ML20125D296

Lessons Learned from the Special Inspection Program for Emergency Operating Procedures.Conducted October 1988 - September 1991

ML20125D296
Person / Time
Issue date:	10/31/1992
From:	Greg Galletti, Sutthoff A Office of Nuclear Reactor Regulation, SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:
References
NUREG-1358, NUREG-1358-S01, NUREG-1358-S1, NUDOCS 9212150088
Download: ML20125D296 (38)

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NUREG-1358 Supplement No.1 Lessons Learned from de Specia: Ins pection Program for Emergency Operating Procecures Conducted October 1988-September 1991 g

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AVAILABILITY NOTICE -

• Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:

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i NUREG-1358 Supplement No.1 Lessons Learned from the Special Inspection Program for Emergency Operating Procedures Conducted October 1988-September 1991

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Manusenpt Completed: October 1992 l hic P:6! hci OcL?u l'"J Division of Reactor Controls and lluman Factors Omce of Nuclear lleactor Regulation U.S. Nuclear Itcgulatory Commission Washington, DC 20555 g r au g

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AllSTRACT

'this supplernent to NUREG-1358, "lxssons Learned state of the EOPs and efforts to resalve programmatic From the Special Inspection Program for Emergency Op- problems, and (3) provide the industry with additional crating Procedures-Conducted March-October 1988," clarification and guidance on the critical elements of an dated April 1989, discusses the results of the third phase effective liOP program for use in upgrading their EOP of the Nuclear RegulatoryCommission's(NRC's)Special programs.

Inspection Program for limergency Operating Proced-ures (liOP-3). The results of the EOP-3 inspections, conducted October 1988 through September 1991,iden-tified continuing deficiencies in the liOP programs at a The NRC staff expects licensees to take advantage of the -

number of plants. These deficiencies have contributed lessons learned from the EOP inspection program to im.

significantly to 10 of the 15 (679c') unsatisfactory operator prove their development, implementation, and mainte-requalification programs since 1988. nance of EOPs. Ilowever, the information contained in this supplement is provided as guidance; it does not im-Inspection findings are discussed to(l) supplement previ- pose any new requirements related to the t.pgrading of ous findings. (2) keep the industry abreast of the current E ops.

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CONTENTS Page Abstract . . .. .. . .. .. . . . . . . . . .. - .. .. ..- iii Acknowledgment . . ., .. . . . . .. . .... . .. . . ... .... . .... vii 1 Introduction . . ... . . . . ... . .... . . . .. I 2 Discussion . .... . . . . .. . ... . . . .... .. I 2.1 liasis Documents . .. . .. . . .. . . . . . .. ...... . 3 2.1.1 Technical Guidelines . .. . .. . . . .. . ... . ............ .... 3 2.1.2 Writer's Guide ... . ... . . ... ..... . ... ... .... ... .... 5 2.2 liOP Production . . . . . ... . . . . .. ... . . . . ... ... 5-2.2.1 Emergency Operating Procedures . .. . .. .... .... . ... .. .. ... 6 1 2.2.2 Support Procedures . . . . ... .. . . ... . .. .. .. .. ... .. 6 2.3 Verification and Validation . . ..... . . . . .. . .. .. . . 8 2.4 Training . . . . . . .. .. . . . . . ... .. .. ...... ... 8 2.5 Maintenance and Revision . . . . . . . . .. .. , , , .... . . . 9 .

2.6 Management Issues . . . . . .. , . . . . . ... . .. 10 2.7 EOP Followup inspections . . ... . . . . . .. ..... ....... . ... . 10 3 Conclusions . .. ., . . . . . . . ... 11 4 References .. .. . .. . . . . .. . .. ... .. 11 Appendices l A List of Plants Inspected During 1988-1991 Under Temporary Instruction 2515/92 13 for the Third Phase (EOP-3) . .. .. ... ... .. .. . .. . . .... .... .

, 13 Checklists of Criteria for the Development of Emergency Operating Procedures and Support Procedures .. . .. . ... ... . ...... .. . . . .... . .. . 15 l

i C Inspection Procedure 42001, "limergency Operating Procedures" .. ... . .. . . . .. . .. .... 21 l

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ACKNOWLEDGMENT

'this report was prepared through a joint effort of person- International Corporation (SAIC). 'lhe authors would nel from the lluman Factors Assessment Ilranch, Divi. like to acknowledge the efforts of NRC headquarters and sion of Licensce Performance and Quality I! valuation, regional staff, the personnel from COMl!X Corporation, Office of Nuclear Reactor Regulation, Nuclear Regula- and the personnel from SAIC associated with the liOP tory Commission (NRC), and from 3cience Applications program for their contributions in developing this report.

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1 INTRODUCTION tinued to identify sigmficant technical concerns yvith li-eensees' liOP development and implementation. Ihere-The U.S. Nuclear Regulatory Comrmssion (NRC) imti. fore, the staff decided to provide the industry with ated its timergency Operatmg Procedures (EOPs) In. additional clarification and guidance on the critical cle-spection Program to determine if licensees were meeting ments of an !!OP development program.

the requirementsof Three Mile Island (TMI) Action Plan item 1.C.1 (NURI G-0%0, NURiiG-0737, and Supple- The information in this supplement is based on 62 I!OP-3 ment I to NURiiG-0737). During the pilot phase inspections conducted from October 1988 through Sep-(1:OP-1) and second phase (liOP-2) of the program. the tember 1991. A list of the plants inspected is provided in NRC staff identified concerns with the industry's liOP App 2nda A. The staff continued with the evaluation of development and implementation. As a result, the staff the licensees' liOP programs through a performance-issued NURl!G- 1358. "1 essons 1.carncJ From the Spe~ based onsite inspection effort (l!OP-3) of all licensees cial inspection Prograrn for limergency Operating Proc ~ no! previously evaluated during liOP-1 or I!OP-2 and edures, conJucted hlarch-October 1958," in April 1954 reseral additional followup inspections at plants that had to reiterate the critical elements of effective !!OP genera' been inspected during the earlier efforts. Ih Section 2 t ion. below, the staff reiterates the issues described in NURIiG-1358 and discusses additional issues that have The results of the cariy phases (l!OP-1 and !!OP-2) of been identified since NUREG-1358 was released. This the !!OP inspection effort.dunng which 30 nuclear plants supplement also includes a series of checklists (Appendix were inspected, were desenbed in NURI G-1358. The 11) that the staff developed to aid licensees in identifying staff focused on issues related to the (1) technical guiJe- potential weaknesses in their !!OP programs and in pre-lines associated with liOP development, (2) actual pro- paring explicit criteria for evaluating and upgrading their duction of EOPs from these guidelines, (3) verification programs.The staff developed the checklists after analyd and validation (V&V) and maintenance processes associ- ing weaknesses and good practices for liOP development ated with the liOPs. (4) operator training on the !! ops, and implementation identified during the !!OP inspee-and ($) management involvement in the EOP develop- tions. In addition, the staff developed and implemented ment process. The staff believed that a discussion of the NRC Inspection Procedure (IP)42001," Emergency Op-weaknesses founJ during these inspections would be suf- erating Procedures," to conduct liO P followup inspection ficient to assist bcensees in correcting techmeat deficien- activities. A copy of IP 42001 is provided in Appendix C to cies in their liOP development programs and in upgrad- this supplement.

ing their EOPs a reflect these improvements.

Following the release of NURl!G-1358, NRC staff

• DISCUSSION participated in a series of EOP workshops sponsored _

by the Nuclear Management and Resources Council in :,URl!G-1358 the staff described the requirements of (NUM ARC)and the four nuclear steam system suppliers TM1 Action Plan items I.C.1 and I.C.9 associated with the (NSSS) owner's groups (Habcock & Wilcox, Combustion re-analysis of transients and accidents, the development

!!ngineering, General lilectrie, and Westinchouse). The of symptom based liOPs, and the development of a long-meetines w cre held in Washington, D.C., J u'ne 26 and 27, term program for upprading liOPs. The report also de-1989, a'nd in Denver, Colorado, June 29-30,1989. The scribed the results of early inspection efforts (see infor-purpose of the meetings was to convey to the nuclear in. mation Notice (IN) 66-64, dated August 1986, and dustry the results of the l!OP inspections to date and to Supplement I to IN S6-64, dated April 1987)and the de-

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provide a forum for the nuclear industiy to share informa, velopment of the initial phases of the EOP3 Inspection tion on then-current EOP activities. The staff initiated Program (I!OP-1 and !!OP-2). The chronology of events the third phase of the EOP inspection effort (EOP-3)in associated with the !! ops is given in the following figure.

October 19SS to determine the effectivenessof the indus. A detailed discussion on the background is provided in try's initiatives to improve the EOPs and address previ. NUREG-1358.

ously identified deficiencies, in Generic 1.etter (Gl ) S2-33, which transmitted Supple.

At the completion of EOP-3, the staff found the indus- ment I to NURiiG-0737," Requirements for limergency try's EOPs had not significantly improved since Response Capability, the staff clarified several of the NURI G-135S was issued. Although some licensees had FMI Action Plan requirements. Item I.C.1 required that addressed the concerns raised in NUREG- 1358 and had each licensee submit to the NRC for review a set of docu-effectively mcorporated the standards for I!OP develop- ments to be used for the development of plant specific ment described in NUREG-OS99, "Guidehnes for the EOPs. These documents, called the " procedures genera-preparation of Emergency Operating Procedures,' tion package" (PGl"n included, as a mirumum, four basic August 1952, the majority of the 1 OP-3 inspections con- elements:

1 NUREG-1358, Supp. I

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-l1979l-a 1980 May - NURE04MO,TM1 Action Plan, item 1C1, issued November - NUREG-0737, Item I.C 1 issued -

1982 August - NUREG 4W1 msued December - NUREG-0737, Supp.1 Item I.C1, issued 1986 June - Temporary Instructnn 2515/79 issued August - Information Notice 8(44 issued l 1987 Apnl - Information Notice 86-64. Supp.1, issued -l:

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'I 1988 March - EOP-1 inspections began -

April - Temporary Instruction 2515/92 issued -

May - EOP-2 inspections began -

October - EOP-3 inspections began 1989 January - NUREG-5223 issued April -- - NUREG-1358 issued June - NUMARC/NSSS workshops conducted October - EOP followup inspections began 1991 January - Inspection Procedure 99tK) issued -

June - Inspection Procedure 42001 issued - l

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b j Figure-Chronology of IiOP-Related livents 4

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- NURIiG-1358, Supp. I ~2

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(1) plant-specific technical guidelines (PSTGs) includ- development and maintenance of quality EOPs over the ing plant-specific information justifying safety- entire plant life-significant differences from the generic technical guideline $

2.1.1 Technical Guidelines (2) a writer's guide that details specific methods to be in NUlUiG-1358 the staff described the weaknesses used by the licensee in preparing EOPs based on the found in the technical guidelines. These weaknesses indi '

PSTGs cated that many licensees did not understand the need to control the technical basis documents and maintain com-(3) a description of the program to be used for the vali. plete, up-to-date justifications for technical deviations dation of the upgraded EOPs from the genene guidelines. During the EOP4 inspec-tion effort it became increasty.ly apparent that many h-(4) a description of the traming program for the up, censees required additional clat.fication about what con-graded EDI, stitutes adequate techru, cal has s documents for the development of EOPs. Some of the ' ost widely observed During the PGP review process, the staff ident:fied con.

weaknesses in the technical baie acuments included cerns with implementation of the guidelines for the e development of plant-specific EOPs. These concerns incomplete documentation of the plant-specific methods used for transient mitigation ranged from a failure to develop plant-specific technical guidance to inadequate verification of the plant specific e incomplete documentation of deviations or justifica-EOPs against the documents comprising the PGPs. As a result, the staff focused additional resources on the EOP tiori for deviations between the generic technical guidelines and the PSTGs implementation issue and established an inspection pro-gram that emphasized a performance-based review of the e technically inadequate justification of deviations licensees EOPs.

from the generic technical guidelines

- Followingct.mpletion of the EOP4 inspection effort,the e incomplete or nonexistent set point documentation staff prepared this supplemental discussion to reiterate its expectations for the development of upgraded EOPs e deviations between the PSTGs and 'EOPs and to disseminate to the nuclear industry the findings from the EOP-3 inspections. e lack of administrative control over the technical 5

- guidelines to ensure plant modifications were re-flected in the technical basis for the EOPs and to en-2.F Basis Documents sure the technical guidelines are maintained as coa-r- trolled documents The PSTGs and the procedure writer's guide form the basis for the development of EOPs.These documents re- Hecause of these observed weaknesses, the staffis provid-flect the technical considerations associated with the miti- ing additional clarification (e.g., definition of technical

( gation strategies encompassed in the EOPs and provide guidance and examples of deviations and additions to the .

!' the criteria for translating these technical considerations technical guidelines which should be addressed in the into plant specific procedures. These documents do not PSTG) on what constitutes adequate technical guidance stand alone or ensure adequate production of EOPs by for the development of EOPs.

thernselves; they are simply tools to be used in conjunc-tion with additional supporting documentation and ad- NUREG-0899 defines technical guidelines as ministrative controls to develop quality EOPs.

L Documents that identify the equipment or sys-hese documents do, however, play an integral pa rt in t he tems to be operated and list the steps necessary development, implementation, and maintenance of the to mitigate the consequences of transients and EOPs over the entire plant life. Appropriate administra- accidents and restore safety functicas.TechniJ tive controls should be in place to ensure that these basis cal guidelines represent the translation of engi-guidelines are maintained current. Changes to the techni- neering data derived from transient and acci-cal basis for the EOPs can arise from various circum- dent analyses into information? presented in stances (e.g., operational experience or plant moihfica- such a way that it can be used to write EOPs.

tion) and should be reflected in the PSTGs. Changes in 'There are two types of technical guidelines, as

- the format and presentation of the EOPs should be gov- defined below. Generic technical guidelines erned by the criteria established in the writer's guide, are guidelines prepared for a group of plants With appropriate controls,licensecs can help ensure the - with a similar design. Plant-specific technical 3 NUREG-1358, Supp. I

y guiddines are one of the following: a,Techni- calculations, and with information that cam be translated cal guidelines prepared by plants not using into plant specific EOPs.

generic technical guidelines, or b, Where a-plant is using generic technical guidelines, a llecause the PSTGs provide the technical basis (i.e., the description of the planned method fordevelop- equipment or systems to be operated and the steps neces-ing plant-specific liOPs from the generic sary to mitigate the consequences of transients and acci-guidelines including plant-specific information dents and restore safety functions) for the development (e.g., deviations from generic technical guide- of EOPs, thera should be no deviations between the lines necessary because of ditferent plant PSI Gs and the EOPs. Although it is not necessary for the equipment, operating characteristics, or de- liOPs to use the exact terminology of the PSTGs, the sign). 110Ps must preserve the logic of the mitigation strategies defined in the PSTGs.'fhis is especially important when The NRC Standard Review Plan (NUREG4)S00)further converting text-based P$l'Gs to flowchart-formatted describes the PSTGs and defines specific examples of de- liOPs because the changes in format mandate changes in _.

viations and additions that should be addressed as part of the level of detail that can be incorporated in the flowpath the PSTGs. including symbols (e.g., re.vording an "lF A, TlIEN 11" logie state-ment to a question format in a decision bk)ck reduces the e any modification to the mitigative strategy of the ge, detail provided in individual steps). Ily accounting for neric technical guidelines these tert changes during the development of the plant-specific technical guidelines, licensees can help ensure

• - differences in equipment operating criteda that the mitigation strategies will not be incorrectly al-tered as a result of rewording or reformatting the PSTGs i e differences in equipment operating characteristics steps. q The techuical guidelines should be maintained as con-

• identification of the methods and equipment used to trolled documents and all relevant modifications to the address the technical areas of the generic technical pl nt or changes to the EOi implementation strategies guidelines that are specified as " plant specific, should be reflected in these guidelines The techmcal ba-sis documents are not just historical records, they are the e plant-specific set points or action levels that are cal- foundation for controlling the quality, consistency, and culated or determmed in a manner other than speci' adequacy of the liOPs.

fied in the generic technical guidelines One good practice observed during the EOP-3 inspec-e actions that are taken in addition to those specified tions for the development of the technical guidelines was in the generic technical guidelines and that affect the incorporation of each individual deviation from the '

the mitigative strategy generic tecimical guideline along with its technicaljustifi-cations as part of the PSTGs. The documentation con-

• differences that affect the equipment's ability to sisted of the generic ;cchdal guideline step, the corte-adequately provide the necessary mitigative func- - sponding plant-specific guideline step, the technical basis tion for the step, and a detailed technical justification for any differences between the generic technical guideline step

• . use of different instruments or control parameters and the plant-specific guideline step. The practice in-than those specified in the generic technical guide- cluded documentmg all cautions and notes in the same '

lines or determining instrumentation and control manner.

characteristics in a manner different than, or with a different badis than, that specified in the generic in several instances, licensees prepared detailed set point -

technical guidelines documents.This practice promoted consistent use of set points throughout the EOPs and aided the EOP develop-

-As the PSTGs are developed and maintained, all devia- ment staff during the evaluation and preparation of EOP tions, additions, or changes to set points (including the revisions resulting from plant modifications and opera-values,.models, and calculational methods for deriving tional experience. At least one licensee has implemented such set points) from the generic technical guidelines a computer program to perform the calculations and should he documented with sound, thorough analysis. added addit _ional administrative controls, which require This documentation should be sufficiently detailed to independent review of the set points against results from provide the procedure development staff (e.g., opera- other plants.

tions staff, systems engineers, procedure writers. training staff, and human factors engineers) with the technical ba- The EOP-3 inspections identified a number of weak-sis for such changes, including engineering nnalyses and nesses in the development and maintenance of many 4

NUREG-135S, Supp.1 4

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1 hcensees EOP technical basis guidelines. These weak- a plant-specific EOP program may include other ele-nesses manifested themselves in liOPs that did not suffi- ments not included in these lists, every liensee should ciently detail required operator actions or identify plant- consider these items for applicability to their EOP writ-specifie equipment needed for the actions. Failure to cr's guides. To control the presentation of information in maintain the technical basis documents current was evi- the EOP, a writer's guide should properly address the denced by plant modifications that were not adequately structure and content of each type of procedural step and reflected m the EOPs or supporting procedures. Jould define only one method for presenting each procc-dure component.

2.1.2 Writer's Guide The writer's guide should be a usable, living document.

EOP-3 inspections revealed that deficiencies continued Changes to procedure format may result from changes in in EOP writer's guides. These deficiencies were described plant operating philosophy, findings from ongoing evalu-in NUREG-1358, and, while some licensees had ad. ations of the use of the pmcedures, feedback imm train-dressed some of the concerns, almost all of the licensecs' ing, or further ap< cation of human factors principles to w riter's guides tacked sufficient detail to control the pres. written instructiws. Revisions to the writer's guide entation of information in the EOPs. should be controlled through general plant administra-tive procedures.

Most writer's gui,Jes had omitted important ruidance or failed to explicitly define clear principles for structuring A complete and restrictive writer's guide is critical to the the EOPS. One of the most significant concerns was the effective presentation of information m the EOPs. The generallack of guidance for supporting pmcedures used most techmcally sound procedures can lead to operator in conjunction with the EOPs, including abnormal oper- crror if they are not understandable and usabic, ating pmcedures, standard operating procedures, and pmcedures for kical plam actions.These support proce-dures are used to direct actions crucial to the mitigation of 2.2 EOP Production an event; therefore, the information in EOP support pro- Involvement of operations and training personnel in the cedures should be absolutely c! car and correct. In fact, development of EOPs is necessary to ensure that the support procedures should be held to the same standards knowledge and experience of the EOP user is incorpo-as the EOPs. rated into the EOPs. NUREG-1358 cited several exam.

ples of weaknesses observed in some licensee pmgrams Vague and unrestrictive guidance often was used for im- for EOP production, particularly the lack of a multi <Jis-portant components of the pmcedures. Step structure, ciplinary approach to the development of the EOPs.

caution statements and notes, transitions (referencmg Often a single person developed the EOPs and was also and branching), and logic statements were inadequately responsible for verifying them. In some cases, operations or incorrectly defined and formatted in numerous writer's staff were not involvett in the development of EOP3. In guides. Requirements for references to plant nomencla- other instances, plant management was not attentive to ture, emphasis techniques, placekeeping methods, and its staff's comments associated with EOP development, approved action verbs were omitted from writer's guides.

In some cases, more than one acceptable format for a pro- EOP-3 inspections revealed that some licensees were im-cedure element was included for the pmcedure writer's plementing strong practices for EOP pmduction. Most option. notably, management attention to the EOPs appeared to be improved and additional resources were devoted to Writer's gu: des also generally failed to address the appro- EOP development. In so, . instances, licensees incorpo-priate level of detail for the EOPs. Consequently, the rated multidisciplinary appnaaches to EOP developmeat EOPs reflected inconsistent levels of detail-sometimes by including operations staff, engineering staff, training excessive and at other times inadequ .ie. staff, and additional support personnel in the develop-ment process. H uman factors specialists also participated l The writer's guide is the control dscument for ensuring in the development and validation of the EOPs.

l consistently high standards f or the presentation of infor-l mation throughout the EOPs and their revisions. Omis- Although some licensees had developed robust EOP pro-

-.ons and nonrestrictive guidance result in inconsistencies duction programs, the EOP-3 inspections showed that that will increase over time with revisions to the EOPs the majority of licensee programs still centained weak-and changes in writers of the EOPs. nesses similar to those reported in NUREG-1358.These weaknesses included lack of To aid in the development of complete writer's guides, Appendix B to this suppelment includes lists of major is- e a multidisciplinary appreach to procedure develop-sues to be addressed in any EOP writer's guide. Although ment 5 NU R EG-1358, Supp.1 i

6 o an independent quality assurante review of liOPs e lack of adequate procedural steps to restore reactor o operator feedback on liOP revi ms e incorrect or conflicting set point values incorporated o training input into EOP production in procedures o restiictive writer's guide criter'a e lack of appropnate exit / entry pointsin !! ops l 1

o adherence to criteria established in the writer *S

• lack of adequate detailin proceduralsteps to ensure '

guide appropriate operator response It is very important to have a multidaciplinary team re-

• lack of appropriate guidance to bypass or defeat in-  !

sponsible for the checks and balances in the EOP produc. ter hxts er isolations tion process. In many cases, independent quahty assur-ance reviews did not identify deficiencies in the EOPs. or

• lack of appropriate detail on expected isolation valve they simply were not performed. Communication be- position to aid the operatorin verifying containment tween EOP developers. Sint operators, and training isolation during conditions involving loss of air staff was very informal, n 4. all existent. Operators and training personnel were not always given feedback on 1hese weaknesses placed an increased and unnecessary ,

their comments and in some instances EOP revisions burden on operators to recall from memory infrequent were incorporated withe derator involvemer".1hese activities under conditions of heightened stress and con-practices fostered poor ; ..ator understanding of the tribute significantly to operators taking inappropriate ac-liOPs and a lack of acceptance by operations stafIof the tions during transient rnitigation. It must be emphasized I! ops as quality procedures. that weaknesse' in the development of the !! ops have contributed directly to opetutors' inability to appropri-2.2.1 Etnergency Operating Proceaures ately control plant trar,sients. As noted previously, of the 15 unsatisfactory operator requalification programs since The staff determined that weaknesses in the liOPs have 1988,100f these unsatisfactory programs (67%)were the contributed significantly to operatorv inability to ade- result of problems with the operators' implementation of ,

quately rmtigate transients. Some !! ops contained incor- the liOPs.

rect steps, fFled to incorporate required procedural steps, or incorpomt ed rnitigation approaches that may not The significance of these weaknesses should not be over-have been successful tmder the conditions postulated tooked. The inability of operators to implement appropri-durmg such transients. ate mitigation strategies because of weaknesses in the 1: ops ha> directly affected operations at nuclear power Examples of such weaknesses included plants, and, in some instances, has resulted in enforce-ment actions taken agan t hcensees.

specifying containment ventinr paths that would not accomphsh the intended function.or failure to spec- 2.2.2 Support Procct. ares ify alternate venting nathe Support procedures were used by reference or attach-o specifying the use of equipment that would not be ment in most licensees' EOPs to provide operators with available under loss t f power conditions additional puidance on how to implement operator ac-tions speci. :d in the EOPs. Support procedures are used o lack of procedures to defeat reactor pmtection sys- to reduce tne overall complexity of the !! ops while pre-nm and alternata rod insertion logic trips required serving a reasonable flow of information required for to reset a reactor scram mitigation actions. Support pnxedures enable operatorr or technicians to perform control room or hical actions o lack of hydrogen control procedures without having to carry entire EOPs to these locations.

They also provide a means of presenting the operators o lack of procedures that require recurrent assess- with lengthy detailed procedural steps or repetitive sets of ments of entical safety functions throughout tran- actions that,if embodied in the EOPs themselves, would sient mi tigation be cun bersome and very difficult to implement.

, o lack of prendures to restore po,ver to service busca The guidance provided in support procedures referenced -

l by the EOPs is fundamental to the success of the EOP l- o lack of procedures to perform alternatt voron injec- mitigation strategy. Therefore, tV information in these l tion support procedures should be technically accurate and NUREO-1358 Supp. I 6 l

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presented in a manner that can be understood by those e lack of analysis tu ensure that equipment specified in individuals expected to use the support procedures durmg support procedures would,in fact, be available dur-emergeng situations. ing emer gency situations (e.g., loss of instrutnent air and loss of ac power) llecause suppcrt procedures are fundamental to the suc-cesu,f the 1;OP mitigation strategies, all procedures ref- e lack of verification of adequate emergency lighting  ;

crenced by the liOPs should be controlled in the same manner as the liOPs. Special support procedures, abnor- e inappropriate use of normal operating procedures mal procedures, or standard operating procedures that or procedures not designated for ernergeng situ-ate required to complete the liOPs and hung the plant to "U""5 safe shutdown, should receive the same level of scrutiny '

as the !! ops.

'ihese weaknesses indicated a lack cf V&V of the procc-

'lhe liOP-3 inspections identified numerous deficiencies dures and a lack of restrictive or explicit V&V criteria. In in the preparation, implemen tion, and maintenance of rnany instances administrative controls did not require

!!OP support ; mcedures. 't nese deficiencies resulted formal V&V for support procedures. Some administra-frorn a lack of administrative guidance to control their tive controls specified that a desktop review of support preparation and lack of explicit and restrictive verification pmcedures was sufficient without requiring additional and validation (V&V) during implementation and main- control mom, or in. plant walkdowns, or simulator esalu-tenance. Many of the licensees' support pmcedures were ations to validate support pmcedure actions. Several li-not developed using the same standards for preparation censecs did not identify or consider the effects of envimn.

as the !!O*' hiferences in style, funnat, and terrninol- mental conditions on hical operator actions when they ogy were onen observed between the !! ops and support developed the support procedures. I!OP support pmcc-procedures. 'lhese differences contributed to increasing dures should be verified and validated to be technically the complexity of the !! ops and delaying operator actions correct. 'Ihe pmcedures should be written to the tcVel of associated with _ mitigation. 'Ihe most common weak- detail sufficient to ensure that allindividuals expected to ness s observed in support procedures included perform the activities associated with the 110P support procedures can do so in a safe, reliable manner. I .icensees o lack of consistent style, formatting, and terminology should consider implementing their IIOP V&V criteria or in support procedmes developing additional V&V criteria for reviewing I!OP support pmeedures, o improper sequencing of action steps or improper valve lineup information liOP-3 inspections also revealed some good practices -

with regard to support procedure development and im-o lack of or incorrect plant equipment identifications piementation, For example, some bcensees developed writer's gui@s that included neceptable acronym and ac-o lack of reference to materials or tools required by tion verb lists for use in I? ops and support procedures, procedures and a lack of prestayed equipment (e.g., which promoted consistent application for the develop-keys, jumpers, ladders, reach rmk, and safety equ p' ment of the !! ops and the !!OP support pmcedures. In ment)at the required hications some instances, licensees had revised su pport procedures to conform to a two-column format consistent with their o inadequate analysis of the feasibility of performing liOPs and-had implemented inclusion of contingency actions at component kications in areas that would actions in the support procedures in case expected plant have high radiation or high temperature levels d :r-responses were not obtained. Operators expressed in.

mg emergency situations creased satisfaction with support procedures that con-formed to the development principles used in the I! ops.

-o lack of classmom or walkdown training of non-licensed operators or technicians on the use of sup- Some licensees implemented computer-based software port procedures programs to aid in the de A,pment of !!Olls and support procedures. Some of t' ~e programs contained modules o numerous mismatches between control r oom labels, to assist with formatt ; pmcedures consistent with the .

~ in-plant labels, and procedural step nomenclature plant specific writer's guide and to track transition points .

ar,d references in the !! ops. If a procedu.e was modified.

for com[onents the program helped the !!O~ writer it atify steps af-

+

o lack of appropriate entry / exit points or other refer- feeted by the mothfications in or der to make the appropri-ences into support procedures from !! ops ate changes in all the required places.

7 NURl!G-1358, Supp.1

i 2.3 Verincatioli Allti Viilittriting) cluded inadequate lighting, high noise levels or lack of inadequate V&V temained the most significant contnb-uting cause of the raajotity of problems ideded in in-plant actions that required supplemental tools were llOPs and theit support proceduressince 1988. If the con- common; however, the necess;uy tools were seldom listed trol documents (i.e., PSI Gs und wnter's guide) are mic- or prestaged. In cases whete toob. were prestaged, they quate, venfication agamst these documents wdl ensure were often incorrect in site or specification for the task in technically sound procedures that are understandable some cases, in plant actions were rnixed with control and uscful,if the controf documents ate not adequate, a rcom actions and no clear distinction was made between thorough V&V ptocess will reveal these inadequacies, the two.The location of rarely used equipment was sci- 1 Most V&V processes failed either to identify the flaws in dom identified.'lhorough V&V, including in plant walk- ,

cont rol docurnents or to ensure the integrity and usability downs, would have identified these deficiencies.  !

of the procedures. t inconsistencies in the wording and structure of stcps were V&V inadequacies were esident by the nurnber of I! ops common.The level of detail varied within the same proce-that failed to reflec t the generic and plant speedic techni. dure and references to other necessary procedures were cal guidelines and that iailed to support deviations by ade- often implicit. Graphics within the liOPs were sometimes quate justification. Even with the many omissions in writ. of poor quality and unreadable. In some cases, the ab. ,

er's guides, nt merous cumples of liOPs wer e found that sence of appropriate human factors expertise was appar-deviated f rom what little guidance was provided. Exam. ent. V&V checklists of ten included subjective criteria, ples of these weaknesses included buch as"Is the procedure adequate?", rather than specifie .  !

objective criteria referencing the control documents.

e procedures that did r 1 follow the mitiration strate. V&V documentation was often signed by the procedure ries desenbed in the ;;eneric technical guidelines or writer, indicating a lack of indepe,. dent V&V.

plant 4pecific guidelines Most V&V programs lacked criteria to define the type e procedures that did not fo' low the criteria for style and amount of V&V eqmred for procedure revisions. As and format defined in the writer's guide a result, liOP revisions were sometimes not formally revenfied or revahdated or were subject to inconsistent

• procedures with poor step construction, logic strue. V&V methods. Determination of when a procedural 1ute, refereticing and transition formats, and caution change requited additional V&V were often based on the "

i statement and note structure discretion of the pmcedure writer or the individualinitiat-ing the procedural change.

• procedures with numerous escrepancies between plant equipment identificatii a and pmcedure nm in many cases, V&V was not considered necessary for menclature  !!OP support procedures. As a result, a number of these procedures were not usable, did not provide the intended a procedur es with incon ect operator action set points result, or were in conflict with the strategy of the EOP that referenced them.

• procedures that did not contam adequate detail for . .

. hical operator actions VAV is miended to back up the use of complete end accu.

rate control documents in the development and revision -

-* procedures that did not consider harsh environ; of the pmcedures. It runstitutes the final review before mental factors P"'cedun s an nuplemented. Without an ellectise V&V process, operators may be dependent on unusable or in-

• pmeedures that did not tellect plant modifications correct procedures to mitigate an accident.~lhe potential -

safety consequences imm inadequate V&V of EOPs

• procedures that lacked a specified placekeeping could be sigmficant.

method ,

Many liOPs contained references to labeling and equip.

ment that failed to match the nomenclature used in the  !!OP-3 inspections revealed continued weaknesses in plant, in some cases these discrepancies were dramatic, EOP training. A numbei af operators reported that leaving no method for an operator to ensure that the cor- the simulator scenarios conducted as part of the EOP-3 rect equipment was being operated. Incorrect valve num- inspection took them farther into the l' ops ihan they bers were found throughout EOPs. Manipulation of inac- had experienced in training.In particular, simulator train-cessible valves was requin d by numerous procedures, ing was often limited on functional recovery procedures Other ensimnmental obstacles to EOP perfortnance in, and other less hkely emergeng contingency actions.

N URl!G -1358. Supp.1 X i

. - , , ,,<-n.-n.s., as~ ,,-w-,.--a,-m ,,-,.vm,..-.w,,,-w.,,, r-,,,, , - - , -L~~a , ~.. ,. ,-,.,,,.v, ,,,, l- w m- , - - l=i wN

_ _ _ _ _ _ _ _ _ _ _ _ _.m . . . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ .

l l

Variation in the usage of proadures between operators in several licensee training programs to objectively and was not uncommon. At several plants, management ad- explicitly define the mies and responsibil; ties of the crews mitted that not all aspects of procedure use Sad been de- as well as communicate licensee managements' expecta-fined. tions for the use of procedures.

Non-licensed operators involved in the performance of 2.5 Maintenance and Revision EOP m-plant actions or support procedures used during the esecution of EOPs often lacked EOP-specific train- NUl(EG-1358 cited weaknesses in the lien-s* ap-ing. Other plant personnel. such as craftspersons and proaches to maintaining and revising EOP continu-themists, who rnight be called on during the use of an ing basis. Documentation supporting liG r ~ visions was EOP, generally were unaware of their roles. generally poor, and V&V of I!OP revisions was seldom performed. In NUllEG-1358 the staff recommended i Training on EOP revisions was often uncontrolled, und that licensees establish a formal program for the ongoing lacked criteria for the type and amount of training evaluation and revision of EOPs to ensure that changes to needed. Operators at some plants reported surprise at the plant design, technical specifications, tr chnicai guide-some evisions noted w hile assisting EOP-3 irnpectors on lines, writer's guide, and other plant pmcedures are re-walkdowns. Communication between traming personnel flected in the key elements of a formal rnaintenance and -

and operations staff was of ten poor. Training departrnent revision process.

personnel reported that their input on !!OP usage was often neglected, although imprmement in this area has I!OP-3 inspections revealed that weaknesses in EOP

, been seen recently, maintenance and revision continued to be an issue. Many licensees did not develop or implement formal mecha.

To ruinimin human variation and errorin the perforrn. nisms for revising or evaluating EOP revisions. As men-ance of EOPs, the procedures should be consistently doned earlier, communication among licensee organita-structured, with clear rules of usage. Operators can then tions $g, operations and t rammg) on EOP revisions was ,

be trained to have a common understandingof the proce. often mformal or nonexistent.

dures and their use. Wh n operaNns management thor- . .

.the criteria used to determme if \,&V of revised procc-oughly defines how the) ish the procedures to be per- dures was required were very subjective, if they existed at formed and communicatu this phih, sophy of use to the all. In many cases, V&V of I!OP revisions did not reqmre training department, effective training is maximited.

• " "*"8 of the procedure changes in control room, Even if the procedures are soundly developed and sub- .

plant, or simulator. As a result, changes to plant hard-jected to effective V&V, weaknesses in EOP training, waremiuipment locau,on, and equipment access were not such as those identified during the !!OP inspection pme, always integrated into the EOPs.

ess, increase the risk of error with sigmficant safety impt ,

C"U""' Itevisionswere not alway- iewed against th: guidelines for procedure developeo ic., PSTGs and writer's The staff has focused a tdgnificant amount of attention on guide), and the guidelines were ,:ot always revised to ac-the issue of procedural usage, including developing count for operating experience or plant modifications. As guidance for the review of licensees' procedural adher- a result, format and structure variations were intmduced ence contmls (NI(C Inspection Manual, inspection Pro' into the EOPs, as well as ineffective mitigation strategies.

cedure9900-Operations "Pmcedural Adherence,"and All of which resulted in increased complexity and poten-SFCY-90-337," Procedural Adherence llequirements"). tial confusion in using the EOPs: thereby u'ltimately in-The staff expects licensees to have a process that effee- creasing the probability of operator errors.

tively controls procedural adherence. l ieensee manage-ment should establish expectations for the use of EOPs In some instances, licensees implemented formal revision and support pmcedures and a process to ensure proper proecsses requiring the initiator of a revision to perform commumcation of these expcentions to all plant person- all of the activ..ics associated with implementing the nel responsible for implementing the procedures. change. *lhus, the initiator of a procedural change re-viewed the basis for the pmcedural step, rewrote the step,

.Once again. the importance of these findings cannot be reviewed the revision against the applicable guidelines, minimited considering the number of um;atisfactory op- and peiformed any safety evaluation required for changes ern requalificatica programs resulting from problems affecting the intent of the procedure. Ilecause of the bur-with the operators implementing the EOPs. These pmb- den 7"ced on the initiator, operators did not aggressively lems included ucaknesses in crew communications, com- . pi - correcting deficiencies and imtiating enhance-mand and control, inconsistencies in EOP implementa- rnems A rnultidisciplinary approach toward implement-tion, and failute to follow the EOPs or understand the ing a revision would more likely promote greater operator rules of usage. 'these pmblems exemphfy the weaknesses acceptance of and input to the revision pmcess.

9 NUltEG-1358 Supp.1

1 icensees did not always establish criteria that specified Although licensee management attention appeared to the requirements for trainmg on EOP revisions. In some have improved at some plants, the results of the !!OP-3 instances, revisions made to EOPs were identified inspeethms clearly indicate that many licensees have not through internal communication channels such as night dedicated a sufficient level of resources to the EOP pro-orders or through discussions conducted during liOP pram. Problems ranging from failure to adequately docu-traming. Ilowever, communication of procedure tevi- ment PSTOs to failure to adequately communicate !!OP sions af fecting kical control activities performed by non- rules of usage, combined with the lack of plant manage-licenscd operators or technicians who did not attend for- ment's awareness of NRC inspection findings, indicate mal I!OP training sessions was often overlooked. This weaknesses in licensee management attention to the created a situation m which personnel supporting the EOP program. As stated in NUl(EG-1358, "A perma-EOP implementation were not aware of changes to pro- nent commitment must be made with ongoing attention cedures that they were responsible for implementing in to program needs." Again the staff emphasizes the need an emergency situation. for licensee management to place a high priority on pro-viding the staffing and resources required to develop and The staff again recommenJs that Fcensees consider sev- implement EOP programs that will provide operators and -

eralirnportant elements awociated with the development support staff with high quality llOPs and the training nec-of a formal maintenance and revismn proecss, as de- essary to appropriately implement them.

scribed in NUREO-1358.These elements include e a formal policy to determine when V&V is required N I on a revised procedure Throughout 1989 through 1991, the staff conducted a se-rics of EOP followup inspections to evaluate licensee e a formal notification system that helps ensure aP* resolutions to technical concerns raised during the initial propriate feedback on revisions to operation < and l'OP inspectionL Although programmatic and proce.

training dural improvements were observed at many plants, the staff contin ued to identify significant weak nerscs in licen-e a mechanism to encourage solicitation and utiliza- sees development and revision of the EOPs. In some in-tion of comments as a result of EOP use stances, licensees were aware of specific weaknesses in their programs and were in the process or evaluating cor-e a mechanism to ensure timely disposition of errors in rective actions or developing long term programs to re-the I! ops and to ensure consisteng with technical solve these issues. Notable improvements that were ob-puidelines and the writer's guide served in several licensees EOP development programs included e a program to ensure management of the EOP tech-nical documentation o revisions to writer's guides to define explicit devel. _

opment enteria and to incorporate EOP support e a program to ensure continued review of the EOPs procedures and appheable incorporation of plant design changes into the !! ops and basis documents e revisions to V&V programs to include a multi-disciplinary team approach and to incorporate for-liy implementing such an approach, many of the current mal QA review and support procedures into the weaknesses would be corrected. V&V process e changes to liOP maintenance and revision programs 2.6 M911agellicllt ISStieS to include additional explicit criteria desenbing V&V requirements for liOP revisions, to improve EOP-3 inspections revealed that several licensees had formal communications between operations and started to place greater emphasis and to focus increased training and formalizing the methods for soliciting resourecs on their EOP programs. More licensees imple- comments on EOP usage, and to develop explicit mented multidisciplinary team approaches and improved' training requirements for !!OP revisions -

o ~ awareness of the need for interdisciplinary commu-

r. .ations throughout EOP development and implemen- e improvements to non-licensed operator (NI.0) latian. In some instances, licensees invested in software training included identifying NI O tasks and devel-and hardware products to support the maintenance and oping formal classroom and on the job training on pn> duction of EOPs in-house. Some licensees obtained HOPS for NI Os human factorsand technical expertise to help develop the basis documents for EOP development and to participate The continued weaknesses that the staff observed during in EOP verification and validation. the l!OP followup inspections included incomplete NURHO-1358, Supp. I 10

l technical basis documentation, plant labeling discrepan- contributed significantly to the pmblems with the opera-I caes, inadequate support pmcedures, and concerns about tors' implementation of the !! ops and was a factor in 10 accessthility of some plant equipment. In adJition, some of the 15 (67%) unsatisfactory operator requahfication licensee < had addressed the specific procedure deficien- programs since 1988.

cies identified during the I;OP imtial inspections, but had fatled to correct additional dehciencies not specifically The development, implementation, and maintenance of identdied by the staff, which indicated a sigruficant wcak. uuahty liOPs is contingent on the cffective use of the ness in heensec !!OP mamtenance prograrns. guidelines and administrative controls and effective im-plementation of the processes established for l!OP P"'P"r"li"n, w fundamental components of liOP de.

3 CONCLUSIONS velopment (e.g., preparation of detaded techmcal basis in NUlt!!G-1358 the staff described the root causes of docurnents and procedure writer's guide, !!OP pnx!ue-the widesprcad programmatic weaknesses as the failure lion. YkV, !!OP training, and maintensnce and revision) of the industry to follow the published guidance on up- should be defined, documented, and used by plant per-grading I!OPsl'the most significant programmatic prob. sonnel to establish quahty !! ops. 'ihe criteria for deter-lenn reported in NUlt!!O-1358 included ruining the adequacy of the implementation of these fun-

&cntal components should be explicit, restrictive, and

' tim y used by the procedure development stalf The e lac L of a multidisciplinary team approach isc o " developrnent staff should consist ofindividuals a lack of human factors expertise wn . va iety of dtserplines to ensure appropriate techru-e lack of an independent review to ensure that 110h Ncm is dire are conect and can be performed dure mWon. qed at the tasks associated with and technicians, must play an mtegral role m , this procese, for they are ultimately responsible for tmderstanding and e lack of a systematic process for ensuring that the implementing the pnicedures.

quality of 1; ops does not degrade over time e lack of adequate managernent cornnutment and suf-ficiently high priority of the liOP pmgram within the Nuclear Management and llesources Council licensee organization (N U M AltC), " Industry Workshops on t imergency Oper-atmg P:ocedures (l!OP) Activities (Proceedings)," June in this supplement, the staff characterized the weak- 1989 nesses and st rengths in licensee liOP programs as a result of the third phase of the N11C's special inspection pro. U.S. Nuclear llegulatory Commission, Generic 1 etter gnun for I! ops and the ongoing liOP followup inspec- 82-33, D. liisenhut (NitC) to all licensees, " Clarification uons. It is important to note that the weaknesses in the of TMI Action Plan llequirements, Itequirements for liOP development process ultimately manifest them- limergency llesponse Capability " Supplement I to selves in procedures that are overly complex, ddficult to NUltliG-073 /, December 17,1982, implement, or simply incorrect for their intended func-tion.The staff identified numerous weaknesses in many - , Information Notice 8644,

• Deficiencies in Up-licensees llOPs and support procedures during the !!Op grade Programs for Plant limergency Pmcedures,"

inspections. Overall, these weaknesses represent defi. August 14,19h6, Supplement 1. April 29,1987, ciencies m the processes used by licensees to develop the

- , NilC Inspection Manual, inspection Pmcedure liOPs and I!OF support procedures 'lhey also represent 99%OpaauonVProcedural Adherence," January 14, a failure of the industry to effectively incorporate the 19W -

guidance previously provided by the staff in the lessons learned from the initial inspections, as documented in - , - , inspection Procedure 42001, "limergency N Ulti!G- 1358. Operating Procedures," June 28,1991.

While some licensees have invested considerable efforts __, _.

. Temporary Instruction 25i5/79," Inspection to resolve these pmgrammatic problems, the results of of limergency Operating Pmcedures " lune 25,1986.'

the liOP-3 and ongoing I!OP followup inspection efforts indicate that considerably more attention can and should - , , Temporary Instruction 2515/92,"limergency be focused on improving the pmgrammatic elements of Operating Procedures Team Inspections," April,1988.

liOP production and improving the !! ops and liOP sup-port procedures.The importance of these findingsshould - , NUltliG4660,"NitC Action Plan Developed as a not be overlooked. As noted previously, the weaknesses itesult of the TMI-2 Accident " Volumes 1 and 2, May described in NUltliG-1358 and this supplement have 1980, Itevision 1, August 1980.

11 NUlti!G-1358, Supp.1

- , NUREG-0737," Clarification of TMI Action Plan - , NUREG-1358, " lessons Irarned I' rom the Spc.

Requirements," November 1980, cial Inspection Program for limergency Operating Proce.

dures," April 1989.

- , NURl!G-0800, "U.S. Nuclear Regulatory Com-mission, Standard Review Plan, Office of Nucicar Reac- - , NUREG/CR-5228. " Techniques for Preparing tor Regulation, July 1985. Howchart Format timergency Operating Procedures,"

January 1989.

- , NUREG-0899. " Guidelines for the Preparation of - , SECY-90-337, " Procedural Adherence Require.

Ernergency Operating Procedures," August 1982. ments " October 3,1990.

I i

l J

4 l

I

(

l I

b NUREG-1358, Supp. I 12 I

. , . _ . . - _ _ . , _ , . - . . ,__;_._....._._..,..,._._,n. - -n,--...- . ;. . _ - , , . . . .

APPENDIX A 1.lST OF Pl. ANTS INSPECTED DUltlNG 1988-1991 UNDElt TEMPOllAltY lNSTitUCTION 2515/92 FOlt Tile Till11D PilASE (EOP-3)

Westinghouse: General I:Ic(tric:

licaver Valley liig 1(ock liraidwood lirowns 1 erry Callaway Clinton Catawba I avtlle Comrnanche Peak Ijmerick lhablo Canyon Nine hiile 2 Farley Perry Ginna 1(iver llend Ilad-Jam Neck Susquehanna l1.11. l(obinson WNP-2 Indian Pomi 3 Kewaunce Followup Inspections at hiillstone 3 North Anna Cooper Point lleach 1)uane Arnold Salem Grand Gulf San Onofre 1 llope Creek Seabrook limerick / Peach llottorn Shearon llarns h1illstone 1 South Texa' Oyster Creek Surry Susquehanna Tur key l'omt

$"EIIC llahtock and Wilcos:

T ankee llowe

'three hiite Island I l'ollowup inspections at Combustion 1:ngineering:

Ilyron Callaway ANO-2 Ginna ' Calvert Cliffs indian Point 3 Fort Calhoun Kewaunce hiaine Yankee hicGuire Palisades North Anna Palo Verde Salem Summer l'ollowup Inspection at Suriy Zion Palisades Appenda A 13 NUlti!G-1358, Supp. I

i APPENDIX 11 CIIECKLISTS OF CRITERIA FOR Tile DEVELOPMENT OF EMERGENCY OPERATING PROCEDURES AND SUPPORT PROCEDURES

'the inspections showed that licensees typically failed to e procedure title, abbreviation or acronym (in-address all of the necessary components for an adequate ciuding unit designation for multi unit sites emergency operating procedures (!!OP) program. 'lhis with unit spedfic procedures) appendix gives a set of checklists that should be used to ensure consideration of the major issues of any 1:OP pro- e revision number j grarn. Wher e possible, previously published guidance and  !

good practices identified from the inspections are inte- e revision date i grated.

• review and approval signatures

'lhe issues in the checklists may be addressed in may dif- (2) Procedure lhx!y Icrent ways. 'Ihe items on these lists should be addressed in smne way by every licensee's !!OP program. In some , scope J cases, a licensee may determine that omission of certain '

issues is justified; if so, the reason for climinating the is- , list of necessary equipment, keys, etc.

sucs should be documented. Any elements of a licensee's procedures that do not fall into some category of the fol. e entry conditions lowing lists also should be explicitly addressed in the plant specific writer's guide. e automatic actions (that should have occurred) e immediate actions 1 WRITER'S GUIDE-TEXT e fouowup aca.ms -

FORM AT EOPs A wnter's guide controls the presentation ofinformation in a set of liOPs. Therefore, it is essential that the guid.

ance defined in the writer's guide bc applied consistently 1.2 IHdiVidual Page Content and ,

throughout the procedures, whether the actions are in. Strucittre f cluded in the procedures specifically called !! ops or they are found in other procedures (support procedures) ref-

• pages numbered " _ of _,"

crenced by the I! ops, e pntedure title and number on each page Any actions required to complete the IIOPs and bring the o revision indication on each page plant to safe shutdown should be presented to the user in the same high quality manner and controlled as carefully *- unique step numbers for all steps and substeps (for as the !! ops. Therefore, any procedures referenced by exampic, step - 2.4; substeps - 2.4.1. 2.4.2.)

the llOPs and necessary for safe shutdown of the plant should be controlled by the writer's guide and verified and e if dual column format, unique step numbering be-validated to the same standards as the !! ops. tween columns (for example. left column step - 2.4; corresponding right column step - 2s4.a)

'lhe format for cach item covered under the following topics shoul be defincJ, and where practical, examples e _ all sections begin on a new page should be provided in the writer's guide.

e divisions and headings for procedures and sections addressed 1.1 Procedure Completeness e steps sequenced according to technical necessity and -

human factors principles (equipment and instru-(1) Cover Page mentation layout) e procedure number e use of foldout pages addressed if applicable-Appendix 11 15 - NURiiG-1358 Supp.1 rwmWmww vv rven f ww w w r-trYm-rw+-'mwwCq" -a r yv "'F-*' W N

• page rotation should be minimized

• other terms used as logie terms prohibited (e.g.,

llUT. UNTil., IIXClilrr, Ill!FOltli) e placekeeping aid (s) defined (e.g., table of contents, index tabs, checkoff spaces, and page ribbons)

• TilEN not used to connect steps

• hration infortnation provided for equipment rarely

• use of AND and 011 in the same step prohibited (or =

used or difficult to find use clearly defined and minimited)

• sequentially perforrned lists and non sequentiallists

• TilliN always used with 11: and WillIN 1.5 Heterencing anti llranching

• method provided for tracking the accomplishment of any referenced support procedures and to main- Transitions) tain deat record of abnormal plant system status e prohibited when information could be presented in y (e.g., defeated interkx:ks, abnormal valve lineups' less than 5 pages of text pulled fuser., and lifted leads and jumpers)

• use rninimized 1.3 Action Steps e unique terms defined for each type of transition

• simple action directive , g g g;g

• continuously applicable, time-related, or recurrent

• step number (s) where operator is to enter included steps (Note: Some method of reminding the opera-tor that the step applies must be defined and format e procedure or section title and number included specified.) ,

e concurrent steps (Note: Same method of tracking 1.6 Cautions anct Notes both sequences of steps must be defined and fortnat

. specified.) e distinct and correct definitions for each included

• equally acceptable steps (Note: Attempt to mini.

• cautions mi7e these steps Use only one specific strategy if possible. -

address potential injury or damage placed immediately before first step to which

• contingency actions for any step (Note: Although they apply contingencies are not necessarily addressed by pro-viding an alternative step within the procedure, a complete on a page clearly defined approach to contingency actions is a -

no actions included critical part of any EOP philosophy of use.) -

one topic per caution

• hical actions clearly identified -

structured as follows: X (action or condition) will (or may) result in Y (hazard)

• adequacy of level of detail addressed

• notes 1.4 Logie S(eps

~

E'"*i # ""'I '"PP #'" " """ """"' i""

placed immediately before the first step to

• provide use and format of following terms: which they apply complete on a page inclusive Olt no actions included

{:' " # -

one topic per note 11 NOT Till!N 1.7 Supporting Material /Attaciunent Will!N conjunctive (and, or) defined

• use of tables and figures NUltliG-1358, Supp. I 16 Appendix 11

.- . . - ~ - - _. .. .- .- _ . .

o operator actions in tables and figures prohibited -* use of the following elements of punctuation de-fined:

o titled and numbered uniquely colons o only relevant information provided commas criods ullets o accessible location for attachments hyphens apostrophes Any pmcedures referenced by the !! ops (e.g., support quotation marks procedures, abnormal procedures, or standard operating virgules (/)

procedures) that are required to be complete the h0Ps parentheses and bring the plant to safe shutdown should be controlled e use of the followic.g elements of punctuation prohib-in the same manner as the EOPs. If there is any need for sted:

additional format and content guidance toaccommodate these procedures. it should be addressed within the writ- .

cr's guide. *C* *0I""S dashes cllipses (. . .)

1.8 Vocabulary I"[Isa' ex tion points I question marks 1 e standard American English used ,

o common operator language used 1.10 Units of Measures / Numerals /

Symbols / Plant NomenC!ature o simplest language possibic used

• all limits expressed quantitatively o words used consistently (steps or information ap-pearing in more than one location written identically

• units of measure correspond to related instrumenta-tion (no conversion or calculation necessary) for each use) e

• only numerical values used that can he read to the vague adverbs prohibited (e.g., rapidly, appropri- ,

ately) el f accumn o msuuments availalde o inclusive list of words to use and their definitions in.

cluded

• use of decimals and significant digits specified o list of words to avoid included

• all tolerances bounded o list of approved abbreviations and acronyms in-

• formulas and calculations avoided cluded (one meaning per abbreviation or acronym, one abbreviation or acronym per meaning)

• when formulas or calculations are unavoidable, some aid to performing them is provided I

L l.9 Grammar and Punctuation * .

inclusive list of acceptabic symbols included l- o complete sentences used

• distinction made between verbatim references to-plant labeling and nomenclature and nonverbatim o short, simple sentences used references (It is preferable that procedure refer-ences to plant nomenclature are exact matches to o one idea per step plant labeling.)

o appropriate auxiliary verbs used (e.g., is, be) 1.11 Production SpCCificationS.

o present tense, imperative mode used ("Open valve . all format specifications provided, for exampic X.")

type size o steps written to minimize punctuation type style Appendix 11 17 NUlmG-1358, Supp. l..

margins e ending points line spacing page number location e diredion of flow top to Imttom/left to right step number location hwation of tab!cs e crossed flowpaths prohibited

• quality of reproduction and methods specified e referencing and branching minimized e any color use defined (preferable to avoid or mini- e number of flowpaths within flowchart minimized mize) e dead ends prohibited

-e emphasis techniques and their use defined (e.g.,

tmderlining, bold print, capitalization, framing or 2.2 layout demarcation) e simplest possible presentation -

e emphasis re tricted to that specifically defined e consistent spacing between flowlines and symbols 1.12 Storage and Use e length of flowlines minimized when possible.

e distinct, easily accessible storage hication defined e directional indicators provided on long flowlines e _ method for casy identification defined e hierarchy of steps shown e pl cckeeping method provided (e.g., step number-e adequate control room space available for all possi-ble procedures in use at one time ng, a gnd system, checkoff spaces and grease pen-cils) 1.13 Revisioti

• pagin tion pr vided (when applicable) e e over 11 chart dimensions considered method for temporary revision a method for permanent revision 2.3 Symbols e frequency of revision

• specific rules for format of symbol content defined (should correspond as much as possible to that used e accountability for revision for text format procedures) e no hand-drafted changes allowed e n ym s n an rniat spded for each umque type of step, for example e method allows easy tevision w hen necessary; prohib- decision steps its uncontrolled or excessive changes conditional steps continuously applicable steps action steps 2 WRITER'S GUIDE- cautions tr$ *ch$ "g'""'" ' '""**i""'(" " "'i"8}

FLOWCil ART FORM AT EOPS tabics/figut es in addition to the guidance provided for text format liOPs (see Section 2.4 below), flowchart format liOP writer's e decisions and conditional steps minimized guides should address the following topics.The format for each item covered under the following topics should be e cautions included in flowpath before related step defined, and, where practical, examples should be pro-vided in the writer's guide. e notes preferably included in flowpath;if not, hicated -

consistently in casily accessible location 2.1 Flowpatti Progressioit e Method defined, when necessary, to remind opera-tor of steps or other information located previously e starting points in the flowpath NURiiG-1358, Supp. I 18 Appendix B

2.4 Adaptation of Text Format 3.3 Verification Against Plant Guitlance Imbeling and Instrumentation o question marks may be used in decision symbols

• conducted through walkdowns in the control room and the plant e cover page information may be included on flow-e criteria for acceptability should be defined as part of chart the EOP program e divisions and sections guidance may not be applica- e addresses sequence of actions relative to technical e

necessity and human factors prindples (e.g., plant 9" * " ' " " " "" " '"I e all other issues are also applicable to flowcharts e conducted by individuals with expertise in opera-tions, training, or human factors (Most appropri-l-

2.o Color ately includes the potential users of the procedure /

l E " " " ' " "E

• use minimi/cd o avoid blue for detail 3.4 Validation of In-Planit Actions e avoid yellow on white; no white on yellow

• may be conducted concurrently with verification e avoid red or green on periphery of large charts gainst plant labeling l

I o ensures actions can be physically performed (i.e.,

considers access, lighting and other environmental 3 VERIFICATION AND factors, avadability of necessary equipment, and VAL 1DATION communications)

'Ihc verification and validation (V&V) process should be e conducted by potential users and human factors spc-conducted by a multidisciplinary team (e.g., engineering, cialists at a minimum operations, human factors, training). V&V should be in-dependent and the writer or initiator of revision should not be included in the V&V process. 3.o,. Dynam,ic \,alidtit. ion 3.1 Verification of Teclinical Adeyttacy DJ"".ic validation will ensure that the procedure wor ks, that it is sufficiently detailed for use by a newly beensed e necessary documents listed (e.g., generic technical operator. and that it appropriately reflects crew roles and guidelines (GTG), plant-specific technical guide, asponubilitics.

lines (PSTGs), deviation documentation, technical e conducted through simulator exercises specifications, setpoint documentation, and any other plant-specific documentation) e scenarios should address sing'e, multiple, concur-e special attention paid to deviations from or additions

" " I ' "" "9 "" "' "

to the strategies of the GTG e all pa.ts of all EOPs must be exercised e conducted by individuals with expertise in engineer- a steps that cannot be performed on the simulator ing and/or operations validated through walkdown simulation e validation conducted using the minimum shift com-3.2 Verification of Written Correctness plcment anowed e necessary documents listed (e.g., writer's guide- e conducted by specialists in operations, training, and relevant plant administrative procedures human factors at a minimum o conducted by individuals with expertise in human e feedback processed from the operators performing factors and/or the principles of the writer's guide the scenarios as well as observers Appendix !! 19 N UltliG-1358. Supp.1

-3.6 Verilication 1111(I Vall(lation 0l' Criteria should be established for *e follorfing:

Revisions e ver dication and validation neceswiry for revisions or Criteria should be estabhshed for the following': "Sifh'"C"1 of the respmsibility to a multidiscipli-nary committec e defmmg what verification and validation will be con-e kind and amount of training necessary on revisions ducted on different types of revisions to the proce-dures. or a gnmqnt of the respormbility to a multidisciph,-

nary comnuttee e to determine the appropriate level of verification e providing the necessary training to operators before I and vahJation for revisions considered typographi-cal the revision is implemented in the control room l

I 5 TRAINING i 4 MAINTENANCE AND REVISION i i

OF PROCEDURES The following methods should be used: I i

I e single, multiple, concurrent, and sequential event 4.1 Ongoing Maintenance scenarios exercising au steps of ali EOrs possibic on the simulator Methods should be established for the following:

e simulator walkdowns to cover steps not exercised e regular evaluation of the liOPs by qualified person- during simulator scenarios nel e in plant walkdowns of local actions covered in the e mvolvement of QA in the ongomg evaluation of the liOPs and referenced procedures EOPs e training with normal shift complement in regular e ensuring that all procedures referenced by or refer- toles encing the EOPs be similarly reviewed to ensure no negative effect on the sueecssful performance of the e training with mimmum shift complernent EOPs e training on technical basis of the EOPs 4.2 RcVisioll of ille EOPs e training on the operations department management philosophy of use for the liOPs and referenced pro-Methods should be established for the following: cedurer e consideration and integration of comments from op- Critena should be developed for the following:

erating personnel and training into the !! OPS in-ciudmg a response to the initiator of each potential e training non-licensed operators on their role and any revision procedures they would use to support execution of.

the EOPs e ensuring that any changes in plant design, technical specifications technical guidelines, vendor informa- e ensuring EOP related trainingof any otherindividu-tion regulatory tequirements the writer's yuiJc.or als involved in supporting the esecution of the plant operational philosophy that affects the !! ops EOPS (e.g , chemistry, maintenance) will be integrated into a new revision of the EOPs in a timely manner e providing feedback to t he individuals respmsible for EOP development on the use of liOPs during train-e ensuring that any changes in riant design, technical ing or requalification examinations specifications, technical guid mes, vendor informa-tion, regulatory requiremeu..., that affect the EOP e rnanagement philosophyon the use of EOPs includ-basis documents (c.g., PSTO and writer's puide) will ing issues such as when one can exit from a procc-he integrated into a new revision of the EOF hasis dure, applicability of cautions, out of sequence documents in a timely manner actions procedural adherence, communication style N Ulw o-1358,Supp.I 20 Appendix B

- - . - - - - - - - , - - - - - . - . . . ~ . . - - - - - - - - . , - , -

Al'PENDIX C INSPECTION PROCEDUltE 42001,"EMEltGENCY OPEllATING PitOCEDUllES" I

__ _. . _-_ - _ _ _ _ _ . _ _ . . _ _ _ - _ . _ - ~ . - _ _ . - . _ _ _ _ ._

j#' "'%,' UNITED STATES ei. v; NUCLEAR REGULATORY COMMISSION

{ !'* j wAs.motoN. o c w.s i

} NRC INSPECTION MANUAL l

tsre INSPECTION PROCEDURE 42001 EMERGENCY OPERATING PROCEDURES PROGRAM APPLICABILITY: 2515 42001-01 INSPECTION OBJECTIVES 01.01 To follow op on inspection issues, events, or allegations concerning the licensee's Emergency Opertting Procedure (EOP) Program.

01.02 To de+. ermine whether significant changes to the licensee's E0Ps since the last inspection meet commitments and regulatory requirements.

01.03 To assess the ir. pact of the changes to the licensee's E0Ps on the licensee's E0P program and overall plant safety.

42001-02 INSPECTION FEQUIREMENTS 02.01 Review of E0Ps and S coor_ ting Procedures

a. Conduct an in-depth human facto.n adequacy review of E0Ps where signi- >

ficant human factors changes have b en made,

b. Where significant changes have been made, verify that the procedures are technically correct and accurately incorporate the most recent owner's group generic technical guidance and that any_ deviation (s) warranted by the plant-specific design are adequately justified and incorporated into the E0Ps as required.

c. Verify that entry and exit points are easily followed, and that tran-sitions between and within the Normal Operating, Alarm and Abnormal Operating Procedures and E0Ps are appropriate, well defined, and easy to folloa.

d. Evaluate tir procedures and the licensee writer's guide relative to significant human factors issues raised by changes to structure and format,

e. Determine the extent of deviations in the procedures from the current licensee writer's guide and evaluate the licensee's justification for the deviations,

f. Evaluate decision points in the procedures to determine if they can

~

I be easily discriminated and understood. i Issue Date: 06/28/91 )

l 1

1 NUREG-1358, Supp; 1 22 Appendix C

g. Verify that the use of notes and cautions is consistent and correct in the procedures.

02.02 Use of E0Ps and Supporting Procedures. Where significant - changes have been made, verity that the EOFs and supporting proc 6dures can be physi-cally and correctly performed both inside and outside the control rooms including simulator exercises if appropriate.

02.03 Knowledge and Performance of Duties

a. Verify that the control room staff is aware of and-understands all significant changes to the E0Ps.

b. Verify that operators receive training on revised E0Ps before the revised E0Ps are implemented,

c. Evaluate operator concerns regarding the E0Ps.

02.04 Review of 1.icensee E0P Progranrnatic Controls

a. Verify that the licensee's administrative procedures adequately govern  !

the progran for controlling changes to the E0Ps, the supporting pro- _;

cedures and associated operator training..

b. Verify that the licensee's documentation reflects adequate conduct of activities required by administrative procedures that control the -

E0Ps, and that E0P changes are incorporated, as appropriate, into the  ;

licensee's operator training program.

c. Verify that the licensee's staff possesses the required understanding of administrative procedures governing E0Ps and correctly implements them.

d. Verify that the licensee conducts independent. audits of the E0P pro-gram, as requirev, and has provisions for document control that are' commensurate with -NRC requirements, including facility licensing requirements.

l 02.05 Follow-up of Licensee Corrective Actions involving E0ps

, a. Verify that the licensee's documentation identifies and prioritizes i L

E0P weaknesses and that timely corrective - actions are implamented.

1

b. Evaluate the effectiveness of the licensee's corrective actions by control room and in-plant walkdowns, simulator scenarios, and plant staff interviews as applicable.

42001-03 INSPECTION GUIDANCE General Guidance. This procedure _is intended primarily for use in implemen-ting regional discretionary resources for Regional Initiatives or Reactive Inspection to inspect the significant changes to the licensee's E0Ps and' associated-programs. These inspection activities include the examination of licensee programs to follow up on corrective actions, to review programmatic-controls, and to follow up on identified; issues requiring licensee resolu-tion relative to E0P program deficiencies, weaknesses, or implementation.

Issue Date: 06/28/91 42001 l

Appendix C 23 NUltEG-1358, Supp.1

This procedure is also intended for use in conjunction with NRC Manual Chap-ter 0517,

• Management of Allegations," to examine elements of the licensee's I

E0P Frogram as appropriate to follow up on allegations concerning the pro-gram, it is not intended that each inspection requirement be covered during an inspection. Rather, inspection requirements should be selected or modif-ied, as appropriate, to address the issue or event that prompted the inspet-tion, preparation for the inspection should include a review of issues iden.

tified during previous inspections or operator licensing examination reports that would be indicative of weaknesses in the E0P Program, policy, or imple-mentation. Significant events with a root cause related to E0Ps should also be reviewed in preparation for inspection. During onsite inspection, all major changes, including those related to the resolution of identified is-sues, the base $ for the changes, and the effect of the changes on program ef fectiveness. *.hould be discussed by the team leader with licensee manage-ment.

By reference to the appropriate revision of Regulatory Guide 1.33, " Quality Assurance program Requirements," Section 6.8 of the Standard Technical Specifications requires that Emergency Operating Procedures be established, implemented, and maintained, in addition, the licensee should review the E0Ps to evaluate the safety review functions and the responsibilities of the onsite safety review organization. Further,10 CFR 50 Appendix B. Griterion Y1, requires that quality related A cuments, and changes thereto, be reviewed-f or adequacy and approved for relme by authorized personnel, in general, technical inadequacies or f ailures to properly implement and maintain E0Ps are violations of these requirements.

The NRC evaluates the owner's group Generic Technical Guidelines (GTGs) for safety and approves them. Where licensees elect to deviate from the NRC-approved GTGs, they need to implement correctly the 10 CFR 50.59 process' to ensure safe plant operation, particularly for design basis events, insuf-ficient or incorrect use of the 10 CFR G.59 process to evaluate deviations from the NRC-approved GTGs may constitute a violation.

S ecific Guidance l

03.01 Feview of E0ps

a. The review for human factors adequacy determines whether the E0Ps are adequate for the intended use and whether the licensee has accurately incorporated the guidance of the GTGs. Plant staff interviews should be (onducted with cognizant licensee personnel to assist in determin-ing whether the GTGs remain appropriately incorporated in the E0Ps.

Significant changes to the E0Ps and supporting procedures should be reviewed by inspectors with experience in human factors evaluation.

See NUREG-0899, NUREG-1358 and NUREG/CR-5228. Sec Section 42001-05 of 4

this procedure for full reference.

b. Operator comments on the technical aspects of significant changes to the E0ps, given during interviews with the plant staff, procedure walkdowns, and simulator exercises, should be evaluated and addressed in-- the inspector's E0P--technical adequacy review. Particular attention should be given to the following:

1. Comparison of -the GTG table of contents to the table-of. contents of plant-specific E0Ps and evaluation of the differences.

42001 Issue Date: 06/28/91 NUlWG-1358. Suppi 1 24 Appendix C

-- =. . - --z..

2. Review of licensee documentation addressing the development of plant E00s from GTGs.

3. Evaluation of responses to questions about the interporation of GTGs into the E0P5 from interviews with cognizant licensee per-sonnel.

4 Verification that the licensee has an appropriately prioritized accident mitigation strategies in the procedures and that recom-mended GTG step sequences are followed.

5. Verification that the licensee has an adequate technical justifi-catior, for identified deviations between the plant-specific E00s and the generic technical guidelines. See Generic tetter 82-33, full reference may be found in Section 42001-05 of this procedure, Assessment of the safety significante of identified deviations.

~

fs .

A sample of deviations should be examined to determine if the licensee has reported safety significant deviations to the NRC.

These deviations should be verified to be in accordance wi.th 10 CFR 50.59.

c. The use of walkthroughs and simulator scenarios provides a practical means to verify that the procedures are well defined and easy to follow for entry and en t points and for transitions,

d. For specific program guidance, see HUREG-0899, N'JkEG-1358, and NUREG/

CR-5228.

e. Significant deviations from the licensee's writer's guide for the E0Ps should be reviewed for adequacy. A significant number of minor deviatiot.s should raise questions about the consistency of E0P strutture.

f. A newly qualified operator should be able to properly implement the decision points in the E0Ps without needing further guidance. The logic points should have clear questions that solicit yes or no an- _

swers. See NUREG 0899, NUREG-1358, and NUREG/CR-5228.

g. The caution statements should identify potential hazards, and the notes and caution statements should not contain action statements.

See HUREG-0899, NUREG-1358 and NUREG/CR-5228.

03.02 Use of E0Ps and Supporting Procedures. Where major changes have been made or concerns have been previously identified, walkdowns, simulator exer.

cises on E0Ps and supporting procedures and interviews with plant staff should be conducted. Focus on whether:

a. The changes made to the procedures can be physically implemented and whether operators physically interfere with each other while perform-ing the changed procedures.

L. The changed procedures can be implemented within the time alloted considering the actual accident, the course of events, and the avail-ability of the necessary operating locations involved under those issue Date: 06/28/91 42001 Appendn C 25 N U R W - 1358, happ.1

those conditions.

c. Environmental conditions (such as temperature, steam, flooding, and and radiological hazards) that would exist during the event would prevent items a. and b. above from being accomplished,

d. Plant personnel can ef fectively use the E0Ps and supporting proce.

dures in the control room and other parts of the plant as necessary.

An evaluation of the consistency of instrument and control designe-tions as compared witn installed equipment labels and procedural de-scriptions should be included. Also, the indicators, annunciators, and controls referenced in the procedures are available to the opera-tors.

e. E0P activities that would occur outside of the control room can be performed with equipment on hand.

f. The licensee has validated and verifid the procedures. A docu-mented, comprehensive review should have been conducted by an inde-  ;

pendent, multidisciplinary team, including a human f actors analysis )

of the procedural changes and a walldown of the procedures in the j plart. See NUREG-1358, NUREG/CR 2005, and HU C 3632 which are fully '

referenced in Section 42001-05 of this procedure,

g. The latest revision to the procedures is in the control room, the Technical Support Center, and the Emergency Operation f acility.

03.03 Enowledoe and Performance of Duties

a. The control room staf f should understand how to perform the current E0Ps. To determine whether the operators are aware of recent changes.

to the E0Ps and understand the changes, limited plant-specific simulator scenarios should be conducted on at least one fully staffed shift crew. The simulator scenario should reflect relevant abnormal operating conditions thet require the use of two or more of the E0Ps ,

in which significant changes have been made. Each procedural step should be observed to determine that the correct procedures are used with proper transitions, and that each step is correctly implemented.

Where concerns are identified, the sample size should be expanded.

! Walkdowns should be conducted to further assess the operator's under-standing of the E0Ps, the supporting procedures, and recent changes to the procedures. During the control room and in-plant walkdowns direct observation should be made_ of selected operators in the sinulated performance of selected tasks required by the E0Ps. Such tasks include simulated -handling of equipment, interpretation of instrument readings, following procedures, proper sequencing of actions, and an understanding of information flow patterns related to a specific task. plant-referenced simulators, as required by 10 CIR 55.45 should be used for walldowns to allow hands-on performance for certain tasks. See SECY 90-337 which is fully referenced in Section 42001-5 of this procedure.

b. E0P training is ctered under Inspection procedure 41500.

l l

42001 Issue Date: 06/28/91

- NU Rl;G-1358. Su pp.1 26 Appendix C-

- . , _ . _ . - - .-_ _. ~.~.~ _-_ .- ___- . _ _ . _ _ _ _ _ . . _ _ .

c. Operator concerns regarding the E0Ps may be identified t'y the review of inspection reports, operator licensing examination reports, opera-tor responses to licensee training, procedural revier documentation, Licensee Event Reports (LERs), discussions with the Resident inspec-tors, and terviews with operators. Operators' concerns may be evaluated tg .0P desktop reviews, procedure walkdoans, and simulator crercises.

03.04 Feview of Licensee E0P Programmatic Controls

a. The licensee's administrative procedures should provide controls to ensure that all changes such as changes to the Technical Specifica-tions, setpoints, and those resulting from instrument and equinment modifications, are reflected in a tirnely manner, in the E0Ps, the setpoint documents, and the operator training lesson plans. An' active licensee program should provide for the long-term evaluation of E0Ps as recomended in Section 6.2.3 of NUREG-0899, " Guidelines for the Preparation of Ernergency Operating Procedures." The licensee's E0P --

evaluation program should be technically adequate and the E0Ps should be structured to incorporate operational experience and use, training experience, simulator esercises, control room and in-plant waUdowns and changes in plant design, technical specifications, tect,ni ca l guidelines, Writer's Guide, or cther plant procedures. (See Regula-tory Guide 1.33, Fev 2. which is fully referenced in Section 42001-05 of this procedure,

b. No guidance is necessary,

c. Interview the licensee's staff and management involved in the perform-ance of administrative procedures governing E0Ps to determine if they understand the procedures and if the procedures are implemented consistently among users,

d. See fdREG-1358.

03.05 Follow-up of Littnsee Corrective Actions with Regard to E0P Concerns No guidance is necessary.

42001-04 RESOUPCE EST! MATES for planning purposes, direct inspcction effort to accomplish this proce-dure should be established by the Regional office, consistent with the scope of planned regional initiatives or reactive inspections to be per-formed. Individuals having experience in evaluating human factors should accomplish the parts of this inspection that deal with human factors issues.

Direct inspection effort for reactive inspection or regional initiatives should be recorded on RIT5 against inspection Procedure 42001. If the procedure is used to follow up allegations in conjunction with NRC Manual Chapter 517, the attual time expended should be recorded on RITS against BJ1.

Issue Date: 06/28/91 42001 Appenda C 27 NUlO E IMS, Supp.1

42001-05 REFERENCES 10 CFR Part 50. Appendix B, Criteria y and VI.

10 CFP, 50.54(x) and (y).

10 "FR 50.9.

10 CFR Part 2, Appendix C, Criterion VI.

10CFR50.34(f)(2)(ii)and(v).

10CFR50.36(c)(5).

10 CFR 50.59.

Site Specific Technical Specifications, Chapter 6.

Gereric Letter 82-33, " Supplement 1 to NUREG - 0737, Requirements for Emer-gency Rt snonse Capability," December 17, 1982. (NUDOCS Fiche Address 16681

/208; SECY-90-337, " Procedural Adherence Requirements," October _3,1990. (NUDOCS Fiche Address 70497/142)

Regulatory Guide 1.33, Rev.2, " Quality Assurance Program Requirements (Opere-tion)," 1978. (hUDOCS Fiche Address 00125/155)

NUREG-1358, " Lessor.s Learned From the Special Inspection Program for Emer-gency Operating Procedures," April 1989. (NUDOCS Fiche Address 49726/209)

NUREG-1977, " Guidelines for Preparing Emergency Procedures for Nuclear Power Plants," April, 1981. (NUDOCSFicheAddress 08514/008)

NUREG/CR-4613. " Evaluation of Nuclear Power Plant Operating Procedures Class -

ifications and Interf aces," February 29, 1987. (NUDOCS Fiche Address 39983

/256)

NUREG/CR-3632, " Methods for implementing Revisions to Emergency Operating ^

Procedures," May 1984 (NUDOCSFicheAddress 24534/208)

NUREG-0899, " Guidelines for the Preparation of Emergency Operating Proce-dures," August 1982. (NUDOCS Fiche Address 15513/286)

NUREG/CR-2005, dures Used in Nuclear Rev.1, Power" Checklist Plants,"for Evaluation April 1983. Emerg(ency NUDOCS FicheOperating Address Proce-08790/355)

NUREG/CR-3177, Vols. 1, 2, and 3, " Methods for Review and Evaluation of Emergency Frocedure Guidelines," March 1983. (NUDOCS Fiche Address 21119

/138,1786S/033, and 17862/227)

NUREG/CR-5228, " Techniques for Preparing Flowchart-Format Emergency Operating Procedures," January 1989. (NUDOCS Fiche Address 49670/141)

" Supplement 3, Safety Evaluation for CEN-152, ' Combustion Ergineering Emer-gency Procedure Guidelines,'" November 5, 1986.

42001 Issue Date: 06/28/91 N U RiiG-1358. Supp.1 28 . Appendix C

1 l

l

• Combustion Engineering Emergency Procedure Guidelines," submittal 2 of Revision 3, August 6, 1980.

'Supplemer.t Safety Evaluation Report for ' Westinghouse Owners Group Emergency Response Guidelines, Revision 1,'" July 7, 1986.

' Westinghouse Owners Group Emergency Response Guidelines, Revision 1,

• liovember 30, 1983.

" Safety Evaluation of 'BWR Owners Group Emergency Procedure Guidelines, Revision 4, March 1987,'" 14[00 31331, August 1, 1988.

"BWR Emergency Procedure Guidelines, Revision 4," March 1987 Et40 --

Issue Date: 06/28/91 -B- 42001 Appendix C 29 N Ulti!G- 1358, Supp,1

f JnO f DOM 3 )*, U$ tJUCtr Alt rir QULAroHY COMM $$ loo 1- HLPOd1 f JdMDI H (2.ch I Assigond by f 4HC. AM Vol .

t#tCM 1102, faut 4) . Het and Adhdem PJ#w 3m 3M BIBLIOGRAPHIC DATA SHEET ' + ' . d *"* I i s.. .,wvet im, on in. ,.... . 3 NUlti!O-1358 Supplement No. I e inu Ano sunimt 3 D A I t hl PoH1 PVtnibHf U I essons 1.carned from the Special Inspection Program for I!mergency yy,, I qn Operating Procedures i October 1942 Conducted October 198K - September 1991

• e so on caren nuMot a o ^# ..w m o i vet o, iu roni G. S. Galletti. NitC Technical A. R Sutthoff, S AIC r et nico con om om:in.~. oms; October 19N8 - September 19"!

e et s, onv,,o un#,u A noo - naut Anu Avant s s vi onc. nm.a. om..on, oen c . or u.am u s. tw ., n v.io,y commi.um .m _

'h g a .fvj Atk.ng; el Con!' 8C ior , poofJn hamer AM ,tell6ng ad-$f.St l lhvision of lleactor Controls and lluman l'attors Of fice of Nucicar ittactor llegulation U.S. Nutlear llegulatoiy Commission Washington, I)C 20555 9 woosoona onavua nou - Naut Ano Anontss m retc. in. e. m. as stove. . it conn e tv. nov d. NHC Divmon. o%. Or Rege U% t hetiteer Degdatn*y C wmulton. 4N ma bnQ AM.t t )

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'the results of the team inspections conducted during October 1988 - September 1991 for the Nuclear llegulatory Commission (NitC) limergency Operatmg Procedures (liOPs) Inspection l'rogram are summarized in this report. In-spectmn results are discussed in relation to pnt staf f guidance provided to the utilities for upgrading !! ops. In this _

rejurt, the NitC informs the nuclear powc- ,dustry of concerns that were identified durmg the !!OP team inspections and restates the staff's presious guidance u: < format that more clearly illustrates the consequences of programmatie w eak nesses.

'lhe information contained in this report is prosided so that licensees may take advantage of the lessons learned from the IMIP inspection effort. This report does not impose any new requirernents related to the upgrading of liot's.

?? > f V WOADS/D( scn pion s n..st vwren or pN ases inat v,m ass'st resea etes m locatrng th. tocwxt } O Avat ADu v ST AHMLNT Unhmited 14 SE C UHtT Y CL A S S'F tC ATION human factors , , , , ,

emergency operating procedure inspection report Unclawhed o wn m.mo Unclassified is emt a c# exu 10 UH1Ct.

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1 Printed on recycled paper

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OCTODER NUREG-1358, Supp. No.1 LESSONS LEARNED FROST TIIE SPECLAL INSPECTION FROGRA31 FOR E31ERGENCY OPERATING FROCEDURES UNITED STATES FinsT ctAss Matt

.-- POSTAGE AND rEEs rAto NUCLEAR REGULATORY COMMISSION ,

usNRc WASHINGTON, D.C. 20555-0001 '-

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