ML20116D273

Revised Procedure GP-R-212110R, Procedures Generation Package for Vermont Yankee Nuclear Power Plant

ML20116D273
Person / Time
Site:	Vermont Yankee
Issue date:	01/23/1985
From:	GENERAL PHYSICS CORP.
To:
Shared Package
ML20116D266	List: ML20116D263 ML20116D273
References
GP-R-212110R, NUDOCS 8504290353
Download: ML20116D273 (55)

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PROCEDURES GENERATION PACKAGE FOR THE VERMONT YANKEE NUCLEAR POWER PLANT

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i Prepared for:

VERMONT YANKEE NUCLEAR POWER CORPORATION f

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. GP-R-212110R l

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January 23, 1985 I

I General Physics Corporation Columbia, Maryland 8504290353 850423 PDR ADOCK 05000271 F PDR

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, .' s TADLE OF CONTENTS Section Page

1. I NT RO D UC TION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1 Purpose................................................... 1 1.2 Scope ................................................... 1 1.3 Organization.............................................. 1

2. PLANT-SPECIFIC TECHNIC AL GUIDELINES . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

! 2.1 General................................................... 2 2.2 Program Description....................................... 2 2.2.1 Mechanics of Conversion............................ 2

3. OE WRITER'S GUIDE.............................................. 6 3.1 General................................................... 6 3.2 Document Description...................................... 6

4. OE VERIFICATION PROGRAM........................................ 7 i

4.1 General.'.................................................. 7 4.2 Program Description....................................... 7

5. O E VALI D AT ION P ROG RAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 5.1 General................................................... 9 5.2 Program Description....................................... 9

6. OE TRAINING PROGRAM............................................ 11 6.1 General................................................... 11 6.2 Pro gr am De s cript ion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 6.3 Training Program Goals.................................... 11 6.4 OE Training Methods....................................... 12 6.4.1 Classroom Instruction.............................. 12 6.4.2 Self-Help Supplementation. . . . . . . . . . . . . . . . . . . . . . . . . . 12 6.4.3 Control Room Walk-throughs......................... 12 6.4.4 S imula to r Ex e r cis e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '13

, APPENDIX A OPERATIO.9AL EMERGENCY PROCEDURES WRITER'S GUIDE APPENDIX B VALIDATION USING TABLE-TOP METHOD APPENDIX C VALIDATION USING WALK-THROUGH METHOD APPENDIX D VALIDATION USING SIMULATOR METHOD 1

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1.0 INTRODUCTION

1.1 Purpose ,

The purpose of this Procedures Generation Package (PGP) is to describe the emergency operating procedures development at the Vermont Yankee Nuclear Power Plant.

r The EOPs are designated as Operational Emergency Procedures (OEs) and will be referred to as OEs in this document.

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1.2 Scope 1

This document was developed in response to Supplement 1 to NUREG-0737, Item 7.2b.

I 1.3 Organ!zation 3

This document consists of the following six parts:

I l-I e Introduction e Plant-Specific Technical Guidelines e OE Writer's Guide (as Appendix A) e OE Verification Program l

o OE Validation Program I e OE Training Program

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, Each part describes the approach taken as part of the overall OE Implementation Plan for Vermont Yankee.

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, , GP-R-212110 GENERAL PHYSICS CORPORATION 2.0 PLANT-SPECIFIC TECHNICAL GUIDELINES l 2.1 General l

The following methodology for converting the General Electric Emergency Procedure Guidelines (EPGs) into OEs has been developed and will be used by

. Vermont Yankee.

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, j The EPGs, Revision 3, will be used for the initially implemented OEs.

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The following major items were considered in the methodology to be l nsed l

i 3- e Process for conversion from Generic to Plant-Specific Technical i Guidelines

! e Location of the plant-specific technical information 1

e How the plant-specific technical information will be used e The use of other plants EOPs '

e Documentation requirements

• l e Use of the background information supplied with technical guidelines 2.2 Program Description j

1 , 2.2.1 Process for Conversion from Generic to Plant-Specific Technical Guidelines i

, 2.2.1.1 Preparation The designated OE writing team will obtain and review

! the following plant-specific technical information (OE i

source documents):

J jj e General Electric EPGs, Revision 3A, with background i

information e Vermont Yankee FSAR l e Vermont Yankee Operational Emergency Procedures (OEs) Writer's Guide which is based on the industry I '

j document Emergency Operating Procedures Writing j Guideline (INPO 82-017) developed by the Emergency 2

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'i Operating Procedures Implementation Assistance (OEPIA) Review Group and published by INPO.

e Technical Specifications for Vermont Yankee e Current Plant drawings I~

I 2.2.1.2 Writing OEs

! The OE writing team will follow the intent of each of the EPGs adding plant specific information where a

designated. Concurrently, the writers will review appropriate OE source documents. Where exceptions to the EPGs are taken in the OEs, these will be documented.

2.2.1.3 Initial Draf t of the OEs The Operational Emergency Procedures Writing Team (OEWT) will prepare the OEs in accordance with para. 2.2.1.1 of the PGP. These will be submitted for review to the Operation Review Team and the OE Coordinator. The OEWT will then re-write the OEs utilizing the results of this i review and prepare a report consisting of a cross-reference between the BWROG EPG steps and the OE steps, as well as a list of deviations from the BWROG EPG.

l The OEs and the report prepared by the OEWT will be submitted for review by both the Independent Review Team (IRT) and the Operational Emergency Procedures Coordinator (OEC). The IRT will prepare a report of their findings and submit it to the OEC and will be utilized in the preparation of the Plant-Specific ,

Technical Guidelines and subsequent revisions of the  !

OEs.

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i The OEC will review the reports from both the OEWT and i

He will make recommendations for resolution of the IRT.

! their findings and comments. These recommendations will l

l be documented in a report which, together with those f, reports submitted by the OEWT and IRT, will be forwarded 3

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• n GENERAL PHYSICS CORPORATION to the Senior Operations Engineer, a permanent member of the plant operations staff, for review and approval.

The Senior Operations Engineer will initiate a tracking 7._

system indicating the status of those deviations for which it is determined that (1) inadequate justification

/ has been provided or (2) would require a safety evaluation. It is his responsibility to ensure that the

< status of all deviations are resolved prior to k implementation of the OEs.

The OEC will revise the OEs with the approval of the Senior Operations Engineer and Operations Supervisor.

1 The OEs will then be submitted to the Plant Operations

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Review Committee (PORC) for their review and

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recommendation for approval for Operator Training /OE validation.

Af ter obtaining PORC recommendation for approval, the OEs will be submitted to the Plant Manager, and subsequently to the Manager of Operations for their review for use in Operator training /OE validation.

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2.2.1.4 Revisions to Initial Drafts of OEs Any deviations from or additions not provided for in the i BWROG EPGs which are required to resolve recommendations resulting from the verification / validation of the OEs f will be documented by the OEC. These deviations and

, additions, together with the justification for deviation, will be submitted to' the Operations Engineer for his review and approval.

Revisions of the OEs will be submitted to the ORT and the Operations Supervisor for review and recommendation.

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Prior to implementation, the revised OEs and all additions not provided for in the BWROG EPGs together jq with their justification, will be submitted to PORC for their review and recommendation for approval, and forwarded to the Plant Manager.

f i lI The Plant Manager will review the completed OEs and related information as described above. With his

,. approval these will be forwarded to MOO for final review and approval.

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4 3.0 OE WRITER'S GUIDE 1

j< 3.1 General 4

The OE Writer's Guide provides specific, detailed instructions on writing OEs and flowchart guidelines. In addition to establishing sound writing

) 7-principles, the guide promotes consistency among all OEs and their revisions, l independent of the OE writer. The Writer's Guide is based on the industry document Emergeneg_ Operating Procedures Writing Guideline (INPO 82-017 ),

V developed by the EOPIA Review Group and published by INPO.

l 3 2 ~ Document Description 1

I lJ" Information on the following major items is included in the plant- l

! specific Writer's Guides i

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! e OE Definition

, e OE Format j . e Writing Instructional Steps j

i e Mechanics of style e Typing Format i

e Flowchart Guidelines i

1 I The Vermont Yankee Operational Emergency Procedures briter's Guide is 1

provided as Appendix A.

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4.0 OE VERIFICATION PROGRAM 4.1 General

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OE verification is the evaluation performed to confirm the written correctness of the procedure and to ensure that applicable generic and plant-(-- specific technical information has been incorporated properly. This l evaluation also checks that the human factors aspects presented in the Writers Guide for OEs have been applied.

4.2 Program Description When developing this OE verification program, the following items were

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considered:

e How OE verification will be performed e How completion of the OE verification process will be documented e What process will be used in resolving discrepancies i

The verification program is based on the industry document Emergency Operating Procedures verification Guideline (INPO 83-004), developed by the OEPIA Review Group and published by INPO.

The following is e description of the four objectives of the Verification Progran and how this verification is to be performed, documented, and the process used in resolving discrepancies:

F 4.2.2 Third-Party Review Process 4

Objectives:

e' Verify that the OEs are technically correct, in that they accurately reflect the technical guidelines and other OE source documents.

= Verify that the OEs are written correctly; i.e., they accurately reflect the plant-specific writers guide.

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2 5.0 OE VALIDATION PROGRAM I i

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$ ,_ 5.1 General l I

OE validation is the evaluation performed to determine that the actions j specified in the procedure can'be performed by the operator to manage the I

emergency conditions effectively. The OE validation will evaluate the  !

I operator's ability to manage emergency conditions using the OEs and control I'l 1

l room hardware. It will validate that part of the OE not covered by any I

,- technical validation of generic technical guidelines.

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5.2 Program Description  !

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, In developing the OE validation program, the following major items were l

f considered: i

, < e How OE validation will be performed  ;

o How to use simulators, walkthroughs, or table top methods of [

l validation i, l e How operating and training experience will be integrated into the program evaluation  !

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e The evaluation criteria to be applied and the methods to be followed l l in resolving discrepancies j o How completion of the OE validation process will be documented i fI j! The program was based on the industry document Emergency Operatinq

! ( Procedures Validation Guideline (INPO 83-006), developed by the OEPIA Review 4

j Group and published by INPO. The Vermont Yankee validation program for 1

j i Emergency Operating Procedures addresses the following objectives  ;

e The OEs are unable, i.e., they can be understood and followed with a

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j minimum of confusion, delays, and errors.

I e A correspondence exists between the procedures and the control room / plant hardware.

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. GP-R-213110 GENERAL PHYSICS CORPORATION e The instru:tions presented in the OEs will be consistent with the shif t manpower, qualifications, training, and experience of the operating etaf f.

e Assurance that the procedures will work, i.e., that the procedures guide the operator in mitigating transients and accidents.

A description of the methodologies of Table-Top Validation, Walk-Through Validation, and Simu:ator Validation are provided as Appendices B, C and D, respectively.

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6.0 OE TRAINING PROGRAM l l 6.1 General l <

OE training will be a vital element in the overall operator training

! -, program at Vermont Yankee. A unified ef fort on the part of the training ii

! departmant and the OE writers will result in operators who are knowledgeable in both the use and the intent of these procedures.  !

l i 6.2 Program Description

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l In developing training in the area of OEs, the following major items were ,

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e What type of operator training should be provided (initial, refresher) e What method of operator training should be followed i e What operator knowledge and skill level is required i i e What procedure tasks exist that require operator decision-making e What training material is'needed to support OE training requirements

!L e What current operator licensing requirements or guidelines exist

( 63 Training Program Coals The initial overall training goals for OE training are as follows:  ;

I j e To enable the operators to understand the structure of the OEs j

e To enable the operators to understand the technical basis of the OEs [

e To enable the operators to have a working knowledge of the technical  ;

content of the OEs ,

I e To enable the operators to use the OEs under operational conditions l L.  !

The following sections outline the approach to be used to train licensed I operators on OEs.  !

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• GP-R-212110 GENERAL PHYSICS CORPORATION 6.4 OE Training Methods s

As part of the training program, OE training will be included to l g- establish an operations staff which is capable and competent to respond to any t

I off-normal plant situation. This training will consist of classroom instruction, control room walk-throughs, and simulator exercises:

6.4.1 Classroom Instruction y_-

l Classroom instruction sessions will be conducted. Included in the information presented during this method will be the following:

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.-- e The logic behind the development of OEs e The process used to develop the OEs e The OEs themselves, including supporting technical and human i factors information 6.4.2 Self-Help Supplementation Classroom instruction will be supplemented by self-help techniques.

d. Se'.f-help essentially entails having the trainees review and study the information presented in the classroom instruction via required readings. Trainees will be permitted to implement self-help during shif ts when they are not performing required duties.

6.4.3 Control Room Walk-Throughs I

E An important part of the instruction on OEs will be the practical

experience gained through procedure walk-throughs in the control room.

f During this method of training, the team approach to using OEs will be stressed. This walk-through training will also concentrate on l information flow and interactions of the operators in the control room.

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6.4.4 Simulator Exercises Training on OEs will be conducted for all licensed operators using

- scenarios on a control room simulator. Training will be conducted with all operators performing their normal control room functions. Additional training will be conducted where the members of a crew alternate  !

l responsibilities. This additional training promotes understanding of the  ;

other operator's responsibilities in the overall conduct of the actions,  !

t and will lead to enhanced communications within the control room.

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I APPENDIX A OPERATIONAL EMERGENCY PROCEDURES WRITER'S GUIDE F

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7 TABLE OF CONTEi.TS L

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1. Introduction................................................... 1

1.1 Purpose and Scope

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i I 2. Flowchart Guidelines........................................... 2 2.1 Identification Information............................... 2 i

2.2 Contents................................................. 2 2.3 Symbol Coding............................................ 3 2.4 Nomenclature / Punctuation................................. 4 2.5 Functional Flow and Branching............................ 4

. 2.6 Readability / Style........................................ 5 i

' 5 2.7 Ease of Use..............................................

2.8 Flowchart Instruction Step Length and content............ 5 2.9 Use of Logic Terms....................................... 6 2.10 Commands................................................. 7 2.11 Component Identification................................. 7 2.12 Level of Detail.......................................... 8

3. Appendices Guidelines.......................................... 9 3.1 OE Appendix Procedures Numbering......................... 9 3.2 Cover Sheets............................................. 9 3.3 Procedure Numbering...................................... 9 3.4 Revision Numbering....................................... 9 3.5 Revision Identification.................................. 9 3.6 Page Identification and Numbering. . . . . . . . . . . . . . . . . . . . . . . . 10 3.7 Page Format.............................................. 10 o

3.8 Appendix Organization.................................... 10 t

3.9 Section Numbering........................................ 11 3 10 Instruction Step Length and Content...................... 11 3 11 Us e o f Lo g i c Te rms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 3.12 Component Identification................................. 13 3.13 Lev e l o f De t a i 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 3.14 General Typing Format.................................... 14

3.15 Heading and Text Arrangement............................. 14 3.16 B re a k i n g o f Wo rds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

4. Mechanics of Style............................................. 15 4.1 Spelling................................................. 15 4.2 Hyphenation.............................................. 15 1 4.3 Punctuation.............................................. 15 I 4.4 vocabulary............................................... 16 4.5 Numerical Values......................................... 17

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4.6 Abbreviations, Letter Symbols, and Acronyms.............. 17

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SECTION 1. INTRODUCTION

1.1 Purpose and Scope

The purpose of this writer's guide is to provide administrative and technical guidance on the preparation of Operational Emergency Procedures f' (OEs) and associated flowcharts. The writer's guide applies to the writing of l

all OEs and flowcharts.

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SECTION 2. FLOWCHART GUIDEIINES 9 .

2.1 Identification Information 2.1.1 Information Sufficiency

a. The path number and title shall appear on each flowchart.

b. The date of issue / revision shall appear on each flowchart.

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c. Identification information shall be provided on end path procedures to provide rapid identification.

2.1.2 Informat5on Consistency

a. The location / format of identification information shall be consistent for each flowpath and end path procedure.

.2.2 contents 2.2.1 Clarity and Conciseness

a. Flowpath actions shall be written as short, concise h statements.

b. Statements within caution and information blocks shall be cJear and concise.

c. Questions in decision blocks shall be written clearly.

d. Adverbs and articles shall be used as little as possible in flowpaths.

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• • The use of double negatives shall be avoided.

j 2.2 2 consistency of Terminology

a. Terms within and among flowcharts shall be consistent.

b. Caution and information blocks shall not deliver commands.

c. Action blocks shall contain action instructions as specific verbs.

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d. All decision blocks shall require a yes/no response.

2.2.3 Complexity

a. The number of actions called out per action block shall be no greater than one.

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b. Decision blocks using "and/or" logic should be avoided.

c. Numerous objects of actions appearing in an action block l shall be listed and bulleted for ease of identification.

2.2.4 Sufficiency and Appropriateness of Information

a. Any graphs or tables that are included in action blocks shall

! be adequate for readability and extraction of values.

I b. The operator shall not be required to leave the flowchart l

prior to entering the end path procedure to acquire additional information.

c. Values utilized in the flowcharts shall correspond to the values that the operator will obtain from plant instrumentatior..

2.3 Symbol coding 2.3.1 Standardization

a. Flowchart symbols shall be those that are commonly used and L recogaized in the industry.

2.3.2 Ease of Identification

a. Major symbol blocks (action blocks, decision blocks, caution /information blocks, key parameter blocks) shall be readily detected and discriminable.

b. Symbols shall be used to direct the operator from the flowchart to the correct End Path procedure (Path-to-End Path symbols); and they shall be adequately coded for ease of 4

t identification.

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c. Symbols shall be used to aid the operator in finding the correct entry point into a flowchart (Path-to-Path symbols);

l and they shall be adequately coded for ease of identification.

d. Symbol coding shall be used consistently.

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r GP-R-212110 GENERAL PHYSICS CORPORATION 2.4 Nomenclature / Punctuation I*

2.4.1 Use of logic words

a. Conditional statements shall be written so that the I description of the condition appears first, followed by the action instructions.

r l 2.4.2 Abbreviations

a. Abbreviations shall be used with discretion and shall be i

supported by an abbreviations list.

b. Abbreviations shall be used consistently within and among I flowcharts.

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a. Punctuation shall be used in flowcharts to aid the user, e.g. , periods to help operators separate action statements ; a question mark to aid in identification of interrogative statements.

2.4.4 Methods of Emphasis

a. Conditional statements shall be underlined.

b. Commands shall be bold type.

2.5 Functional Flow and Branching 2.5.1 Grouping of Paths

a. The spacing of paths shall be sufficient to allow operators easy and accurate movement through flowchart branches.

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b. The direction of flow shall be apparent through the use of directional arrows.

2.5.2 Ordering / Entry

a. Instructional and caution blocks shall be placed immediately ahead of the blocks to which they apply.

b. There shall be adequate means for returning the user to the correct branch in the flowchart after exiting.

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c. Paths / actions shall be presented in the order of importance 1

and use.

,.i 2.5.3 Consistency of Branching Methods

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a. Branching methods shall be used consistently.

y_ 2.6 Readability / Style l

2.6.1 Character Size 2 a. Character size shall be sufficient to permit rapid and accurate recognition under conditions of normal and emergency lighting.

2.6.2 Character style l a. The character style shall meet human factors standards.

I b. The spacing between letters and words shall provide for rapid and accurate character recognition.

2.7 Ease of Use 3' L 1

2.7.1 Verification provisions l-

I a. The flowcharts shall be designed to permit tracking of i

movement through its branches.

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4 I 2.7.2 Size of Flowcharts

a. Flowcharts shall not be too large to permit ease of use.

4 2.8 Flowchart Instruction Step Length and Content Flowchart instruction steps will be succinct and precise in that 1 5 succinctness denotes brevity; preciseness means exactly and correctly l

l, . defined. General rules to be used in meeting these objectives are as follows:

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a. Instruction steps should deal with one idea only.

I b. Short, simple sentences should be used.

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l l,, c. Complex evolutions should be described in a series of steps, with each step made simple.

d. Objects of operator actions should be specifically stated.

l e. Limits should be expressed quantitatively.

f. Identification of components and parts should be technically correct

(-- and complete.

-k g. When a<:tions are required based upon receipt of an annunciated alarm,

-- the alarm set point should be listed.

h. If required for proper understanding, describe the system response time associated with performance of the instruction.

l 1. When system response dictates a time frame within which the instruction must be accomplished, denote the time frame. However, avoid using time to initiate operator actions, as operator actions should be related to plant parameters.

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j. When anticipated system responses may adversely affect instrument indications, (1) describe the conditions that will likely introduce instrument error and, (2) describes a means of determining if instrument error has occurred using a CAUTION.

k. When additional confirmation of system response is considered necessary, prescribe the backup readings to be made.

2.9 Use of Logic Terms

, When logic statements are used, logic terms will be highlighted so that

< all the conditions are clear to the operator. Highlighting will be achieved by underlining. Use logic terms as follows:

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a. Avoid the use of AND and OR within the same action. When AND and OR

' I are used together, the logic can be very ambiguous.

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b. When attention should be called to combinations of conditions, the word AND shall b,e placed between the description of each condition.

The word AND shall not be used to join more than three conditions.

In four or more conditions need to be joined, a list format shall be used.

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. c. The word OR shall be used when calling attention to alternative combinations of conditions. The use of the word OR shall always be t

l in the inclusive sense.

i i d. When action steps are contingent upon certain conditions or 1

I~~ combinations of conditions, the step shall begin with the words II; or i.l WHEN followed by a description of the condition or conditions, a 1

comma, and the word THEN followed by the action to be taken. WHEN is l

l used for an expected condition. IE; is used to determine the specific I ,

course of action based upon plant conditions.

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e. Use of IF NOT should be avoided.

2.10 Commands Commands shall be highlighted by the use of bold type.

2.11 Component Identification I

( The following rules are to be followed with regard to component identification:

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a. Equipment, controls, and displays will be identified in operator language (common usage) terms.

b. When the engraved names and numbera on legend plates and alarm windows are specifically the item of concern in the procedure, the

, i engraving should be quoted verbatim.

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c. The names of plant systems titles are emphasized by initial 5

capitalization.

d. If the component is seldom used or difficult to locate, location information should be given I

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• GP-R-212110 GENERAL PHYSICS CORPORATION 2.12 Level of Detail The level of detail required is the detail that a newly trained and

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licensed operator would desire during an emergency condition. To assist in determining the level of detail, the following rules apply:

a. For control circuitry that executes an entire function upon actuation of the control switch, the action verb appropriate to the component suffices without further amplification of how to manipulate the control device; recommended action verbs to be utilized are:

1. For power-driven rotating equipment: Sta rt , Stop

2. For valves: Open, Close, Throttle Open, Throttle close, Throttle j'

l 3. For power distribution breakers: Synchronize and Close, Trip.

b. For multiposition control switches that have more than one position for a similar function: placement to the desired position should be specified.

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. GP-R-212110 - GENERAL PHYSICS CORPORATION SECTION 3. APPENDICES GUIDELINES OE Appendices are detailed operator instructions supporting the OEs.

They are referred only in and by the OEs.

r 3.1 OE Appendix Numbering Each OE Appendix shall be uniquely identified. This identification permits easy administration of the process of procedure preparation, review, revision, distribution, and operator use. A descriptive title is to be used that also designates the scope.

3.2 Cover Sheets

+

Every OE Appendix shall have a cover sheet. The primary purposes of this cover sheet are, (1) to identify the procedure it supports and, (2) to

! identify the authorized revision.

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3.3 Appendix Numbering Appendices will be numbered as follows:

OE 31XX Appendix A

3.4 Revision Numbering

.s Two digits following the "Rev" abbreviation will be used to designate procedure revision levels:

• Rev 01

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3.5 Revision Identification A change bar located in the left margin alongside the text change will be used to indicate a lef t-hand column change; a change bar located in the right margin alongside the text change will be used to indicate a right-hand column change.

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• . GP-R-212110 GENERAL PHYSICS CORPORATION 3.6 Page Identification and Numbering Each page of the procedure will be identified by:

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1. The procedure number followed by the Appendix number

2. The revision number

3. The page number, written as "Page of ."

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The Appendix number and revision number will be located at the top right of each page. The page number will be centered at the bottom of each page.

3.7 Page Format f~

f A dual-column format will be used in which the lef t-hand column is designated for operator actions and notes, and the right-hand column is designated for information and caution.

3.8 Appendix Organization I The following section headings will be used for all Appendices.

1. PREREQUISITES - A listing of any initial conditions which must be established before starting the procedure.

- 2. PROCEDURE - A sequential listing of operator steps. The entry conditions will be those plant parameters which, when exceeded, i require entry into and execution of the OE.

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( 3. RESTORATION - A sequential listing of steps for returning of systema

{ and conditions to normal. The operator actions will be succinct, identifiable instructions that give appropriate directions to the l

t,, user.

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GP-R-212110 GENERAL PHYSICS CORFORATION 3.9 Section Numbering In the following format will be utilized in section numbering:

f I 1. The first section shall be designated by a capital letter.

2. The second section shall be designated by a number.

l 3. The third section (if required) shall be designated by a lower case letter.

3 10 Instruction Step Length and content Instruction steps will be succinct and precise and will be located in the r instructions column of the right hand page. Succinctness denotes brevity; preciseness means exactly and correctly defined. General rules to be used in meeting these objectives are as follows:

1. Instruction steps should deal with one idea only.

2. Short, simple sentences should be used.

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3. Complex evolutions should be described in a series of steps, with each step made simple.

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4. Objects of operator actions should be specifically stated.

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5. For instructional steps that involve an action verb relcting to three or more objects, the objects will be listed with space i provided for operator checkoff.

6. Limits should be expressed quantitatively.

f 7. Identification of components and parts should be technically l.

correct and complete.

8. When actions are required based upon receipt of an annunciated alarm, the alarm set point should be listed.

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GP-R-212110 GENERAL PHYSICS CORPORATION

9. If required for proper understanding, describe the system response time associated with performance of the instruction.

11. When system response dictates a time frame within which the instruction must be accomplished, denote the time frame. However, avoid using time to initiate operator actions, as operator actions should be related to plant parameters.

12. When anticipated system response may adversely affect instrument indications, (1) describe the conditions that will likely introduce instrument error and, (2) describes a means of determining if instrument error has occurred by using a CAUTION.

13. When additional confirmation of system response is considered necessary, prescribe the backup readings to be made.

1 3.11 Use of Logic Terms i

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! k Use logic terms as follows:

1. Avoid the use of AND and OR within the same action. When AND and OR are used together, the logic can be very ambiguous.

. 2. When attention should be called to combinations of conditions, the word AND shall be placed between the description of each condition.

The word AND shall not be used to join more than two conditions. If

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{ two or more conditions need to be joined, a list format shall be used.

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3. The word OR shall be used when calling attention to alternative combinations of conditions. The use of the word OR shall always be l

L in the inclusive sense.

4. When action steps are contingent upon certain conditions or combinations of conditions, the step shall begin with the words II[ or 6

WHEN followed by a description of the condition or conditions, a

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l GP-R-212110 GENERAL PHYSICS CORPORATION comma, and the word THEN followed by the action to be taken. WHEN is used for an expected condition. j[F,is used to determine the specific course of action based upon plant conditions.

5. Use of IF NOT should be avoided.

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l 3.12 Component Identification The following rules are to be followed with regard to component

identification

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1. Equipment, controls, and displays will be identified in operator

j. language (common usage) terms.

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l 2. When_the engraved names and numbers on legend plates and alarm i

I windows are specifically the item of concern in the procedure, the engraving should be quoted verbatim and emphasized by using all capitals.

3. The names of plant systems titles are emphasized by initial f

l capitalizatior..

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4. If the component is seldom used or difficult to locate, location information should be given.

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3.13 Level of Detail {

t The level of detail required is the detail that a newly trained and

!( licensed operator would desire during an emergency condition. To assist in determining the level of detail, the following rules apply:

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1. For control circuitry that executes an entire function upon actuation of the control switch, the action verb appropriate to the component l

suffices without further amplification of how to manipulate the control devicer recommended action verbs to be utilized are:

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. " GP-R-212110 GENERAL PHYSICS CORPORATION l

a. For power-driven rotating equipment: Start, Stop.

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b. For valves: Open, Close, Throttle Open, Throttle Close, Throttle.

c. For power distribution breakers: Synchronize and Close, Trip.

2. .For multiposition control switches that have more than one position g

for a similar function: placement to the desired position should be

! specified.

3.14 General Typing Format The following general requirements are to be followed:

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1. Paper size should .be 8-1/2 X 11 inches.

2. White, bond paper should be used.

3.15 Heading and Text Arrangement Block style should be used. First-level section headings shall be in full capitals and bold typer second-level section headings shall be in full capitals; and third-level section headings shall be placed in initial capitals.

1. Section numbers shall begin at least five spaces from the left-hand printed border.

2. At least three line spaces shall be allowed between headings and respective text.

3. At least two line spaces shall be allowed between paragraphs.

4. Text will be typed using single line spacing.

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3.16 Breaking of Words Breaking of words shall be avoided.

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, GP-R-212110 GENERAL PHYSICS CORPORATION SECTION 4. MECHANICS OF STYLE 4.1 Spelling Spelling should be consistent with modern usage. When a choice of spelling is offered by a dictionary, the first spelling should be used.

4.2 Hyphenation 9

, Hyphens are used _between elements of a compound word when usage calls for it. The following rules should be followed for hyphenation:

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1. When doubt exists, the compound word should be restructured to avoid hyphenation.

2. Hyphens should be used in the following circumstances:

a. in compound numerals from twenty-one to ninety-nine.

b. in fractions.

c. in compounds with "self".

d. when the last letter of the first word is the same vowel as the first letter of the second word.

e. when misleading or awkward consonants would result by joining the words.

f. to avoid confusion with another word.

g. when a letter is linked with a noun.

4.3 Punctuation Punctuation should be used only as necessary to aid reading and prevent i

misunderstanding. Punctuation should Le in accordance with the following rules:

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GP-R-212110 GENERAL PHYSICS CORPORATION

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1 4.3.1 Brackets d

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, Brackets are not to be used.

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4.3.2 Colon i

b Use a colon to indicate that a list of items is to follow.

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4.3.3 Parentheses l

Parentheses shall be used to indicate alternative items in a procedure, instruction, or equipment numbers.

4.3.4 Period Use a period at the end of complete sentences and for indicating the decimal place in numbers.

4.4 Vocabulary Words used in procedures should convey,the proper understanding to the trained person. The following rules apply:

1. Utilize simple words (i.e. short words of few syllables).

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2. Utilize common usage.

, 3. Utilize words that are concrete rather than vague, specific rather than general, familiar rather than formal, precise rather than blanket.

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4. Define key words that may be understood in more than one sense.

5. Verbs with specific meanings should be used.

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GP-R-212110 GENERAL PHYSZCS CORPORATION e 6. Equipment status should be denoted as follows:

a. Operable / Operability /Available - These words mean that a system, subsystem, train, component, or device is capable of performing its specified function (s) in the intended manner.

b. Operating - This word means that a system, subsystem, train, I

component, or device is in operation and is performing its specified function.

4.5 Numerical Values The use of numerical values should be consistent with the following rules:

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1. Arabic numerals should be used.

l 2. For numbers less than unity, the decimal point should be preceded by a zero; for example: 0 . 1.

3. The number of significant digits should be equal to the number of significant digits available from the display (and required by the necessary reading precision of the operator).

4. Acceptance values should be specified in such a way that addition and subtraction by the user is avoided if possible. This can be done by stating acceptance values as limits.

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{ 5. Engineering units should always be specified for numerical values of process variables, and should be the same.

i 4.6 Abbreviations, Letter Symbols, and Acronyms l

The use of abbreviations should be minimized. Abbreviations may be used

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where necessary to save time and space, and when their meaning is I

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GP-R-212110 GENERAL PHYSICS CORPORATION I

. unquestionably clear to the intended reader. Consistency should be maintained throughout the procedure.

Capitalization of abbreviations should be uniform. If the abbreviation is comprised of lowercase letters, it should appear in lowercase in a title or r

heading. The period should be omitted in abbreviations except in cases where the omission would result in confusion.

Letter symbols may be used to represent operations, quantities, elements, relations, and qualities. -

The symbol 'L' will be used to provide a space for the operators to check off each procedural step as it is completed.

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' APPENDIX B OPERATIONAL EMERGENCY PROCEDURES VALIDATION USING TABLE-TOP METHOD i

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O OE Validation Using Table-Top Method The table-top method conL sts of four phases: planning, preparation for and conducting the evaluation, nd resolving the OE discrepancies which are found during the evaluation.

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1. Planning the Table-Top Method The planning phase consists of the following activities:

- 1.1 Designate Evaluator (s) - When the table-top method has been designated as being the most effective method for a given validation session, table-top evaluators who are skilled in plant operations, procedures, training and test evaluation methods will be appointed.

I 1.2 Review the Test Plan - As part of planning for a table-top, a

test plan will be developed. Developing a test plan will require consideration of the following

a. Purpose of conducting the validation

1) Specific objective (s) to be tested

2) Specific principles and guidelines to be tested I

( b. Selection of scenarios required to satisfy validation objectives to be tested

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c. How OEs are to be tested

d. Rules for plant personnel and evaluator behavior during

' validation

e. Detection and classification of errors

f. Administration of test plan

2. Preparing for the Table-Top Af ter the resources to support the table-top have been selected, the evaluator (s) will:

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2.1 Arrange for use of required OEs, specifications, and related technical documentation.

2.2 Arrange for the use of room equipped with adequate surface to

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lay out OEs and related documentation.

2.3 Review event scenarios already developed and select those which are appropriate for the table-top method.

2.4 Arrange for the use of required plant personnel, giving consideration to the advantages / disadvantages of the following arrangements that can be used with the table top

4 l a. One-on-One - One member of the observer / review team and one plant person.

, b. One-on-Crew - One member of the observer / review team and an l operrting crew.

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c. Team-on-Crew - The observer / review team and the operating crew.

d. Team-on-One - The observer / review team and one plant person.

! 3. Conducting the Table-Top

! 3.1 The evaluators' leader shall:

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a. Provide the evaluators with a copy of the OEs to be validated and debriefing forms. 1 i

( b. Review with the entire team how the table-top will be  !

l conducted.

c. Review the overall objective and technique of the table-top with plant personnel who are taking part in the validation. ,

d. Provide the plant personnel with a copy of the OEs to be validated.

j e. Review the use of the debriefing form with the plant ,

( personnel.

f. Provide plant personnel and evaluators with a copy of the scenarios.

l , g. Review the event-sequences and scenarios and any underlying

! assumptions about them.

I j 3.2 Plant personnel shall:

a. Use the OEs as the evaluator (s) lead them through the scenario.

3.3 At the end of the scenarios, the evaluator should:

a. Interview the plant person (s) to find out if the OEs are understandable and sensible in terms of operating the pint.

I I b. Document discrepancies which are found in the OEs.

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c. Forward a copy of discrepancies to the OEPC.

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I APPENDIX C OPERATIONAL INERGENCY PROCEDURES VALIDATION USING WALK-THROUGH METHOD l

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OE VALIDATION USING WALK-THROUGH METHOD i

1. Review the Test Plan As part of planning for a walk-through, a test plan will be developed. Developing a test plan will require consideration of the

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following:

1.1 Purpose of conducting the validation

a. Specific objective (s) to be tested

b. Specific principles and guidances to be tested 1.2 Selection of scenarios required to satisfy validation objectives to be tested.

1.3 How OEs are to be used.

I 1.4 Rules for plant personnel and evaluator behavior during validation 1.5 Detection and classification of errors 1.6 Administration of test plan.

2. Preparing for the Walk-Through 2.1 After the resources to support the walk-through have been selected, the evaluator (s) will:

a. Provide the plant personnel with a copy of the OEs to be l validated.

b. Review the use of the observation and debriefing forms with the plant personnel.

c. Feview with event sequences and scenarios and any underlying assumptions about them.

d. Arrange for use of specific type of equipment.

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1) Real equipment

2) Dynamic simulators

3) Mock-up

4) Operator auxiliary equipment (e.g. , respirators, protective clothing, radiation detectors) if required

5) Audio / Visual (A/V) equipment

e. Arrange for the use of required personnel

1) Real operating crew

2) Non-operating specialists

3) Observer / review team

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4) A/V equipment I

l f. Review event scenarios already developed and select those which are appropriate for the walk-through method.

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j 3. Conducting the Walk-Through 3.1 The evaluators' leader shall: '

! a. Review with the evaluators the responsibilities of each member, clarifying all questions concerning use of forms or

, use of videotape.

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b. Review the overall objective and techniques of the walk-through with plant personnel who are participating in the walk-through.

c 3.2 Plant personnel shall:  ;

F-l a. Walk / talk through actions they would take during specific situations covered by the event-sequence (s) and scenario (s).

b. Describe actions they are taking i

c. Identify information sources used to take actions i d. Identify controls used to carry out actions, expected system response (s), how response (s) verified, and action (s) to be taken if response (s) did not occur.

3.3 Evaluator 1 shall:

a. Direct walk-through I.

b. Coordinate efforts of plant personnel, evaluators and video team.

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c. Review scenario (s)

d. Ask appropriate "what if" questions

e. Note problems and discrepancies encountered by plant personnel.

i 3.4 Evaluator 2 shall:

a. Track plant personnel usage of OEs

b. Record discrepancies and problems encountered by plant personnel.

c. Ask appropriate "what if" questions i ,

I 3.5 Evaluator 3 (if used) shall:

a. Track plant personnel usage of OEs.

b. Record discrepancies and problems encountered by plant personnel on Attachment 6.

c. Coordinate A/V with videotape crew.

d. Ask appropriate "what if" q testions t~

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APPENDIX D VALIDATION USING SIMULATOR METHOD t

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( CONTENTS 7

Page

1. INTRODUCTION.................................................... 1

'g 1.1 B a c k gr ou n d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

! 1.2 Objective and Scope....................................... 1 i

2. METHODOLOGY FOR SIMULATOR VALIDATION............................ 3 2.1 Performance of Simulator Runs............................. 3

-1 3. ANALYSIS AND FRESOLUTION........................................ 4

, 3.1 Debriefing of Operators................................... 4 3.2 Analysis of Videotapes.................................... 4

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-; REFERENCES .......................................................... 7

l. APPENDIX A - Debriefing Guidelines

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1.1 INTRODUCTION

i 1.1 Background f The Nuclear Regulatory Commission " Requirements for Emergency Response j Capability" (Ref. 1) discusses an upgrade for emergency operating procedures (EOPs). The goal of the upgraded emergency operating procedures is to

" improve human reliability and the ability to mitigate the consequences of a j broad range of initiating events and subsequent multiple failures or operator t errors, without the need to diagnose specific events" (Ref. 1, p . 15). A functional orientation, rather than event basis, and human factors considerations are to be incorporated into procedures to achieve this end.

The requirements for upgrade of EOPs include a submittal from licensees

, at least three months prior to formal operator training on the upgraded procedures. The submittal, called a Procedures Generation Package (PGP), is l~ to include:

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(1) plant-specific technical guidelines l (2) writer's guide (3) description of validation program (4) description of training program This document is intended to fulfill a portion of the requirements for a description of the validation plan, i.e., a description of the Operating Emergency Procedures (OEPs) Simulator Validation Plan. It is.also intended to describe the validation methodology in detail that will permit vermont Yankee personnel, in conjunction with human factors specialists, to conduct an initial validation of the OEPs. The methodology can be adapted in part or as i a whole for an ongoing procedure validation program.

1.2 Objective and Scope The " Guidelines for the Preparation of Emergency Operating Procedures" (Ref. 2) outline the following objectives for procedure verification /

validation; the process should ensure:

a. That OEPs are technically correct, i.e., they accurately reflect the technical guidelines. -

b. That OEPs are written correctly, i.e., they accurately reflect the

, plant-specific writer's guide.

i c. That OEPs are usable, i.e., they can be understood and followed  !

without confusion, delays, errors, etc. ,

d. That there is a correspondence between the procedures and the s control room / plant hardware, i.e. , control / equipment / indications that are referenced, are available (inside and outside of the 1 control room), use the same designation, use the same units of measurement, and operate, as specified in the procedures.

e. That the language and level of information presentation, in the EOPs is compatible with the minimum number, qualifications, training and experience of the operating staff.

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I i f. That there is a high level of assurance that the procedures will i work, i.e. , the procedures guide the operator in mitigating transients and accidents. (Ref. 2, p. 10).

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! During the simulator runs, the actual usability of the procedures (objective "c") will be the focus of the process. All the objectives will be evaluated to some extent during the simulator validation. The use of the j simulator will provide the high level of assurance that the procedures will work as preposed in objective "f."

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2. METHODOLOGY FOR SIMULATOR VALIDATION

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l 2.1 Performance of Simulator Runs The simulator runs will provide an objective context in which to evaluate

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j the usability of the procedures. In contrast to walking through the procedures in a static environment in which dynamic procedural problems may be verl ked, the simulation environment will mimic the operating conditions for r.

i a more objective challenge to the procedures. The simulation will also I provide a setting in which the operators can be faced with a reasonably realistic emergency situation for which they must diagnose the symptoms and

{ proceed accordingly using the new procedures.

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The operating crew chosen for the simulator runs will have been

. familiarized with the new procedures during training. The crew will not be briefed on the actual scenarios to be run. The operators will, however, be briefed on the purpose of the validation. It will be made clear to them that it is not their performance that is being evaluated, but the performance of f the new procedures.

Each scenario will be simulated separately with a debriefing session after the run. . During the run, validation team members will be observers.

The tape record of the scenario will permit the observers to analyze occurrences later. ,

During the simulater runs, if the crew kakes an acceptable alternate path that is as correct as the expected path, they will be allowed to continue uninterrupted. If the operating crew momentarily takes an unexpected alternate path that is an incorrect path, and are able to get back on the correct path using the procedure within a reasonable amount of time, the simulation should continue undis+ arbed. If, however, the crew takes an unexpected alternate path that is incorrect and shows no sign of recovering, I the simulation will be stopp>d. If an obvious, remediable error is involved, I e.g., a page of the procedut e was missing, the problem should be corrected and the run started again where it went astray. If, however, the problem is not obvious or readily remediasle the simulator run will have to be postponed i until such time as the problem is diagnosed or corrected.

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3. ANALYSIS AND RESOLUTION 3.1 Debriefing of Operators The operator debriefing session will be conducted immediately after each l scenario run on the simulator. The comments of the operators who have participated in the exercise provide one of the most important sources of f

information for evaluating the procedure set. Operator actions which do not lend themselves to direct observation, such as symptom diagnosis or conversion of displayed values can be described by the operators during the debriefing.

The operators' comments also contribute to greater accuracy in analyzing deviations from expected operator actions which occurred during the

' scenario. It is essential that the operators be debriefed as soon as possible after the scenario has been completed so that their comments on the events of the scenario will be comprehensive.

l A validation team member will explain the debriefing process and its purpose to the operators and elicit from them general comments on the impact f of the procedures on their performance. These comments will be recorded and I used later in the analysis phase. The operators will be asked to discuss procedure-related problems they encountered during the scenario, and they will be asked to identify possible reasons for any procedure-related problems that they encountered during the run. The operators will also be asked to present potential solutions to any procedure-related problems. All discrepancies, possible reasons, and potential solutions identified during the debriefing will be documented.

3.2 Analysis of Videotapes

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( The purpose of analyzing the videotapes for discrepancies between expected operator actions and actual operator actions is to identify potential snortcomings in the procedures. Each discrepancy identified during the debriefing and videotape review will be analyzed on a case-by-case basis to determine if it is an error or if it is an acceptable discrepancy and should be deleted from consideration. A discrepancy that impacts adversely on

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operator performance or plant condition should be considered an error. An i example of an acceptable discrepancy would be an operator action in a sequence that is different from the expected order but equally admissible.

The validation team will then use the evaluation criteria presented in Appendix A to assist them in determining whether an error was due to a procedural problem or other causes such as control room hardware, training, or manpower. Errors which can be identified as being caused by procedural shortcomings will be documented. When the procedure-related errors have been identified, these errors may be categorized

• as follows:

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( (1) Error of ommission (intentional or unintentional) i e omits an entire task e Omits a step in a task f

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(2) Error of commission f

i e Selection error

- Selects wrong control

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Mispositions control l

I (3) Error of sequence (4) Time error e Too early e Too late 1

(5) Qualitative error e Too little e Too much

[ Categorizing errors will permit a summary of the types of errors caused

{ by a procedure. For example, in a given procedare, if 80% of the errors

• identified were errors of omission, the analyst would want to verify that the

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reentry to a procedure from which the operator had branched was not causing l

him to omit steps. However, if 80% of the errors identified were qualitative errors, the analyst would want to check the level of detail of instruction for that section of the procedure. Figure 1 outlines the steps involved in analyzing the discrepancies.

The final product of the analysis will be a compilation of procedure-

{

related errors. Specific errors will be categorized into the types listed ,

i previously. Then, descriptions of procedure-related problems will be forwarded to the responsible Vermont Yankee personnel for resolution.

Videotapes of the scenarios will be turned over to Vermont Yankee at the conclusion of the project.

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• The list of types of human error was furnished by Dr. Alan Swain, Sandia National Laboratories, for use in NUREG/CR02744 prepared by General Physics.

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f Identify discrepancies between simulator run and expected operator actions.

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If would discrepancy  ;; No  : Categorize as have an adverse impact acceptable on safe or efficient discrepancy.

plant operation?

U Yes V

Was the error  :: No tr Categorize

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procedure-related? as error l

not attributed to procedures i

U Yes if

' Categorize type of error.

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Figure 1. Flowchart for Analysis of Discrepancies g

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t REFERENCES

[ 1. U.S. Nuclear Regulatory Commission, " Supplement 1 to NUREG-0737, "USNRC l Generic Letter No. 82-33, December 1982.

2. U. S. Nuclear Regulatory Commission, " Guidelines for the Prepartation of f-Emergency Operating Procedures," USNRC Report NUREG-0899, August 1982.

1 Available from the U.S. Government Printing Office, Washington, D.C.

20402.

r I 3. The EOPIA Review Group, " Emergency Operating Procedures validation Guideline." The Institute of Nuclear Power Operations, Atlanta, Georgia,

January 1983.

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APPE MIX A l

I DEBRIEFING GUIDELINES I

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1 Scenario:

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t Emergency Operating Procedures Validation 7

Guidelines for Debriefing ,

- T The following val,idation criteria are presented in the form of questions and are to be used by the validation team as guidelines only; they provide structure to the debriefing process.

Evaluators should check whether a criterion has been met or indicate N/A if the criterion could not be evaluated or was not applicable. Procedure-related problems, indicated on this form by "N", can be documented in greater j detail using the attached comments sheet (e.g., whether it is a generic problem or occurs at one step in a procedure). .

f 1.1 Useability

! 1.1.1 Level of Detail

1. Was there sufficient information to perform the specified s actions at each step?

2. Were all alternatives explicit at each decision point?

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

4. Were the EOPs missing information needed to manage the emergency condition?

5. Were the contingency actions as stated in the EOPs j

sufficient?

6. Could the operator use titles and nu=bers to find referenced i

or branched procedures?

1.1.2 Understandability N Was the typef ace easy to read?

1.

,;;, 2. , , Were the emphasized items noticed?

3. Were the figures and tables easily and accurately read?

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4. Was interpolation of values on figures and charts difficult?

5. Were caution and note statements understood?

C. Was the organization of the EOPs understood?

7. Was the EOP step understood?

8. Were the step sequences understood?

9. Could the operator find the particular step or set of steps f

when required?

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10. Could the operator return to the procedure exit point without omitting steps when required?

11. Could the operator enter the branched procedure at the I

correct point?

12. Could the operator exit from a given EOP at the correct branch?

1.2 Operability Correct 1.2.1 Technical Correctness

1. Were the instructions appropriate for the emergency condition?

2. Were the procedure actions able to be performed on the plant r

in the designated sequence?

! 3. Did the operator find alternate success paths not in the EOPs.

4. Was the procedure action able to be performed on the plant at the designated time intervals?

5. Could the operator obtain the necessary information from designated plant instrumentation when required by the procedure?

6. Did the plant symptoms direct the operator to the applicable EOP by its entry conditions?

1.2.2 Compatibility

1. Were the EOP instructions compatible with the operating shift manning?

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s.

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2.

Were the procedure actions able to be performed by the operating shift?

f Did the EOPs help coordinate the actions of the operating 3.

shift?

4. Did the operator have to use responses or other equipment not specified in the EOPs to accomplish his task?

Did the plant conditions seen by the operator correspond to 5.

what was in the EOP7 6.

Were the instrument readings and tolerances consistent with the instrument values stated in the EOP7

7. Were the operators able to distinguish the EOP from other procedures in the control room?

8.

Were the EOPs physically compatible with the work situation (to bulky to hold, binding wouldn't allow them to lay flat in work space, no place to lay the EOPs down to use)?

9.

Was the plant condition compatible with the action which the EOP directed to be performed at a time interval or specified time?

10. Was the operating shift able to follow the designated action step sequences?

11. Did the plant conditions allow the operator to correctly follow the action step?

Signature of Evaluator i