
several industry-specific terms have varying spellings, such as "startup" versus " start-up." common usage at GGNS-1 is the guidance here, and Appendix 3E lists these terms.
3.6.2 Abbreviations and Acronyme The use of abbreviations and acronyms depends heavily on user f amiliarity; that is, their meaning must be unquestionably clear 3-19
o e
MISSISSIPPI POWER & LIGHT COMPANY to an expected procedure user. On the other hand, they are needed to save space in the flowchart format, and it is virtually impossible to spell them out at their first mention, which is normally done in single-or double-column format procedures. Therefore, the following guidelines apply:
a.
Spell out all words in procedure titles.
b.
Use abbreviations and acronyms that the operator learns in the course of training.
c.
Ensure that abbreviations and acronyms are consistent with labels in the control room.
d.
Use abbreviations for units of measure:
FT, not FEETs PSI, not POUNDS PER SQUARE INCH.
e.
Define all abbreviations used in the introductory section at their first mention.
f.
List and spell out in the Definitions section any abbrevia-tions that may not be common knowledge to the least trained user.
g.
Be consistent in using abbreviations and acronyms always spell them the same way.
h.
To make an abbreviation plural, add a lower case as
Reserve the apostrophe for showing possessive.
Appendix 3F contains abbreviations and acronyms used in GGNS-1 EPs.
4 3.6.3 Hyphenation Hyphenating (dividing) a word at the end of a text line should be avoided in the flowcharts. If hyphenation is difficult to avoid because of space, words must be divided as shown in a current dictionary, and at least three letters must be carried down to the next line.
Hyphens are used to link elements of a compound word (called a unit modifier), such as "nine-digit number" and "long-term control." Hyphens are also used in the following circumstances:
e In compounds with "self":
self-explanatory When the last letter of the first word or prefix is the e
same vowel as the first letter of the second words re-ene rgine 1-20
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MISSISSIPPI POWER & LIGHT COMPANY When misleading or awkward consonants would result by e
joining the words:
non-nuclear Hyphens are not used with the following prefixes unless confusion results from closing up the wordt e
pre e
micro e
post e
mini e
re o
multi e
sub o
non e
super 3.6.4 Punctuation a.
Brackets Use brackets to avoid double sets of parentheses:
REFER TO PROCEDURE EP-5 (RAPID RPV DEPRESSURIZATION) b.
Colon Use a colon to indicate that a list of items will follow.
c.
Comma The following rules apply:
1)
Use a comma between the "if" or "when" clause and the action clause of a conditional statement.
2)
Use a comma for numerical values of five digits or more, e.g., 100,000, 50,000, 2000.
3)
Use a comma to set off an introductory phrase or word.
4)
Use a comma before the conjunction connecting the last item in a series of three or more:
AVOID RPV HIGH MTER LEVEL TRIP ON RFPTs, RCIC, AND NPCS INJECTION VALVE (E22-F004)
Note that within the flowcharts a series of three or more items is listed vertically, so commas are not used.
3-21
e MISSISSIPPI POWER & LIGHT COMPANY d.
Parentheses Parentheses are used to give additional, defining information:
RHR (STEAM CONDENSING MODE)
They are also used to indicate an abbreviation or acronym on its first mention RESIDUAL REAT REMOVAL (RER) e.
Period A period is used to end a complete statement, although it is generally not used within the flowchart symbols. A period is omitted when 1)
Listing items vertically. For examples e
RCIC e
HPCS e
LPCS e
LPCI 2)
Spelling an acronym HPCS, not H.P.C.S.
3)
Abbreviating units of measure FT, LB, PSI. However, IN. is used to avoid confusion with the word IN.
3.6.5 Acceptance Criteria and Calculations The following rules apply Be as specific as possible when stating qualitative a.
acceptance criteria. Avoid using vague words like "satisf actory" or " normal."
Express quantitative acceptance criteria and tolerances in b.
ranges so that the operator does not need to mentally add or subtract.
7 f
Use tables of values or graphs in the procedure to avoid c.
operator calculation.
4 If calculation cannot be avoided, simplify the calculation, l
d.
provide the formula, and provide space for calculating.
For examples i
RECORD FEED PUMP SUCTION PRESSURE:
P=
psig O
)
RECORD FEED PtStP SUCTION TEMP T=
F I40K UP VAPOR PRESSURE AT T:
VP =
psig f t of head l
NPSH = 2 3 (P
) - (VP :
)
=
3-22 l
MISSISSIPPI POWER E LIGHT COMPANY 3.6.6 Numerical Values The following rules apply:
a.
Always use arabic numerals.
b.
For brevity in the flowchart format, use the numeral instead of the word:
3, not three.
For numbers less than one, precede the decimal point by a c.
zero:
0.1.
d.
Ensure that the number of significant digits is equal to the number of significant digits available from the display (and required by the necessary reading precision of the operator).
Specify engineering units for numerical values of process e.
variables, and ensure that they are consistent with the units predominantly displayed to the operator.
3.7 EP Revisions and Updates 3.7.1 Review Requirements EPs may be reviewed as a result oft Revision of the BWROG Emergency Procedure Guidelines a.
b.
Revision of other procedures referenced in the EPs c.
Revision of the FSAR d.
Revision of the Technical Specifications Feedback received from the Verification and Validation e.
(V&V) activities indicating procedural problems f.
NRC correspondence received that changes the scope of the EPs g.
Operating experience 3.7.2 Revision Process If it is determined that a revision is necessary, the revision will be prepared in accordance with this writer's guide. If the revision is significant, a special training session may be required.
(Minor revisions are covered in routine requalification training.)
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MISSISSIPPI POWER & LIGHT COMPANY 9
3.8 Personnel Utilization to Accomplish EPs 3.8.1 Personnel Responsibilities i-Specific personnel (i.e., Shift Supervisor, Shift Superintendent, etc.) will have defined responsibilities when i
the EPs are in use. These responsibilities will be developed by the GGNS-1 Operations Department and modified as necessary af ter the V6V activities.
3.8 2 Training Personnel responsibilities during EP use will be addressed during initial and requalification training for all GGNS-1 licensed operators. Additional training experience will be i
gained during the annual Emergency Preparedness exercises.
3.9 Use of Procedures to Combat Emeroencies 3.9.1 Use of EPs The EPs provide guidance to mitigate the consequences of transients and accidents. These procedures are organised for I
entry based on specific plant symptoms.
3 9.2 Use of EPPs The EPPs direct the operations required if other site personnel or outside agencies need to be involved. These procedures are normally executed concurrently with the EPs where required.
3.9.3 Use of SOIs, IOIs and ONEPs System Operating Instructions, Integrated Operating Instructions and Off-Normal Event Procedures may be used tot i
Perform specific, complex evolutions that are too detailed a.
to be included in an EP.
b.
Maintain the plant in a stable shutdown state after the EP ( s) has been exited.
3 10 Guidelines on Equipment Use during Emergencies
~ 3.10 1 Emergency Use of Equipment f
SOIs and,IOIs provide for plant operation or shutdown using equipment within design limits. However, it may be necessary during emergencies to use equipment in a manner beyond its j
design limit. Guidance will be provided where practicable to ensure successful temporary operation, although a shortened service life may result.
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MISSISSIPPI POWER & LIGHT COMPANY
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3.10.2 Documentation If any equipment is operated beyond its design specification, the following should be noted in the control room log:
Component affected o
Parameter exceeded or value operated at e
Length of time operated above design limits e
3.10.3 Return to Service Equipment operated above design limits during EP use should not be used for " normal" operations until evaluated by the technical staff.
3.11~ Appendices 3.11.1 Appendix 3 A - Planning Guidance for the Procedure Writer 3.11.2 Appendix 3B - List of GGNS-1 Emergency Procedures 3.11.3 Appendix 3C - Sample Format 3.11.4 Appendix 3D - Action Verbs 3.11.5 Appendix 3E - Vocabulary 3.11.6 Appendix 3F - Abbreviations and Acronyms I
i l
l.
3-25
o MISSISSIPPI POWER & LIGHT COMPANY APPENDIX 3A - PLANNING GUIDANCE FOR THE PROCEDURE WRITER Before starting a first draf t of any document, a writer should research the topic, analyze the audience, and either outline or diagram the major points to be covered to establish ciganization and sequence. This appendix contains guidance in these areas that is specific to the GGNS-1 EP writer. -
3A.1 Gather Technical References The first step in procedure development is research into the technical documents to which the procedure must adhere. These documents include a.
PSTGs: The EPs are to be written based on these guidelines.
b.
Although the EPs are directly derived from the PSTGs, it may be necessary to verify technical information by referring to the generic EPGs.
c.
. Technical Specifications: All acceptance criteria must conform to the GGNS-1 Technical Specifications.
d.
FSAR: This report will be needed to verify plant commitments.
3A.2 Gather Supporting References and Guidelines 3A.2.1 Writing Guidelines Additional references on writing and style are needed to write the procedure. The following are recommended:
a.
A current dictionary: A dictionary is needed to determine spelling and hyphenation of words.
McGraw-Hill Dictionary of Scientific and Technical Terms, b.
1984 ed.:
This dictionary may be used to determine the spelling and abbreviations of terms too technical to be included in a nontechnical dictionary.
Words into Type, 3rd ed., Prentice-Hall, 1974: This book c.
may be used to clarify principles of grammar, usage, and style.
d.
NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures," August 1982: This NUREG contains the human factors principles upon which this writer's guide is based, and may be helpful to clarify or amplify this guide.
3A-1 I
+
.ol.v.
r,
,a
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MISSISSIPPI POWER E LIGHT COMPANY e.
INPO 82-017, " Emergency Operating Procedures Writing Guidelines," July 1982: Many of the principles outlined in this INPO document are restated in this writer's guide. The original INPO document may be needed for further guidance on a specific point.
3A.2.2 MP&L Procedures a.
Administrative Procedure 01-S-02-3, Rev. 13, " Author's Guide, Safety Related," September 4, 1984.
b.
Operations Section Procedure 02-S-01-1, Rev. 10,
" Author's Guide for Operations Section Instructions, Safety Related," June 29, 1984.
3A.3 Analyze the User Research,into the expected procedure user is needed to ensure a workable procedure. Most questions on style and content can be answered by first asking "Who is the user?"
ractors to be considered in user analysis include a.
Level of training and education 1).
What is the level of the least trained?
2)
What i: the level of the most trained?
3)
Is there a wide range of operators with different levels of training?
b.
Years of experience: The same questions apply.
c.
Expected environment 1)
What are the physical conditions, such as lighting, control room layout, and number of operators in the control room?
2)
What is the expected stress level? How will it affect the c -
operator's ability to read, comprehend, and efficiently execute the procedures?
d.
Past problems with procedures 1)
What kind of procedural deficiencies have led to user difficulties at GGNS-17 2)
What problems have other plants had and how did they resolve r
them?
l l
3A-2 l
MISSISSIPPI POWER & LIGHT COMPANY L
3A.4 Outline the Major Points i
Outlining or charting out the procedure's major paths or steps helps the writer examine the logic and organization early.
In the outline, flow diagram, or event tree, show the following:
a.
Sequence, including concurrent flow paths b.
Decision points Any third party verification, approval, or notification points c.
d.
Interfaces with other EPs e.
Interfaces with other plant procedures, such as EPPs The outline or chart can then be filled out into a procedure draf t.
i i
L.
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MISSISSIPPI POWER & LIGIT COMPANY APPENDIX 3B - LIST OF GGNS-1 EMERGENCY PROCEDURES Number Title 05-S-01-EP-001 Reactor Pressure Vessel (RPV) Control 05-S-Cl-12-002 Primary Containment Control 05-G-01-EP-003 Secondary Containment Control J
05-S-01-EP-004 Radioactivity Release Control 05-S-01-EP-005 RPV Level Restoration 05-S-01-EP-006 Emergency RPV Depressurization 05-S-01-EP-007 Steam Cooling 05-S-01-EP-008 Core Cooling Without Level Restoration 05-S-01-EP-009 Alternate Shutdown Cooling 05-S-01-EP-010 RPV Flooding 05-S-01-EP-Oll Reactor Level / Power Control-fC-d.
MISSISSIPPI POWER & LIGHT COMPANY o
APPENDIX 3C - SAMPLE FORMATS
+
3C.1 Page Margins 3C.1.1 Introductory Section The introductory section of an EP will be typed and reproduced on 8-1/2" x 11" paper. The page margins will ben 1)
Left:
1" 2)
Right:
1" 3)
Top:
1/2" above running heading showing plant name 4)
Bottom: At least 1" 3C.1.2 Flowcharts The flowcharts will have at least a 1" margin on all four side s.
The title block in the lower right corner will be at least 1" from the right and bottom edges of the chart.
3C.2 Page Layouts This appendix contains the following sample page layouts:
Figure Title Page 3C-1 EP Cover Sheet 30-2 3C-2 Introductory Section 3C-3 3C-3 Flowchart Format (example) 30-4 3C-1
MISSISSIPPI POWER & LIGHT COMPANY
~
PLANT OPERATIONS MANUAL Wolee 05 05-Section 01 Revision Date
[ERCENCY PRDCEDURE SArETY RELATED Prepared:
/
Date Type Or veladation Reviewed:
Date Date TecnnAcal Revae.
Plant Quality superintencent Eoncurrence:
Rac<inem Protection superintencent Approved:
Date Plant Manager List of Effective Pages:
Pace:
1-List of TCN's Incorporated Revision g
Figure 3C-1.
IP Cover Sheet 3C-2
y i
e MISSISSIPPI POWER & LIGHT COMPANY e
s i
GRAND GULT WCLEAR STATION EMERGEN0Y PROCEDURE
Title:
No.:
Revision:
Page
- 1. 0 purport A concise statement of the objective of this EP that begins with "To..."
2.0 SCOPE A brief' description of the EP's scope, that is, the specifie events or functions it covers or is limited to.
3.0 der!N!T!'E Definitions of (1) any important words in the procedure that may be understoco in more than one sense, and (2) abbreviations used that may not be common knowledge to the user.
4.0 GENERAL PRE 0AUTIONS Any precautions that apply to the procedure as a whole. Specific cautions applying to a procedure step are located on the procedure flowchart.
5.0 PROCEDURE An imperative statement directing the operator to the procedure flowchart (s).
6.0 REFERIN0ts 6.1 Documents Needed References referred to or branched to in this procedure.
6.2 source Documents Documents used to develop this procedure (for traceability and verification of content).
Figure 3C-2.
Introductory Section 3C-3
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APPENDIX 3D - ACTION VERBS The following are some of the action verbs commonly used in the EPs.
Allow - To permit a stated condition to be achieved before proceeding, for example, " allow pressure to stabilize."
Check - To perform a physical action that determines the state of a variable or status of equipment without directing a change in status, for example, " check suppression pool level."
Close - To change the physical position of a mechanical device so that it prevents physical access of flow or permits passage of electric current, for example, "close valve."
Complete - To accomplish specific procedural requirements, for example,
" complete valve checkoff list."
Establish - To make arrangements for a stated condition, for example,
" establish communication with control room."
Inspect - To measure, observe, or evaluate a feature or characteristic for comparison with specified limits; method of inspection should be included, for example, " visually inspect for leaks."
Open - To change the physical position of a mechanical device, such as a.
valve.or door, to an unobstructed position that permits access of flow, for example, "open valve."
Record - To document a specified condition or characteristic, for example,
" record pressure."
Set - To physically adjust to a specified value an adjustable feature, for example, " set diesel speed to..."
Start - To originate motion of an electric or mechanical device directly or by remote control, for example, " start charging pumps."
Stop - To terminate operation, for example, "stop charging pumps."
Throttle - To operate a valve in an intermediate position to obtain a certain flow rate, for example, " throttle valve to..."
Trip - To activate a semiautomatic feature, for example, " trip breaker."
Vent - To permit a gas or liquid confined under pressure to escape at a vent, for example, " vent pump."
Verify - To observe an expected condition or characteristic, for example,
" verify discharge pressure is stable."
4 MISSISSIPPI POWER & LIGHT COMPANY APPENDIX 3E - VOCABULARY
. 3E.1 Use of Shall, Will, Should, May, and Must The following definitions apply when these words are used in EPs:
A requirement established by a specific regulation or shall/will regulatory requirement.
A recommendation' but not an enforceable regulatory should requirement. Management expects each employee using plant directives to carry out any "should" statement unless circumstances prevent or necessitate deviation.
In those unusual occurrences where deviation is necessary, the employee must justify the exception to the responsible Manager.
An option, neither a recommendation nor a i
may requirement.
A requirement that is established by MP&L must management.
"Must" may also be used to meet regulatory intent.
3E.2 Recommended Spellings bleed line (two words) blowdown (noun or edj.): " blowdown mode" bus (singular), busses (plural) cool down (verb) cooldown (noun or adj.):
" plant cooldown"
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de-energize (use the hyphen) drywell (one word) feed line (two words) feed pump (two words) feedwater (one word) i flow path (two words) igniter
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line up (verb):
"Line up the feed line."
lineup (noun):
" Verify valve lineups."
letdown (noun):
" Return letdown to normal."
makeup (noun or adj.~):
" makeup water".
motor driven (no hyphen) motor operated (no hyphen) re-energize (use the hyphen) re-establish (use the hyphen) setpoint (one word) shut down (verb):
" Shut down reactor."
shutdown (noun):
" Verify reactor shutdown."
stand by (verb):
"to stand by" standby (noun or adj.):
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start up (verb):
" Start up water treatment"
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startup (noun):
" plant startup" steam line (two words) subcooling (one word) 3E.3 Words to Avoid frequently - Imprecise normal - Do not use as the sole acceptance criterion; too vague.
satisfactory - Do not use as the sole acceptance criterion; too vague.
shut, as in " shut the valve" - Use "close."
slowly - Imprecise 3E-2
4 MISSISSIPPI POWER & LIGHT COMPANY APPENDIX 3F - ABBREVIATIONS AND ACRONYMS ADS automatic depressurization system APRM average power range monitor ARI Alarm Response Instruction ATWS anticipated transient without scram a
CTMT/DRWL containment /drywell CRD control rod drive CST condensate storage tank ECCS emergency core cooling system EP Emergency Procedure EPP Emergency Plan Procedure FS AR Final Safety Analysis Report HCU hydraulic control unit HPCS high pressure core spray IOI Integrated Operating Instruction IRM intermediate range monitor LER Licensee Event Report LFMG low frequency motor generator LPCI low pressure coolant injection LPCS 3aw pressure core spray MCC motor control center MG motor generator MSIV main steam isolation valve MSL main steam line j
NPSH net positive suction head ONEP Off-Normal Event Procedure PCT peak cladding temperature psid pounds per square inch differential psig pounds per square inch gage PSRC Plant Safety Review Committee QA Quality Assurance
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MISSISSIPPI POWER E LIGHT COMPANY RCIC reactor core isolation cooling RFPT reactor feed pump turbine RER
~ residual heat removal rpm revolutions per minute RPS reactor protection system RPV reactor pressure vessel RWCU reactor water cleanup SDV scram discharge volume SJAE steam jet air ejector SLCS standby' liquid control system SOI System Operating Instruction SP Surveillance Procedure SPDS Safety Parameter Display System SPMS suppression pool makeup system SRM source range monitor SEV safety relief valve TEMP temperature TAF top of the active fuel TCN Temporary Change Notice Tr.
temperature element a
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4.
VERIFICATION AND VALIDATION PLAN 4.1 Introduction As part of the EP Upgrade Program for GGNS-1, the new procedures will undergo verification and validation (V&V) af ter they are written. This section presents MP&L's plan for conducting the EP V&V process.
The plan is based primarily on the guidance provided in four industry documents: (1) NUREG-0737 Supplement 1, " Requirements for Emergency Response Capability," (2) NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures," (3) INPO 83-004, " Emergency Operating Procedures Verification Guidelines," and (4) INPO 83-006, " Emergency Operating Procedures validation Guidelines." In particular, the overall EP V&V ef fort for GGNS-1 will address the following six objectives (from Section 3.3.5.1 of NUREG-0899):
That EPs are technically corrects i.e.,
they accurately reflect the a.
PSTG s.
b.
That EPs are written correctly; i.e., they accurately reflect the GGNS-1 EP Writer's Guide.
That the language and level of information presentation in the EPs c.
are compatible with the minimum number, qualification, training, and experience of the operating staf f.
d.
That EPs are usable 1.e., they can be understood and followed without confusion, delays, and errors.
That there is a correspondence between the procedures and the e.
control room / plant hardwarer i.e., control / equipment indications that are referenced are available inside and outside of the control room, use the same designation, use the same units of measurement, and operate as specified in the procedures.
f.
That there is a high level of assurance that the procedures will works i.e., the procedures guide the operator in mitigating transients and accidents.
The Institute of Nuclear Power Operations (INPO) defines EP verification as an evaluation performed to confirm the written correctness of the EPs and to ensure that the generic and plant specific technical aspects have been properly incorporated. In following this definition, EP verifi-cation for GGNS-1 will address aspects of the first five objectives stated above. This evaluation will encompass all the actions necessary to ensure that a correct translation of all source documents into the EPs has occurred. *The evaluation will also ensure that an auditable trail of documentation shows step by atep how the BWROG EPGs are converted into the GGNS-1 EPs.
This will require that the GGNS-1 PSTGs (developed before draf ting the EPs) be evaluated for written correctness and technical accuracy as well.
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INPO defines EP validation as an evaluation to determine that the actions specified in the EP can be followed by trained operators to manage the emergency conditions in the plant.
NUREG-0899 objectives "c,"
"d," and "f" above will be addressed by a method that is fully auditable.
Figure 4-1 correlates each of the six NUREG-0899 objectives with specific portions of the GGNS-1 V&V process. As shown in the figure, EP verification will evaluate objectives "a,"
"b," and "e" fully, and objectives "c" and "d" partially.
EP validation will complete the evaluation of "c" and "d" and will also fully evaluate objective "f."
As noted at the bottom of Figure 4-1, three primary V&V methods to be used by GGNS-1 are tabletop discussions, walk-throughs, and simula-tion. In the tabletop method, personnel will explain and discuss procedure steps in response to a proposed scenario.
In the walk-through method, control room operators will conduct a step-by-step enactment of a proposed scenario for Validation Team observers without carrying out the actual control functions. In the simulator method, control room operators responding to a, simulated scenario will perform actual control functions on the GGNS-1 simulator for evaluation by validation Team observers.
4.2 PSTG and EP Verification The focus of the verification process will be to evaluate the written correctness and technical accuracy of the GGNS-1 PSTGs and EPs.
Static aspects of the PSTGs and EPs such as plant specific valve numbers, setpoints, footnotes, and format will be confirmed to be in accordance with the BWROG EPGs, the GGNS-1 PSTG Preparation Guide, and the GGNS-1 EP Writer's Guide. Supporting procedures that are referenced or utilized will be documented to exist and evaluated to ensure that the intended f unctions referenced by an EP can be accomplished. In sddition, the EPs will be partially evaluated for usability and compati-bility with the minimum number, qualifications, training, and experience of the GGNS-1 operating staf f.
Finally, the existence of adequcte documentation for the PSTG and EP verification will be confirmed.
The verification process described in this section is modeled af ter INPO 83-004, " Emergency Operating Procedures Verification Guidelines," and includes four phases preparation, assessment, resolution, and documen-tation. Each of these phases is described separately below. The preparation phase will be conducted prior to verifying the PSTGs, and will apply to both PSTG and EP verification. The assessment, resolu-tion, and documentation phases will be performed for each of the PSTG and the EP verification efforts.
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NUREG-0899 V&V Process Components V&V Objectives Verification Validation a.
Technically correct e
Comparison of PSTG and EPs (TT)
Comparison of EP Writer's b.
Written correctly e
Guide (TT) e Evaluation Criteria Checklist (TT) e Evaluation during Review by operating c.
Compatible with e
minimum number, shift complement slow-paced walk-qualification, train-in conjunction with throughs and "real-ing and experience tabletop review time" scenario of operating staff for objective "d"
exercises (WT &
(TT)
SIM) d.
Usable e
Review by operating e
Evaluation during shift complement to slow-paced walk-evaluate readability, throughs and "real-completeness, accuracy, time" scenario and convenience (TT) exercises (WT & SIM)
Comparison of con-e.
Correspondence exists e
between procedures trol room instru-and control room /
mentation and plant hardware controls (I&C) and EP references to IEC (WT) e Evaluation of f.
Guide operators in real-time" scenario mitigating transients exekcises (SIM) and accidents l
V&V Methods:
Individual or group evaluation TT - Tabletop Step-by-step enactment of scenario operator actions without WT - Walk-Through carrying out actual control functions Control functions performed by operators in simulator SIM - Simulator Figure 4-1.
Correlation between VEV Objectives and Process
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I 4.2.1 Verification Preparation Phase The first step in the preparation phase will be to designate personnel, including a human factors engineer, as an Independent Review Team. These evaluators will be persons other than those who write the PSTGs and/or EPs.
Also, selected GGNS-1 operations personnel will review the procedures and provide input from their operating experience and philosophy.
AftertheIndependentReviewTeamhasbeendesignateb, applicable source documents for conducting the verification will be identified and obtained. The principal source documents for the verification will be the BWROG EPGs, the PSTG Preparation Guide, and a GGNS-1 specific EP Evaluation Checklist. This checklist (Appendix 4A) has been developed from the guidance presented in three docurents:
(1) NUREG/CR-2005, " Checklist for Evaluating Emergency Operating Procedures Used in Nuclear Power Plants," (2) INPO 83-004, " Emergency Operating Procedures Verification Guidelines," and (3) the GGNS-1 EP Writer's Guide. Finally, PSTG and EP discrepancy sheets and EP verification completion records (as shown in Appendices 4B, 4C, and 4D) will be prepared to provide adequate documentation of the verification.
4.2.2 PSTG Verification Assessment Phase During the assessment phase, the PSTGs will be reviewed by the Independent Review Team. A step-by-step comparison of the PSTGs with the BWROG EPGs and the PSTG Preparation Guide will ensure proper incorporation of generic and/or plant specific technical information into the PSTGs. In addition, the Independent Review Team will verify that the documentation required to support the PSTGs (including calculations, tables, and figures) is complete.
The discrepancy sheet shown as Appendix 4B will be used to document the results of all these verification reviews and to record any discrepancies noted. This form provides not only for documenting each discrepancy but also for documenting the resolution of each discrepancy.
l 4.2.3 EP Verification Assessment Phase During the EP assessment phase, the EPs will be reviewed by the Independent Review Team and by GGNS-1 operations personnel.
They will be compared to the appropriate source documents assembled during the preparation phase. In particular, the following comparisons and reviews will be conducted:
Compar'ison of the EPs with the requirements of the GGNS-1 o
PSTGs 4-4
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MISSISSIPPI POWER & LIGHT COMPANY Comparison of the EPs with the GGNS-1 EP Writer's Guide o
Review of each EP using the EP Evaluation Checklist e
Tabletop review of the EPs by GGNS-1 operations personnel e
to initially assess usability and compatibility Comparison of contirol room IEC with the references to IsC i
e made in the EPs The step-by-step comparison of the EPs with the requirements of the GGNS-1 PSTGs will' ensure the completeness and technical accuracy of the EPs. Comparison of the EPs with the Writer's Guide will ensure written correctness and the incorporation of j
human factors engineering principles. The EP Evaluation Check-l list (Appendix 4A) will act as a further tool for confirming the written correctness of each EP.
The tabletop review by opera-tions personnel, though subjective in nature, will identify early any potential problems that control room crews might have in accepting and adapting to the upgraded EPs. The control room walk-through of the EPs will check each reference to IEC in the EPs against the control room labels displayed on the equipment.
Additionally, units of measurement used in the procedures will be checked to ensure that they are consistent with those j
l displayed on instruments.
The discrepancy sheet shown as Appendix 4C will be used to document the results of all EP verification reviews. The sheets will also document the resolution of each discrepancy. The checklist item nunber for each deviation from the EP Evaluation Checklist will be noted on the corresponding discrepancy sheet.
All discrepancy sheets will be routed back to the Independent Review Team leader. He will present all sheets to the EP Upgrade Program project manager for designation of corrective action to be taken.
A key element of the assessment phase will be to ensure an auditable documentation trail showing the step-by-step-conversion of the BWROG EPGs to the GGNS-1 EPs. This requirement will be met through the review of all PSTG/EP documentation used during procedure development.
i 4.2.4 Verification Resolution Phase 1
During the resolution phase, the GGNS-1 EP Upgrade Program l
project'. manager will distribute the discrepancy sheets to appropriate GGNS-1 personnel for the determination of corrective i
action to be taken on the PSTGs or EPs. The project manager will ensure that an adequate resolution is provided for each discrepancy, and will approve the resolutions by signing each discrepancy sheet. Resolutions will be incorporated by the 4-5
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personnel who prepared the PSTGs or EPs, and each discrepancy sheet will be signed of f by.the writer incorporating the resolution. The discrepancy sheets will then be forwarded to the project manager for a review of the resolutions.
4.2.5 Verification Documentation Phase Following review of the EPs and acceptance of all resolutions, an EP verification completion record (Appendix 4D) will be completed for each EP.
This record (along with accompanying verification worksheets, evaluation checklists, and discrepancy sheets) will provide the verification documentation package for each EP.
4.3 EP validation The EP validation, which is to be performed concurrently with the Detailed Control Room Design Review (DCRDR) Validation, will determine whether the actions specified in the EPs can be performed by trained operators to manage emergency conditions successfully. As shown in Figure 4-1, the validation process will evaluate the ability of the EPs to effectively guide operators in mitigating transients and accidents.
In addition, validation will complete the evaluations of EP usability and compatibility initiated during the EP verification.
The GGNS-1 validation process is presented in Figure 4-2 and is modeled after INPO 83-006, " Emergency Operating Procedures Validation Guidelines." It includes the four phases of preparation, assessment, resolution, and documentation. The preparation phase will focus on the development of lists of expected operator actions and performance evaluation guidelines for the scenarios to be used in exercising the EPs.
During the assessment phase, the scenarios will either be run on the GGNS-1 simulator or be walked through in the control room. The control room operating crew will use the EPs to restore the plant to a safe condition. Based on a debriefing of the operators and an analysis of videotapes of the simulator runs, procedure-related errors will be identified (equipment and man / machine interface concerns will also be identified for resolution as a part of the DCRDR program). The EP discrepancies causing these errors will be listed, and resolutions will be developed during the resolution phase. Documentation produced during the validation will be collected and organized during the documentation phase to provide a traceable history of the initial validation effort.
This documentation will also lay the groundwork for instituting an The ongoing EP validation program coupled with the training program.
ongoing validation program will provide a means of continuously evaluating the EPs.
4.3.1 Validation, Preparation Phase As shown in Figure 4-2, the key steps involved in preparing for EP validation will be as follows:
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Designate validation Team personnel.
a.
b.
Define and develop representative scenarios for both the simulator and walk-through methods of validation.
c.
Conduct walk-throughs to refine the scenario descriptions.
d.
Evaluate differences between the simulator and. the control room that may affect how the simulator scenarios are written.
Prepare necessary observer forms and checklists prior to e.
the exercises.
f.
Familiarize operating crews being used for the validation with the new EPs.
Each of these steps is discussed below:
a.
Designate Validation Team Personnel A team of qualified personnel will be appointed to prepare and conduct the validation effort. The team will include training / operations personnel, a human factors engineer, simulator instructors, operating crews, and videotape camera operators. Figure 4-3 outlines the responsibilities of these members of the team.
The subject matter experts from training and operations will be familiar with the new procedures and with the design and operation of the simulator and control room.
The simulator instructor will understand the hardware' design, sof tware programming capabilities, and operation of the simulator. Operations personnel will respond to simulated transients and accidents, or walk through scenarios in the control room. To the extent possible, the control room staffing during simulator runs will resemble the staffing under normal plant operating conditions.
Validation Team personnel will run videotape cameras during simulator runs and walk-throughs.
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PREPARATION DESIGNATE VALIDATION TEAM PERSONNEL DEFINE REPRESENTATIVE SCENARIOS I
DEVELOP SCENARIO TASK ANALYSIS WORKSHEETS CONDUCT WALK THROUGHS EVALUATE DlFFERENCES TO REFINE SCENARIO BETWEEN SIMULATOR DESCRIPTIONS AND CONTROL ROOM PREPARE SIMULATOR EXERCISE FORMS AND LISTS OF EXPECTED OPERATOR ACTIONS FAMILIARIZE OPER ATING CREWS WITH NEW EPs CONDUCT CONTROL ROOM WALK THROUGHS AND SIMULATOR VALIDATION RUNS DEBRIEF OPERATORS ASSESSMENT AN ALYZE VIDEOTAPES IDENTIFY DISCREPANCIES
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CLASSIFY DISCREPANCIES I
RESOLUTION IDENTIFY AND INCORPORATE RESOLUTIONS i
ORECT DOCWENTADON DOCUMENTATION Figure 4-2.
EP validation Process l
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TRAINING HUMAN OPERATIONS FACTORS SIMULATOR OPERATING CAMERA PERSONNEL SPECIALIST INSTRUCTOR CREW OPERATORS PREPARE FOR ON. SITE DATA COLLECTION X
X EmFORM SIMULATOR DEsRIEF OPERATORS X
X X
X DETERMINE DISCREPANCIES X
X X
FILL OUT DISCREPANCY X
X SHEETS Figure 4-3.
Validation Team Members and Their Responsibilities b.
Define and Develop Representative Scenarios The initial basis for EP validation will be the DCIOR Validation scenarios. Additional scenarios to fully exercise the EPs will be developed for EP validation. To the extent possible, each scenario will be planned to include a unique set of paths through the EPs so that the entire collection of scenarios will exercise as much of the procedure network as possible. Each scenario will include the initial plant conditions, action sequences, and l
expected outcome for a hypothetical plant emergency.
A systematic process will be used to choose transient and accident events for constructing scenarios. This will provide a representative sampling of events to ensure that the EPs will be exercised sufficiently. First, scenarios designed for use in the DCIIDR Verification and Validation will be examined to see how much of the EP network is exer-l l
c ised. A matrix (see Figure 4-4) of emergency procedures I
(control functions) versus NRC identified critical safety functions (CSFs) will be used to identify which control functions and CSFs are challenged by the DCICR scenarios.
Training and operations personnel on the Validation Tesa l
will then develop additional scenarios to ensure that all emergency procedure control functions are challenged.
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9 MISSISSIPPI POWER & LIGHT COMPANY A brief narrative description of each scenario will be prepared and will includes Initial plant conditions e
e Sequence initiator e
Progression of actions Final plant conditions
- e e
Major systems exercised Task Analysis Worksheets (as shown in Appendix 4E) will also be completed for each scenario. This will indicate the anticipated operational steps required in each scenario, as well as the appropriate information and control requirements, means of operation, and IEC present on the control boards. Completed Task Analysis Worksheets will serve as templates for conducting the scenario run-throughs during the assessment phase. The worksheet will be completed in the following manner:
- 1) The discrete steps in the GGNS-1 EPs will be recorded in order of performance in the " Procedure Step Number" column of the Task Analysis Worksheet. Branching points, if any, will be recorded in the " Scenario Response" column.
- 2) A brief description of operator tasks (in order of procedural steps) will be recorded in the
" Task / Subtask" column of the Task Analysis Worksheet.
More tasks may be described than are explicitly called out in the procedural steps. In this case, a dash will be entered in the " Procedure Step No." and " Scenario Response" columns when no explicit procedural step is present in the EPs.
All tasks, both explicit and implicit, will be documented by using operations, engineering, and human factors personnel.
- 3) The operator decision and/or actions linked to task performance will be recorded in the " Decision and/or Contingent Action Requirements" column. System functional response will be described when appropriate in this column. This set of data will include branching points in the EPs that determine the outcome of the scenario.
- 4) Requirements for successful task performance will be recorded in the "Information and control Requirements" column. These requirements typically will be parameters, components, or procedural information 1
necessary for operators to assess plant conditions or l
system status adequately.
4-11 n
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e MISSISSIPPI POWER & LIGHT COMPANY Steps 1 through 4 above will be completed prior to 1
exercising the scenarios, using independent sources of data f
other than the actual IEC present in the control room. The i
remaining columns of the Task Analysis Worksheet will be completed from data obtained during the EP and DCRDR validation.
- 5) Af ter the tasks, decision requirements, and information and control requirements have been specified, the specific Isc that the operator actually uses for each procedural step will be documented. All IEC will be listed that is needed to (1) initiate, maintain, or remove a system from service, (2) confirm that an appropriate system response has or has not occurred, (3) make a decision regarding plant or system status.
The "Means" column on the Task Analysis Worksheet refers to how the information and control requirements are presented on the control boards (e.g., switch or meter). The "IEC Identification" column will provide the specific panel number and identification number of the control or instrument.
c.
Conduct Walk-Throughs to Refine Scenarios Using the scenario descriptions and Task Analysis Worksheets, preliminary walk-throughs of the scenarios will be conducted in the GGNS-1 simulator to ensure that the scenarios are consistent with the simulator capabilities.
The scenario descriptions and task analysis information will be modified as necessary. These walk-throughs will also provide the necessary information for preparing the lists of expected operator actions and performance evaluation criteria for the simulator validation runs.
d.
Evaluate Differences between Simulator and Control Room r
Prior to conducting simulator scenario runs, an assessment i
i will be made of the dif ferences between the simulator and l
the control room. This evaluation will determine any l
significant differences that will affect the scenarios.
Differences in control room design will be noted when lists of expected operator actions are prepared so that attention can be given to the differences during the simulator runs and subsequent analysis. If necessary, the portion of the scenario that requires use of a panel not in the simulator will be walked through in the control room.
i 4-12
P k
1 MISSISSIFPI POWER & LIGHT COMPANY Prepare Validation Forms and Checklists e.
f Using the Task Analysis Worksheets and the results of the scenario walk-throughs, the Validation Team will prepare a Simulator Exercise Form (Appendix 4F) for each scenario.
The Simulator Exercise Form will present a synopsis of the scenarios to be used for the simulator method and will identify the plant conditions that need to be simulated.
This information will assist the Validation Team in defining the path of events to be incorporated into each scenario. Scenarios that cannot be simulated will be readily identified, and will be performed by the walk-through method. For maximum efficiency, personnel familiar with simulator operations will be involved with this stage of the preparation.
Af ter defining the scenario and the procedure steps that the operators could follow in responding to the emergency, the Validation Team will prepare a List of Expected Operator Actions (Appendix 4G) for use in evaluating the scenario run-throughs. The list will identify A procedure set for the scenario and specific steps e
from each procedure Operator actions that follow an expected path 'through e
the scenario l
I A description of specific points at which differences e
between the control room and simulator may affect operator performance Discrepancies between actual performance and expected e
performance Categorization of discrepancies i
e l
l The expected operator actions will be taken directly from l
the procedures and the Task Analysis Worksheets. Addition-l al actions will be specified for any case in which the j
procedures or Task Analysis Worksheets do not actually delineate actions explicitly. The' actions will not need to be copied in detail from the Task Analysis Worksheets; however, a level of detail sufficient for observers to follow the action will be needed. The form will provide a l
concise description of expected actions in one place, rather than requiring observers to flip through worksheets grouped by scenarios. The forms will also provide space for additional data such as simulator / control room
}.
differences and notation of potential procedure-4-13 l
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O 9
MISSISSIPPI POWER & LIGHT COMPANY related errors. A trial simulator run may be conducted by the validation Team to ensure that the simulator script is consistent with the delineation of operator actions and simulator modeling.
It is recognized that several operator options may exist in the procedures and that the operators' actual path through the procedure set may differ from the path defined by the Validation Team. The procedure for dealing with deviations from expected operator action is described in Section 4.3.2.
Finally, the Validation Team will prepare a checklist of exercise evaluation criteria to be used during the assessment phase, as well as a debriefing checklist to be used after each scenario is run on the simulator. The checklist and debriefing form will be developed from the guidance provided in INPO 83-006, " Emergency Operating Procedures Validation Guideline."
f.
Documentation The necessary documentation for the assessment phase will include the following:
Copies of the appropriate EPs from which the scenarios o
were derived Description of differences noted between the simulator e
and the control room e
Task Analysis Worksheets e
Simulator Exercise Forms Lists of Expected Operator Actions e
e Exercise Evaluation Criteria Checklist Operator Debriefing Checklist e
g.
Conduct Crew Familiarization Before their arrival at the simulator, the operating crew (s) to be used for the assessment phase will be familiarized with the new procedures during classroom and simulator training sessions.
In addition, control room /
simulator differences, such as human factors design, operation design, and workspace design, that may affect the run-throughs will be discussed.
4-14
MISSISSIPPI POWER Er LIGHT COMPANY Before starting the assessment, operators taking part will be briefed concerning:
e validation objectives e
Validation methodology Operator responsibilities during validation e
After all personnel have been briefed and are in place at the simulator or control room, the assessment phase will begin.
4.3.2 validation Assessment Phase The assessment phase will focus on collecting infc.rmation during the simulator runs and control room walk-throughs, and on analyzing the results of these exercises to identify differences in actual versus expected operator actions. Operator performance deviations will then be used to identify potential discrepancies in,the EPs.
Certain general actions will be applicable to the assessment phase regardless of the method used. The validation Team leader will review the responsibilities of each team member. Some individuals will be observers and data recorders, while others will be support equipment operators. All Validation Team per-sonnel will be familiarized with the overall format and sequence for conducting the assessment. If feasible, they will perform a
" dry run" of the assessment using an abbreviated form of the scenario (s).
If the team has questions concerning use of either the observation or debriefing forms, the questions will be clarified. Coordination with the video crew will be finalized at this time.
a.
Conduct Simulator Validation Runs f
Simulator runs will provide an objective context within which to evaluate the usability, compatibility, and effectiveness of the procedures (refer to Figure 4-1).
In contrast to walking through the procedures in a static environment in which oversights may occur, the simulation environment will mimic the operating conditions for a more realistic challenge to the procedures, requiring the operators to diagnose the observed symptoms and use the EPs to implement corrective actions.
Each scenario will be simulated separately with a debriefing session after the run.
During the run, validation Team members will be observers; at a minimum, two training / operations personnel and one human factors 4-15
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9 MISSISSIPPI POWER & LIGHT COMPANY
~
v specialist will participate.
As necessary, notes will be made to document potential deviations from the expected operator actions and/or deviations from expected simulator performance. The videotape recording of the scenario will permit the observers to analyse the run in greater detail.
During the simulator runs, if the operating crew takes an acceptable alternate path, they will be allowed to continue. If the crew takes an incorrect path but returns to the correct path within a reasonable amount of time, the simulation will continue. However, if the crew takes an incorrect path and shows no sign of recovering, the simulation will be stopped if an obvious, remediable error is involved (e.g., a page of the procedure is missing),-the problem will be corrected and the run resumed.
If, the problem is not obvious or readily correctible, the simulator run will be postponed until the problem is diagnosed or corrected.
b.
Conduct Control Room Walk-Throughs For the walk-through method of validation, the following steps will be carried out by the operators:
Walk er talk through the actions they would take during e
the specific situations covered by the scenario (s) e Describe actions they are taking Identify information sources used to take actions e
Identify controls used for carrying out actions, e
expected system responses, how these responses are verified, and the actions to be taken if the responses do not. occur Validation Team personnel wills e
Direct the walk-through e
Coordinate the efforts of operators, observer /
reviewers, and video crew e
Review scenarios Ask appropriate "what if" questions e
Note problems and discrepancies encountered by e
operators Record operator cammdnts e
4-16
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MISSISSIPPI POWER & LIGHT COMPANY c.
Debrief O,perators after Simulator Runs The operator debriefing session will be conducted immediately after each scenario run on the simulator. The comments of the operators who have participated in the exercise will provide one of the most important sources of information for evaluating the procedure set. Operator actions that do not lend themselves to direct observation, such as symptom diagnosis or conversion of displayed values, will be described by the operators during the debriefing. The operators' comments will also contribute greatly to analyzing the deviations from the expected operator actions. All discrepancies, possible causes, and potential solutions identified during the debriefing will be documented.
A validation Team member will explain the debriefing process to the operators and elicit thier general comments on the procedures. This may be augmented by a videotape display of the specific action or set of actions in question.
The operators will be asked to identify possible reasons for any procedure-related problems they encoun-tered. Questions from the operator debriefing checklist will be asked to prompt the operators. The operators will also be asked to present potential solutions to any procedure-related problems.
The Validation Team members will then present problems and discrepancies they identified during the scenario. If the operators deviated from the EPs, regardless of the path they took through the scenario, this will be discussed.
This discussion may also be augmented by a videotape display of the specific action or set of actions in question. The operators will be asked to identify possible reasons for procedure-related problems. Again, the questions in the operator debriefing checklist will be used to determine whether the procedure caused the discre-I l
pancy. The operators will be asked to present potential solutions to these problems.
l l
l
- d..
Analyze Videotapes of simulator Runs l
The form shown as Appendix 4G will be used during the analysis of the simulator runs. By comparing the expected operator actions with the actions performed during the scenario, the Independent Review Team will be able to note any discrepancies.
The observers will have made notes on the forms during the scenario runs.
However, it will not be possible to record 4-17
MISSISSIPPI POWER & LIGHT COMPANY
?:.
i all operator actions during the run. A review of the videotapes will be necessary to record all actions and te identify all discrepancies. Comments elicited from the operators during the debriefing will be helpful in the analysis of the videotapes.
4.3.3 validation Resolution Phase The discrepancies identified during assessment will be evaluated in the resolution phase of validation. For some discrepancies, no resolution will be required. Discrepancies that require resolution will be evaluated for the specific type of error involved, and for recommended resolutions.
a.
Classify Discrepancies The purpose of analyzing the discrepancies between expected and actual operator actions will be to identify potential deficiencies in the procedures..Each discrepancy identified during the debriefing and videotape review will be analyzed case by case to determine whether it is a procedural error or an acceptable discrepancy. Figure 4-5 outlines the steps involved in analyzing the discrep-ancies. A discrepancy that adversely affects operator performance or plant conditions will be considered an error.
The Validation Team will use the exercise evaluation criteria developed from INPO 83-006 to assist them in determining whether an error was or was not procedure related. Errors identified as procedural deficiencies will be documented on EP Discrepancy Sheets (Appendix 4C).
When the procedure-related errors have been identified, they will be categorised as follows:
- 1) Error of omission e
Omits an entire task e
omits a step in a task
- 2) Error of comunission e
Selects wrong control Mispositions control e
- 3) Error of sequence
- 4) -Timing error e
Too early e
Too late 4-18
w e
MISSISSIPPI POWER & LIGHT COMPANY IDENTIFY DISCREPANCIES BETWEEN SIMULATOR RUN AND EXPECTED OPERATOR ACTIONS i f WOULD DISCREPANCY HAVE AN ADVERSE NO CATEGORIZE AS EFFECT ON SAFE OR ACCEPTABLE EFFICIENT PLANT DISCREPANCY OPERATION?
YES If CATEGORIZE AS WAS THE ERROR NO ERROR NOT PROCEDURE
- ATTRIBUTED TO RELATED7 PROCEDURES YES If C ATEGORIZE TYPE OF ERROR Figure 4-5.
Flowchart for Discrepancy Analysis 4-19 s
MISSISSIPPI POWER & LIGHT COMPANY t
- 5) Qualitative error e
Too little e
Too much b.
Identify and Incorporate Resolutions Recommendations for discrepancy resolutions will be noted on the EP Discrepancy Sheets by the Independent Review Team and approved by the project manager.
Resolutions will be incorporated into the deficient EPs, and these revised EPs reverified prior to final review and approval.
The OGNS-1 simulator training program will provide periodic feedback on the EPs in an informal manner that effectively uses GGNS-1 material and personnel resources. Regular classroom or simulator instructors will identify any discrepancies or problems with the EPs found during operator training.
4.3 4 Validation Documentation Phase To provide an auditable history of the initial validation of the EPs, all documentation generated during the validation process will be organized for retention. As a minimum, this documen-tation will includes List of Independent Review Team members e
e Evaluation guidelines e
Discrepancy Sheets e
Simulator Exercise Forms Lists of Expected Operator Actions e
4.4 Appendices 4.4.1 Appendix 4A - EP Evaluation Checklist 4.4.2 Appendix 4B - PSTG Discrepancy Sheet 4.4.3 Appendix 4C - EP Discrepancy Sheet 4.4.4 Appendix 4D - EP Verification Completion Record 4.4.5 Appendix 4E - Task Analysis Worksheet 4.4.6 Appendix 4r - Sample simulator Exercise Porm 4.4.7 Appendix 4G - Sample List of Expected Operator Actions 4-20
MISSISSIPPI POWER E LIIHT COMPANY APPENDIX 4 A - EP EVALUATION CHECKLIST Yes jijl N/A Area I.
OVERALL PROCEDURE: WRITTEN CORRECTNESS A.
Legibility 1.
Are the borders adequate on all procedure page s?
2.
Are the text, tables, graphs, figures, and charts legible to evaluator?
B.
Format Consistency Does the procedure contain all sections required by policy?
C.
. Identification Information 1.
Does the procedure title describe the purpose of the procedure?
2.
Does the cover sheet correctly provide the following:
a.
Procedure title b.
Procedure number c.
Revision number d.
Number of pages 3.
Does each page correctly provide the following a.
Procedure number b.
Revision number c.
Page of 4.
Does.the procedure have all its pages in the correct order?
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MISSISSIPPI POWER & LIGHT COMPANY
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N/A Area Yes j
II.
SPECIFIC STEPS, CAUTIONS, AND NOTES A.
Written Correctness
~1.
Information Presentation a.
Are instruction steps numbered correctly?
b.
Are user-optional sequence steps identified?
c.
Are instruction steps constructed to comply with the following:
(1)
Steps deal with only one idea.
(2)
Sentences are short and simple.
(3)
User actions are specifically stated.
(4)
Objects of user actions are specifically required.
(5)
Objects of user actions are adequately stated.
(6)
If there are three or more objects, they are in a list.
(7)
Punctuation and capitalization are proper.
(8)
Abbreviations are correct and understandable to the operator.
(9)
Acronyms are defined the first time and used consistently.
d.
Are instruction steps presented in the correct sequence?
When an action instruction is based on e.
receipt of an annunciator alarm, is the setpoint of the alarm identified?
f.
Are cautions placed properly?
4 A-2
MISSISSIPPI POWER & LIGHT COMPANY Area Yes
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N/A
~
g.
Are cautions constructed to comply with the following?
(1)
They do not contain user actions.
(2)
They do not use extensive punctuation for clarity.
(3)
They make proper use of emphasis.
i.
Are notes properly used?
j.
Are notes properly placed?
k.
Are notes. worded so that they do not contain user actions?
1.
Are numerical values properly written?
m.
Are values specified in such a way' that mathematical operations are not required of the user?
n.
Is a chart or graph provided in the procedure for necessary user calcu-lations?
o.
Are units of measurement in the procedure the same as those used on equipment?
2.
Procedure Referencing and Branching a.
Do the referenced and branched procedures exist?
b.
Is the use of referencing minimized?
c.
Are referencing and branching instructions correctly worded?
(1)
"Go to" (branching)
(2)
" Refer to" (referencing) d.
Are the exit conditions compatible with the entry conditions of the referenced or branched procedure?
. _, _ _ - -. _ _ -. _ _ _ ~. _
l MISSISSIPPI POWER & LIGHT COMPANY Area Yes
- jio, N/A B.
Technical Accuracy 1.
Entry Conditions or Symptoms Information a.
Are the entry conditions of the procedure listed correctly?
b.
If additional entry conditions have been added, do they comply with the following:
-(1)
Appropriate entry conditions for which the procedure should be used.
(2)
Not-excessive 2.
Quantitative Information a.
Do the quantitative values comply with the applicable source document?
b.
Are values used in procedure computed accurately?
c.
When calculations are required, are equations presented with sufficient information for user to use?
r 3.
Plant Hardware Information: Is the following plant hardware specified in the procedure available to the user:
a.
Equipment b.
Controls c.
Indicators d.
Instrumentation 4A-4
P MISSISSIPPI POWER & LIGHT COMPANY APPENDIX 4B - PSM DISCREPANCY SHEET PSM DISCREPANCY SHEET EP
Title:
EP Number:
PSM Step Number:
Discrepancy:
Date Evaluatiori:
Resolutions v
Resolution Approved:
YES NO (Circle One)
Dater Approved by:
Resolution Incorporated by:
Dates 4B-1
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MISSISSIPPI POER & LIGIT CDMPANY APPENDIX 4C - EP DISCREPANCY SHEET EP DISCRWANCY SEET EP
Title:
W Nabe r:
W Step Nabe r Evaluation Criteria Checklist Item Naber:
Discrepancy:
Evaluation:
Date:
Resdlution:
O Resolution Approved:
YES NO (Circle One)
Approved by:
Date Resolution Inoorporated by:
Date:
r.
t MISSISSIPPI PONER & LIGRT COMPANY APPENDIX 4D - EP VERIFICATION COMPLETION RECORD EP VERIFICATION COMPLETION HECORD EP Title Revision:
EP Number:
1.
Verification is complete a.
EP versus PSTG b.
EP versus Writers Guide c.
EP Evaluaton Checklist d.
Tabletop Review e.
Control Room Versus EP 16C 2.
Resolution effected for all applicable Discrepancy Sheets Verification Engineer:
Dates Dates Approved by:
l 4201
MISSISSIPPI POWER E LIGHT COMPANY I.
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9 MISSISSIPPI POWER & LIGNT COMPANY APPENDIX 4F - SAMPLE SIMULATOR EXERCISE FORM EMERGENCY PROCEDURE VALIDATION EP N'. '.
TITLE:
DATE:
4 SYNOPSIS OF EVENT: Plant operating at 1004 power. Minor Pressuriser Code safet/ V31ve leak rapidly degenerates into code safety Valve failure, resulting in a 2.5 X 10 lbm/hr LOCA. Reactor trips on Low Pressure (1820 5
psig) and the subsequent pressure reduction results in ESFAS actuation at 1720 psig.
SEQUENCE EVENT TIME MALFUNCTION DESCRIPTION INTENT 1
00:00:00 ICO9 Initialise at IC 1004 Power 2
00:00:01 RC27A (50%)
Pxr code safety Leak Initiate LOCA 3
00:01:00 RC27A (50%)
Rx Trip at 1820 peig (EP Wo.) Entry Condition 4
00:05:00 RC27A (50%)
ESFAS Actuation (EP No.) Entry Condition 5
00:05:30 MU118 "S'
SI pump trip Challenge RCS Inventory 6
00:09:15 I/O Override PRT Rupture Disc Challenge Failure Containment 4F-1
4 APPENDIX 4G - SAMPLE LIST OF EXPECTED OPERATOR ACTIONS Initial Conditions:
10s power, all stations in " Auto" Simulator /
Control Peference to Room Simulator Procedure Expected Operator Exercise Step Action Differences Discrepancy Category 1.
Recognize RCS pressure 2.
reduction as symptom of abnormal occurrence.
6 Attempt to locate cause O
and correct.
H 3.
EP-X, Perform immediate actions E
steps A-D for reactor trip (EP-X, EP-Y, steps A-D).
Go to EP-Y perform g
steps A-D steps A-D.
Continue attempts g
m to isolate cause.
I H
4.
EP-2, Perform verification of steps A-Z ESFAS Subsystem actuation.
w Verify PORVs shutz if not, shut block valves.
U O
Initiate monitoring of CSFSTs. Branch to EP-XX.
k
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MISSISSIPPI POWER & LIGHT COMPANY 5.
EP TRAINING PROGRAM DESCRIPTION 5.1 Introduction EP training will be a vital element in the overall operator training program at GGNS-1.
A unified effort on the part of the training department and the EP writers will result in operators who are knowledgeable in both the intent and use of these procedures.
5.2 Training Program Development When Seveloping training on EPs, the following major items will be considered The type of operator training to be provided (initial, refresher) e The operator knowledge and skill level required to effectively use e
the EPs The method of operator training to be used (classroom instruction, e
control room walk-throughs, and/or simulator exercises)
The training materials needed to support EP training requirements e
The current operator licensing requirements and guidelines e
5.3 Training Program Objectives The objectives of this training program ares To enable the operators to understand the regulatory requirements a.
for the EPs, by the review oft
+
" Clarification of TMI Action Plan Requirements"
(
e NUREG-0737 Supplement 1
" Requirements for Emergency Response Capability" e
" Guidelines for the Preparation of Emergency Operating Procedures" i
b.
To enable the operators to understand the philosophy behind the approach to the EPs including:
P e
The need for symptom-oriented procedures as opposed to event-oriented' procedures i
The content and use of each EP, including entry conditions and l
e i
exit criteria (i.e., its structure and approach to transient and 5-1
o V
MISSISSIPPI POWER & LIGHT COMPANY accident mitigation, including the control of safety functions, -
accident evaluation and diagnosis, and the achievement of safe, stable, or shutdown conditions) e The use of flowcharts for operator actions 5.4 Training Methods As part of the overall training program, EP training will be included to establish an operating staff that is capable and competent to respond to any off-normal plant situation. This training will consist of classroom instruction, simulator exercises, and/or walk-throughs as appropriate.
5.4.1 Classroom Instruction Classroom instruction will give the operators an understanding of the:
e Structure of the EPs e
Technical basis for procedure steps e
Philosophy behind the procedures e
Relationships among procedures e
Use of flowcharts 5.4.2 Simulator Exercises Simulator exercises will provide practical experience in executing each procedure individually and multiple procedures concurrently. A variety of scenarios, including multiple, simultaneous, and sequential failures, will be used. These scenarios will stress knowledge of the procedure inter-relationships, ability to locate and use instrumentation, and experience in using the procedures.
5.4.3 Control Room Walk-Throughs For those EPs, or portions of EPs, not amenable to simulation, walk-throughs will be conducted. The areas to be emphasized during the walk-throughs are identical to those emphasized during the simulator exercises, but will be addressed in a static, rather than dynamic, environment.
5.5 Requalification Training Annual requalification training will include scenarios requiring use of the EPs.
5-2
7.
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MISSISSIPPI POWER & LIGHT COMPANY 5.6 Training on Revisions Procedure revisions will be reviewed to determine whether retraining is necessary. If necessary, training on minor revisions will be conducted through a program of preshift briefings, lectures, or required reading. Training on major revisions will be conducted by classroom instruction, walk-throughs, and/or the GGNS-1 simulator.
5.7 Operator Feedback Operator feedback will be considered in determining any additional training needs in this area.
5-3
,