ML20196J235
| ML20196J235 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Oconee, Arkansas Nuclear, Three Mile Island, Crystal River  |
| Issue date: | 06/29/1999 |
| From: | Birmingham J NRC (Affiliation Not Assigned) |
| To: | Carpenter C NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9907070200 | |
| Download: ML20196J235 (29) | |
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j UNITED STATES NUCLEAR REGULATORY COMMISSION t WASHINGTON, D.C. 30006-0001
\ ***,+/ June 29,1999 MEMORANDUM TO: Cynthia Carpenter, Chief Generic issues, Environmental, Financial and Rulemaking Branch Division of Regulatory Improvement Programs
' Office of Nuclear Reactor Regulation FROM: Joseph L. Birmingham, Project ManagerM Generic issues, Environmental, Financiarand Rulemaking Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JUNE 17,1999 MEETING WITH THE BABCOCK &
7 WILCOX OWNERS GROUP TO DISCUSS EMERGENCY OPERATING PROCEDURE (EOP) INSPECTIONS On June 17,1999, representatives of the Babcock and Wilcox Owners Group (B&WOG) and Framatome Technologies, Inc. (FTI) met with members of the Nuclear Regulatory Commission (NRC) to discuss the B&WOG EOP program. The B&WOG began by referring to the recent NRC inspection of EOPs at Crystal River-3 which had resulted in several NRC open items, '
B&WOG then described its actions taken to improve the EOP program. Areas of improvement included (1) increased similarity of EOP programs at B&WOG sites, (2) improved process control and monitoring, (3) consistent implementation expectations, and (4) arranging for independent assessment of the EOP programs. The B&WOG discussed with the NRC significant differences in the way their EOP program is arranged conpared to other Owners Groups. The differences occurred primarily because of the manner in which the documentation
, : for their program evolved.. The B&WOG then discussed some proposed actions they believed would make inspection of their program easier and also more effective. These actions included it changes to NRC Inspection Procedure IP 42001, " Emergency Operating Procedures." \
The NRC and B&WOG discussed in detail the changes to the EOP program that had been implemented or were being implemented. A key item discussed was the B&WOG Technical ^y
! Basis Document (TBD). This document consists of three volumes. Volume 1 is a mitigation 60 l 4 guideline that provides an organization of vendor preferred options but is not a procedure r " template. Volume 2 provides the bases of Volume 1 actions. Volume 3 is a compilation of
- vendor approved options. From the meeting discussion, NRC understands that Davis Besse,
. . Three Mile Island, and Crystal River use Volume 1 of the Technical Basis Document as the reference emergency procedure guideline (EPG) for plant-specific EPGs and EOPs, and that 1 documentation establishing plant-specific deviations is based upon Volume 1. We also understand that Arkansas Nuclear One (Unit 1) and Oconee will use Volume 1 as the reference O : EPG following publication of TBD Revision 9.
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There was some discussion of using only Volume 3 as the reference. NRC explained that by using only Volume 3, important aspects of sequence and timing that are captured by referencing 4 Volume 1 could be missed. The NRC mentioned that referencing all three volumes may be i acceptable for the upcoming inspection at Oconee.
Regarding the recommended changes to IP 42001, the staff indicated that a revision of the procedure was not expected for some time. The staff believes that revising the procedure is not d necessary at this time because inspections of EOP programs are not performed to the procedure on a verbatim basis and because material, such as the information B&WOG
- presented during the meeting, is also used. ,
A list of meeting attendees is in Attachment 1 and the slides presented during the meeting are in Attachment 2.
Attachments: As stated cc w/atts:
Mr. M. Kelly, Manager - Mr. W. R. McCollum, Site Vice President Florida Power Corporation . Oconee Site 8200 West Venable - Duke Energy Corporation Crystal River, Florida - 7800 Rochester Hwy. l Seneca, SC 29672 ' l I
Mr. Michael Schoppman, Manager B&WOG Licensing Operations Framatome Technologies, Inc.
1700 Rockville Pike, Suite 525 Rockville, MD 20852-1631.
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- m C. Carpenter - -2 June 29, 1999 l
There was some discussion of using only Volume 3 as the reference. NRC explained that by using only Volume 3, important aspects of sequence and timing that are captured by referencing Volume 1 could be missed. The NRC mentioned that referencing all three volumes may be acceptable for the upcoming inspection at Oconee.
Regarding the recommended changes to IP 42001, the staff indicated that a revision of the .
procedure was not expected for some time. The staff believes that revising the procedure is not necessary at this time because inspections of EOP programs are not performed to the procedure on a verbatim basis and because material, such as the information B&WOG l presented during the meeting, is also used. .
l A list of meeting attendees is in Attachment 1 a'nd the slides presented during the meeting are in Attachment 2.
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Attachments: As stated '
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l Mr. M. Kelly, Manager Mr. W. R. McCollum, Site Vice President Florida Power Corporation Oconee Site 8200 West Venable - Duke Energy Corporation Crystal River, Florida l 7800 Rochester Hwy.
l Seneca,~ SC 29672 Mr. Michael Schoppman, Manager
B&WOG Licensing Operations Framatome Technologies, Inc.
- 1700 Rockville Pike, Suite 525 i Rockville, MD 20852-1631 -
Distribution:
Hardcoov w/att Email Public. D. Matthews F. Akstulewicz J. Donohew Central files C. Carpenter W. Rogers PGEB R/F K. Laadis J. Birmingham l W. Landis Warren Lyon D. LaBarge D. Trimble - R. Pelton R. Schin
- See Previous Concurrences DOCUMENT NAME:g:\ jib \bwog617a.wpd OFFICE RGEB RGEB* C:RGEB*
l NAME- JBirmingham:sw FAkstulewicz CCarpenter 1
DATE 06/14/99 06/24/99 06/24/99 OFFICIAL RECORD COPY
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Attendees for B&WOG Meeting with NRC June 17,1999 l NAME ORGANIZATION William R. McCollum Duke Power, Oconee William McIntyre Duke Power, Oconee i Anthony Stallard First Energy, Davis Besse l
William Heysek GPU Nuclear i Mark Goecke Entergy, Arkansas Nuclear 1 Mike Kelly Florida Power Corporation, OSC Chairman Rick Edwards Framatome Technologies, Inc. (Framatome)
Mike Schoppman" Framatorne 1
Brent Brooks Framatome Ron Dorman Framatome Warren Lyon NRC Joseph Birmingham NRC-David LaBarge NPC, Oconee PM ;
! Walt Rogers NHC !
David Trimble NRC !
Rick Pelton NRC i
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V NRC INSPECTION MANUAL LHFB INSPECTION PROCEDURE 42001 EMERGENCY OPERATING PROCEDURES l
l PROGRAM APPLICABILITY: 2515 42001-011NSPECT10N OBJECTIVES 01.01 To follow up on inspection issues, events, or allegations conceming the licensee's Emergency Operating Procedure (EOP) Program.
01.02 To determine whether significant changes to the licensee's E0Ps since the last inspection meet commitments and regulatory requirements.
01.03 To assess the impact of the changes to the licensee's EOPs on the licensee's E0P program and
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overall plant safety.
42001-021NSPECTION REQUIREMENTS 02.01 Review of EOPs and Sucoortina Procedures
- a. Conduct an in-depth human factors adequacy review of EOPs where significant human factors changes have been made,
- b. Where significant changes have been made, verify that the procedures are technically correct and accurately it.::orporate the most recent owner's group generic technical guidance and that any deviation (s) warranted by the plant-specific design are adequately justified and incorporated into the EOPs as required. For B&W designs, verify that EOPs fully accomplish the mitigative strategies and priorities defined in the B&WOG Emergency Operating Procedure Technical Basis Document and that any deviation (s) are adequately justified and incorporated into the EOPs as required.
- c. Verify that entry and exit points are easily followed, and that transitions between and within the Normal Operating, Alarm and Abnormal Operating Procedures and E0Ps are appropriate, well defined, and easy to follow.
(p) d. Evaluate the procedures and the licensee writer's guide relative to significant human factors issues raised by changes to structure and format.
Issue Date: 06/28/91 42001
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... e. Determine the extent of deviations in the procedures from the current licensee writer's guide and evaluate the licensee's justification for the deviations.
- f. Evaluate decision points in the procedures to determine if bley can be easily discriminated and understood.
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- g. Venfy that the use of notes and cautions is consistent and correct in the procedures.
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02.02 Use of E0Ps and Supportina Procedures. Where significant changes have been made, verify that the EOPs and supporSng procedures can be physically and correctly performed both inside and outside the controlroomsincluding simulatorexercisesif appropriate.
02.03 Knowledae and Performance of Duties
- a. Verify that the control room staff is aware of and understands all significant changes to the EOPs.
- b. Verify that operators receive training on revised E0Ps before the revised EOPs are implemented, j c, Evaluate operator concems regarding the EOPs.
02.04 Review of l.icensee E0P Proarammatic Controls
- a. Verify that the licensee's administrative procedures adequately govem the program for controlling changes to the E0Ps, the supporting procedures and associated operator training.
- b. Verify that the licensee's documentation reflects adequate conduct of activities required by administrative procedures that control the E0Ps, and that E0P changes are incorporated, as appropriate, into the licensee's operator training program.
- c. Verify that the licensee's staff possesses the required understanding of administrative procedures goveming E0Ps and correctly implements them.
C') d. Verify that the licensee conducts independent audits of the EOP program, as required, and has V provisions for document control that are commensurate with NRC requirements, including facility licensing requirements.
02.05 Follow-up of Licensee Corrective Actions involvina E0Ps
- a. Verify that the licensee's documentation identifies and prioritizes E0P weaknesses and that timely corrective actions are implemented.
- b. Evaluate the effectiveness of the licensee's corrective actions by control room and in-plant walkdowns, simulator scenarios, and plant staff interviews as applicable.
42001-031NSPECTION GUIDANCE General Guidance. This procedure is intended primarily for use in implementing regional discretionary resources for Regional Initiatives or Reactive inspection to inspect the significant changes to the licensee's EOPs and associated programs. These inspection activities include the examination of licensee programs to follow up on corrective actions, to review programmatic controls, and to follow up on identified issues requiring licensee resolution relative to E0P program deficiencies, weaknesses, or implementation.
This procedure is also intended for use in conjunction with NRC Manual Chapter 0517, " Management of
- Allegations," to examine elements of the licensee's E0P Program as appropriate to follow up on allegations J conceming the program. It is not intended that each inspection requirement be covered during an inspection.
Issue Date: 06/28/91 42001
U Rath:r, inspection requirements should be selected or modified, as appropriate, to address the issue or event that prompted the inspection. Preparation for the inspection should include a review of issues identified during previous inspections or operator licensing examination reports that would be indicative of weaknesses l in the EOP Program.jolicy, or imp lementation. Significant events with a root cause related to EOPs should '
O also be reviewed in preparation for inspection. During onsite inspection, all major changes, including those V related to the resolution of identified issues, the bases for the changes, and the effect of the changes on program effectiveness, should be discussed by the team leader with licensee management.
By reference to the-appropriate revision of Regulatory Guide 1.33," Quality Assurance Program l Requirements," Section 6.8 of the Standard Technical Specifications requires that Emergency Operating Procedures be established, implemented, and maintained. In addition, the licensee should review the EOPs l
i to evaluate the safety review functions and the responsibilities of the onsite safety review organization.
Further,10 CFR 50 Appendix B, Criterion VI, requires that quality related documents, and changes thereto, be reviewed for adequacy and approved for release by authorized personnel. In general, technical inadequacies or failures to properly implement and maintain EOPs are violations of these requirements.
The NRC evaluates the owner's group Generic Technical Guidelines (GTGs) for safety. Where licensees elect to deviate from the NRC-approved GTGs, they need to implement correctly the 10 CFR 50.59 process to ensure safe plant operation, particularly for design basis events. Insufficient or incorrect use of the 10 CFR 50.59 process to evaluate deviations from the NRC-approved GTGs may constitute a violation. The NRC has reviewed the B&WOG EOP Technical Basis Document (TBD) as a body of generic vendor-preferred EOP guidance for the B&WOG licensees. The TBD is a product of formal B&WOG commitments to close open items on the initial SER of B&WOG EOP guidance. Therefore, the TBD shall be used as the reference basis for E0P inspections of B&WOG licensees. The TBD includes, as Volume 1, the B&WOG Generic Emergency Operating Guidelines (GEOG) which provides an example of the TBD mitigation strategies and prionties to be used for the B&W design plant.
i Y Specific Guidance 03.01 Review of EOPs
- a. The review for human factors adequacy determines whether the EOPs are adequate for the intended use and confirms that application of human factors considerations from the plant specific writers guide incorporates the guidance of the GTGs, or for B&WOG licensees, effectively supports and implements the mitigative strategies and priorities established in the TBD. Plant staff inter ws should be conducted with cognizant licensee personnel to further confirm this assessment..
Significant changes to the E0Ps and supporting procedures should be reviewed by inspectors with experience in human factors evaluatior.. See NUREG-0899, NUREG-1358 and NUREG/CR-5228.
See Section 42001-05 of this procedure for full reference.
- b. Operator cornments on the technical aspects of significant changes to the EOPs, given during interviews with the plant staff, procedure walkdowns, and simulator exercises, should be evaluated and addressed in the inspector's EOP technical adequacy review. Particular attention should be given to the following:
i 1. Comparison of the GTG table of contents to the table of contents of plant-specific E0Ps and evaluation of the differences. For B&W designs, a one-to-one match is not required, but the same general mitigative philosophies should be employed.
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- 2. Review of licensee documentation addressing the development of plant EOPs from GTGs.
42001 Issue Date: 06/28/91 L
v For B&W designs, review of licensee documentation addressing the development of plant E0Ps from the TBD.
- 3. EvaIuation of the responses to questions from interviews with cognizant keensee personel about the incorporation of GTGs into the EOPs, or for B&W designs, incorporation of TBD (V9 mitigation strategies and priorities into the EOPs.
- 4. Verification that the licensee has an appropriately prioritized accident mitigation strategies in the procedures and that recommended GTG step sequences are followed. For B&W designs, this criterion is satisfied by verification that the licensee has appropriately prioritized accident mitigation strategies in the EOPs based on TBD priorities and, where the GEOG identifies a specific step sequence as significant to the mitigation strategy, that such step sequences are maintained or are otherwise identified and justified.
- 5. Verification that the licensee has an adequate technicaljustification for identified saftey significant deviations between the plant-specific EOPs and the generic technical guidelines or GEOG. For B&W designs, differences which do not alter the TBD mitigation strategy or priorities are not safety significant. See Generic Letter 82-33. Full reference may be found in Section 42001-05 of this procedure.
- 6. Assessment of the safety significance ofidentified deviations. A sample of deviations should be examined to determine if the licensee has reported safety significant deviations, determined to constitute unreviewed safety questions, to the NRC. These deviations should be venfied to be in accordance with 10 CFR 50.59.
- c. The use of walkthroughs and simulator scenarios provides a practical means to verify that the procedures are well defined and easy to follow for entry and exit points and for transitions.
- d. For specific program guidance, see NUREG-0899, NUREG-1358, and NUREG/CR-5228.
- e. Significant deviations from the licensee's wnter's guide for the EOPs should be reviewed for adequacy. A significant number of minor deviations should raise questions about the consistency of EOP structure.
- f. A newly qualified operator should be able to properly implement the decision points in the E0Ps without needing further guidance. The logic points should have clear questions that solicit yes or no answers. See NUREG-0899, NUREG-1358, and NUREG/CR-5228.
- g. The caution statements should identify potential hazards, and the notes and caution statements should not contain action statements. See NUREG-0899, NUREG-1358 and NUREG/CR-5228.
03.02 Use of EOPs and Supportino Procedures. Where major changes have been made or concems have been previously identified, walkdowns, simulator exercises on E0Ps and supporting procedures and interviews with plant staff should be conducted. Focus on whether,
- a. The changes made to the procedures can be physically implemented and whether operators physically interfere with each other while performing the changed proceNres.
- b. The changed procedures can be implemented within the time allotted considering the actual accident, the course of events, and the availability of the necessary operating locations involved l Issue Date: 06/28/91 42001 1
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under those ccnditions.
- c. Environmental conditions (such as temperature, steam, flooding, and radiological hazards) that l would exisfBuring the event would prevent items 03.02a. and 03.02b. above from being p accomplished.
l V l d. Plant personnel can effectively use the EOPs and supporting procedures in the control room and
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other parts of the plant as necessary. An evaluation of the consistency of instrument and control designations as compared with installed equipment labels and procedural descriptions should be included. Also, the indicators, annunciators, and controls referenced in the procedures are available to the operators,
- e. EOP activities that would occur outside of the control room can be performed with equipment on hand.
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- f. The licensee has vaiidated and verified the procedures. A documented, comprehensive review should have been conducted by an independent, multidisciplinary team, including a human factors analysis of the procedural changes and a walkdown of the procedures in the plant. See NUREG-1358, NUREGICR 2005, and NUREG-3632 which are fully referenced in Section 42001-05 !
of this procedure.
- g. The latest revision to the procedures is in the control room, the Technical Support Center, and the !
Emergency Operation Facility.
03.03 Knowledae and Performance of Duties O a. The control room staff should understand how to perform the current EOPs. To determine whether b the operators are aware of recent changes to the EOPs and understand the changes, limited plant-specific simulator scenarios should be conducted on at least one fully staffed shift crew. The ,
simulator scenario should reflect relevant abnormal operating conditions that require the use of two or more of the E0Ps in which significant changes have been made. Each procedural step should be observed to determine that the correct procedures are used with proper transitions, and that each step is correctly implemented. Where concems are identified, the . sample size should be i expanded. Walkdowns should be conducted to further assess the operator's understanding of the EOPs, the supporting procedures, and recent changes to the procedures. During the control room and in-plant walkdowns direct observation should be made of selected operators in the simulated performance of selected tasks required by the EOPs. Such tasks include simulated handling of equipment, interpretation of instrument readings, following procedures, proper sequencing of actions, and an understanding of information flow pattems related to a specific task.
Plant-referenced simulators, as required by 10 CFR 55.45 should be used for walkdowns to allow hands-on performance for certain tasks. See SECY 90-337 which is fully referenced in Section 420014)5 of this procedure.
- b. EOP training is covered under Inspection Procedure 41500.
- c. Operator concems regarding the EOPs may be identified by the review of inspection reports, operator licensing examination reports, operator responses to licensee training, procedural review documentation, Licensee Event Reports (LERs), discussions with the Resident inspectors, and 77 interviews with operators. Operators' concems may be evaluated by EOP desktop reviews, U procedure walkdowns, and simulator exercises.
42001 Issue Date: 06/28/91 l
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'. 03.04 Review of Licensee EOP Praarammatic Controls
- a. The license 6's administrative procedures should provide controls to ensure that all changes such as r3 changes to the Technical Specifications, setpoints, and those resulting from instrument and b equipment modifications, are reflected in a timely manner, in the EOPs, the setpoint documents, and the operator training lesson plans. An active licensee program should provide for the long-term
- evaluation of EOPs as recommended in Section 6.2.3 of NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures." The licensee's E0P evaluation program should be technically adequate and the EOPs should be structured to incorporate operational experience and use, training experience, simulator exercises, control room and in-plant walkdowns and changes in plant design, technical specifications, technical guidelines, Writer's Guide, or other plant procedures. (See Regulatory Guide 1.33, Rev 2. which is fully referenced in Section 42001-05 of this procedure).
- b. No guidanceis necessary.
- c. Interview the licensee's staff and management involved in the performance of administrative procedures goveming EOPs to determine if they understand the procedures and if the procedures are implemented consistently among users.
- d. See NUREG-1358.
03.05 Follow-up of Licensee Corrective Actions with Reaard to EOP Concems. No guidance is necessary.
/N U 42001-04 RESOURCE ESTIMATES For planning purposes, direct inspection effort to accomplish this procedure should be established by the Regional office, consistent with the scope of planned regional initiatives or reactive inspections to be performed. Individuals having experience in evaluating human factors should accomplish the parts of the inspection that deal with human factors issues. Direct inspection effort for reactive inspection or regional initiatives should be recorded on RITS against inspection Procedure 42001. If the procedure is used to follow up allegations in conjunction with NRC Manual Chapter 517, the actual time expended should be recorded on RITS against BJ1.
42001-05 REFERENCES 10 CFR Part 50, Appendix B, Criteria V and VI.
10 CFR 50.54(x) and (y).
10 CFR Part 2, Appendix C, Criterion VI.
10 CFR 50.34(f)(2)(ii)and (v).
Issue Date: 06/28/91 42001
Site-Specific Technical Specifications, Chapter 6.
Generic Letter 82-33, " Supplement 1 to NUREG - 0737, Requirements for Emergency Response Capability,"
December 17,1982. (NUDOCS Fiche Address 16681/208)
SECY-90-337,' Procedural Adherence Requirements," October 3,1990. (NUDOCS Fiche Address ,
70497/142) :
Regulatory Guide 1.33, Rev.2, " Quality Assurance Program Requirements (Operation)," 1978. (NUDOCS l
Fiche Address 00125/155)
NUREG-1358, " Lessons Leamed From the Special Inspecton Program for Emergency Operating
. Procedures," April 1989. (NUDOCS Fiche Address 49726/209)
NUREG-1977, " Guidelines for Preparing Emergency Procedures for Nuclear Power Plants," April,1981.
(NUDOCS Fiche Address 08514/008) 1
[ NUREG/CR-4613, " Evaluation of Nuclear Power Plant Operating Procedures Classifications and Interfaces,"
l February 29,1987. (NUDOCS Fiche Address 39983 /256)
NUREG/CR-3632, " Methods for implementing Revisions to Emergency Operating Procedures," May 1984.
(NUDOCS Fiche Address 24534/208)
NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures," August 1982.
1 (NUDOCS Fiche Address 15513/286)
NUREG/CR-2005, Rev.1, " Checklist for Evaluation Emergency Operating Procedures Used in Nuclear Power Plants," April 1983. (NUDOCS Fiche Address 08790/355)
NUREG/CR 3177, Vols.1,2, and 3, ' Methods for Review and Evaluation of Emergency Procedure Guidelines," March 1983. (NUDOCS Fiche Address 21119/138,17803/033, and 17862/227)
NUREG/CR-5228, " Techniques for Preparing Flowchart-Format Emergency Operating Procedures," January l 1989. (NUDOCS Fiche Address 4%70/141)
' " Supplement 3, Safety Evaluation for CEN-152, ' Combustion Engineering Emergency Procedure Guidelines,"
November 5,1986.
" Combustion Engineering Emergency Procedure Guidelines,' Submittal 2 of Revision 3, August 6,1986.
" Supplement Safety Evaluation Report for ' Westinghouse Owners Group Emergency Response Guidelines, ,
Revision 1," July 7,1%6.' )
l
" Westinghouse Owners Group Emergency Response Guidelines, Revision 1," November 30,1983.
" Safety Evaluation of 'BWR Owners Group Emergency Procedure Guidelines, Revision 4, March 1987,"
42001 Issue Date: 06/28/91 ;
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7; .-
NEDO 31331, August 1,1988.
"BWR Emergency Procedure Guidelines, Revision 4," March 1987.
B&W Owners Group Emergency Operating Procedures Technical Basis Document.
, END O
O Issue Date: 06/28/91 42001 t
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NRC INSPECTION MANUAL LHFB INSPECTION PROCEDURE 42001 EMERGENCY OPERATING PROCEDURES PROGRAM APPLICABILITY: 2515 42001-011NSPECTl0N OBJECTIVES 01.01 To follow up on inspection issues, events, or allegations conceming the licensee's Emergency Operating Procedure (EOP) Program.
01.02 To determine whether significant changes to the licensee's EOPs since the last inspection meet commitments and regulatory requirements.
(~3 01.03 To assess the impact of the changes to the licensee's EOPs on the licensee's EOP program and :
() overall plant safety.
42001-021NSPECTl0N REQUIREMENTS 02.01 Review of EOPs and Supportina Procedures j l
- a. Conduct an indepth human factors adequacy review of E0Ps where significant human factors l changes have been made. I
- b. Where significant changes have been made, verify that the procedures are technically correct and accurately incorporate the most recent owner's group generic technical guidance and that any l deviation (s) warranted by the plant-specific design are adequately justified and incorporated into the {
E0Ps as required. For B&W desians. verify that EOPs fully accomplish the mitiaative strateales i
and oriorities defined in the B&WOG Emeraency Operatina Procedure Technical Basis Document j and that any deviation (s) are adeauately justified and incorporated into the E0Ps as reauired.
- c. Verify that entry and exit points are easily followed, and that transitions between and within the l Normal Operating, Alarm and Abnormal Operating Procedures and EOPs are appropriate, well !
defined, and easy to follow.
(~] d. Evaluate the procedures and the licensee writer's guide relative to significant human factors issues V raised by changes to structure and format.
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...- e/ Determine the extent of deviations in the procedures from the current 1;censee writer's guide and evaluate the licensee's justification for the deviations, j
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j f.. Evaluate decision points in the procedures to determine if they can be easily discriminated and O- understood, I
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l 9 Vuify that the use of notes and cautions is consistent and correct in the procedures.
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02.02 . Use of EOPs and Suocortina Procedures. Where significant changes have been made, verify that the E0Ps and supporting procedures can be physically and correctly performed both inside and outside the 8
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l LJ control rooms including simulator exercises if appropriate. I 02.03 Knowledae and Performance of Duties
- a. Verify that the control room staff is aware of and understands all significant changes to the E0Ps. l
- b. Verify that operators receive training on revised E0Ps before the revised EOPs are implemented.
- c. Evaluate operator concems regarding the E0Ps.
02.04 Review of Licensee E0P Proarammatic Controls
- a. Verify that the licensee's administrative procedures adequately govem the program for controlling i changes to the E0Ps, the supporting procedures and associated operator training.
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- b. Verify that the licensee's documentation reflects adequate conduct of activities required by administrative procedures that control the E0Ps, and that E0P changes are incorporated, as i appropriate, into the licensee's operator training program.
- c. Verify that the licensee's staff possesses the required understanding of administrative procedures goveming EOPs and correctly implements them.
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- d. Verify that the licensee conducts independent audits of the EOP program, as required, and has provisions for document control that are commensurate with NRC requirements, including facility licensing requirements.
02.05 Follow-up of Licensee Corrective Actions involvino E0Ps
- a. Verify that the licensee's documentation identifies and prioritizes EOP weaknesses and that timely corrective actions are implemented.
- b. Evaluate the effectiveness of the licensee's corrective actions by control room and in-plant walkdowns, simulator scenarios, and plant staff interviews as applicable.
42001-031NSPECT10N GUIDANCE General Guidance. This procedure is intended primarily for use in implementing regional discretionary resources for Regional Initiatives or Reactive Inspection to inspect the significant changes to the licensee's EOPs and associated programs. These inspection activities include the examination of licensee programs to follow up on corrective actions, to review programmatic controls, and to follow up on identified issues requiring licensee resolution relative to EOP program deficiencies, weaknesses, or implementation.
This procedure is also intended for use in conjunction with NRC Manual Chapter 0517, " Management of 3
(d Allegations,' to examine elements of the licensee's E0P Program as appropriate to follow up on allegations conceming the program. It is not intended that each inspection requirement be covered during an inspection.
Issue Date: 06/28/91 42001l
3 Rather, inspection requirements should be selected or modified, as appropriate, to address the issue or event i . that prompted the inspection. Preparation for the inspection should incia a review of issues identified ,
u 'during previous inspections or operator licensing examination reports that would be indicative of weaknesses l p' -
. in the EOP Program,lolicy, or implementation. Significant events with a root cause related to EOPs should also be reviewed in preparation for inspection. During onsite inspection, all major changes, including those s ,
related to the resolution of identified issues, the bases for the changes, and the effect of the changes on i program effectiveness, should be discussed by the team leader with licensee management.
By reference to the appropriate revision of Regulatory Guide 1.33, " Quality Assurance Program j Requirements," Section 6.8 of the Standard Technical Specifications requires that Emergency Operating '
Procedures be established, implemented, and maintained. In addition, the licensee should review the EOPs to evaluate the safety review functions and the responsibilities of the onsite safety review organization.
i Further,10 CFR 50 Appendix B, Criterion VI, requires that quality related documents, and changes thereto, be reviewed for adequacy and approved for release by authorized personnel. In general, technical inadequacies or failures to properly implement and maintain EOPs are violations of these requirements.
p_ . l The NRC evaluates the owner's group Generic Technical Guidelines (GTGs) for safety :-d ry:= thE l- Where licensees elect to deviate from the NRC approved GTGs, they need to implement correctly the 10 CFR 50.59 process to ensure safe plant operation, particularly for design basis events, insufficient or incorrect use l of the 10 CFR 50.59 process to evaluate deviations from the NRC-approved GTGs may constitute a violation.
The NRC has reviewed the B&WOG EOP Technical Basis Document (TBD) as a body of aeneric vendor-
. oreferred EOP auidance for the B&WOG licensees. The T bD is a product of formal B&WOG commitments to close open items on the initial SER of B&WOG EOP auidance. Therefore, the TBD shall be used as the j reference basis for EOP insoections of B&WOG licensees. The TBD includes. as Volume 1. the B&W'OG
' Generic Emeroency Ooeratina Guidelines (GEOG) which provides an example of the TBD mitiaation strateoies and priorities to be used for the B&W desian olant.
f Soecific Guidance 03.01 ReviewofEOPs
- a. . The review for human factors adequacy determines whether the EOPs are adequate for the intended use and confirms that aoolication of human factors considerations from the olant specific i
writers ouide :-d WN' N 2 = 5 : =r2!y incorporatesd the guidance of the GTGsg for B&WOG licensees effectively supoorts and implements the mitiaative strateaies and priorities established in the TBD. Plant staff interviews should be conducted with cognizant licensee personnel to further confirm this assessment.=M !" dim-!"; WN' N GTGc =0!"
- : p'^#2'y t=wJ !" N EO%. Significant changes to the EOPs and supporting procedures should be reviewed by inspectors with experience in human factors evaluation. See NUREG-0899, NUREG-1358 and NUREG/CR-5228. See Section 42001-05 of this procedure for
- full reference, u b. Operator comments on the technical aspects of significant changes to the EOPs, given during interviews with the plant staff, procedure walkdowns, and simulator exercises, should be evaluated i and addressed in the inspector's EOP technical adequacy review. Particular attention should be given to the following:
- 1. Comparison of the GTG table of contents to the table of contents of plant-specific EOPs and evaluation of the differences. For B&W desians, a one-to one match is not reauired, but the same ceneral mitiaative chilosoohies should be employed.
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- 2. Review of licensee documentation addressing the development of plant EOPs from GTGs.
For B&W desians. review of licensee documentation addressino the development of plant EOP's from the TBD.
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!V 3. Evaluation of the, responses to questions from interviews with coanizant !icensee personel l about the incorporation of GTGs into the E0Ps, or for B&W desians, incorporation of TBD mitiaation strateaies and priorities into the EOPs. from inter!!cw; whogszant !!centcc ,
pe'conne! '
- 4. Verification that the licensee has an appropriately prioritized accident mitigation strategies in the procedures and that recommended GTG step sequences are followed. For B&W desians, this criterion is satisfied by verification that the licensee has appropriately orioritized accident mitiaation strateaies in the EOPs based on TBD priorities and. where the GEOG identifies a specific steo seauence as sianificant to the mitiaation strateay, that such steo seauences are maintained or are otherwise identified and justifed.
- 5. Verification that the licensee has an adequa;e technical justification for identified saftev sianificant deviations between the plant-specific E0Ps and the generic technical guidelines or GEOG., For B&W desians, differences which do not alter the TBD mitiaation strateay or priorities are not safety sianificant. -See Generic Letter 82-33. Full reference may be found l in Section 42001-05 of this procedure. l
- 6. Assessment of the safety significance ofidentified deviations. A sample of deviations should !
be examined to determine if the licensee has reported safety significant deviations, determined to constitute unreviewed safety auestions, to the NRC. These deviations should A be verified to be in accordance with 10 CFR 50.59.
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- c. The use of walkthroughs and simulator scenarios provides a practical means to verify that the procedures are well defined and easy to follow for entry and exit points and for transitions.
- d. For specific program guidance, see NUREG-0899, NUREG-1358, and NUREG/CR-5228.
- e. Significant deviations from the licensee's writer's guide for the E0Ps should be reviewed for adequacy. A significant number of minor deviations should raise questions about the consistency of EOP structure.
- f. A newly qualified operator should be able to property implement the decision points in the E0Ps without needing further guidance. The logic points should have clear questions that solicit yes or no answers. See NUREG-0899, NUREG-1358, and NUREG/CR-5228.
- g. The caution statements should identify potential hazards, and the notes and caution statements i should not contain action statements. See NUREG-0899, NUREG-1358 and NUREG/CR-5228. :
03.02 Use of E0Ps and Supportina Procedures. Where major changes have been made or concems j have been previously identified, walkdowns, simulator exercises on EOPs and supporting procedures and j interviews with plant staff should be conducted. Focus on whether:
I O a. The changes made to the procedures can be physically implemented and whether operators V physically interfere with each other while performing the changed procedures.
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- b. The changed procedures can be implemented within the time allotted considering the actual accident, the course of events, and the availability of the necessary operating locations involved under thosb conditions.
O i d c. Environmental conditions (such as temperature, steam, flooding, and radiological hazards) that would exist during the event would preventitems 03.02a. and 03.02b. above from being accomplished.
- d. Plant personnel can effectively use the EOPs and supporting procedures in the control room and other parts of the plant as necessary. An evaluation of the consistency ofinstrument and control designations as compared with installed equipment labels and procedural descriptions should be included. Also, the indicators, annunciators, and controls referenced in the procedures are available to the operators.
- e. EOP activities that would occur outside of the control room can be performed with equipment on hand.
- f. The licensee has validated and verified the procedures. A documented, comprehensive review should have been conducted by an independent, multidisciplinary team, including a human factors analysis of the procedural changes and a walkdown of the procedures in the plant. See NUREG-1358, NUREG/CR 2005, and NUREG-3632 which are fully referenced in Section 42001-05 of this procedure.
- g. The latest revision to the procedures is in the control room, the Technical Support Center, and the l Emergency Operation Facility. I O
b 03.03 Knowledae and Performance of Duties
- a. The control room staff should understand how to perform the current EOPs. To determine whether ,
the operators are aware of recent changes to the EOPs and understand the changes, limited plant-specific simulator scenanos should be conducted on at least one fully staffed shift crew. The simulator scenario should reflect relevant abnormal operating conditions that require the use of two or more of the EOPs in which significant changes have been made. Each procedural step should be observed to determine that the correct procedures are used with proper transitions, and that each step is correctly implemented. Where concems are identified, the sample size should be expanded. Walkdowns should be conducted to further assess the operator's understanding of the j EOPs, the supporting procedures, and recent changes to the procedures. Duririg the control room and in-plant walkdowns direct observation should be made of selected operators in the simulated performance of selected tasks required by the E0Ps. Such tasks include simulated handling of equipment, interpretation of instrument readings, following procedures, proper sequencing of actions, and an understanding of information flow pattems related to a specific task.
Plant-referenced simulators, as required by 10 CFR 55.45 should be used for walkdowns to allow hands-on performance for certain tasks. See SECY 90-337 which is fully referenced in Section 42001-05 of this procedure.
- b. EOP training is covered under Inspection Procedure 41500.
l c. Operator concems regarding the EOPs may be identified by the review of inspection reports,
' L operator licensing examination reports, operator responses to licensee training, procedural review l42001 Issue Date: 06/28/91
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documenta ;on, Licensee Event Reports (LERs), discussions with the Resident inspectors, and i
interviews tith operators. Operators' concems may be evaluated by E0P desktop reviews, procedure walkdowns, and simulator exercises. !
l 03.04 Review of Licensee EOP Proara-matic Controls
- a. The licensee's administrative procedures should provide controls to ensure that all changes such as changes to the Technical Specifications, setpoints, and those resulting from instrument and equipment modifications, are reflected in a timely manner, in the EOPs, the setpoint documents, and the operator training lesson plans. An active licensee program should provide for the long-term evaluation of E0Ps as recommended in Section 6.2.3 of NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures." The licensee's EOP evaluation program should j be technically adequate and the E0Ps should be structured to incorporate operational experience and use, training experience, simulator exercises, control room and in-plant walkdowns and changes in plant design, technical specifications, technical guidelines, Writer's Guide, or other plant procedures. (See Regulatory Guide 1.33, Rev 2. which is fully referenced in Section 42001-05 of this procedure).
- b. No guidanceis necessary. I
- c. Interview the licensee's staff and management involved in the performance of administrative procedures goveming E0Ps to determine if they understand the procedures and if the procedures are implemented consistently among users.
- d. See NUREG-1358. i O 03.05 necessary.
Follow-up of Licensee Corrective Actions with Reaard to E0P Concems. No guidance is !
42001-04 RESOURCE ESTIMATES For planning purposes, direct inspection effort to accomplish this procedure should be established by the Regional office, consistent with the scope of planned regional initiatives or reactive inspections to be performed. Individuals having experience in evaluating human factors should accomplish the parts of this inspection that deal with human factors issues. Direct inspection effort for reactive inspection or regional initiatives should be recorded on RITS against inspection Procedure 42001. If the procedure is used to follow up allegations in conjunction with NRC Manual Chapter 517, the actual time expended should be recorded on RITS against BJ1.
42001-05 REFERENCES 10 CFR Part 50, Appendix B, Criteria V and VI.
10 CFR 50.54(x) and (y).
10 CFR Part 2, Appendix C, Criterion VI.
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L3 y 10 CFR 50.34(f)(2)(ii) and (v).
-.10 CFR 50.59.
.. Site-Specific Technical Specifications, Chapter 6.
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Generic Letter 82-33, " Supplement 1 to NUREG - 0737, Requirements for Emergency Response Capability,"
December 17,1982. (NUDOCS Fiche Address 16681/208) l l - SECY-90-337," Procedural Adherence Requirements,". October 3,1990.- (NUDOCS Fiche Address
! 70497/142).
!. : Regulatory Guide 1.33, Rev.2, " Quality Assurance Program Requirements (Operation)," 1978. (NUDOCS L
Fiche Address 00125/155)
NUREG-1358, " Lessons Leamed From the Special inspecton Program for Emergency Operating Procedures," April 1989. (NUDOCS Fiche Address 49726/209) i NUREG-1977," Guidelines for Preparing Emergency Procedures for Nuclear Power Plants," April,1981.
(NUDOCS Fiche Address 08514/008)
L NUREG/CR-4613, " Evaluation of Nuclear Power Plant Operating Procedures Classifications and Interfaces,"-
February 29,1987. (NUDOCS Fiche Address 39983 /256)
O NUREG/CR-3632, " Methods for Implementing Revisions to Emergency Operating Procedures," May 1984.
(NUDOCS Fiche Address 24534/208)
NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures," August 1982.
(NUDOCS Fiche Address 15513/286)
NUREG/CR-2005, Rev.1, " Checklist for Evaluation Emergency Opsrating Procedures Used in Nuclear Power Plants," April 1983. (NUDOCS Fiche Address 08790/355)
NUREG/CR 3177, Vols.1,2, and 3, " Methods for Review and Evaluation of Emergency Procedure Guidelines,"_ March 1983. (NUDOCS Fiche Address 21119/138,17863/033, and 17862/227) i NUREG/CR-5228, " Techniques for Preparing Flowchart-Format Emergency Operating Procedures," January
- 1989. (NUDOCS Fiche Address 49670/141)
" Supplement 3, Safety Evaluation for CEN-152, ' Combustion Engineering Emergency Procedure Guidelines," j November 5,1986. !
i
. Combustion Engineering Emergency Procedure Guidelines," Submittal 2 of Revision 3, August 6,1986.
' " Supplement Safety Evaluation Report for ' Westinghouse Owners Group Emergency Response Guidelines, Revision 1," July 7,1986. '
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i . W:stinghouse Owners Group Emergency Resp snse Guidelines, Revision 1," November 30,1983. I
' Safety Evaluation of 'BWR Owners Group Emergency Procedure Guidelines, Revision 4, March 1987,"
NECO 31331, August'1,1988.
!' 'BWR Emergency Procedure Guidelines, Revision 4," March 1987.
B&W Owners Group Emeroency Operatina Procedures Technical Basis Document.
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