ML20138R455

Validation Procedure for Emergency Operating Procedures

ML20138R455
Person / Time
Site:	Pilgrim
Issue date:	03/08/1984
From:	Mathis C BOSTON EDISON CO.
To:
Shared Package
ML20138R443	List: BECO-85-228, Forwards Rev 0 to Procedure 1.3.4-10, Writers Guide for Emergency Operating Procedures, Validation Procedure for Emergency Operating..., in Response to ML20138R450 ML20138R455 ML20138R460
References
PROC-840308, NUDOCS 8512310294
Download: ML20138R455 (24)

Text

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BOSTON UE') ISOn COMPANY NUCLEAR OPERATIONS DEPARTMENT PILGRIM NUCLEAR POWER STATION VALIDATION PROCEDURE FOR EMERGENCY OPERATING PROCEDURES 0

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approvea "0RC Cl)afrman Date kl(jth @lGf& -

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FOR INFORidATiON

.. ONLY TABLE OF CONTENTS l

SECTION PAGE

1. Introduction............................................ 3 1.1 Purpose............................................ 3 1.2 Scope.............................................. 3 1.3 Applicability...................................... 3

2. R e f e re n c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3. Definitions............................................. 3

4. Responsibilities........................................ 4 4.1 Nuclear Ope rat ions Manage r. . . . . . . . . . . . . . . . . . . . . . . . . 4 4.2 Nuclear Training Manager.....'...................... 4 *

5. Process for EOP Validation.............................. 4 5

5.1 Preparation........................................

5.2 Assessment......................................... 5 5.3 Resolution......................................... 5

6. Documentation........................................... 5 Attachments:

1. Checklist for Table-Top / Walk-Through Methods of Validation.................................... 7

2. Checklist for Simulator Method of Validation. . . . . . 12 Forms:

'EOP Validation Form................................... Form 1 Table-Top / Walk-Through Scenario Form.................. Form 2 Table-Top / Walk-Through Evali'ation Fo rm. . . . . . . . . . . . . . . . Form 3 Simulator Scenario Form............................... Form 4 Simulator Evaluation Form............................. Form 5 Procedure Discrepancy Sheet........................... Form 6 Page 2 of 15

.. 1 FOR INFORidATiON !

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1. INTRODUCTION 1.1 PURPOSE The purpose of this procedure is to guide the administrative process used in validation of the emergency operating procedures (EOP's)

'and to assign responsibilities for the. process.

' l .' 2 SCOPE

- - - - This procedure identified the aspects of the validation program process and gives guidance that encompasses three validation methods -

table-top, walk-through, and simulator. Specific guidance for each method is presented in its. appropriate checklists (see Attachments 1 and 2).

1.3 APPLICABILITY This procedure applies to E0P validation prior to implementation and E validation subsequent' to implementation for Pilgrim Nuclear Power

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Station.

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2. REFERENCES e Emergency Operating Procedures Validation Guideline (INPO 83-006) e BWR Owner's Group Emergency Operating Procedures Guidelines,

- t Revision 2 1,

e Appendix A, BWR EPGs, Revision 1 r +

! e FSAR j

e NRC Inspection Findings,' Resolutions  ;

5 e Results of E0P verification ,

3. DEFINITIONS I Control Room Simulator - a device that dynamically models the plant i functions as presented in the control room.

' 7 ~~ Emergency Operating Procedures (EOPs) - Plant procedures directing  !

operator actions necessary to mitigate consequences of transients 1 and accidents that cause plant parameters to exceed reactor protec-tion setpoints, engineered safety feature setpoints, or other appro-priate technical limits. ,

Emergency Operating Procedure Guidelines (EPCs) - Guidelines that provide technical bases' for the development of E0Ps.

E0P Source Documents - Documents or records upon which E0Ps are based.

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FOR INFORMATiON

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E0P Validation - The evaluation performed to determine that the actions specified in the E0P can be followed by trained operators to manage the emergency conditions in the plant.

Mock-Up - Static device (e.g., models, photos, drawings) that portrays control room hardware and configuration.

l. Scenario - A structural plan of parameter and plant symptom changes that provide operating cues for the conduct of assessment.

Simulator Validation - Method of validation whereby control room operators perform actual control functions on simulated equipment during a scenario for an observer / review team.

Table-Top Validation - Method of validation whereby personnel explain and/

or discuss procedure action steps for an observer / reviewer in response to a scenario or as part of an actual industry operating experience review.

Walk-Through Validation - Method of validation whereby control room opera-tors conduct a step-by-step enactment of their actions during a scenario for an observer / review team without carrying out the actual control functions.

4. RESPONSIBILITIES

( 4.1 Operations Review Committee The Operations Review Committee shall approve all E0Ps and revisions.

4.2 Nuclear Training Manager

, The Nuclear Training Manager shall be responsible for the following:

o managing the validation program and ensuring its smooth coordination with the training program e coordinating for rotating operating crews through the training /valida-

, tion sessions e scheduling simulator training time for validation purposes as appropriate ,

e reviewing discrepancies and resolutions forwarded to him by observer /

review personnel e forwarding recommended resolutions and procedure changes et ;he Nuclear Operations Manager for approvali the Nuclear Training Manager will devise l a system to track the recommended changes.

5. PROCESS FOR E0P VALIDATION 4 Regardless of the validation method, the E0P validation process can be described by the three phases of: (1) preparation, (2) assessment, and (3) resolution.

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FOR INFORMATiON

- . ONLY 5.1 Preparation ,

Each validation method will involve the preparation of scenarios using the appropriate scenario forms: -

Table-Top / Walk-Through Scenario Form Simulator Scenario Form Attachment 1 gives specific guidance for the preparation of a Table-Top /

Walk-Through Validation.

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Attachment 2 gives specific guidance for the preparation of Simulator Validation.

5.2 Assessment The assessment phase of each validation type is described in the applicable Arcachment 1 or 2.

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5." Resolution Resolution will be accomplished by reviewing discrepancies and comments presented on the Procedure Discrepancy Sheet. The observer / reviewer will ,

propose solutions, if needed, and forward to the Nuclear Training Manager for approval, with the other designated documentation.

(- - 6. DOCUMENTATION I The documented items needed to provide a history of the validation program

, , are specified on each validation method checklist (Attachments 1 and 2).

$- - These items will be maintained as a validation package in the document control storage area.

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FOR INFORinTiONI

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A T T A C 11 M E N T S (w

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FOR INFORMATiON ONLY ATTACHMENT 1 1

CHECKLIST FOR TABLE-TOP /.

WALK-THROUGH METHODS OF VALIDATION ,

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1. PURPOSE The purpose of this checklist is to provide guidance for the table-top and walk-through methods of validating E0Ps.  !

2. VALIDATION PROCESS E0P validation will be conducted in three parts: preparation, assessment, i

and resolution.

l 2.1 PREPARATION .

j The designated instructor will be responsible for the following:

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-l e e using and completing the E0P Validation Form  ;

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e developing or modifying scenarios to support the scope of validation and filling out the Table-Top / Walk-Through following the attached  !

j (f example t

o modifying / selecting the developed evaluation cirteria to support the l scope of validation i

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FOR INFORidATiON

- ONLY To do this, fill out the following checklist:

Obtain copy of the E0P Validation Form ,

Fill in the Procedure to be validated: name, number, and revision Fill in the purpose of validation (choose 1):

transition between procedures use of single procedure transition into attachments ability to perform concurrent actions use of multiple procedures Fill in validation method (choose 1):

Walk-through Table-top ,

Simulator Fill in Instructor / Observer Obtain copy of Table-Top / Walk-Through Scenario Form fill in lines 1-4 fill in scenario description and initial plant condition fill in the bottom section List the progression through the steps of the procedure in the first column.

List the symptoms which could cause transition.

List where the transition should take the operator.

See example on page #9 to check your work.

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FOR INFORMATiON

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I SAMPLE

' TABLE-TOP / WALK-THROUGH SCENARIO FORM PROCEDURE NO: E0P-01 TITLE: REACTOR TRIP OR SAFETY INJECTION DATE: June 1. 19XX PURPOSE: To evaluate transition from E0P-01 to E0P-02 via step 27 of E0P-01.

SCENARIO DESCRIPTION: A reactor trip is initiated by a faulty relay on RC? No. 1. RapidactkonoftheDumoanti-rotation ____

device causes the pump coupling to fail, resulting in the failure of the pumps seal packanes

(- INITIAL PLAhT CONDITIONS: 100% on line PLANT PARAMETER / ,

PROCEDURE STEP SYMPTOM TO TRANSITION TO

' DESCRIPTION CAUSE TRANSITION -(PROCEDURE. STEP)

Step 1-26 are None N/A normal responses to a reactor trip .

Step 27 addresses High containment E0P-02, Step 1 containment Pressure or Contain-Parameters ment Radiation i

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FOR INFORid4 TION

. ONLY 2.2 ASSESSMENT The designated instructor will perform the following duties:

e brief the operators on the scope of validation and how the assessment will be conducted e follow the developed or modified scenario by first giving the plant initial conditions and then give the changing plant parameters as talking or walking through the procedures e stop the talk-through or walk-through assessment for discussion of any identified discrepancies, e conduct a debriefing with the operators as soon as possible after each walk-through assessment, using the following sequence:

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- brief the participants on the purpose and objectives for debriefing using the Table-Top / Walk-Through evaluation form:

a. have operators present problems and discrepancies which they had identified during assessment

( b. have operators provide possible reasons for problems

c. present other problems and discrepancies identified during assessment

d. have operators describe possible reasons for the other problems

e. summarize the findings of the debriefing for the operators.

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e rccord discrepancies and comments on Procedure Discrepancy Sheets (PDS).

2.3 RESOLUTION The designated instructor will perform the following duties: .

e review comments and discrepancies e propose resolutions on PDS for the Nuclear Training Manager e submit the validation package to the Nuclear Training Manager.

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FOR INFORidATiON

. ONLY The Nuclear Training Manager will perform the following duties:

o review proposed resolutions with appropriate staff e select resolutions for incorporation in the E0Ps 4

e present the revised E0Ps to the Nuclear Operations Manager for approval.

3. DOCUMENTATION The following documentation will be submitted as a validation package:

o completed E0P Validation Form l e Table-Top / Walk-Through Scenario Forms e PDS Forms used e Table-Top / Walk-Through Evaluation Forms i

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_ . _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ . _ _ _ . _ _ . . _ _ . _ _ . _ . _ _ _ _ _ _ . . _ _ . _ _ _ _ _ _ . _ . _ _ . _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . . _ _ _ . . _ _ _ _ _ _ _ _ . _ . _ _ _ _ . _ _ . . . _ . _ _ . . _ _ _ . . _ . _ _ . _ . . _ ___m____ ___.._

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FOR INFORMATiON ONLY ATTACHMENT 2 l

• CHECKLIST FOR SIMULATOR

! METHOD OF VALIDATION

1. PURPOSE The purpose of this checklist is to provide guidance for the simulator method of validating E0Ps.

2. VALIDATION PROCESS E0P validation will be conducted in three parts: preparation, assessment, and resolution.

2.1 PREPARATION The designated observer / reviewer will be responsible for the following:

e using and completing the E0P Validation Form e developing or modifying scenario runs to support the scope of validation

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e completing the upper portion of the Simulator Scenario following the attached example and forwarding to the simulator instructor To do this, fill out the following checklist:

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Obtain copy of the E0P Validation Form Fill in Procedure to be validated: name, number and revision Fill in purpose of Validation; choose 1:

transition between procedures use of single procedure transition into attachments ability to perform concurrent actions use of multiple procedures Fill in validation method (choose 1): ,

Walk-Through

-Table-Top Simulator Fill in Instructor / Observer Obtain copy of form 2. ,

Fill in lines 1-4 Fill in scenario description and initial plant condition

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FOR INFORid& TION

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, 'l, . Fill in the bottom section L;st the progression through the steps of the procedure i i column.

I List the symptoms which could cause transition. .

List where the transition should take the operator.

l See example on page #14 to check your work.

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FOR INFORiviATiON

. ONI.Y f SAMPLE SIMULATOR SCENARIO FORM PROCEDURE NO.: E0P-01 REVISION: 01 TITLE: REACTOR TRIP OR SAFETY INJECTION DATE: June 1, 19XX PURPOSE: To evaluate transition from E0P-01 to E0P-02 via step 27 of E0P -01 SCENARIO DESCRIPTION: _ A reactor trip is initiated by a faulty relay on RCP No. 01. RCP seal packages fail.

INITIAL PLANT CONDITICNS: 100% on line SIMULATOR SEQUENCE (to be completed by the simulator supervisor):

EVENT TIME MAISUNCTION NO. HR: MIN:SEC I/O OVERRIDE DESCRIPTION INTENT 1 00:10:00 MAL No. 46 RCP 1 Trip Reactor Trip 2 00:10:30 MAL No. 48 RCP Shaft Hi Reverse Flow Loop 1 -

3 00:11:00 MAL No. 52A Seal Fails 70 GPM Flow in 5 min.

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FOR INFORiviATiON

. ONLY 2.2 ASSESSMENT f The designated instructor will perform the following duties:

o brief tha operating crew on the scope of the validation and how the assessment will be conducted e brief the operating crew on initial plant conditions for each scenario run o conduct a debriefing with the operators as soon as possible after each scen-ario run using the following sequence:

- brief the participants on the purpose and objectives for debriefing

- using the Simulator Evaluation Form:

a. have operators present problems and discrepancies which they have identified during assessment

b. have operators provide possible reasons for problems

c. present other problems and discrepancies identified during assessment -

d. have operators describe possible reasons for the other problems

e. cummarize the findings of the debriefing for the operators e record discrepancies and comments on the Procedure Discrepancy Sheet (PDS).

2.3 RESOLUTION The designated observer / reviewer will perform the follcwing duties:

o review comments and discrepancies e propose resolutions on PDS for the Nuclear Training Manager e submit the validation package to the Nuclear Training Manager.

The Nuclear Training Manager will perform the following duties:

o review proposed resolutions with appropriate staff a select resolutions for incorporation into the EOPs o present the revised E0Ps to the Nuclear Operations Manager for approval.

3. DOCUMENTATION The following documentation will be submitted with the validation package:

e completed E0P Validation Forms

• Simulator Scenario Forms e PDS forms a. sed '

e Simulator Evaluation Forms Page 15 of 15

FOR INFORMATiO

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- FOR INFORinTiON

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i E0P VALIDATION FORM Page of E0P

Title:

E0P Number: Revision:

Scope of Validation:

Validation Method or Methods to be Used:

- Designated Observer / Reviewer (s):

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r j Preparation Completed on by:

(" by:

Assessment Completed on Operator (s) Involved: Qualification: (SRO, RO, STA) t Resolution Corrpleted on by:

Documentation Package Forwarded on by:

eO Form 1

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FOR INFORiiATION

. ONLY TABLE-10P/ WALK-THROUGH EVALUATION FORM 4

I. USABILITY Y N A. LEVEL OF DETAIL

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

2. Are the alternatives adequately described at each decision point?

3. Are the labeling, abbreviations, and location information as provided in the E0P sufficient to enchle the operator to find the needed equipment?

4. Is the EOP missing information needed to manage the emergency condition?

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5. Are the contingency actions sufficient to address the symptoms?

6. Are the titles and numbers sufficiently descriptive to enable the operator to find referenced and branched procedures?

B. UNDERSTANDABILITY

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l. Is the E0P easy to read?

2. Are the figures and tables easy to read with accuracy?

3. Can the values on figures and charts be easily determined?

4. Are caution and note statements readily understandable?

5. Are the E0P steps readily understandable?

II. OPERATIONAL CORRECTNESS A. PLANT COMPATIBILITY

1. Can the actions specified in the procedure be performed in the designated sequence?

2. Are there alternate success paths that are not included in the EOPs?

3. Can the information from the plant instrumentation bc obtained, as specified in the EOP?

4. 'Is information or equipment not specified in the E0P required to accomplish the task?

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'. Page 1 of 2 Form 3

FOR I FORMATION

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t TABLE-TOP / WALK-THROUGH SCENARIO FORM PROCEDURE NO.:

TITLE:

DATE:

PURPOSE:

SCENARIO DESCRIPTION:

INITIAL PLANT CONDITIONS:

PLANT PARAMETER PROCEDURE STEP SYMPTOM TO TRANSITION TO DESCRIPTION CAUSE TRANSITION (PROCEDURE, STEP) 9 Form 2

- FOR INFORiuTiON

• TABLE-TOP / WALK-THROUGH EVALUATION FORM (continued)

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5. Are the instrument readings and tolerances stated in the E0P consistent with the instrument values displayed on the instru-ments?

6. Is the E0P physically compatible with the work situation (too bulky to hold, binding would not allow them to lay flat in work space, no place to lay the E0Ps down to use)?

7. Are the instrument readings and tolerances specified by the E0P for remotely located instruments accurate?

B. OPERATOR COMPATIBILITY

1. If time intervals are specified, can the procedure action steps be performed on the plant within or at the designated time intervals? ,

2. Can the procedure action steps be performed by the operaung' shift?

3. If specific actions are assigned to individual shif t personnel, does the E0P adequately aid in the coordination of actions among shift personnel where necessary?

4. Can the operating shift follow the designated action step sequences?

5. Can the particular steps or sets of steps be readily located when required?

6. Can procedure exit point be returned to without omitting steps when required?

7. Canprocedurebranchesbeenteredat the correct point?

8. Are E0P exit points specified adequately?

s Page 2 of 2 l Form 3

FOR INFORMATiON

, ONLY SIMULATOR SCENARIO FORM PROCEDURE NO.: REVISION:

TITLE:

DATE:

, PURPOSE:

SCENARIO DESCRIPTION:

C INITIAL PLANT CONDITIONS:

EVENT TIME MALFUNCTION ,

NO. HR: MIN:SEC I/O OVERRIDE DESCRIPTION INTENT 1

• For additional space, use back.

l Form 4 I

FOR INFORisATiON

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SIMULATOR EVALUATION FORM ]

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I. USABILITY Y N A. LEVEL OF DETAIL

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

2. Are the alternatives adequately described at each decision point?

3. Are the labeling, abbreviations, and location information as provided in the E0P sufficient to enable the operator to find the needed equipment?

4. Is the E0P missing information needed to manage the emergency condition?

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5. Are the contingency actions sufficient to address the symptoms?

I 6. Are the titles and numbers sufficiently descriptive to enable the operator to find referenced and branched procedures?

B. UNDERSTANDABILITY

1. Is the E0P easy to read?

+ 2. Are the figures and tables easy to read with accuracy?

3. Can the values on figures and charts be easily determined?

4. Are caution and note statements readily understandable?

, 5. Are the EOP steps readily understandable?

j II. OPERATIONAL CORRECTNESS f A. PLANT COMPATIBILITY

- 1. Can the actions specified in the procedure be performed in the designated sequence?

2. Are there alternate success paths that are not included in the E0Ps?

3. Can the information from the plant instrumentation be obtained, as specified in the E0P?

4. Are the plant symptoms specified by the E0P adeguate to enable the operator to select the applicable E0P?.

5. Are the E0P entry conditions appropriate for the plant symptoms displayed to the operator? Page 1 of 2 Form 5

I- FOR INFORiviATiON ONLY  ;

SDfULATOR EVALUATION FORM (continued)

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6. Is information or equipment not specified in the EOP required to accomplish the task?

7. Do the glant responses agree with the E0P basis?

8. Are the instrument readings and tolerances stated in the E0P consistent with the instrument values displayed on the instruments?

9. Is the E0P physically compatible with the work situation (too bulky to hold, binding would not allow them to lay flat in work space, no place to lay the E0Ps down to use)?

B. OPERATOR COMPATIBILITY

1. If time intervals are specified, can the procedure action steps be performed on the plant irithin or at the designated time intervals?

2. Can the procedure' action steps be performed by the operating shift?

3. If specific actions are assigned to individual shift personnel, does the E0P adequately aid in the coordination of actions among shift personnel where necessary?

4. Can the operating shift follow t,he designated action step

, sequences?

5. Can the particular steps or sets of steps be readily located when required?

6. Can procedure exit point be returned to without omitting steps ,

when required?

7. Can procedure branches be entered at the correct point?

8. Are E0P exit points specified adequately?

Page 2 of 2 Form 5 i

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FOR INFORii4 TION o ONLY PROCEDURE DISCREPANCY SHEET EUP: REVISION: STEP NO.:

DISCREPANCY: (attach a copy of the page where the discrepancy occurs)

EVALUATOR: DATE:

3- RESOLUTION:

SUPERVISOR: DATE:

APPROVED: YES NO (circle one)

NUCLEAR TRAINING MANAGER: DATE:

RESOLUTION INCORPORATED BY: DATE:

Form 6

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