ML20128C075

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Rev 3 to Administrative Directive AD-2, Authors Guide for Operations Dept Documents
ML20128C075
Person / Time
Site: Salem  
Issue date: 02/19/1985
From:
Public Service Enterprise Group
To:
Shared Package
ML18092A616 List:
References
AD-2, NUDOCS 8505280177
Download: ML20128C075 (58)


Text

i t

ATTACHMENT 2 SALEM GENERATING STATION OPERATIONS DEPARTMENT DOCUMENT APPROVAL COVER SHEET

Title:

Authors Guide for Operations Department Documents No.:

AD-2 Unitt 1/2 Rev.:

3 Remarks:

fif ty-four pages of text, no forms, revised to incorporate requirements for Emergency Cperating Procedures.

Safety Related Review (Ref. AD-13) :

S/R yes no x

Author's Checklist Completed:

yes x

Date#*!d!W-Author C

.SRO

/

h Date 8

Ops. Eng._

/

DateT ~/9 -7 SOTS + h M M A

Date A O N

/

M Ops. Mgr.

m P[

m Date

/

QA Date 83 SORC W

Dateo i M

General Mariager** 4 ebfW Date e

  • required for SPM documents only

+ required for EOP validation acceptance only

    • required for safety related documents and fire protection documents Salem Unit 1/2 AD-1-B-1 0505200177 050515 PDR ADOCK 05000272 F

PDR

ADMINISTRATIVE DIRECTIVE - 2 AUTHOR'S GUIDE FOR OPERATIONS DEPARTMENT DOCUMENTS 1.0 PURPOSE 1.1 This directive provides standardized guidelines on how to format and prepare documents and procedures so that they are complete, accurate, convenient, readable, and acceptable to their users.

1.2 The scope of this directive encompasses all docu-a-*s under the cognizance of the Operations Departman particular, however, the guidance has been providea :or use in prepar$ng the following documents.

1.2.1 Administrative Directives 1.2.2 Operations Directives 1.2.3 Integrated Operating Procedures 1.2.4 Emergency Operating Procedures a

1.2.5 Abnormal uperating Procedures 1.2.6 Operating Procedures 1.2.7 Surveillance Procedures 1.2.8 Periodic Inspection Surveillance 1.2.9 Alarm Response Procedures 1.3 Although it is intended that all guidance provided within this directive is to be followed, it is not the purpose of this document to establish implementation requirements (e.g. priorities, schedules, etc.).

The implementation of this guide shall be controlled by the Operations Manager.

2.0 DOCUMENT DESIGNATIONS, NUMBERING, AND LAYOU" 2.1 Procedure Designations 2.1.1 Each operations Department document shall be uniquely identified with a combination of alpha-numerical designators.

a.

This identification facilitates the administration of the process of document preparation, review, revision, distribution, use and even subsequent records handling, storage, and future retrieval MAST kev. 3 Salem Unit 1/2 1

AD-2 2.1.2 The unique identifier assigned to each document above is provided in the respective subsections of Section 5.0 below.

2.2 Cover Sheets 2.2.1 All Operations Department documents shall be controlled by use of the Operations Department Document Approval Cover Sheet as specified in AD-1, Changes to Station Documents.

2.2.2 With the exception of Alarm Response Procedures, each individual procedure and instruction shall have a' separate Document Approval Cover Sheet.

2.2.3 For Alarm Response Procedures, the Document Approval Cover Sheet will also be used but may be used to control the procedures on either an individual or group basis providing that there is adequate traceability.

2.3 Page and Revision Identification 2.3.1 Each page of the document shall have the procedure designator, the page number, the revision number, and the unit number to which the procedure is applicable.

2.3.2 The layout of the above required information is described in AD-4, Typist Guide.

2.4 Text Numbering 2.4.1 The text of the various Operations Department documents presents guidance and instructions.

To accommodate the presentation of this type of information, the following numbering / lettering system shall be used.

1.0 section heading 1.1 section (Section number is underlined in EOP's only).

1.1.1 subsection a.

step (1) subscep (a) part Salem Unit 1/2 2

Rev. 3

AD-2 2.4.2 The layout (e.g. spacing, indentation, etc. )

associated with text number is described in AD-4, Typist Guide.

2.5 Attachments 2.5.1 Attachments (e.g. figures, tables, checkof f sheets, flowcharts, etc.) to procedures and instructions are permitted provided that they enhance the document by containing only the relevant information needed to clarify, provide documentation, or accomplish the purpose referenced in the text.

If the information present'ed in an attachment can be presented in the text of the document, then it should be presented in the text.

2.5.2 Attachments' shall be numbered sequentially corresponding to their order of reference within the text.

The symbol (#) and abbreviatien (No.)

are unnecessary and should not be usec.

2.5.3 Page and revision identification of each attachment shall be as described in section 2.3.

2.5.4 The text (if any) of each attachment should be numbered in accordance with section 2.4.

2.6 Footnote Numbering 2.6.1 Footnotes in the text of the procedures should be avoided at all times.

2.6.2 Footnotes may be used in figures, tables, and checkoff sheets.

2.6.3 Footnotes shall be on the page on which they are referenced and numbered for that page.

Footnotes l

may be repeated as often as necessary.

2.6.4 Footnotes in tables should be designated by I

asterisks.

MMTER Salem Unit 1/2 3

Rev. 3

AD-2 3.0 MECHANICS OF STYLE 3.1 Spelling 3.1.1 Spelling should be consistent with modern usage.

When a choice of spelling is offered by a dictionary, the first spelling should be used.

3.2 hyphenation 3.2.1 The use of hyphens should be avoided unless its omission would result in confusion.

3.2.2 Hyphens should be used in the following circumstances.

x a.

In compound numerals from twenty-one to ninety-nines Example:

one hundred thirty-four b.

In fractions; Example:

one-half In compounds using the word "self";

c.

Example:

self-contained d.

When the last letter of the first word is the same vowel as the first letter of the second word; Example:

fire-extinguisher e.

When misleading or awkward consonants would result by joining two words; Example:

bell-like f.

To avoid mispronunciation or confusion with another word; Examples pre-position vs. preposition g.

When a letter is linked with a noun; Example:

0-ring h.

To separate chemical elements and their atomic weights Example U-235 MASTER Salem Unit 1/2 4

Rev. 3

AD-2 3.3 Punctuation 3.3.1 Punctuation should only be used as necessary to aid reading and prevent misunderstanding.

Word order should be selected to require a minimum of punctuation.

When extensive punctuation is necessary for clarity, the sentence should be rewritten and possibly mace into several sentences.

3.3.2 Punctuation should be in accordance with the following rules:

Brackets should not be used except in

{

a.

formulas.

b.

A colon should be used to indicate that a list of items is to follow.

A comma should be used after conditional c.

phrases for clarity and ease of j

I understanding.

{

d.

Parentheses should be used to indicate alternative items in a procedure or instruction.

They can also be used to contain detailed information or data relevant to the sentence or phrase; such as equipment number, tolerances, etc.

Parentheses are used in formulas.

An apostrophe is to be used to indicate the e.

possessive case or the plural of letters and figures.

3.4 Capitalization I

3.4.1 Capitalization should conform to standard American English usage.

Some examples are a.

Names of Organizations (1)

The formal names of organizations, institutions, or companies should be capitalized.

Examples:

Nuclear Regulatory Commission l

Public Service Electric and Gas Company MASTER Salem Unit 1/2 5

Rev. 3

AD-2 (2)

The informal reference to an organization or company should be lower cased.

Examples:

the commission i

the company b.

Documents and Publications (1)

The official titles of documents and publications should be capitalized.

Examples:

Code of Federal Regulations Operations Department Manual (2)

Do not capitalize articles and prepositions in a title unless used as -

the first word.

Example:

The American College Dictionary c.

Titles in an Organizational Structure (1)

Capitalize official staff positions and titles.

Examples:

Operations Manager Senior Shift Supervisor (2)

Do not capitalize general classifications or groups of personnel.

Examples:

operator electricians d.

Systems and Components (1)

Capitalize the titles of plant systems.

Examples:

Residual Heat Removal System Reactor Coolant System (2)

Capitalize the names of ma]or plant components.

Examples:

Charging Pump No. lA Diesel Generator MASTER Salem Unit 1/2 6

Rev. 3

AD-2 s

3.4.2 Capitalization, in addition to 3.4.1 above, should be used as a technique for emphasizing certain words, phrases, or headings and for presenting plant specific information.

Some examples are:

a.

Text Headings (1)

The major section headings in the text of documents shall be in full capitals.

Examples:

INTRODUCTION FINAL CONDITIONS (2)

The keywords in subsection heading shall be capitalized.

Examples:

Containment Purging Initiation of Excess Letdown b.

Document Attachments (1)

Capitalize references to tables, figures, etc.

(2)

Capitalize the titles of attachments when used within the text.

(3), Fully capitalize a title when it heads a table, figure, etc.

(4)

Capitalize column headings within a table.

c.

Operational Modes (1)

Capitalize the modes of operation as they apply to a specific plant condition (i.e. combination of core reactivity condition, power level, and average reactor coolant temperature).

Examples:

Hot Standby Cold Shutdown (2)

Capitalize modes of operation as they apply to a specific system configuration.

dxamples:

Hot Leg Recirc Cold Leg In]ection MASTER Salem Unit 1/2 7

Rev. 3

AD-2 d.

System, Component, and Device Identifiers (1)

Capitalize all letters of system acronyms, and the letters in component and device codes.

Examples:

RHR (for Residual Heat Removal System) 21SJ54 (for valve designator) 1GDITB3D (for breaker designator)

(2)

When using the exact wording from nameplates, engravings, alarm windows, etc. in procedures, it shall be fully capitalized.

Examples:

CVCS FLOW CONTROL AUTO GENERATOR PROTECTION TURB TRIP e.

Logic Words and Action Verbs (1)

Fully capitalize all logic Words when used in text to describe to the user a precise set of conditions or sequence of actions.

Examples:

IF AND THEN (2)

Fully capitalize the main action verb in a statement.

When two action verbs are used together capitalize both.

When the action verbs are split in the statement capitalize only the first verb.

Examples:

CLOSE 2SJ135 VERIFY OPEN ISJ1 and ISJ2 3.5 humerals, Units, and Tolerances 3.5.1 The use of numerical values should be consistent I

with the following rules:

I a.

Numbers shall be arabic numerals and should not normally be spelled out except when the number begins a sentence.

l MASTER Salem Unit 1/2 8

Rev. 3 l

AD-2 b.

For numbers less than unity, the decimal point should be preceded by a zero (e. g.

0.3).

c.

The number of significant digits should be equal to the number of significant digits available from the display and the reading precision of the operator.

d.

When it is necessary to use exponents, the "E"

format should be utilized.

Examples:

10,000 = 1.0E04 436,500 = 4.365E05 0.00162 = 1.62E-03 e.

When numerals are used to refer to instrumentation readings, the operator should be able to relate those numerals to those used on the instrumentation without conversion, translation, or manipulation.

3.5.2 The use of units of measure should be consistent with the following rules:

a.

Units of measure used should be familiar to the person using the document.

b.

When instrument parameters are referenced, the units of measure should be included.

c.

When units are used to refer to instrumentation readings, the operator should be able to relate the units to those used on the instrumentation without conversion, translation, or manipulation.

3.5.3 The use of tolerances should be consistent with the following rules:

a.

Tolerance (high and low) should be specified whenever applicable to bound numerical values and to avoid approximations.

b.

The units in which tolerances are expressed should be the same as the units on the display or control to which they refer.

MASTER Salem Unit 1/2 9

Rev. 3

AD-2 c.

Acceptance values should be specified in such a way that addition and subtraction by the user is avoided.

For example, do.not use 2235215 psig, instead use 2220 to 2250 p s1' g.

3.6 Underlining 3.6.1 Emphasis of necessary key words and phrases in a procedure shall be accomplished by underlining the entire word or phrase.

3.6.2 This practice should be used with discretion.

Too much underlining may result in reduced effectiveness; too little underlining may result in key words or phrases not standing out when necessary.

3.7 Sentence Structure and Vocabulary 3.7.1 The structuring of sentences should be consistent with the following rules:

a.

Sentencea, clauses, and phrases should be shore and written using simple word order (sub]ect, verb, object).

b.

There should be only one main thought per sentence.

c.

Action steps should be in the active voice and imperative mode.

For example, state CLOSE valve ISJ1 rather than stating valve ISJ1 should be closed.

d.

Action steps should be in the positive form rather than the negative form.

For example, state CLO62 the valve rather than stating do not leave the valve OPEN.

3.7.2 The simplest, most familiar, and most specific words that accurately convey the intended meaning should be used.

The user should understand all words used in the procedures.

To achieve this overall objective, the following guidance should be followed:

Use short words and words that are common in a.

ordinary conversation.

Salem Unit 1/2 10 Rev. 3

AD-2 b.

.Use nomenclature that the user is trained to use and which are standard in the nuclear power industry.

c.

Use concrete and specific words that describe precisely what the user is to do or observe.

d.

Use words and meanings consistently throughout the procedures.

Avoic using adverbs that are difficult to e.

define in a precise manner (e.g. frequently, slowly).

f.

Use specific action verbs and logic words as prescribed in 3.8 below.

3.8 Word Usage 3.6.1 Use of Shall, Will, Should, and May a.

Shall denotes mandatory compliance by personnel under the direct control of the document.

b.

Will denotes expected compliance by personnel or equipment not under the direct control of the document.

2 c.

Should denotes the best or expected but not mandatory choice in an option situation.

d.

May denotes permission but not requirement.

3.8.2 Use of Action Verbs a.

Adjust: To regulate or to bring to a more satisfactory state: for example,

'" ADJUST Seal Pressure Control Valve 1CV71...".

b.

Align:

To bring into line or alignment; or come into precise adjustment or correct relative position; Example: " ALIGN the valves in accordance with Check Off Sheet 4.1.".

Salem Unit 1/2 11 Rev. 3

i AD-2 8

c.

Allow:

To permit a stated condition to be achieved prior to proceeding, Example: " ALLOW discharge pressure to stabilize".

d.

Attach:

To make fast as by tying, gluing, or fastening; Example: ATTACH a tygon tube to the Cold Leg drain."

e.

Check:

To perform a comparison with a procedural requirement; Example: " CHICK if SI can be terminated".

f.

Clone:

To change the physical position of a mechanical device so that it prevents physical access or flow or permits passage of electrical current; Example: "CLOGE valve 1FP142".

g.

Complete:

To accomplish specified procecural requirements; Example: " COMPLETE steps 7 through 9 of Section 5.0".

h.

Decrease:

To cause to grow progressively less; Example: " DECREASE steam generator levels to 33%".

i.

Discharge:

To give outlet or vent to a fluid or other contents; Example: " DISCHARGE the tank to...".

l J.

Drain:

To draw off (liquid) gradually or l

completely; l

Example: " DRAIN the water from the reactor Cavity...".

k.

Establish:

To make arrangements for a l

stated condition; Example: "SSTABLISH communication with the control roca".

l 1.

Fill:

To raise the level of; Example: FILL the Accumulator in accordance with...".

MASIG Salem Unit 1/2 12 Rev. 3 I

I I

l

AD-2 m.

Flush:

To cause to flow to cleanse or wash out; Example: " FLUSH the discharge piping by opening 1WL156, lwL56, and 1DRS for two minutes".

n.

Increase:

To cause to grow progressively greater; Example: " INCREASE power at 3% per hour or less".

o.

Inspect:

To observe or evaluate a feature or characteristic for comparison with specitled limits; method of-inspection should be included; Example: " visually INSPECT for leaks".

p.

Monitor:

To watch, observe, or check especially for a special purpose or to keep track of, regulate, or control the operation; Example: " MONITOR Source Range Neutron level while filling the RCS".

q.

Notify:

To make known or to give notice of or report an occurrence; Example: " NOTIFY the Chemistry Department to sample the batch for boric acid concentration".

r.

Open:

To change the physical position of a mechanical device, such as valve or door to the unobstructed position that permits access or flow or prevents passage of electrical current; Example: "OPEN 11SJ49 and 12SJ49 RHR Discharge to Cold Legs".

s.

Purge:

To make free of an unwanted substance as an impurity or a foreign material; Example: " PURGE the PRT by performing the following steps".

t.

Record:

To document the specified condition or characteristic; Example: " RECORD discharge pressure".

gHER Salem Unit 1/2 13 Rev. 3 l

-.,~

-,, +

AD-2 u.

Release:

To set free from re'straint or confinement; Example: " RELEASE the tank to the Circulating Water System as described in step 5.2".

v.

Request:

To ask for; Example: " REQUEST the Control Room Operator to open 2WL51".

w.

Sample:

To test or to judge-the quality; Example: " SAMPLE the PRT for Oxygen concentration".

x.

Select:

To take or choose by preference from a number or group; Example: " SELECT the tank to be recirculated on the Low Level Cutoff Selector Switch".

y.

Set:

To physically adjust to a specified value an adjustable feature; Example: " SET channel R22 HI alarm to 25 mr/hr".

z.

Start:

To originate motion of an electric or mechanical device directly or by remote control; Example: " START the Positive Displacement Charging Pump".

aa.

Stop:

To terminate operation; Example: "STOP the Positive Displacement Charging Pump".

bb.

Survey:

To examine as to condition, situation, or value; Example: " SURVEY the resin discharge line to determine background radiation levels before initiating resin removal".

cc.

Throttle: To operate a valve in an intermediate position to obtain a certain flow rate; j

Example: " THROTTLE 2CC71 as required to maintain temperature".

l dd.

Transfar:

To cause to pass from one to another; Example: " TRANSFER the boric acid solution from the Concentrate Holding Tank to the Boric Acid Storage Tanks".

Salem Unit 1/2 14 Rev. 3

AD-2 ee.

Trip:

To manually activate a semi-automatic feature; Example: " TRIP the reactor".

ff.

Vent:

To permit a gas or liquid confined under pressure to escape at a vent; Example: " VENT the pump".

gg.

Verify:

To observe an expected condition or characteristic; Example: " VERIFY discharge press is stable at 200 PSIG".

Usage:

VERIFY is not used in the EOPs or AOPs.

The YES/NO cecision step and IF...,

THEN contingency is substituted to streamline the decision making process.

3.8.3 Use of Logic Words Logic words ae used to describe a set of a.

conditions, or to sequence action 3-ns contingent upon conditions.

b.

Each letter of a Logic word is capitalized.

c.

Logic terms are limited to the following:

(1) AND (2) OR (3)

IF...,

THEN (4)

WHEN..., THEN d.

The use of AND and OR within the same step should be avoided.

If the situatier requires such use, the step should be organized so as to minimize logic ambiguity.

e.

Logic words should not be used to Join action steps. When "and" and "or" are used 7

in action steps as conjunctions they are not capitalized.

f.

Rules of usaga:

(1)

Use of AND (a)

AND is used to join two or mcre conditions in a list.

(b)

AND is placed on a separate line between conditions and is centered on the conditions.

Salem Unit 1/2 15 Rev. 3

--n

AD-2 (c)

EXCEPTION:

AND may be placed within a condition when. joining components that are a part of the condition.

(2)

Use of OR (a)

OR is used to join alternate conditions in a list.

(b)

OR is placed on a separate line between conditions and is centered on the conditions.

(3)

Ose of IF...,

THEN (a) 1F..., THEN is used to identify contingency actions to be taken when an action can not be accomplished, or an expected response is not obtained.

(b)

IF..., THEN will not be used as the initial level of a decision making process.

Verification or diagnostic decisions are handled using the YES/NO tormat.

IF..., THEN may be used during subsequent levels of the decision process if the process must be continued in the right hand column of a dual column format procedure.

(c)

The IF...,

NOT step is placed in the right hand column and aligned with the action step.

In the single column format the IF...,NOT is used as a substep to the action step it supports.

l (d)

The IF is followed by a clarification of when additional action is required.

In this context the phase IF NOT, THEN is l

inadequate and will not be used.

l (e)

When more than one contingency is l

l necessary, the additional IF...,

THEN l

steps are placed immediately after the first contingency ano are numbered on the

[-

same order as the first contingency.

I MASTER l

Salem Unit 1/2 16 Rev. 3 l

AD-2 (4)

Use of WHEN..., THEN (a)

WHEN..., THEN is used to identify a condition upon which an action is contingent, where the condition may occur at any time during the procedure.

(b)

WHEN..., THEN by its nature provides a decision process for performance of an action.

It should be confined to this application and not used in place of a YES/NO r,ype decision.

g.

E2amples of Logic Term use and format.

(1) Example 1:

3.12 has SI flow been terminated as indicated by:

3.12.1 11 AND 12 Pump stopped.

AND 3.12.2 BIT Isolated.

YES NO ---------

a.

GO TO step 3.13.

t 3.12.3 GO TO step 3.23.6.

(2)

Example 2:

3.20 Are Pzr PORVs closed?

YES NO ---------

a.

IF Pzr Press less than l

2315 PSIG, THEN:

l (1)

MANUALLY CLOSE PORVs.

(2)

IF PORVs can not be closed, THEN cIdse Block Valve.

l (3)

IF Block valve can not

(

be closed, THEN GO TO j

ECP-LOCA-1, " Loss of l

t Reactor Coolant."

l-Salem Unit 1/2 17 m

Rev. 3

AD-2 (3)

Example 3:

3.29 Are all SI Termination criteria met?

3.29.1 R'CS subcooling greater than 10*F.

AND 3.29.2 Pzr level greater than 5%.

(10% ADVERSE)

AND 3.29.3 RCS Press stable or increasing.

AND 3.29.4 Heat Sink satisfied:

a.

Total AFW flow greater than 24E04 lb/hr.

OR b.

Greater than 10% NR in at least one SG.

YES NO ---------

a.

GO TO step 3.30.

t 3.29.5 GO TO EOP-TRIP-3.

"SI Termination."

(4)

Example 4:

3.36.4 STOP 11 and 12 RHR Pumps.

3.36.5 WHEN both of the following occur, THEN start 11 and 12 RHR Pumps.

a.

RCS cubcooling less than 10*F.

AND b.

RCS Press less than 225 PSIG (400 PSIG ADVERSE)

Salem Unit 1/2 18 Rev. 3

AD-2 (5)

Example 5:

3.16.2 RESET Blackout Loading IF and SEC fails to reset, for each Diesel THEN de-energize affected Generator.

SEC at 115 VAC Vital Instrument Cabinet in Relay Room:

(1) lA VIB24.

(2)

IB VIB27.

(3)

IC VIB9.

3.9 Abbreviations, Acronyms, and Symbols 3.9.1 An approved listing of abbreviations, acronyms, and symbols is provided in Administrative Directive 6.

3.9.2 The abbreviations, acronyms, and symbois used in Operations Department documents should be those familiar to the user so that there is normally no need for the user to refer to Administrative Directive-6.

3.9.3 The use of abbreviations, acronyms, and symbols should be consistent with the following rules:

a.

Capitalization of abbreviations should be uniform.

b.

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

,in confusion.

c.

Acronyms may be used if they are defined or commonly used.

l l

d.

Symbols common to the user may be utilized to represent operations, quantities, elements, relations, l

and qualities.

e.

Subscripts shall not be used; for example, the chemical relationship of water should be written H20.

MASTER Salem Unit 1/2 19 Rev. 3

AD-2 f.

Abbreviations, acronyms, and symbols should be used for the benefit of the user not the writer.

That is, for saving reading time, ensuring clarity when space is. limited, and in communicating mathematical ideas.

g.

When abbreviations, acronyms, or symbols are used to identify labels or equipment parts, the operator should be able to immediately recognize the identity and location of the label or equipment part.

4.0 PRESENTATION OF MATERIAL 4.1 Style of Expression 4.1.1 All Operations Department documents should be written in a style that presents the information in a simple, familiar, specific, and unambiguous manner.

As such, the author of any given document is responsible for ensuring readability, (ie, legibility and intelligibility).

With this in mind, author's shall strive to generate documents that can be:

a.

Easily read, b.

Read rapidly without interruption, c.

Precisely understood, d.

Uncerstood without the aid of additional

material, e.

With regard to the information presented, be accepted by the user, f.

Easily learned, g.

Retained, and h.

Used easily for instruction.

MASTER Salem Unit 1/2 20 Rev. 3

AD-2 4.1.2 In writing Operations Department documents (i.e.

especially technical procedures), too much detail should be avoided in the interest of the user being able to effectively execute the instructions in a timely manner.

To assist in determining the level of detail to be provided in any given procedure, the following general rules will apply:

The level of detail required in an a.

l administrative type procedure is the detail that the user will need to perform the j

administrative function described by the document without further guidance.

(

i b.

The level of detail required in a technical-type procedure is the detail that a newly trained operator would desire.

Standard practices for observing for c.

abnormal results need not be prest within procedural steps.

For examp.e, observation of noise, vibration, erratic flow, or discharge pressure need not be specified by steps that start pumps.

d.

Information on the location of equipment, controls, or displays that are infrequently 1

(

used, are in out of the way places, or are otherwise difficult to find should, as a J

(

minimum, be provided.

4.1.3 Procedures of a given category shall be consistent in organization, format, styl-nd content.

4.1.4. User aides (e.g. figures, tables, graphs, flow charts, etc.) may be utilized.

However, when l

utilizing such aids they must be:

l Self-explanatory and stand alone, a.

l b.

Legible, and Readable under the expected conditions of c.

use and within the reading precision of the user.

MASTER Salem Unit 1/2 21 Rev. 3

AD-2 4.2 Writing Instructional Steps 4.2.1 For administrative type procedures, the single column format should be used.

For technical procedures, either the single column or a dual column format may be used.

Format requirements for each procedure category are specified in section 5.0.

4.2.2 For technical procedures especially, the instructional steps shall be as concise and precise as possible.

General guidelines to be followed are:

a.

Instruction steps should deal with only one idea.

b.

Short, simple sentences should be used in preference to long, compound, or complex sentences.

8 Complex evolutions should be prescribed in a c.

series of steps, with each step made as simple as practicable.

d.

Ob]ects of operator actions should be specifically stated.

This includes identification of exactly what is to be done and to what.

l e.

Limits should be expressed quantitatively whenever possible.

f.

Mandatory sequence of steps is assumed l

unless otherwise stated.

g.

Identification of components and parts should be complete.

1 I

h.

Expected results of routine tasks need not be stated.

l i.

When actions are required based upon receipt of an annunciated alarm, list the setpoint of the alarn for ease of verification, if l

appropriate.

IdASTER 1

l Salem Unit' 1/2 22 Rev. 3 i

AD-2 j.

When requiring resetting or restoration of an alarm or trip, list the expected results immediately following the resetting or restoration if it would be beneficial to the

user, k.

When considered beneficial to the user for proper understanding and performance, describe the system response time associated with performance of the instruction.

1.

When system response dictates a time frame within which the instruction must be accomplished, prescribe such time frame.

If possible, however, avoid using time to initiate operator actions.

Operator actions should be related to plant parameters.

m.

When anticipated system response may adversely affect instrument indications, describe the conditions that will likely introduce instrument error and means of determining if instrument error has occurred by using a NOTE.

n.

When Adverse Containment conditions (4 PSIG and greater) will affect the accuracy of an instrument, then provide a dual setpoint with the rollowing format:

(1)

Is SG NR level greater than 5%

(15% ALVERSE) o.

When additional confirmation of system response is considered necessary, prescribe l

the backup readings to be made.

l 4.2.3 Sequencing Steps l

a.

As the overriding consideration, tasks and l

actions in instructional steps should be j

sequenced according to technical necessity.

b.

The physical layout and organization of the control room (or other plant areas) shculd l

be considered in sequencing steps.

(

ESTER Salem Unit 1/2 23 Rev. 3

AD-2 4.2.4 Verification Steps a.

Verification steps, or sign off spaces, are to be used to determine whether the objective of a task or sequence of actions has been correctly achieved.

b.

Procedural categories requiring sign off spaces are specified in section 5.0 below.

4. 2. 5-Nonsequential Steps A,given step may require that an action be a.

carried out at various intervals throughout a procecure.

These nonsequential s,teps should be written into procedures using an approach that clearly identifies to the operator where and when these steps apply, the conditions under which they apply, and/or the time sequence required for their performance.

4.2.6 Equally Acceptable Steps Equally acceptable steps are those for which I

a.

any one of several alternative steps or sequence of steps may be equally correct.

For these steps, the operator should always be directed to carry out one of the alternative steps (or sequences), but should also be given the other alternatives when it l

l is possible that the designated steps (or l

sequence) cannot be done (e.g., a designated l

piece of equipment is unavailable).

4.2.7 Recurrent Steps a.

Recurrent steps are those that require the operator to repeatedly perform a given action, typically, monitoring or centrolling some plant parameter.

( e. g.', " CHECK AFWST level every 30 minutes").

For these steps, l

the operator should be told when or how l

often the steps are to be performed, be reminded to perform the steps, and be told i

the conditions for which the steps should no l

longer be carried out.

MASTER I

l Salem Unit 1/2 24 Rev. 3

AD-2 4.2.8 Time-Dependent Steps a.

Time dependent steps are those that are required of the operator at some specified time interval, or some time after an action has taken place.

A means should be provided to assist the operator in performing the step (s) within the required time frame.

4.2.9 Concurrent Steps a.

Concurrent steps are those which have to be performed at the same time.

The procedure should explicitly indicate which steps are concurrent so that operators can easily refer to both (or all) sets of steps.

The maximum number of concurrent steps should not be beyond the capability of the control

~

room staff to perform them.

4.2.10 Diagnostic Steps Diagnostic steps are those which' lead the a.

operator to the appropriate section of the procecure.

These steps should assist the operator in diagnosis, and provide clear and unambiguous guidance leading to the diagnostic decision, as well as clear and unambiguous referencing to the appropriate section or the procedure.

These steps may include the use of status trees, flow diagrams, graphs or other operator aids.

4.2.11 Shift manning a.

Procedures should be structured so that they l

can be executed by the minimum controi room l

crew as specified in the Technical Specifications.

4.2.12 Step Grouping l

Steps should be groupad on a page such that a.

no step carries over to the next page.

If a-l step is too long to fit on one page, then consider making it several smaller steps.

l b.

Grouping is of most importance in procedures where many actions are anticipated in a short time.

Grouping and step length restrictions may be relaxed when the pace of action approximates routine plant evolutions.

Salem Unit 1/2 25 Rev. 3

AD-2 4.2.13 Decision steps a.

Decision steps take the form of a question with a yes or no answer.

b.

The question should be worded in the same way it would be asked orally of an operator.

c.

Decision steps are used only in procedures using the dual column format.

d.

The decision step is structured so that the course of action resulting from a YES evaluation is in the left hand column, and actions for a NO evaluation is in the right hand column.

e.

Decision steps ae generally used in place of verify and check actions to simplify the decision process.

4.3 Use of Cautions, Precautions, and Notes 4.3.1 Cautions a.

Cautions contain information that the operator must be aware of to avoid personal injury, loss of life, a long term health g

hazard, or damage to equipment.

b.

Cautions will normally take the form of an action to be taken when a specific condition occurs.

(1)

In this context cautions are a special l

type of instructional step.

Use of Cautions should be limited to maintain their emphasis.

- (. )

Cautions may also contain information 2

used to prevent actions by cperators that could lead to unsafe conditions.

l c.

Cautions will extend across both columns of l

a dual column procedure to set the caution apart from normal steps.

l d.

Cautions will normally be placea immediately before the step to which they refer.

Cautions may be placed immediately after the associated step if this will improve understanding of the content of the caution.

Salem Unit 1/2 26 Rev. 3

AD-2 e.

Chutions should be written so that they can be read completely without interruption by intervening steps or page turning.

f.

Cautions that carry over from an earlier procedure should be placed at the beginning of the subsequent procedure and/or placed on the Continuous Action Summary page, if used.

4.3.2 Precakio s

,s_

a.

Cautionary information that should be reviewed before commencing a procedure is grouped together into a Precautions section.

b.

Section 5.0 of AD-2 identifies those procedure types that utilize precautions.

4.3.3 Notes Supplementary information required to a.

support a procedural step that is not cautionary in nature should be presented as a Note.

b.

Notes precede the procedural step to which they apply.

In some cases a Note may be more appropriately placed after the applicable procedural step.

In multiple l

column formats, the Notes may be placed in I

the right hand column.

The author shall l

determine the most correct location for Note placement within a procedure.

Because they are supplemental, Notes shall c.

l not airect the user to initiate or perform any actions.

  • 4. 4 Calculations and Formulas 4.4.1 The use of calculations and formulas in operating procedures and especially Emergency Operating Procedures should be minimized because oft a.

Time requirements for performing the calculations, and b.

The increased possibility of operator error.

4.4.2 If a value has to be determined in order to perform a procedural step, a graph, chart, or similar operator aid should be provided when possible.

M Rev. 3 Salem Unit 1/2 27 l

AD-2 4.4.3 When calculations or formulas are required they should be as simple as possible and adequate space should be provideo for entry of any required data and for recording the results.

4.5 P'rocedure Referencing 4.5.1 The practice of referencing (i.e. between steps in the same procedure or from a step in one procedure to steps in another procedure) is allowed in the writing of Operations Department documents.

4.5.2 The fol' lowing general rules shall apply to the practice of referencing:

a.

The practice of referencing should be minimized.

When possible, the information or steps that could be referred to should be incorporated into the procedure where the information or steps are required.

b.

When necessary to refer to another procedural step or even another procedure, the reference statement should be clear and concise.

That is:

(1)

Exactly where to go (i.e. what procedure and/or what step), and (2)

Exactly what to do (complete what procedural steps, what to do with the

" referring procedure" and what to do with the " referred procedure").

c.

The words GO TO should be used to direct the user to leave the procedure in use and use the procedure referred to.

d.

The words "in accordance with (or IAW) "

should be used to direct the operator to utilize a separate procedure to accomplish a task while remaining in the parent procedure.

Both procedures are accomplished simultaneously unless the parent procedure requires otherwise.

~

MASTER

)

\\

Salem Unit 1/2 28 Rev. 3 J

AD-2 4.6 Location Informat' ion 4.6.1 Procedures should provide operators information on the location of equipment, controls, or display that are infrequently used, are in out-of-the-way places or otherwise difficult to find.

5.0 FORMAT REQUIREMENTS 5.1 Directives, Administrative and Operations 5.1.1 Designation a.

The designation for Administrative Directives shall be AD.

The designation for Operations Directives shall be OD.

b.

A sequential number will follow the AD or OD designator to specifically identify each individual directive.

c.

As such, each individual Administrative &

Operations Directive will have a unique identifier; for example, AD-1, AD-6, OD-1, CD-8, etc.

5.1.2 Format Arrangement a.

The single column (i.e. standard sentence approach) format should be utilized in preparing ads and CDs.

b.

Specific. guidance regarding page layout, text numbering, etc. is provided in Section 2.0 of this directive and in AD-4, Typist Guide.

5.1.3 Format Organization No specific format organization requirements a.

have been established for Administrative or Operations Directives so the administrative i

guidelines and information to be included l

can be presented in a manner that fits the need.

MASTER r

Salem Unit 1/2 29 Rev. 3 l

AD-2 5.2 Integrated Operating Procedures 5.2.1 Designation a.

The designation for Integrated Operating Procedures shall be IOP.

b.

A sequential number will follow the IOP designator to specifically identify each individual IOP.

c.

As such, each individual IOP will have a unique identifier; for example, IOP-1, IOP-4, etc.

5.2.2 Format Arrangement a.

The dhal column format should be used in preparing IOPs.

(1)

The dual column approach shall begin with the Prerequisite section of the-procedure (refer to subsection 5.2.3 below).

(a)

The left hand column shall be used for operator action statements.

(b)

The right hand column shall be used to present contingency actions for use when the response to the action statements are not obtained and to provide supplementary information and l

notes.

l (2)

The single column approach should be used only for the first three sections of the procedure (refer to subsection 5.2.3 below).

l b.

Specific guidance regarding page laycut, l

text numbering, etc. is provided in Section 2.0 of this directive and in AD-4, Typist Guide.

MASTER Salem Unit 1/2 30 Rev. 3

AD-2 5.2.3 Format Organization a.

The format organization and content requirements for each IOP are as follows:

(1)

Directly underneath the title of the IOP on the first page, there shall be three lines as follows:

START TIME TERMINATION TIME COMPLETION TIME Each line shall be accompanied by a space for the date and a space for a signature.

(2)

Section 1.0 PURPOSE (a)

This section shall provide a brief and concise statement that describes what is intended to be accomplishea.

(3)

Section 2.0 PRECAUTIONS (a)

This section shall detail pertinent cautionary information that is generally applicable to the entire procedure.

(4)

Section 3.0 ATTACHMENTS LISTS (a)

This section shall identify, by listing, each attachment (e.g.

graph, figure, table, check off r

l sheets, etc.) to the procedure.

(b)

Check Off Sheets, when used, shall contain a sign off space for the operator to initial after i

completion of each major step.

l In addition, each check off sheet shall contain a sign off space l

for the appropriate reviewer's l

l signature.

i MASTER t

Salem Unit 1/2 31 Rev. 3

a AD-2 (5)

Section 4.0 PREREQUISITES (a)

This section shall detail the requirements and conditions that must be met prior to the performance of the procedural steps (i.e. section 5.0).

(b)

Each prerequisite step shall have a sign off space for the operator to initial after completing the step.

(6)

Section 5.0 PROCEDURE (a)

This section shall contain the instructional steps and applicable contingency actions that are necessary to meet the purpose of the procedure, f

(b)

Each pertinent instructional step shall have a sign off space for the operator to initial after completing the step.

(c)

This section may include supplementary information, cautionary information, and notes.

(7)

Section 6.0 FINAL CONDITIONS (a)

This section shall provide a l

brief summary statement or l

statements that describes the l

plant condition (s) that the completion of the procedure resulted'in.

~

(b)

The statements pr,ovided in this section should be complimentary to Section 1.0, Purpose.

l MASTER Salem Unit 1/2 32 Rev. 3 L

AD-2 5.3 Emergency Operating Procedures 5.3.1 Designation a.

The designation for Emergency, Operating Procedures shall be EOP.

b.

A second level designator for each EOP shall immediately follow the EOP acronym.

"-is second level designator shall identif, an EOP as:

(1)

Applicable to a type of accident (e. g.

TRIP, LOCA, SGTR, etc.), or (2)

Providing function restoration guidance for a specific situation or conaition (e.g. FRSM, FRHS, etc. ).

c.

A sequential number will follow the second level designator to specifically identify each individual EOP as classified.

/

d.

As such, each individual EOP will have a unique identifier.

As examples:

(1)

Two EOPs dealing with a LOCA would be shown as EOP-LOCA-1 and EOP-LOCA-2.

(2)

Two EOPs that provide function-restoration guidelines associated with Inadequate Core Cooling would be shown as EOP-FRICC-1 and EOP-FRICC-2.

e.

Procedure Titles (1)

Procedure titles will be selected to minimize confusion among procedures I

dealing with similar applications.

(2)

Titles in general, and EOP titl-in particular, should be in the fu. af a brief statement of the scope of the

,i~

procedure.

MASTER Shlem Unit 1/2 33 Rev. 3

AD-2 5.3.2 Format Arrangement a.

The dual column format shall be used in preparing EOPs.

(1)

The cual column approach shall begin with the Immediate Actions section of the procedure (refer to subsection 5.3.3 below).

a.

The left hand column shall be used for operator action statements, b.

The right hand column shall be used to present contingency actions for use when the response to the action statements are not obtained and to provide supplementary information and notes.

Action statement resulting from decision steps are also placed in the right hand column.

(2)

The single column approach shall be used only for the first section of the procedure (refer to subsection 5.3.3 below).

a.

Specific guidance regarding page layout, text numbering, etc. is proviced in Section 2.0 of this directive and in AD-4, Typist Guide.

5.3.3 Format Organization a.

The format organization and content

. requirements for each EOP are as follows:

(1)

Section 1.0 ENTRY CONDITIONS (a)

This section shall contain a list of the conditions under which the procedure is used.

MASER Salem Unit 1/2 34 Rev. 3

AD-2 (b)

The entry conditions will include only those alarms, indicatiens, operating conditions, procedure referrals or other unique symptoms that the operator is to use in deciding to use the procedure.

It is neither required nor desired, for example, to list all alarms associated with a given condition (e.g. reactor trip).

( 2,)

Section 2.0 IMMEDIATE ACTIONS (a)

This section shall contain those actions (both automatic and manual, both required and contingency) that the operator should either be verifying or taxing immediately when there are indications of an emergency.

(b)

This section should include only those actions that stop further degradation of existing conditions, to mitigate their consequences, and to allow operators to evaluate the situation.

(c)

This section may include supplementary information, cautionary information, and notes.

(d)

This section shall contain no sign off spaces.

i l

MASTER Salem Unit 1/2 35 Rev. 3 l

L

AD-2 (3)

Section 3.0 SUBSEQUENT ACTIONS (a)

This section shall contain those actions (both required and contingency) that the operators should take to return the plant to a normal, stable, or a steady-state condition or to provide tor a safe, extended shutdown period under emergency conditions.

(b)

This section may include supplementary information, cautionary information, or notes.

(c)

This section shall contain no sign off spaces.

(4)

Section 4.0 ATTACHMENTS LIST (a)

This section shall identify,- by listing, each attachment (e. g.

graph, figure, table, etc.) to the procedure.

(b)

The EOP should contain no check off sheets.

(5)

Continuous Action Summary pages (CAS)

(a)

Continuous Action Summary pages contain actions that may become necessary at any time during the performance of an EOP.

(b)

CAS pages are placed on the reverse side of the respective EOP pages.

(c)

CAS ptges are not used in Functional Restoration EOPs or opposite pages containing only Immediate Action steps of any EOP.

MASTER

~

Salem Unit 1/2 36 Rev. 3

AD-2 (d)

A two column format is used for the CAS pages.

The left column contains a brief summary of the action required.

The right column is a synopsis of the condition requiring the action.

(e)

A step reference is placed to the extreme right of the condition.

If the action is not referenced in the procedure,.then two dashes

(--)

are used in place of the step reference.

This would apply to Continuous Actions that carry over from previous procedures.

(f)

Carry over actions should be limited to those itmes that are well known and widely used.

"AS itmes with limited applic..

shoulc be supported in the text of the procedure.

(g)

CAS pages are not included in the numbering scheme of the procedure.

5.4 Abnormal Operating Procedures 5.4.1 Designation a.

The designation for Abnormal Operating Procedures shall be AOP.

b.

A sequential number will follow the AC?

designator to specifically identify each individual AOP.

c.

As such, each individual AOP will have a unique identifier; for example, AOP-1, AOP-4, etc.

l l

MSTER i

Salem Unit 1/2 37 Rev. 3 l

AD-2

'5.4.2 Format Arrangement a.

The dual column format should be used in preparing AOPs.

(1)

The dual column approach shall begin with the Immediate Actions section of the procedure (refer to subsection 5.4.3 below).

(a)

The left hand column shall be used for operator action statements.

(b)

The right hand column shall be used to present contingency actions for use when the response to the action statements are not obtained and to provide supplementary information and notes.

Action statements resulting from decision steps are also placed in the right hand Column.

(2)

The single column approach shall be used only for the first section of the procedure (refer to subsection 5.4.3 below).

(a)

Specific guidance regarding page layout, text numbering, etc. is provided in section 2.0 of this directive and in AD-4, Typist Guide.

5.4.3 Format Organization i

The format organization and content a.

l requirements for each AOP are as follows:

l I

i (1)

Section 1.0 ENTRY CONDITIONS (a)

This section shall contain a list of the conditions under which the procedure is used.

l MASTER Salem Unit 1/2 38 Rev. 3

AD-2 (b)

The entry conditions will include only those alarms, indications, operating conditions, procedure referrals, or other unique symptoms that the operator is to use in deciding to use the procedure.

It is neither required or desired, for example, to list all alarms associ:

with a given condition.

(2)

Section 2.0 IMMEDIATE ACTIONS (a)

This section shall contain those actions (both automatic and manual, both required and contingency) that the operator should either be verifying or taking immediately when there are indications of an abnormal condition.

(b)

This section shou 15' Include only those actions that stop further degradation of existing conditions, to mitigate their consequences, and to allow operators to evaluate the situation.

(c)

This section may include supplementary information, cautionary information, and notes.

(d)

This section shall contain no sign off spaces.

(3)

Section 3.0 SUBSEQUENT ACTIONS (a)

This section shall contain those actions (both required and contingency) that the operators should take to return the plant to a normal, stable, or a steady state condition or to provide for a safe, extended shutdown period under abnormal conditions.

ESTER Salem Unit 1/2 39 Rev. 3

AD-2 (b)

This section may include supplementary information, cautionary information, or noter.

(c)

This section shall contain no sign off spaces.

(4)

Section 4.0 ATTACEMENTS LIST (a)

This section shall identify, by listing, each attachment (e. g.

graph, figure, table, etc.) to the procedure.

(b)

The AOP shall contain no check off sheets.

(S)

Continuous Action Summary pages (CAS)

(a)

Continuous Action Summary pages contain actions that may become necessary at any time during the performance of an AOP.

(b)

CAS pages may be placed on the back side of the respective AOP.

(c)

CAS pages are not used opposite pages containing only Immediate Action steps of any AOP.

(d)

A two column format is used for the CAS pages. The left column contains a brief summary of the action required.

The right column is a synopsis of the condition requiring the action.

(e)

A step reference is placed to the extreme right of the condition.

If the action is not referenced in the procedure, then two dashes

(--)

are used in place of the step reference.

This would apply to Continuous Actions that carry over from earlier procedures in the sequence.

MASTER Salem Unit 1/2 40 Rev. 3 J

AD-2 (f)

Carry over actions should be limited to those items that are well known and widely used.

CAS items with limited application should be supported in the text of the procedure.

(g)

CAS pages are not included in the numbering scheme of the procedure.

5.5 Operating Procedures 5.5.1 Designa' tion The designation for Operating Procedures a.

shall be OP.

b.

A second level designator for each Operating Procedure shall immediately follow the OP acronym.

This second level designator shall identify the system that the Opegating Procedure is applicable to.

For examples; RHR, RMS, TAC, 4KV, etc.

A sequential number will follow the second c.

level designator to specifically identify each individual Operating Procedure as classified.

d.

As such, each individual Operating Procedure will have a unique identifier.

As examples:

(1)

Two Operating Procedures dealing with RMR system operations would be shown as OP-khR-1 and OP-RHR-2.

(2)

Three Operating Procedures dealing with FP system operations would be shown as OP-FP-1, OP-FF-2, and OP-FP-3.

5.5.2 Format Arrangement a.

The single column (i.e. standard sentence approach) format should normally be used in preparing Operating Procedures.

The dual column format, however, may be used if it more adequately presents the procedure.

MASTER Salem Unit 1/2 41 Rev. 3

AD-2 h.

When the dual column format is used for Operating Procedures:

(1)

The dual column approach shall begin with the Procedure section of the Operating Procedure (refer to subsection 5.5.3 below).

(a)

The left hand column shall be used for operator action statements.

(b)

The right hand column shall be used to present contingency actiona for use when the response to the action statements are not*

obtained and to provide supplementary information and notes.

(2)

The single column approach shall then be usec ror the first four sections of the procedure (refer to subsection 5.5.3 below).

(c)

Specific guidance regarding page layout, text numbering, etc. is provided in Section 2.0 of this directive and in AD-4, Typist Guide.

5.5.3 Format Organization a.

The format organization and content requirements for each Operating Procedure are as follows:

(1)

Section 1.0 PURPOSE (a)

This section shall provide a brief and concise statement that describes what is' intended to be accomplished.

l Salem Unit 1/2 42 Rev. 3

AD-2 (b)

The purpose statement will be numbered so that a procedure which addresses more than one operating method of the system or component can be readily identified; for example:

1.1 This procedure prc the instruction nece.....

fort 1.1.1 Normal Operation of the CFCU's.

1.1.2 Operation of the CFCU's without Service Water available.

The intent is to have the purpose statement sub-section 1.1 serve as an index, listing those operating methods addressed by the procedure.

(c)

In those cases where the procedure is performed to meet some requirement, such as Administrative requirements, this information shall be included in the purpose statement after sub-section 1.1 and will be numbered as the next sub-section.

For example:

1.2 This procedure is performed IAW the requirments of OD-71.

(2)

Section 2.0 INITIAL CONDITIONS (a)

The section shall detail the requirements and conditic:

.at must be met prior to the performance of the procedural steps (i.e. section 5.0).

MASTER Salem Unit 1/2 43 Rev. 3 l

l

AD-2 (3)

Section 3.0 PRECAUTIONS (a)

This section shall detail pertinent cautionary information that is generally applicable to the entire procedure.

(4)

Section 4.0 ATTACHMENTS LIST (a)

This section shall identify, by listing, each attachment (e. g.

graph, figure, table, check off sheets, etc.) to the procedure.

(b)

Check off sheets, when used, shall contain a sign off space for the operator to initial after completion of each major step.

In addition, the last page of each Check off sheet shall co'ntain a sign off space for the appropriate reviewer's signature.

(5)

Section 5.0 PROCEDURE (a)

This section shall contain the instructional steps and applicable contingency actions that are necessary to meet the purpose of the procedure.

i i

Salem Unit 1/2 44 Rev. 3 t

AD-2 (b)

The sub-sections in Section 5 shall be numbered.so that they conform to the numbering of sub-sections in Section 1.

For example in the case shown above, sub-section 5.1 will read 5.1 NORMAL OPERATION OF THE CFCU'S The procedural steps will then start with 5.1.1 for this operating method.- When all steps for this condition have been listed, a new sub-section shall begin which conforms to the next operating method listed in Section 1, with the procedural steps numbered as above.

The two digit sub-section headings shall be in all caps as a means of identitying that a different operating method is now being addressed.

(c)

This section may include supplementary information, cautionary information, and notes.

(d)

Sign off spaces in the body of the procedure are not required nor desired.

MASTER

~

Salem Unit 1/2 45 Rev. 3

AD-2 5.6 Surveillance Procedures 5.6.1 Designations a.

The designation for technical specification related Surveillance Procedures assigned to the Operations Department shall be SP (0).

The designation for non-technical specification surveillances, called Periodic Inspection / Surveillance, shall be PI/S.

b.

For Surveillance Procedures (Operations),

the technical specification surveillance requirement number (main number if more than one requirement) that the Surveillance Procedure (Operations) was written to fulrill shall immediately follow the Surveillance Procedure (Operations) designator to specifically identify each individual procedure.

(1)

As such, each individual Surveillance Procedure will have a unique identifier; for example, SP (0) 4. 4. 6.3, SP (0) 4. 5. 2 (b), SP (0) 4.9. 4, etc.

c.

For Periodic Inspection /Surveillances, each shall be numbered as follows:

(1)

A second level designator for each Periodic Inspection / Surveillance shall immediately follow the PI/S acronym.

This second level designator shall identify the system that the Periodic Inspection / Surveillance is applicable to.

For examples; FP, CA, CN, etc.

(2)

A sequential number will follow the second level designator to specifically identify each individual Periodic Inspection / Surveillance as classified.

MASTER

~

Salem Unit 1/2 46 Rev. 3 i

AD-2 (3)

As such, each Periodic Inspection / Surveillance will have a unique identifier.

As examples:

(a)

Two Periodic Inspection /Surveillances dealing with FP system inspections would be shown as PI/S-FP-1 and PI/S-FP-2.

(b)

One Periodic Inspection / Surveillance dealing with a CA system surveillance would be shown as PI/S-CA-1.

5.6.2 Format Arrangement a.

The single column (i.e. standard sentence approach) format should normally be used in preparing Surveillance Procedures (Operations) and Periodic Inspection /Surveillances.

The dual column format, however, may be used if it more adequately presents the procedure.

b.

When the cual column format is used for a Surveillance Procedure (Operations) or Periodic Inspection / Surveillance:

(1)

The dual column approach shall begin with the Procedure section of the procedure (refer to subsection 5.6.3 below).

(a)

The left hand column shall be used for operator action statements.

(b)

The right hand column shall be used to present contingency actions for use when the' response to the action statements are not obtained and to provide supplementary information and notes.

1 (2)

The single column approach shall be used for the first four sections to the l

procedure (refer to subsection 5.6.3 i

below).

I Rev. 3 Salem Unit 1/2

1 l

AD-2 l

c.

Specific guidance regarding page layout, text number, etc. is provided in Section 2.0 of this directive and in AD-4, Typist Guide.

5.6.3 Format Organization a.

The format organization and content requirements for each Surveillance Procedure (Operations) and Periodic Inspection / Surveillance are as follows:

(1)

Section 1.0 PURPOSE (a)

This section shall provide a brief and concisc statement that describes what is intended to be accomplished.

(b)

The purposo statement will be numbered ';o that a procedure which aduresses more than one operating method of the system or component which meets the surveillance requirement can be readily identified, for example:

1.1 This procedure provides the instructions necessary to perform the following:

1.1.1 Determine the Identified RCS Leak Rate.

1.1.2 Determine the Unidentified RCS Leak Rate.

The intent is to have the purpose statement sub-section 1.1 serve l

as an index, listing those i

operating methods for meeting the surveillance requirements l

addressed by the procedure.

l Salem Unit 1/2 48 Rev. 3

AD-2 (c)

With regard to Surveillance Procedures (Operations), the specific technical specification surveillance requirements (i.e.

l numbers) that the procedure is written to meet shall be identified in the next sub-section.

The traquency requirement for the surveillance procedure will also be included here.

( 2,)

Section 2.0 INITIAL CONDITIONS (a)

The section shall detail the requirements and conditions that must be met prior to the performance of the procedural steps (i.e. section 5.0).

(b)

Each initial condition shall have a sign off space for the operator to initial after completing the step.

The " sign offs" may be included directly in the body of the procedure or in a check off sheet whichever approach better lends itself to the procedure and to records storage considerations.

(3)

Section.3.0 PRECAUTIONS (a)

This section shall cetail pertinent cautionary information that is generally applicable to the entire procecure.

(4)

Section 4.0 ATTACHMENTS LIST (a)

This section shall identify, by listing, each attachment (e.g.

graph, figure, table, check off sheets,.etc.) to the procedure.

k (b)

Check off sheets, when used, shall contain a sign off space p

for the operator to initial, afte,r completion of each major step.

In addition, the last page of each Check off sheet shall contain a sign off space for the appropriate reviewer's signature.

Rev. 3 l

Salem Unit 1/2 49 l

AD-2 (5)

Section 5.0 PROCEDURE (a)

This section shall contain the instructional steps and applicable contingency actions that are necessary to meet the purpose of the procedure.

(b)

The sub-sections in Section 5 shall be numbred so that they conform to the numbering of sub-sections in Section 1.

For example.in the cabe shown above, sub-section 5.1 will read:

5.1 DETERMINE THE UNIDENTIFIED LEAK RATE The procedural steps will then start with 5.1.1 tor this operati.sg method.

When all steps for this condition have been listed, a new sub-section shall begin which conforms to the next operating method listed in Section I, with the procedural steps numbered as above.

The two digit sub-section headings shall be in all caps as a means of identifying that a different operating method is now being addressec.

(c)

Each pertinent instructional step shall have a sign off space for the operator to initial after completing the step.

The " sign offs" may be included directly in the body of the procecure or in a check off sheet which ever approach better lends itself to the procedure and to records storage considerations.

(d)

This section may include supplementary information, cautionary information, and notes.

MASTER

~

Salem Unit 1/2 50 Rev. 3

3 AD-2 5.7 Alarm Response Procedures 5.7.1 Designation The general designation for all Alarm a.

hesponse Procedures shall be ARP.

(1)

A second level designator for each Alarm Response Procedure shall immediately follow the ARP acronym.

This second level designation shall identify the system which the alarm addresses.

For example (a)

The Reactor Coolant System shall be identified as RCS (b)

The Safety Injection System shall be identified as SJ An exception will be made in the case of those alarms on local panels where no system designation will be necessary.

(2)

A third level designator for each Alarm Response Procedure shall immediately follow the system designator.

This third level designator shall identify the type of alarm.

For examples (a)

The control room overhead annunciator alarms shall be identified as OHA.

(b)

The local panel annunciator alarms shall be identified as PNL.

(c)

The control console bezel alarms shall be identified as BZL.

(d)

The auxiliary alarm typewriter alarms shall be identified as AUX.

MASTER Salem Unit 1/2 51 Rev. 3 l

3 AD-2 (3)

A fourth level designator shall be used to identify the specific alarm within a given alarm type.

No specific approach shall be defined herein; however, whatever approach is used it shall be used consistently.

Some example approaches are (a)

For control room overhead annunciator alarms, the grid location should be used (e.g. AS,

C32, D15, etc.).

(b)

For local panel annunciator alarms, the panel number should be used (e.g. 47 0, 10 4,

661, etc.).

In addition, the grid location could also be specified.

(c)

For control console bezel alarms, the bezel drawing number could be used.

(d)

For auxiliary elarm typewriter alarms, the couputer acdress point should be.used.

(4)

As such, each Alarm Response Procedure will have a unique identifier.

For example

.(a)

Overhead annunciator alarms ARP-SJ-OHA-D26, ARP-RCS-OHA-AIS etc.

(b)

Local panel alarms, ARP-PNL-470 or ARP-PNL-470-A4, etc.

(c)

Control console bezel alarms, ARP-RCS-BZL-202060-1 ARP-RCS-BZL-20 20 6 0-2 AkP-SJ-BZL-228507-1, etc.

(d)

Auxiliary alarm typewriter alarms, ARP-AUX-072, ARP-AUX 332, etc.

MASTER Salem Unit 1/2 52 Rev. 3

AD-2 5.7.2 Format Arrangement a.

A formal format arrangement (i.e. single or cual column) is not specified for alarm response procedures.

b.

Specific guidance regarding page layout is provided in AD-4, Typist Guide.

5.7.3 Format Organization a.

The format organization and content requirements for each Alarm Response Procecure is as follows:

(1)

ALARM (a)

The exact wording of the alarm as it is displayed on the annunciator, bezel, etc. shall be provided.

(2)

ENTRY CONDITION (a)

This section shall contain a list of the conditions under which the procedure is used.

(b)

The entry conditions shall include alarm setpoints, and may include indications, operating conditions, procedure referrals, etc.

(3)

AUTOMATIC ACTIONS (a)

This section should contain those actions that the operator should be verifying upon receipt of the alarm or initiation of the procedure.,

(4)

MANUAL ACTIONS (a)

This section should contain those actions that the operator should take to return the abnormal condition to a normal condition.

Salem Unit 1/2 53 p,y, 3

AD-2 (5)

SUPPLEMENTAL INFORMATION (a)

The inclusion of this section is optional.

, l (b)

This section, when included in an Alarm Response Procedure, can be used to detail such information as reference documents, bistable numbers, equipment locations, etc.

b.

Signature or sign off spaces in Alarm Response Procedures are neither required nor desired.

END OF PROCEDURE FINAL PAGE l

1 l

i i

MASTER i

l i

i l

l Salem Unit 1/2 54 Rev. 3 i

7 ATTACHMENT 3 SIMULATOR SCENARIOS

~

1.

Reactor Trip 2.

Spurious SI 3.

Reactor Trip - ATWS 4.

Blackout - Reactor Trip - Natural Circulation Cooldown 5.

Loss of All AC 6.

DBA LOCA 7.

Small Break LOCA - Cooldown 9.

Small Break LOCA - No ECCS 11.

Secondary Break outside Containment 12.

Secondary Break all MSIVs fail open i*d 13.

Sequential Secondary breaks 14.

Loss of all feed water 15.

Loss of all feedwater and all AC 16.

Secondary break inside containment and small break LOPCA (PORV) 17.

Secondary break inside containment and loss of all AC 18.

500 GPM SGTR, Cooldown via backfill 20.

SGTR with no RCS pressure control 25.

SGTR and LOCA 26.

SGTR gius secondary break in ruptured SG e e

ATTACHMENT 3 SIMULATOR SCENARIOS (CONT.)

SUPPLEMENTAL MALFUNCTIONS (USED TO ENCHANCE STANDARD SCENARIOS) 1.

Failure of SI or Charging Pump to start 2.

Fall one or more AFW Pumps 3.

Inadvertant Containment Isolation Phase B 4.

Fail both RHR Pumps 5.

Fail both Containment Sump Suctions 6.

Fail BIT isolations closed 7.

Fail Aux Feed throttle valves open or closed 8.

Fail one Vital Bus / Diesel Generator 9.

PORV fails open,.can be isolated with block valve 10.

Loss of offsite power s

.A m

~~

ATTACHMENT.34 EOP - SCENARIO CROSS REFERENCE SCENutIo 1 2 3 4 5 6 7 9 11 12 13 14 15 16 17 18 20 25 26 TRIP 1 X X X X X X X X X X

X X

X X

X X

X X

X 2

X X X 3

X 4

X 5

X 6

X urA 1 X X X

2 X

3 X

4 X

5 X

6 X

I48C 1 X

X X

2 X

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SGrR 1 X

X X

2 X

3 X

X-

.}

4 X

5 x

ICFA 1 X

2 X

3 X

FRSM 1 X

2 X

FROC 1 X

2 X

3 X

FRHS 1 X

2 3

X 4

5 X

FRr5 1 X

2 X

FRCE 1 X

i 2

X 2

X 3

FRCI 1

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2 X

3

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UNITED STATES ANAGER o NUCLEAR ~

NUCLEAR REGULATORY COMMISSION LICENSING aad REGULATION

[

g WASHINGTON, D. C. 206se 3

)

DEC 27 '84.b December 19, 1984

~

l:

Docket Nos. 50-272 M

3iijg and 50-311 U4NCer

  • Nik ear Mensno na news Mr. Richard A. Uderitz, Vice President -

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-ii Prmcw Ec Nuclear

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Public Service Electric and Gas Company Post Office Box 236 sener seeman

-l" Hancocks Bridge, New Jersey 08038 t

l i

Dear Mr. Uderitz:

I

SUBJECT:

PRELIMINARY SAFETY EVALUATION REPORT ON THE PRv ;suuRE5 GLGATHN' I k

PACKAGE FOR SALEM NUCLEAR GENERATING STATION, U m1m2 l

Sw or are The staff has completed a preliminary review of your May Mh3 =944al 130'1

" Procedures Generation Package (PGP) for Emergency Operation Procedures (EOPs)". The enclosed Preliminary Safety Evaluation Report identifies open items which must be addressed in order for us to complete our review.

The PGP, as specified in Generic Letter 82-33, consists of four parts: (1)-

Plant-Specific Technical Guidelines, (2) Writer's Guide, (3) a description of the Validation / Verification Program for E0Ps, and (4) a description of the Training Program for Upgraded E0Ps. Criteria for our review of PGP are not currently in the Standard Review Plan.

Therefore, our review was based on NUREG-0899 " Guidelines for the Preparation of Emergency Operating Procedures," the reference document for the E0P upgrade portion of Supplement 1 to NUREG-0737 (Generic Letter 82-33).

The open items are discussed in Section 2 of the report.

Your response addressing each of the items should be provided by May 15, 1985.

Sincerely, 3

rga ief Operating React Bra'nch #1 Division of Licensing

Enclosure:

y As stated 7

lgct p ucgiga i

'U9 RMULrl';.';

cc w/ enclosure:

See next page l

.j.;

g; nim ".,

_ _l 3/_ __. ;

ty wwwa y,.

4 Mr. R. A. Uderitz Salem Nuclear Generating Station Public Service Electric & Gas Company Units 1 and 2 Mad J. Wetterhahn, Esquire Regional Radiation Representative cc:

Conrer and Wetterhahn EPA Region II i

Suite 1050 26 Federal Plaza 1747 Pennsylvania Avenue, NW New York,llew York 10007 i

Washington, DC.20006 j

Mr. R. L. Mittl, General Manager Richard Fryling, Jr., Esquire Nuclear Assurance and Regulation Assistant General Solicitor Public Service Electric & Gas Co.

Public Service Electric & Gas Company Mail Code T160 - P. O. Box 570 P. O. Box 570 - Mail Code T5E Newark, New Jersey 07101 Newark, New Jersey 07101 i

Gene Fisher, Bureau of Chief U.S. Nuclear Regulatory Comission Bureau of Radiation Protection 631 Park Avenue 380 Scotch Road King of Prussia, PA 19406 Trenton, New Jersey 08628 Lower Alloways Creek Township 1

Mr. John M. Zupko, Jr.

c/o Mary O. Henderson, Clerk J

General Manager - Salem Operations Municipal Building, P.O. Box 157 Public Service Electric & Gas Company Hancock Bridge, NJ 08038-'

i Post Office Box E Hancock Bridge, New Jersey 08038 Mr. Alfred C. Coleman, Jr.

t Mrs. Eleanor G. Coleman i

Mr. Dale Bridenbaugh 35 K Drive i

M.H.B. Technical Associates Pennsville, New Jersey 08070 1723 Hamilton Avenue San Jose, California 95125 Carl Valore, Jr., Esquire Valore, McAllister, Aron i

James Linville, Resident Inspector and Westmoreland, P.A.

Salem Nuclear Generating Station 535 Tilton Road U.S. Nuclear Regulatory. Comission Northfield, NJ 08225 Drawer I Hancock Bridge, New Jersey 08038 June D. MacArtor, Esquire i

Deputy Attorney General Richard F. Engel Tatnall Building l

Deputy Attorney General Post Office Box 1401 Department of Law and Public Safety Dover, Delaware 19901 CN;113-i State House Annex Harry M. Coleman, Mayor Trenton, New Jersey 08625 Lower Alloways Creek Township Municipal Hall Richard-B. McGlynn, Comission Hancock Bridge, New Jersey 08038

(

Departmen1; of Public Utilities State of New Jersey 101 Comerce Street j

Newark, New Jersey 07102 I

f i

  • w Salem Nuclear Generating Station Units 1 and 2 DL cc: Mr. Edwin A. Liden, Manager Nuclear Licensing & Regulation l

Public Service Electric & Gas Company Post Office Box 236' Hancock Bridge, New Jersey 08038 Mr. Charles P. Johnson Assistant to Vice President, Nuclear Public Service Electric & Gas Company Post Office Box 570 80 Park Plaza - 15A Newark, New Jersey 07101 Mr. David Wersan Assistant Consumer Advocate Office of Consumer Advocate 1425 Strawberry. Square Harrisburg, PA 17120

  • i Frank Casolito, Acting Chief Bureau of Radiation. Protection f

Department ~of Environmental Protection 380 Scotch Road Trenton, New Jersey 08628 l

O 1

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PRELIMINARY SAFETY EVALUATION REPORT

~

PROCEDURES GENERATION PACKAGE SALEM NUCLEAR GENERATION STATION, UNITS 1/2

(

1.

INTRODUCTION Following the Three Mile Island (TMI) accident, the Office of Nuclear Reactor Regulation developed the "TMI Action Plan" (NUREG-0660 and NUREG-0737), which required licensees of operating reactors to reanalyze transients and accidents and upgrade emergency operating procedures (EOPs) (Item I.C.1).

The plan also required the NRC staff to develop a t

long-tenn plan that integrated and expanded efforts in the writing, reviewing", and monitoring of plant procedures (Item I.C.9).

NUREG-0899,

~

" Guidelines for the Preparation of Emergency Operating Procedures,"

represents the staff's Tong-tenn program for upgrading E0Ps, and

,; j describes the use of a " Procedures Generation Package" (PGP) to prepare E0Ps. Submittal of the PGP was made a requirement by Supplement 1 to I

NUREG-0737, " Requirements for Emergency Response Capability (Generic Letter 82-33)." The Generic Letter requires each licensee to submit to the NRC a PGP which includes:

(i) Plant-Specific Technical Guideline (ii) A Writer's Guide (iii) A Description of the Program to be Used for the Validation of E0Ps (iv) A Description of the Training Program for the Use of

~

,.a Upgraded E0Ps This reporf describes the review of Public Service Electric and Gas Company's (PSE&G) response to the Generic Letter related to development and implementation of E0Ps for Salem 1 and 2.

(Section 7 of Generic Letter 82-33.)

Our; review was conducted to determine the adequacy of the licensee's program for preparing and implementing E0Ps.

Criteria for the review of a PGP are not currently in the Standard Review Plan (SRP).

Therefore,

$5 EU U 0

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({ff.

this review was based on NUREG-0899, the reference document for the E0P upgrade portion of Supplement 1 to NUREG-0737 (Generic Letter 82-33).

Review criteria based on this guidance will be developed for the next SRP revision. Section 2 of this SER briefly discusses the five parts of the licensee's submittal, the staff review methods, and the acceptability of the submittal.

Section 3 contains the conclusions of this review.

As indicated in the following sections, our review determined that the procedure, generation program for Salem 1 and 2 is acc'eptable with the exception of the items identified in Section 2.

The licensee.should address these items in a revision to the PGP, or lustify why such revisions are not necessary.

Our review of the licensee's response to these items will be included in a supplement to this SER.

The revision of the PGP, and subsequently of the E0Ps, should not impact the schedule for the use of the E0Ps. The revision should be made in accordance with the licensee's administrative procedure.

2.

EVALUATION AND FINDINGS In a letter dated May 20., 1983, from E. A. Liden (PSE&G) to S. A. Varga (NRC), the licensee submitted its PGP.

The PGP contained the following j

five sections:

Plant-Spec fic Administrative and Technical Guidelines and E0P

~

Preparation Author's Guide Verification Program

Validation Program Training Program

' The comments on these sections, with the verification program and validation program connents combined, are presented below:

A.

Plant-Specific Administrative and Technical Guidelines and E0P Preparation The Plant-Specific Administrative and Technical Guidelines and E0P

~

Preparation section was reviewed to deterinine if it provided adequate-infor1 nation to meet the objectives of NUREG-0899. The licensee described how the administrative controls for the preparation of E0Ps have been incorporated into their existing controls and how the Westinghouse Owners Group Emergency Response Guidelines (ERG) have been converted into plant-specific E0Ps. The process described for converting the generic guidelines into E0Ps appears adequate, however, the following items should be addressed in the Plant-Specific Administrative and Technical Guidelines and EOF Preparation:

~

(1) Eor utility record purposes'and to assure the staff of the use

  • of NR'C approved generic guidelines, the PGP should specify the-pmc.

[ revision or date of the generic guidelines used as the basis for Wh"C

//)q ttre-plant-specific guidelines. The PGP stated that a wegw combination of the high and low pressure versions of the ERGS (w/J, M was used. Because Salem has high pressure safety injection sN #*

systems, the portions taken from the low pressure gui,deline should be considered deviations from the approved generic guideline,s.

4-(2) Section 2.3.2 describes the use of a comparative analysis g ggg, between the draft E0Ps and the applicable EP.Gs to identify 3, pg,ap w deviations but there is no discussion of an evaluation of the S N W 3

safety significance of the deviations. All deviations from, andW EO additions to, the generic technical guidelines nust be evaluated

/

to datermine.their. safety-significance and this process should t

be described.in the:PGP.i (3) -If the process described in item 2 identifies any safety significant deviations from, or additions to, the generic

\\p g F/

.T AI I

technical guidelines,g submitta13hohld:( (a)31distify the 4

safety significant deviations or additions found, and g p t,34a5 (b)sprovide.the. technical. justification (i.e.,tengineering g (z.)

evaluation or analysis, as appropriate) for the plant-specific approach.

l (4) The generic guidelines include guidance for operators to use u-mM safety injection to inject boron, if necessary, during an pj%,,

67 Anticipated Transient Without Scram (ATWS). As an addition to g. sm say o

the generic guidelines bases, provide criteria, with n N3*:N

/

justification, for operator verification that the reactor is shut down and f.or operator termination of the safety injection.

l

($

Describe the process for using the generic guidelines and

.b ;/[

' background documentation to identify the characteristics of 7IC rp needed instrumentation and controls.

For the information of pg. * 'd

~

Y this type that is not available from the ERG and background

/

b documentation, describe the process to be used to generate the W.

necessary instrumentation and control characteristics. -T'his process can be described in either thg_PGP or Detailed Cootrol hb Room Dodgn Review progrm Plan with appropriate cross-referencing.

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-.With satisfactory resolution of the above items, the instructions for Salem Plant-Specific Administration and Technical Guidelines and E0P Preparation should provide adequate translation of the ERGS into plant-specific E0Ps. The staff will confinn that the ifcensee adequately addresses these items and will describe the review in a supplement to the SER.

B.

Writer's Guide e

The writer's guide was reviewed to detennine if it provided

~

acceptable methods for accomplishing the objectives of NUREG-0899.

y

~~

The licensee described a process that will use the Salem ERGS and writer's guide to develop emergency procedures. The procedures will use a single column format for entry conditions and will use a dual column format for the operator actions. Our review of the writer's guide revealed the following shortcomings:

1) There shiifufd'6e"FbYieff statement ofl scope to~ describe theTY iDW6/

general purpose of the E0P. Note that carefully worded titles J O M may be used to accomplish this objective.

(SeeNUREG-0899, Subsection 5.4.3).

.(26 Tiicor.poration of sign-off provisions and checkoff lists into the i

E0Ps is explicitly ruled out in AD-2 (Section 5.'3.3., pg.

L 32-33). However, the E0Ps are used under circumstances which l

could produce significant stress on the operators. Therefore,

~

I placekeeping aid (s) should be implemented by the operators to up.

prevent skipping or repeating steps. Use of placekeeping aids, r,,,.

such as checkoff spaces, is one method that helps to facilitate the placekeeping.

If aids are not to be used, describe the method (s) to be used by the operators to keep place as the procedures are used.

(3)

Identification of caritrol room equipment is covered in AD-2 (Subsection 4.2.2.g).

In addition to the infonnation provided there, the writer's guide should specify that co'ntrol room

[ equipment be identified in a manner that is easily understood by the operator and consistent with the nomenclature used on the equipment labels and in..other.. procedu'res.y (See NUREG-0899, Subsection 5.6.2.)

(4),The writer's guide should proiTEgnidancFonWtolfovide'

~

location information!(for^ equipment,-controltriCdfsplaji)'iifdd how this-infomation wil1~ be. presented.

(SeeNUREG-0899, 3

Subsecti5n5.7.11.)

')

(5) The directions for the use of logic tems in AD-2 (Subsection g

3.8.3, pg. 15 and 18) provide most of the needed guidance for the g

use of these tenns. However, thec. format:ofelegie steps EWAC

/ employing these.. terms should..be-provided.in'additiom to-the Also,.tha examples

/ examples currently. presented in the.-PGP..

should be corrected to be consistent with each other and the guidance selected for fomatting the steps. This should help ensure consistency and reduce the potential for operator confusion under stress.

(67 The [ollowing items should be included to enhance the useability of the E0Ps:

7.

(a) The E0Ps should be distinctly identifiable from other

[

documents and should provide the operators easy access to y

any procedure or part of a procedure.

(SeeflUREG-0899, Subsection 6.1.4.)

(b) The writee'sJguide should. specify;that the.quali.ty of all v/

reproductions of' E0rs be comparable to the originals to ensure readability.

(SeeNUREG-0899, Subsection 6.2.2.)

(7) The:EOP step numbering-system should provide information so.that goperators_carLquickly< determine-where-they-are-irerelation-to tim rest of the document._ The step numbering system described in AD-2 (pg. 2) could require operators to review the document "to obtain the entire step identifier if the subsection extended

~

over one page. One method of accomplishing this goal would be.

tu. :

to use a numbering system that allows the complete step rys 7 identifier to precede to each step or substep.

For example, step "a" of Subsection 1.1.1 could be written as 1.1.1.a and Substep (1) could be written as 1.1.1.a(1). This would provide imediate identification of each action step even if the L

subsection extended over more than one page.

(See NUREG-0899, l

Subsection 5.5.5.)

l (8) Due to the nature of control rooms, control room events, staff capabilities and the turnover in control room shift crews, the E0Ps should be structured so that they can be executed by the c<wV

/:.

minimum control' room ~ crew as specified in the technical 2 specifications.

(SeeNUREG-0899, Subsection 5.8.1.)

l I

(The following item is provided for information and should be considered when the P-SWG is revised.)

l l

1 (9) The guidance for verification steps (AO-2, Subsection 4.2.3, pg.

22-23) is acceptable; however, the reference made to Section 5.0 inSubsection4.2.3bsis~unsliar.

TWprobleurco' lt be resolved-u by simply listing the procedural categories for which verification steps-are'requ' irid"ratheF than'referriiig~the user-

~

to another major section of the procedure.

With adequate resolution of the above items, the staff concludes that.

the Salem writer's guide provides adequate guidance for translating the technical guidelines into E0Ps that should be useable, accurate, u

complete, readable, convenient to use and acceptable to control room;,

l.

operators. The staff will confirm that the licensee adequately

{;,

.),

addresses these items in the writer's guide, and will report its review in a supplement to the SER.

C.

Validation / Verification The descriptions of the licensee's validation / verification programs were reviewed to deterinine if they acceptably address the' objectives l

stated in NUREG-0899. The verification program described in the PGP has two objectives:

1) to.deterinine that the procedures conform to the format and principles specified in the writer's guide, and 2) to determine that the procedures are technically accurate, consistent witMthe plant-specific technical guidelines and include all appropriate licensing commitments. The objective of the validation program described in the PGP is to ensure that a trained operating i

shift can manage emergency events using the E0Ps.

During cur review s

of the verification / validation program, we identified the following deficiencies:

(1) The validation program as described in the PGP (pg. 10-15) contains a number of the essential items that are needed for a thorough validation program.

However, the following additional items should be include:

(See NUREG-0899, Subsection 3.3.5.)

i

/

(a) An indication that the validation will demonstrate that the

,50ausan ba_offeettvety-implemented bf theminimunrcrew staffiny' required by the technical specifications, g-JPIM )

vfti) The criteria used to choose the scenarios for validation.

E h"indfiaifdf~satsifi6PIsIodibli'wl11 tufE3EMis'id"on M

the simulator andithat' the"scenafios"to' tEis'ad will

  1. g incliide~multigie:(siidiia'n'eous and sequential) failures.

[

An indication of how the portions of the' E0Ps which cannot- -

~

@)

be" tested-welle onf thr~ simulator wilt"b'e#Validiti( by some E

Y otheF method (e.g., control room walk-throughs).

~

(2) The validation program needs to detemine if the infnrmation

']

g required by the operator, as detemined by the task analysis q

4 I

performed for the technical guidelines, is available in the l

control room. # discussion _oL. thin should be-included-in the I

validation _programbb(Thiselementmaybedoneinconjunction f f

with the Control Room Design Review.)

l (3) There_should.be a. description of the method by which differences 3 atween unis At1Fbe-taken into account in the valI'datioU

/

h

-[veWfTditfon' p~rograms.

~

Upon retalution of the above items the validation / verification l

program should be' adequate to accomplish the validation / verification objectives stated in NUREG-0899 and should provide assurance that the E0Ps adequately incorporate the guidance of the writer's guid6 and generic technical guidelines.

The staff will confirm that the licensee adequately addresses these items in the PGP and will report its review in a supplement to the SER.

i

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

o i I Training Program The licensee's description of the operator training program for the E0Ps was reviewed to deterinine if it adequately addresses the objectives of NUREG-0899. The training program described in the PGP is planned to be implemented as a part of the requalification program. The program consists of classroom instruction and simulator training (on the pli.at-specific simulator) on a shift basis using the team Approach to emergency response. Both written and perforinance

[

evaluations are planned.

c.

The training program dercription addresses most of the desired I

j objectives, however, the following areas should be addressed:.

(1.) For-walk-throughs' and simulator exercises, the staff needs

[

assurance that.a wide variety > of-scenarios'will be used,-

4 including multiple (simultaneous-and sequential) failures.

() For portions. of E0Pothat cannot be' exercised on the simulator, 4

~

there needs to.be a-discussion of the mechanism by which these.

areas.will be. covered.by some other training methods.

With the in,clusion of the above items, the staff' concludes that the trathing program will acceptably address the objectives-of NUREG-0899 and should provide assurance that the operators are adequately trained on the E0Ps prior to implementation of the E0Ps in the control room.

The staff will confirm that the licensee adequately addresses these items and will report its review in a supplement to the SER.

/

3.

CONCLUSIONS Based on the review, we conclude that, with the exception,s noted in Section 2 of this SER, the Public Service Electric and Gas Company PGP for Salem 1 and 2 meets the requirements of Supplement I to NUREG-0737 L

and describes acceptable methods for accomplishing the objectives stated in NUREG-0899. The staff therefore has reasonable assurance that E0Ps developed and implemented in accordance with the program described in the licensee's PGP should be adequate for control room personnel to effectively mitigate the consequences of a broad range of accidents and o

multiple failures.

Future changes to the PGP having safety significance r

should be brought to the attention of the NRC and will be reviewed in accordance with 10 CFR 50.59.

This review and evaluation was performed with the assistance of Battelle i

Pacific Northwest Laboratories personnel, t

Principle Reviewer:

W. Kennedy e

A

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