ML20138R460

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Emergency Operating Procedures Verification
ML20138R460
Person / Time
Site: Pilgrim
Issue date: 10/26/1984
From: Mathis C
BOSTON EDISON CO.
To:
Shared Package
ML20138R443 List:
References
PROC-841026, NUDOCS 8512310296
Download: ML20138R460 (13)


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FOR INFORMhiiON ONLY (PIL72-H1)

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OA BOSTON E ison COMPANY NUCLEAR OPERATIONS DEPARTMENT PILGRIM NUCLEAR POWER STATION EMERGENCY OPERATING PROCEDURES VERIFICATION k .

List of Effective Pages All Pages Rev. O Attachments All Pages Rev. 0 3 g ~

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FOR INFORisTiON ,

()NLY l (PIL72-E2)

I. PURPOSE I The purpose of this procedure is to deliniate the administrative pro-cess used in the verification of the Emergency Operating Procedure (EOP's) and to assign responsibilities for carrying out the activities of the process.

II. SCOPE i

This procedure identifies and directs the phases of the verification process.

III. APPLICABILITY This process applies to initial E0P implementation and revisions for Pilgrim Nuclear Power Station.

IV. REFERENCES Pilgrim Nuclear Power Station Writers Cuide for Emergency Operating Procedures.

Pilgrim Nuclear Power Station Emergency Procedure Technical Guide-lines.

E0P Verification Guideline - E0 PIA /INPO, January, 1983.

V. DEFINITIONS Emergency Operating Procedures (EOPs) -

Plant procedures directing operator actions necessary to mitigate the consequences of transients and accidents that cause plant parameters to exceed reactor protection ,

system setpoints, engineered safety features setpoints, or other tech-nical limits.

Emergency Operating Procedures Guidelines (EPGs) - Guidelines that pro-vide sound technical bases for the development of E0Ps, specific for PNPS developed from generic BWR EPGs.

EOP Source Documents - Fundamental documents or records upon which E0Ps are based.

E0P Technical Accuracy - Proper incorporation of plant-specific techni-cal information from E0P source documents and plant hardware into E0Ps.

E0P Verification - The evaluation performed to confirm the written cor-rectness of the E0Ps and to ensure that the plant-specific technical aspects have been incorporated properly.

E0P Written Correctness - Proper incorporation of information from the PilgrLa Nuclear Power Station Writers Guide for E0Ps into the E0Ps.

Symptoms - Displayed plant characteristics that directly or indirectly indicate plant status.

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FOR INi'ORiit4 TION ONI.Y (PIL72-H3)

( VI. RESPONSIBILITIES A. Chief Technical Engineer - The Chief Technical Engineer shall have overall responsibility for the E0P verification process. He shall determine when E0P verification is needed and its scope. He shall approve the discrepancy resolutions and assure that source documents are revised as applicable.

B. Evaluator - The E0P Evaluator is responsible for performing the de-tailed evaluation of the E0Ps per this procedure and for determining resolutions to discrepancies identified during the verification process.

VII. E0P VERIFICATION PROCESS The process of E0P verification consists of four phases: preparation, verification, resolution and documentation.

A. Preparation Phase .

The Preparation Phase consists of the following activities:

Designate personnel to conduct the verification Obtain and review the E0P source documents

1. Designate Personnel The Chief Technical Engineer shall ' appoint the necessary per-acr.r.cl c: e raluators to conduct the verifications. Personnel should be appointed based on operating experience and under-standing of plant hardware, the EPG's and the writers guide.
2. Obtain and Review the E0P Source Documents The , sting of E0P source documents is provided on Attachment B1, and shall be reviewed by the personnel conducting the veri-fication phase. These documents shall be reviewed to ensure they are complete, current, applicable and approved. Any ad-ditional applicable source documents shall be listed.

B. Verification Phase In the verific.ation phase the evaluator shall:

1. Make a gCaeral review of the E0P using the procedure-general portion of the evaluation criteria, Attachment D,Section I, and the source documents.
2. Indicate on Attachment B1 that the evaluation was performed, either by checking the acceptable column or by designating the appropriate discrepancy sheet for any discrepancies identified. l 3 of 4 Rev. 0 l

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I 3. Make a step-by-step review of the E0P using the step-caution-note-specific portion of the evaluation criteria, Attachment D,Section II, and the source documents. -

4. Indicate for each step, on Attachment B2, that the evaluation was performed, either by checking the acceptable column or by designating the appropriate discrepancy sheet for any discre-pancies identified.
5. Document discrepancies for each step and determine the resolu-tion for any discrepancies identified on Attachment C.
6. Complete Attachment A and forward the verification forms with the discrepancy sheets to the Chief Technical Engineer.

C. Resolution Phase In the resolution phase, the Chief Technical Engineer shall:

1. Review the evaluator's comments and approve the resolutions by signing in the appropriate space on Attachment C.
2. Ensure the applicable source documents and procedures are up-dated with approved resolutions and signing the verification fo rms .

( D. Documentation Phase The documentation developed throughout the process shall be main-tained according to procedures 1.3.7, Records, and 1.3.8, Document Control.

VIII. ATTACHMENTS A. E0P Verification Form-General B. E0P Verification Form-Specific C. E0P Verification Form-Discrepancy Sheet Number D. Evaluation Criteria Checklist E. PNPS Emergency Procedure Guidelines (EPGs)

F. Appendix to PNPS Emergency Procedure Guidelines (EPGs) 4 of 4 Rev. O l _ ._ _ _ .

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FOR INFORivikTiON (PIL72-H5)

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ATTACHMENT A E0P VERIFICATION FORM .

Verification Completion Date:

Performed by:

All actions required by the verification have been completed and approved.

Date:

E0Ps Verified:

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ATTACHMENT B-1 E0P VERIFICATION FORM E0P TITLE:

E0P NUMBER: REVISION:

SCOPE OF VERIFICATION:

E0P SOURCE DOCUMENTS USED:

1. 5.
2. 6.
3. 7.
4. 8.

EVALUATORS:

PROCEDURE-GENERAL VERIFICATION

(- Written Correctness AREAS ACCEPTABLE DISCREPANCY SHEET #(S)

LEGIBILITY E0P FORMAT CONSISTENCY IDENTIFICATION INFORMATION .

Technical Accuracy AREAS ACCEPTABLE DISCREPANCY SHEET #(S)

ENTRY CONDITIONS OR SYMPTOMS INFORMATION B 1 of 2 Rev. O

FOR INFORinT (PIL72-H7)

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ATTACHMENT B2 Page OF STEP, CAUTION, NOTE-SPECIFIC VERIFICATION ,

STEP NUMBER, WRITTEN CORRECTNESS TECHNICAL ACCURACY CAUTION OR NOTE ACCEPTABLE DISCREPANCY ACCEPTABLE DISCREPANCY SHEET # SHEET #

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FOR INFORMATION ;

ONLY (PIL72-H8) i' I ATTACHMENT C E0P VERIFICATION FORM -

DISCREPANCY SHEET NUMBER Procedure and Step Number:

Discrepancy:

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l Resolution:

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l Evaluator: Date:

Approved Yes No (Circle one)

Chief Technical Engineer: Dates

, , Resolution Incorporated By: Date:

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FOR INFORMATiON

- 1 ONLY (PIL72-H9) i l ATTACHMENT D EVALUATION CRITERIA CHECKLIST -

AREA REFERENCE

I. PROCEDURE

-GENERAL A. Written Correctness

! 1. Legibility

a. Are the text, tables, graphs, figures, WG VI.C, VI.F, and charts legible to the evaluator? IV.I
b. If pages are rotated they comply with WG VI.E the following:

(1) The top of the page with rotated print is the normal left-hand edge (2) The page margins do not rotate (3) Page identification and numbering will not be rotated

2. E0P Format Consistency h a. Do the following sections exist in each E0P: WG III.B 4

Section I - PURPOSE Section II - ENTRY CONDITION Section III - OPERATOR ACTIONS Section 'IV - DISCUSSION Section V - ATTACHMENTS

b. Is the operator actions section presented in WG III.A single - column format on each page?
c. Is the page layout consistent with the sample WG III.A, page formats? WG ATTACHMENT A
d. When logic sequence diagrams are used do they WG IV.A(3),

consist of the proper logic symbols? WG ATTACHMENT A, Page 4.

3. Identification Information
a. Is the procedure title descriptive of WG.II.A

! the purpose of the procedure?

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b. Does the cover sheet correctly provide WGII.A, II.B, the following: II.C, II.D (1) Procedure title (2) Procedure number (3) Revision number (4) List of effective pages
c. Does each page correctly provide the WG II.E, IV.I(3) following:

I (1) Procedure designator (2) Revision number (3) Page of numbers 1

d. Does the procedure have all its pages in the correct order?

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, B. Technical Accuracy

1. Entry Conditions or Symptoms Information l a. Are the entry conditins of the E0P PNPS PSTG listed correctly?

( b. If additional entry conditions have been added, do they comply with the following:

(1) Appropriate entry conditions for WG III.B

. which the E0P should be used.

(2) Not excessive. WG III.B I

II. STEP, CAUTION, NOTE-SPECIFIC A. Written Correctness i

1. Information Presentation
a. Are instruction sections numbered correctly? WG III.C I
b. Are instruction steps numbered correctly? WG III.D
c. Are operator contingency actions identified? WG IV.A(2)
d. Are instruction steps constructed to comply t with the following:

(1) Steps deal with only ane action or WG.IV.A reaction. '

(2) Sentences are short a0d simple WG.IV.A t

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(3) Complex evolutions are prescribed in WG IV.A a series of steps, each step as simple -

as practicable.

(4) Objects of operator actions are speci- WG IV.A fically stated.

(5) Expected indications are presented WG IV A(1)

(6) Operator actions are appropriate for WG IV A(1) the expected indications.

(7) When anticipated system response may WG IV.A adversely affect instrument indicators, are the conditions described that will likely introduce instrument error and means of determining if instrument error has occurred, by using a NOTE or when considered critical, a CAUTION.

(8) When additional confirmation of system WG IV.A response is considered necessary, are the available and expected backup readings

to be made prescribed?

' (9) Instructional steps that involve an WG IV.A action verb relating to three or more objects are listed with space provided i for operator checkoff.

(10) Punctuation, capitalization and hyphena- WG VB, VC,

(\ tion are proper. IV.I(2)

(11) Abbreviations are correct and under- WG V.F standable to the operator.

i e. Do instruction steps make proper use of WG IV.B i logic structure?

f. When an action instruction is based on WG IV.A receipt of an annunciator alarm, is the setpoint of the alarm identified?

j g. Are notes and cautions placed properly? WG IV.C 1

h. Are notes and cautions used appropriately? WG IV.C

? i .- Are cautions and noter constructed to comply with the following:

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(1) They do not contain operator actions. WG IV.C (2) They make proper use of emphasis. WG IV.E, VI.G

j. Are numerical values properly written? WG V.E
k. Are values specified in such a way that WG V.E mathematical operations are not required of the user? '
l. Are units of measurement in the E0P the WG V.E same as those used on equipment?

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FOR INFORisiiON ONLY (PIL72-H12)

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m. Are units of measure on figures, tables, WG IV.I(1) and attachments given for numerical values -

which present observed measurement data or calculating results?

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2. Procedure Referencing and Branching
a. Do the referenced and branched procedures WG IV.F identified in the E0Ps exist for operator use?
b. Is the use of referencing steps minimized? WG IV.F
c. Are referencing and branching instructions WG IV.F correctly worded using the key words "go to",

" EXECUTE PROCEDURE", or " ENTER Procedure"?

d. When only a few steps are involved in the WG IV.F referencing are they stated in the procedure wherever they are needed?
e. Are the exit conditions compatable with the i entry conditions of the referenced or branched procedure?

( f. Do the instructions avoid routing users past important information such as cautions pre-ceeding steps?

B. TECHNICAL ACCURACY

1. Instruction Step, Caution, and Note Information
a. Is the EPG technical foundation (strategy) changed by any of the following changes in E0P steps, cautions, or notes:

(1) Elimination (2) Addition (3) Sequence (4) Alteration

b. Are correct plant-specific adaptations WG IV.G, IV.H incorporated per PNPS PSTG:

(1) Syst.c.ss (2) Instriaentation (3) Limits (4) Controis (5) Indications i

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2. Quantitative Information 3
a. Do the quantitative values, including  ;

tolerance bands, used in the E0P comply '

with the applicable E0P source documents?

b. Where PSTG values are not used in the E0P, are the E0P values computed ac-curately?
c. When calculationa are required by the E0P, are equations presented with suf-  ;

ficient information for operator use?  !

3. Plant Hardware Information
a. Is the plant hardware specified in the E0P available for operator use:

(1) Equipment (2) Controls (3) Indicators (4) Instrumentation L

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