ML20202E471
| ML20202E471 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/05/1997 |
| From: | FLORIDA POWER CORP. |
| To: | |
| Shared Package | |
| ML20202E456 | List: |
| References | |
| AI-402C, NUDOCS 9712080041 | |
| Download: ML20202E471 (42) | |
Text
LMQ_Rev.5l Effective Date 11/05/97 ADMINISTRATIVE INSTRUCTIONS AI-402C FLORIDA POWER CORPORATION l CRYSTAL RIVER UNIT 3 AP AND E0P VERIFICATION AND VALIDATION PLAN APPROVED BY: Interpretation Contact
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(SIGNATURE ON FILE)
DATE:
INTERPRETATION CONTACT: Manager, Nuclear Plant Operations 9712080041 971203 PDR P ADOCK 05000302 PDR
TABLE OF CONTENTS SECI1ON PAGE l l
l L O PU RE95E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 REEERENCES ............................... ............................. 1 2.1 IMELEMENILNG_REEERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2 . 2 DEYELQEMENIALREEERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I h0_ PERSONNEL _INQQCIRINAIION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3 .1 DEEIN IIIQN S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3 . 2 RESEQNSI BILIHES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.3 DESCRIEIlON ............................... ........................ 4 h0__INSIRUCIl0NS ............................... ........................... 5 4 .1 ERQCEDURE_YERI FICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $
4.1.1 Ytrif.igal.ign of _Wri t TAD _C9fftCiness . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 4.1. 2 Yari fication of Technical _ Accuracy . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 4 . 2 PB0CEDURE_YALIDATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
- 4. 2.1 Malida119nsf_ Control Room _Acticas . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
- 4. 2. 2 Yalidation of In-Pl ant _ ACliODs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 LD EQLLOW _UE_ ACIIQNS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 ENCLOSURES 1 Veri fi cation of Written Correctness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 2 Verification Discrepancies and Resolutions. . . . . . . . . . . . . . . . . . . . . . . 29 3 Veri fication of Technical Correctness. . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 4 Validation of Control Room Actions............................... 33 5 Evaluation Criteria for Procedure Validation (Optional Record.
Non-Quality)........................ ............................ 35 6 Rules For Conducting Simulator Validi tions (Optional Record, Non-Quality)..................................................... 38 7 Vali dation of In-Pl ant Action s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 AI-402C Rev. 5 Page i
10 PURPOSE The purpose of the Verification and Validation Plan is to provide instructions for the evaluation of written correctness, technical content, usability, and operational correctness of procedures used to mitigate and correct abnormal and eme",ency conditions. The first step in this process is procedure verification, which provides assurance of written correctness of the procedure and proper incorporation of technical guidelines. The second step is procedure validation, which provides assurance that the procedure contains sufficient and understandable operator information, and that it is compatible with plant response, plant hardware, and the shift manpower.
.. , 4 REEERENCES 2.1 IELEENIIMLREEEEENCES :
2.1.1 AI-402A, Writer's Guide for Abnormal- and Emergency Operating Procedures 2.1.2 E0P - TBD Cross Step Document 2.1.3 TBD - E0P Cross Step Document 2.2 DEYELQPMENTAL REEEEENCES 2.2.1 NUREC 4999 Guidelines for the Preparation of Emergency Operating Procedures 2.2.2 NUREG-1358, Lessons Learned from the Special Inspection Program for Emergency Operating Procedures (Includes TI 2515/92) 2.2.3 NUREG-1358 51, Lessons Learned from the Special Inspection Program for Emergency Operating Procedures (including NRC Inspection Vanual 42001) 2.2.4 NUREG-800, Standard Review Plan 13.5.2 Appendix-A: Review Procedures for the Evaluation of Procedures Generation Packages
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1,0 l PERSONNEL _JNDOGAINAUQN l
3.1 DEEINIILQNS 3.1.1 APs - Abnormal Procedurcs - Procedures which provide guidance to Operations personnel responding to or mitigating the effects of off-normal plant conditions that do not meet any entry conditions-listed in E0P-1.
3.1.2 EOPs - Emergency Operating Procedures - Plant procedures that are used to mitigate symptoms listed in E0P-1 resulting from an upset in plant control parameters.
3.1.3 In-plant Validation - Method of validation whereby in-plant personnel conduct a step-by-step enactment by walk-down of those steps in an E0P/AP specific to in-plant activities.
3.1.4 Major Revision - A procedure change which involves a modification of branching to other procedures or a major technical revision.
3.1.5 Operational Correctness - A characteristic that indicates the degree to which the procedure is compatible with plant response, hardwa 4, and the shift manpower to manage emergency conditions in the plat.:.
3.1.6 PSTG - Plant Specific Technical Guidelines - Technical guidelines to be used by the E0P Coordinator for development and revision of CR-3 Emergency Operating Procedures. The PSTG consists of the B&W Owners Group Emergency Operating Procedures Technical Bases Document (TBD),
the E0P Cross-step Documents, the CR-3 Deviation Document (DD-01), ,
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and the E0P/AP Writer's Guide (AI-402A).
3.1.7 Scenario - A structural plan of parameter and plant symptom changes that provide operating cues for the conduct of assessment.
3.1.8 Simulator Validation - Method of validation whereby control room personnel perform actual control functions on simulated equipment during a scenario for an observer / reviewer.
3.1.9 Source Documents - Documents used for the basis of AP and E0P construction or revision. These documents may include, but are not limited to: MARS. PSTG, FSAR, engineering analyses, commitments.
EDBD, ADB, ITS, and equipment technical manuals.
3.1.10 Symptoms - Plant characteristics that directly or indirectly indicate plant status.
3.1.11 Table-Top Validation - Method of validation whereby personnel explain and/or discuss procedure steps for an observer / reviewer in response to a scenario or as part of an actual industry operating experience review.
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- _ 3.1.12 Technical Accuracy - A characteristic that indicates the degree to i which proper incorporation of plant specific technical information j has been made.
3.1.13 Usability - A characteristic that indicates the degree to which the procedure provides sufficient and understandable operator ;
information to macage emergency conditions in the plant.
3.1.14 Validation - Yhe act or process of supporting or collaborating on a.
sound or authoritative basis. Types of validation include:
o Simulation - validation performance using a neck-up, spare equipment, or cimulators including the control room simulator, o Walk-through - a validation that confirms the physical devices named in the procedure are identical to the devices in the plant i and that it is physically possible to perform each step in the procedure.
I o Table-top - validation performance by the reviewer or group of l reviewers reading the procedure and mentally interpreting and <
evaluating the procedure information to ensure that it will be 7
usable when implemented under normal conditions and alternative j scenarios.
3.1.15 Verification - The evaluation performed to confirm the written correitness of the procedure and to ensure that the technical guidelines have been properly incorporated.
3.1.16 Walk-Through Validation Method of validation whereb/ control room personnel conduct a step-by % sp enactment of their actions during a scenario for an observer / reviewer without carrying out the actual control functions.
3.1.17 Written Correctness - The proper incorporation of Administrative Instruction (e.g., Writer's Guide)- format and information into the. <
written document.
3.1.18 Writer's Guide - The FPC procedure used to provide administrative and technical guidance for the preparation of Abnormal and Emergency ,
Operating Procedures used at CR-3.- This procedure is AI-402A, Writer's Guide for Abnormal and Emergency Operating Procedures.
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3.2 REif9NSIAILII1ES
3.2.1 Originator
o Written correctness and technical accuracy of the procedure.
o Initiating changes to other procedures and documents as necessary due to step number or branching changes that affect-other procedures and documents.
o Ensurin the verification and validation summary forms are properl initiated and attached to the procedure.
o Resolution of all discrepancies found during procedure verification and validation.
3.2.2 Rev: ewers:
o Verification of written correctness and techaical accuracy of the procedure.
o Validation of usability and operational correctness of ths ,
procedure. '
3.2.3 Observers
o Directing validation efforts, o Documenting comments and discrepancies-found during validation.
3.2.4 Manager, Nuclear Plant Operations:
o Final acceptance of procedure verification and validation. !
o Coordinating efforts between Nuclear Operations and Nuclear Training to support the validation efforts.
3.2.5 Nuclear Simulator Training Supervisor:
o Scheduling of simulator time, o Ensuring that simulator validation scenarios are compatible with the scope and fidelity of the simulator.
L 3.3 DESCRIPT10N l This procedure describes the methods used to provide verification and validation of Abnormal Procedures (APs) and Emergency Operating l Procedures (EOPs). Verification and validation must be performed for new procedures, should be performed for revised procedures, and may be performed whenever determined to be necessary by Nuclear Operations management.
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J 140 INSIR'G10NS 4.1 ERQCEDURE VERIFICATION 4.1.1 Verification of Written CorI_mCintal 4.1.1.1 The Originator completes Enclosure 1 as follows:
- a. Identify the procedure title, number, current revision, and PRR number,
- b. Identifies the scope of verification required.
If the procedure is a new procedure, 08 if a major revision has occurred, IlfEN indicates a total procedure verification is required.
IE NQI, IliEN indicates the applicable procedure sections and/or steps which require verification.
- c. Designates the reviewers. The originator is not a reviewer.
A minimum of 1 reviewer who is a member of Nuclear Plant Operations is designated. Along with members of Nuclear Operation., personnel from other disciplines such as engineering, quality programs, licensing, and training are considered-for participation in the procedure review process.
Utilizing various disciplines ensure all aspects of written correctness are appr41 sed. Reviewer selection includes consideration of famOtarity with AI-402A, Abnormal and Emergency Procedure Writers Guide,
- d. Identifies critaria to be used for each procedure verification by checking the appropriate " Verify: Yes O No 0" spaces in Enclosure 1. Sections 1.1 through 1.5. For new procedures,_
l indi:ates all criteria are verified. For procedure changes, indicates those criteria which are affected by the change are verified.
- e. Places a checkmark in the N/A block under DISCREPANCY for any criteria not verified.
- f. Signs and dates Page 1 of Enclosure 1 as the originator.
l IE the originator is NQ1 a current or prev _ious SRO licensed
-individual, IliEN obtains concurrence of the assignment of verification requirements from a current or previous SRO licensed individual.
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4.1.1.2 Each reviewer performs the following:
- a. Ensures that his or her name is printed on Page 1 of Enclosure 1.
- b. Referencing the Writers Guide, verifies the written correctness of the procedure using the criteria in Enclosu e 1 designated to be evaluated. This is performed by making multiple passes through the procedure verifying one or two aspects of the criteria and marking Yes, No, er N/A by the aspects.
- c. Records the results as follows:
IE any aspect of the criteria is marked "No" (discrepancy),
IBM:
o Indicates the area of discrepancy by placing a check mark in the appropriate "Yes" box on Page 1 of Enclosure 1.
o Explains the discrepancy on Enclosure 2 with sufficient detail to permit accurate resolution.
o Provides suggested solutions as applicable or available on Enclosure 2.
If all aspects of the criteria are marked "Yes" or "N/A",
IHB indicates acceptance of that area by placing a check mark in the appropriate "No" box on Page 1 of Enclosure 1.
- d. Signs and dates the last page of Enclosure 1 indicating the sections he/she verified.
4.1.1.3 The Originator resolves any noted discrepancies and documents the resolution on Enclosure 2.
4.1.1.4 The Manager, Nuclear Plant Operations or his designee performs the following:
- a. Reviews any discrepancies and associated resolutions or justifications,
- b. IE the scope of discrepancy resolution is determined to be significant, IEW indicates the necessity for re-verification by checking "Yes" on Enclosure 1.
If EQI.
ItiEN checks "No" on Enclosure 1.
- c. Indicates review of the procedure verification by signing and dating the last page of Enclosure 1.
- d. Forwards the verification documentation to the originator for final disposition or re-verification.
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-4.1.2 Verification of Technica11_AtcEacy i
, 4.1.2.1 The Originator Completes Enclosure 3 as follows:
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- a. Identifies the procedure title, number, current revision, and i PRR number. ,
l b. IE the technical content of the procedure has been changed, Itim consults with the Manager, Nuclear Plant Operations to a determine if a major revision has occurred.
- c. Identifies the scope of verification required.
If the procedure is a new procedure, 02 if a major revision has occurred, i IBM ii.dicates a total procedure verification is required.
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- H NU, i IBM indicates the applicable procedure sections and/or steps which require verification.
- d. Identifies the source documents used for the development of or revision to the procedure. When applicable, the chapter or -
i section of the source document or the MAR number is specified.
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, e. Designates the minimum number of reviewers and the qualification
., of each (e.g. , NSS, R0 license, inactive SRO license, etc.).
The originator is not a reviewer. A minimum of 1 reviewer with
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an active R0_pr_5RQ license and 1 individual who holds or- l previously held an SRO license is desic'1ated. Reviewer selection includes consideration of the following:
o operating experience and training o knowledge of plant hardware
- o familiarity with source documents c f. Identifies criteria to be used for each procedure verification
- by checking the appropriate " Verify: Yes Omo 0" spaces in Enclosure 2.-Sections 2.1 through 2.4. For new procedures, indicates all criteria are verified. For procedure changes, indicates those c-iteria which are affected by-the cha..y are verified.
l g. Places a checkmark in the N/A block under DISCREPANCY for any criteria not verified.
- h. Signs and dates Page 1 of Enclosure 2 as the originator.
. IE the originator is NQI a current or previous SRO licensed individual,
- IBM obtains concurrence of the assignment of- verification requirements from n current or previous SRO licensed individual.
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4.1.2.2 Each reviewer performs the following:
- a. Ensures that his o.- her name is printed on Page 1 of Enclosure 3.
- b. Referencing the PSTG for deviatior. documentation and all the cross-step documentation (for E0Ps), verifies technical accuracy of the procedure using the criteria in Enclosure 3 designated to be evaluated. This is performed by making multiple passes through the procedure verifying one or two aspects of the criteria and marking Yes, No, or N/A by the aspects.
. c. Records the results as follows:
IE any aspect of the criteria is marked "No" (discrepancy),
IBEN:
o Indicates the area of discrepancy by placing a check mark in the appropriate "Yes" box on Page 1 of Enclosure 3.
o Explains the discrepancy on Enclosure 2 with sufficient detail to permit accurate resolution.
o Provides suggested solutions as applicable or available on Encl 3sure 2.
IE all aspects of the criteria are marked "Yes" or "N/A",
IBEN indicates acceptance of that area by placing a check mark in the appropriate "No" box on Page 1 of Enclosure 3.
- d. Signs and dates the last page of Enclosure 1 indicating the sections he/she verified.
4 1.2.3 The Originator performs the following:
- a. Resolves any noted discrepancies and documents the resolution on Enclosure 2.
- b. Determines if revisions to other procedures are required due to changes in step numbering, branching, or technical content.
IE revisiens to other procedures are required, IHEN lists the procedure numbers and associated PRR numbers on the last page of Enclosure 3.
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4.1.2.4 The Manager, Nuclear Plant Operations or his designee performs the following:
- a. Reviews any discrepancies and associated resolutions or justifications,
- b. LE the scop; of discrepancy resolution is determined to be significant, IHEN indicates the necessity for re-verification by checking -d "Yes" on Enclosure 3.
l If NQI.
1 IBEN checks "No" on Enclosure 3.
- c. Indicates review of the procedure verification by signing and dating -the last page of Enclosure 3.
- d. Forwards the verification documentation to the originator for final disposition or re-verification.
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4.2 ISQCfpJtLMLIDAIION 4.2.1 hlidation of Control Room Actions 4.2.1.1' The originator completes the following on Enclosure s t ' alia
- a. Identifies the procedure title, number, revision, anc "s cumber.
- b. . Identifies ii' a validation is required and if so, the method of validation to be performed. Validation is not required for simple editorial changes that do not alter the intent, scope or technical accuracy of the procedure. The method chosen provides validation of all characteristics necessary to ensure the intent of the new or revised procedure is met ano is based on the nature of changes to a procedure. More than one validation method may often be appropriate. The following table is used as a guide to select the validation Nthod:
l- VALIDATION METHODS j CHARACTERISTIC TO BE VALIDATED Simulator Wal k-Th rough Table-Top l
Procedure information for management of the emergency condition is sufficient & X X X consistent with training ;
Procedure information is easily comprehendible X
__X X Compatible w W h control room hardware X X Compatible with remotely located hardware & response X X Compatible with shift manning levels & policies X X Compatible with plant response X
- c. IE validation is NOI required, IllEN documents the reason in the " Scope of Validation" section.
- d. IE validation is required, ltlEN identifies the scope of validation.
If the procedure is a new procedure, QE if a major revision has been performed, IllEN indicates a total procedure validation required.
IE NQI, ItiEN indicates the applicable procedure sections and/or steps which require validation,
- e. Signs and dates Enclosure 4 as the originator.
- f. Forwards Page 1 of Enclosure 4 to the Manager, Nuclear Plant Operations for concurrence.
4.2.1.2 The Manager, Nuclear Plant Operations or designee performs the following:
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- a. Indicates concurrence with the validation requirement and scope or validation by signing Enclosure 4.
LE_in disagresaent with the validation method or scope, contacts the originator for resolution prior to signing Enclosure 4.
- b. IE- a simulator validation is required, 3 IH1H schedules simulator time with the Nuclear Simulator Training SuperviLor which will permit procedure validation without unnecessarily delaying procedure implementation.
IE simulator scheduling will not permit validation prior to necessary implementation, IDEN designates walk-through validation prior to procedure implc.1entaticts and simulator validation following procedure implementation and signs / dates Enclosure 4 indicating approval for simulator validation delay.
- c. Returns Page 1 of Enclosure 4 to the originator.
4.2.1.3 IE validation is required.
IDEN the originator performs the following:
- a. Completes the scenario description section of Enclosure 4. This includes initial plant conditions and sufficient detail to accomplish validation of the required characteristics of the procedure. Generally, a more detailed scenario description is required for walk-through or table-top validations,
- b. If a simulator validation is to be performed, IHEN sends a copy of Enclosure 4 to the_ Nuclear Simulator Training Supervisor.
4.2.1.4- IE a_ simulator validation is to be performed.
IHEN the Nuclear Simulator Training Supervisor reviews the proposed scenario to ensure it falls within the simulator's tested scope of simulation.
11 simulator configuration or other limitations requires alteration of the scenario, IBEN contacts the originator for resolution.
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4.'2.1.5 IE validation is required, IHEN the originator performs the following:
- a. Designates the observer (s). Observers are present-to monitor and note the procedure validation process as the procedure is used by the reviewers. Automatic techniques, manual techniques, or a combination of both are used to record performance during validation. When manual techniques are used, personnel are designated to observe and record the validation performance.
Observers are required to have an experience level and/or training background to support their assigned function in the assessment. If possible, the ratio of reviewers to observers should not exceed 3 to 1. Enclosure 5 is used as a guide for assessment of performance,
- b. Designates the-minimum number of reviewers and the qualification of each (e.g., NSS, RO license, inactive-SRO license, etc.).
The originator is not a reviewer. A minimum of 1 individual withanactiveRO,orSROlicenseand1individualwithanactivel or inactive SRO license is designated. Reviewer selection includes consideration of the following:
o Operating experience and training o Knowledge of plant hardware 4.2.1.6 Each reviewer ensures that his or her name is printed on Page 1 of Enclosure-4, 4.2.1.7 IE a table-top validation is performed, IHEN each reviewer and observer conducts the validation as follows;
- a. Observer (s):
o Ensure r.eeded procedures are available, o Brief the reviewer (s) on the purpose and _ technique of the assessment, o Direct the table-top discussion.using the scenario being careful not to actively participate as a reviewer, o Maintain data collection, identi'y any discrepancies, and record reviewer (s) ' amments noted during the validation.
- b. Reviewer (s):
o Use the procedure in accordance with the scenario, o Make comments concerning the procedure's usability and operational correctness.
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4.2.1.8 IE a walk-through validation is performed, THEN each reviewer and observer conducts the validation as follows:
- a. Observer (s):
o Ensure needed procedures are ayLilable, o Brief the reviewer (s) on the purpose and technique of the assessment, o Direct the walk-through using the scenario being careful not to actively participate as a reviewer.
o Maintain data collection, identify any discrepancies, and record reviewer (s) comments noted during the validation.
- b. Reviewer (s):
o Using the procedure, walk through the actions that would be taken during specific situations coverad by the scenario, o Describe actions being taken.
o Identify information sources used to take actions.
o Identify controls used to carry out actions, expected system responses, how responses are verified, and actions to be taken if responses do not occur, o Make comments concerning the procedure's usability and operational correctness.
4.2.1.9 If a simulator validation is performed.
THEN each reviewer and observer conducts the validation as follows:
- a. Observer (s):
o Ensure needed procedures are available.
o Brief the reviewer (s) on the purpose and technique of the assessment.
o Perform a brief of the rules to be followed during simulator validation using Enclosure 6.
o Maintain data collection, identify any discrepancies, and record reviewer (s) comments noted during the validation,
- b. Reviewer (s):
o Respond to the scenario according to the rules specified in Enclosure 6.
o Make comments concerning the procedure's usability and operational correctness.
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4.2.1.10 Following procedure validation, observers perform the following:
- a. Using Enclosure 5, debriefs the reviewers to identify any problems not apparent during the validation.
- b. Records comments and any discrepancies with potential solutions on Page 2 of Enclosure 4.
IE no discrepancies 'are noted during the validation, THEN indicates this by placing a check mark in the box designated as "No discrepancies noted" on Page 2 of Enclosure 4.
- c. Obtains reviewers signature and date on Page 2 of Enclosure 4 indicating agreement with the listed discrepancies or the statement indicating no discrepancies were found.
- d. Forwards the completed validation forms to the originator for resolution of any discrepancies.
1 i 4.2.1.11 The originator resolves any noted discrepancies, documents the l resolution on Page 2 of Enclosure 4 and forwards Enclosure 4 to the Manager, Nuclear Plant Operations or designee.
4.2.1.12 The Manager, Nuclear Plant Operations or designee performs the following:
- a. Reviews all the discrepancy resolutions.
IE the scope of discrepancy resolution is determined to be significant, IHEN indicates the necessity for re-validation by checking "Yes" on Page 2 of Enclosure 4.
If NOI, IHEN checks "No" on Page 2 of Enclosure 4.
- b. Indicates review of the procedure validation by signing and i dating Page 2 of Enclosure 4.
- c. Forwards the validation documentatiori to the originator for '
final disposition or re-validation.
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4.2.2 yalidation_qf_In-Plant Actions 4.2.2.1 The originator completes the following on Enclosure 7 as follows:
- a. Identifies the procedure title, number, revision, and PRR number.
- b. Identif,es if a validation is required. Validation is not required for simple editorial changes that do not alter the intent, scope or technical accuracy of in-plant actions of the procedure.
- c. IE validation is required, IBEN identifies the steps specifying in-plant actions.
- d. IE validation is required, IBIN identifies the scope of validation.
IE all steps specifying in-plant actions provide specific direction without referencing / branching to other support procedures IHEN indicates the specific steps in the E0P/AP to be validated.
IE NOI, IHEN indicates the referenced procecare to be validated and the specific steps in the E0P/AP to be validated.
I e. IE validation is NQI required, IHEN documents the reason in the " Scope of Validation" section,
- f. Signs and dates Enclosure 7 as the originator.
- g. Forwards Page 1 of Enclosure 7 to the Manager, Nuclear Plant Operations or designee for concurrence.
4.2.2.2 The Manager, Nuclear Plant Operations or designee performs the following:
- a. Indicates concurrence with the validation requirement and scope of validation by signing Enclosure 7.
If in disagreement with the validation requirement or scope, contacts the originator for resolution prior to signing Enclosure 7.
- b. Returns Page 1 of Enclosure 7 to the originator.
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4.2.2.3 IE validation is required, IHEh the originator performs the following:
- a. Designates the observer (s). Observers are present to monitor and note the procedure validation process as the-procedure is used by the reviewers. Observers are required to-have an experience level equivalent to the reviewers.
- b. Designates the reviewer (s) and the level of qualification (e.g., PPO, SP0, R0 license, etc.). The_ originator is not a reviewer. Reviewer selection includes consideration of the following:
o Operating experience and training o Knowledge of plant hardware 4.2.2.4 Each reviewer ensures that his'or her.name is printed on Page 1 of Enclosure 7.
l-4.2.2.5 Each reviewer and observer conducts the validation as follows: -
- a. Observer (s):
i o Ensure needed procedures are available, o Brief the reviewer (s) on the purpose and technique of the assessment.
o Direct the walk-through using the specified step (s) from the E0P/AP being careful not to actively participate as a reviewer.
o Maintain data collection, identify- any discrepancies, and record reviewer (s)' comments noted during the validation.
- b. Reviewer (s);
o- Walk through the actions that would be taken to perform the step (s) specified by' the E0P/AP.
o Describe actions-being taken.
o Identify information sources used to take actions.
o Identify controls used to carry out actions, expected system responses, how responses are verified, and actions to be taken if responses do not occur.
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4.2.2.6- Following procedure validation, observers perform the following:
- a. Using Enclosure 5, debriefs the reviewers to identify any problems not apparent during the validation.
- b. Records comments and any discrepancies with potential solutions an Page 2 of Enclosure 7.
IE no discrepancies are noted during the validation.
18E8 indicates this by placing a check mark in the box designated as "No discrepancies noted" on Page 2 of Enclosure 7.
- c. Obtains reviewer's signature and date on Page 2 of Enclosure 7 indicating agreement with the listed discrepancies or the statement indicating no discrepancies were found,
- d. Forwards the completed validation forms to the originator for resolution of any discrepancies.
4.2.2.7 The originator resolves any noted discrepancies, documents the resolution on Page 2 of Enclosure 7 and forwards Enclosure 7 to the Manager, Nuclear Plant Operations or designee.
4.2.2.8 The Manager, Nuclear Plant Operations or designee performs the following:
- a. Reviews all the discrepancy resolutions.
IE the scope of discrepancy resolution is determined to be significant, IHEN indicates the necessity for re-validation by checking Yes" on Page 2 of Enclosure 7.
If NQI, IHEN checks "No" on Page 2 of Enclosure 7.
- b. Indicates review of the procedure validation by signing and dating Page 2 of Enclosure 7.
- c. Forwards the validation documentation to the originator for final disposition or re-validation.
5.0 FOLLOW-UP ACTIQNS None AI-402C Rev. 5 Page 17
ENCLOSURE 1 (Page 1 of 11)
YERIFICATION OF WRITTEN CORRECIMESS PROCEDURE TITLE:
PROCFOURE NUMBER: REV NUMBER: PRR NUMBER:
SCOPE OF VERIFICATION:
(Specify either total pre edure or sections / steps)
REVIEWERS: (A minimum of one from Nuclear Plant Operations)
Title Name (Print)
WRITTEN CORRECTNESS VERIFICATION:
DISCREPANCY CRITERIA CRITERIA: YES NO N/A SECTION 1.1 Legibility & Format 1.2 Identification Information 1.3 Information Presentation 1.4 Referencing & Branching 1.5 Logic Statements ORIGINATOR: (signature & date)
SRO CONCURRENCE (if required):
AI-402C Rev. 5 Page 18 ;
ENCLOSURE 1 (Page 2 of 11)
VIRIEICallON FOP. WRIIIf2LLQRRECTNESS (Cont'd)
Yes No N/A 1.1 LEGIBILITY AND FORMAT Veri *y: Yes O No 0 1.1.1 Text, tables, graphs, and figures are clearly readable. [] [] []
1.1.2 Procedure contains proper sections: [] [] []
1.0 Entry Conditions 2.0 Immediate Actions 3.0 Follow-up Actions 4.0 Figures (as applicable) 5.0 Enclosures (as applicable to APs only)
Tables (as applicable) l 1.1.3 Sections 2.0 and 3.0 are in two column format with [] [] []
ACTIONS as heading in left column and DETAIL: as F.eading in right column 1.1.4 Facing pages contain only steps of continuous applicability outlined in a box [] [3 []-
1.1.5 Enclosures formatted correctly:
[] [] []
Uniquely and consecutively numbered with Arabic numerals in the order referenced in the procedure The backside has " BLANK PAGE" centered on the page unless it is the last page of the procedure 1.1.6 Status, notes and cautions formatted cot ectly:
3 3 3 Appears as STATUS. NOIE, CAUTION Status in double line box; note in single line box; caution in thick line box Contents bolded in single space mixed type Single space'between heading and text and between text and bottom of box and separated from subsequent notes, cautions or steps by single space Single line text centered. Multiple line text indented Multiple topics in notes and cautions bulletized AI-402C Rev. 5 Page 19
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ENCLOSURE 1 (Page 3 of 11)
YERIFICATION OF WRITTEN CORRACIMESS (Cont'd)
Yes No N/A 1.1,7 Colons used properly:
[] [] []
Indicate a list to follow Separate calculations from titles Introduce a number or value 1.1.8 Commas used properly:
[] [] []
Separate clauses in logic statements Clarify numbers of 2 5 digits Separate enclosure numbers or full page figures and titles in references Separate procedure numbers, titles, and step numbers in references Separate the designation of an item from its description Provide grammatical accuracy 1.1.9 Periods used correctly: [] [3 []
Numbered steps in the action column Presentation of decimals At the end of complete sentences For presenting step numbers when referencing and branching ;
At the end of entry conditions 1.1.10 Quotation marks used only to reproduce exact information from equipment, controls or displays [3 [] [3 1.1.11 Brackets used to enclose rules
[] [] []
i l
1 l
AI-402C Rev. 5 Page 20
ENCLOSURE 1 (Page 4 of 11)
VERIFICATION OF WRITTEN CORRECTNESS (Cont'd)
Yes No N/A 1.1.12 Slashes used properly: [] [] []
Indicate "per" in units of measure Present fractions or dates 1.1.13 Hyphens used only in compound words, component [] [] []
terminology and procedure numbers 1.1.14 Apostrophes used only to show possession [] [] []
1.1.15 Ellipses (...) used at end of truncated steps on facing pages OOO 1.1.16 Parenthesis used only for presentation of equipment location and rd11tional information [] [] []
1.1.17 Underlining used properly:
[] [] []
Procedure section headings Instruction page column headings Enclosure headings Logic terms The words "any" and "all" when used to introduce a list 1.1.18 Bold print used for procedure title, section headings, referencing and-branching [] [] [3 1.1.19 Steps on a page are separated by either notes, cautions, or horizontal lines [] [3 []
AI-402C- Rev. 5 Page 21
ENCLOSURE 1 (Page 5 of 11)
YERIEICATION OE_ WRITTEN CORRECINESji (Cont'd)
Yes No N/A 1.1.20 Full capitalization used properly: [] [] []
Procedure title Facility designator Procedure abbreviation The abbreviation REV Procedure section headings Instruction page column headings Procedure type designator Referencing and branching (e.g., PERFORM, C0 TO)
"PAGE" at the footer of each page "B' %NK PAGE" on blank facing pages
" SIGNATURE ON FILE" on cover page "LAST PAGE" on footer of last page Accepted abbreviations and acronyms Logic terms AI-402C Rev. 5 Page 22
l ENCLOSURE 1 (Page 6 of 11)
YIRIflCAUDN OF WLUfM10RBECTRESS (cont'd)
Yes No N/A 1.2 IDENIIELCATION _INFORMATIQN Verify: Yes O No 0 1.2.1 Procedure title descriptive of the procedure purpose [] [] []
1.2.2 Cover page formatted correctly: [] [] []
Procedure abbreviation Revision number Procedure number Procedure title Total number of pages !
Review and approval signature 1.2.3 Additional pages formatted correctly: [] []L [3 Procedure number Revision number Proper page number
Procedure abbreviation 1.2.4 All pages present in the proper order
[] [] []
AI-402C Rev. 5 Page 23 j
ENCLOSURE 1 (Page 7 of 11)
VIAIFICATION OF WRITTEN CORRECT! SS (Cont'd)
Yes No N/A 1.3 INE0RMATI0tLERESENIATl_QN Verify: Yes O No 0 1.3.1 Entry conditions are written as a logic sequence, double OOO spaced, and left justified.
1,3.2 Each procedure section and enclosure begins on a new page unless there are no steps in the section.
00O' 1.3.3 Action steps presented properly: OOO Numbered unique',y and consecutively using Arabic-numerals with the first numeral in cach step corresponding to the section in which the step appears L Numbered correctly in both columns and completed on 1 page Each step deals with only 1 main idea As short and simple as possible; the simplest, most familiar, and most specific words are used Actions organized sequentially according to technical necessity and control room layout Details within a step that are required to be performed in order, are numbered consecutively beginning with "1" and include placekeeping aids for each item if two or more steps are presented Bullets are used to present members of a list within a step which have no crder and to delineate each detail that does not require a number even if only one detail is present Placekeeping aids used to present all action steps and members of a list within a step which have 2 2 items Operator actions are specifically stated If other than a control room operator, the step performer is specified by title or department Equally acceptable steps written as a conditional statement when preferred option depends upon plant conditions AI-402C Rev. 5 Page 24
ENCLOSURE 1 (Page 8 of'11)
VERIFICATION OF WRITTEN CORRECTNESS (Cont'd)
Yes No N/A 1.3.4 Recurrent steps are first presented on the facing page [] [] []
when condition is applicable and continues until applicability no longer exists.
1.3.5 Numerical information presented properly: [] [] []
Values- are described with Arabic numerals l Decimal points are preceded by a zero for numbers < 1 When possible, calculations are not required Ranges of values specified rather than using "approximately" where possible 1.3.6 Abbreviations and acronyms used are included in the [] [] []
Writer's Guide or are part of a procedure title and are used consistently throughout the procedure 1.3.7 Facing page information is presented properly: [] [] []
Pages with no information are marked with BLANK PAGE..
centered on the page Information is continuously applicable 1.3.8 Typographically and grammatically correct [] [] []
1.3.9 Status notes presented properly: -[] [] []
Provide only supplemental information Placed at the beginning of the page-immediately before first step or section to which they apply Can be read completely, without interruption Contain no action steps AI-402C Rev. 5 Page 25
ENCLOSUEE_1 (Page 9 of 11).
VERIFICATION OF WRITTEN CORRECTNESS (Cont'd)
Yes No N/Al 1.3.10 Cautions presented properly: [] [] []
Address conditions, practices, or procedures which are hazardous and r y cause injury or damage Placed immediately before first step to which they apply and on subsequent pages that contain applicable steps Can be read completely, without interruption Contain no action steps 1.3.11 Notes presented properly: [] [] []
t- Provide only supplemental information Placed immediately befcre first step to which they apply Can be read complete!y, without interruption Contain no action steps 1.3.12 Figures and tables presented properly: [] [] []
Action steps and the tables to which they-refer are presented, when possible, so they can be viewed-simultaneously Page. rotation is not necessary to read figures or tables Contain only the necessary information Vacant cells in tables are shaded Do not include operator actions Grids on graphs are sufficiently dense such that operators can read the graph without a precision level of less than one-half grid division Axes are labeled in the same units of measure displayed to the operator AI-402C Rev. 5 Page 26
ENCLOSURE 1 (Page 10 of 11)
VERIFICATION OF WRITTEN CORRECTNESS (Cont'd)
Yes No N/A 1.4 REFERENCING AND BRANQilNG Verify: Yes O No 0 1.4.1 Unconditional procedure exits are designated by GO To, OOO followed by the procedure number, procedure name, and the applicable procedure step or section title 1.4.2 Concurrent procedure performance is designated by 000 CONCURRENTLY PERFORM, followed by the procedure number, procedure name, and the applicable procedure step 1.4.3 External procedure performance prior to continuance is OOO designated by PERFORM, followed by the procedure number, procedure name, and the applicable procedure step l
AI-402C Rev. 5 Page 27
ENCLOSURE 1 (Page 11 of 11)
YIBJFICATION OF WRITTEN CQlLRECTNESS (Cont'd)
Yes No N/A
-1.5 LQGIC STATEMENTS Verify: Yes [] No []
1.5.1 Every IE and WHEN has an essociated IBEN OOO 1.5.2 All logic terms except NQI begin a new line [] [] []
1.5.3 IE and IE NQI used to describe conditions which may [] [] []
occur 1.5.4 WHEN describes procedure hold points [] [] []
1.5.5 AND is not used to join 3 or more conditions [] [] []
1.5.6 6ND and QR are nat used in the same statement [] [] []
1.5.7 If exclusive QB is used, it is in the form of Condition A QB B, but not both [] [] []
REVIEWERS:
Signature Date Section Verified Re-verification required: Yes [] No []
Reviewed By:
Manager, Nuclear Plant Operations Date AI-402C Rev. 5 Page 28 l
E_NCLOSURE i YERIEICAIIQR_DISCREPA CIES AND_RESOLUIIONS DISCREPANCY / SUGGESTED SOLUTION RESOLUTION AI-402C Rev. 5 Page 29
l ENCLOSURE 3 (Page 1 of 3)
YERIFICATION OF TEQLNICAL_ACCygACy L
PROCEDURE TITLE:
PROCEDURE NUMBER: REV NUMBER: PRR NUMBER:
SCOPE OF VERIFICATION:
(Specify either total procedure or sections / steps)
SOURCE DOCUMENTS USED:
) BEVIEWERS: l Title Name (Print) Qualification v
TECHNICAL ACCURACY VERIFICATION:
DISCREPANCY
. CRITERIA CRITERIA: YES NO N/A SECTION 2.1 Entry Conditions 2.2 Instruction Information 2.3 Quantitative Information 2.4 Hardware Information ORIGINATOR: (signature & date)
SRO CONCURRENCE (if required):
AI-402C Rev. 5 Page 30
E.NCLOSURE 3 (Page 2 of 3) {
j YER!FICATION OF TECHNICAL ACCUBAQ (Cont'd)
Yes No N/A 2.1 ENTRY CONQIIIQNS Verify: Yes O No O 2.1.1 Appropriate _for which procedure should be used OO0 2.1.2 Consistent with the PSTG OOO 2.1.3 Not excessive OOO 2.2 IN5tAUCTIDNAL INFORMATIQN Verify: Yes O No O 2.2.1 Differences between the procedure and PSTG are OOO determined using the most current revision of the PSTG information and are documented and explained 2.2.2 Cross-step documentation is reviewed and revised as necessary. The implementation, addition or sequencing OOO change of steps, notes, or cautions does not alter the technical intent of the PSTG 2.2.3 Applicable licensing commitments are incorporated 2.2.4 Differences between licensing commitments and the procedure or PSTG are documented OO0 2.3 QUANTITATIVE INFORMATIQN Verify: Yes O No 0-2.3.1 Quantitative values and any applicable tolerance bands are in compliance with the source documents O O. O 2.3.2 Equations used in the procedure are presented with sufficient information for operator use OOO 2.3.3 Plant specific computed values are accurate 0 O O-s AI-402C Rev. 5 Page 31
ENCLO5URE 3 (Page 3 of 3)
YERIFICATION T _ TECHNICAL ACCURACY (Cont'd)
Yes No N/A 2.4 HA_RDWARE INFj)BMAILQN Verify: Yes O No O 2.4.1 Procedure specified equipment, controls, indicators, and [] [] [] ,
instrumentation available for operator use
- 2. 4. 2 - Numerical information for information from instruments- [] [] []
presented properly:
i i Numerical units agree with instrumentation and displays Highest level of significance associated with analog instrumentation is no greater than 1/2 of the smallest discrimination of the instrument Highest level of significance associated with digital instrumentation is no greater than the smallest discrimination of the instrument 2.4.3 Any tools, keys or special equipment necessary for [] [] []
procedure performance are correctly identified and available REVIEWERS:
Signature Date Section Verified i
Related Procedure Revisions /PRR Numbers:
Re-verification required: Yes [] No []
Reviewed By:
Manager, Nuclear Plant Operations Date AI-402C Rev. 5 Page 32
J
. ENCLOSURE 4
)
'(Page 1 of 2)
! YALIDAIELN OF CONTROL RQQtLACTIONS i
! PROCEDURE TITLE: '
I~ .
- ' PROCEDURE NUMBER
- REV NUMBER: PRR NUM3ER:
1
- j. VALIDATION METHOD:
Table-Top Walk-Through _ Simulator None required SCOPE OF VALIDATION:
i 1
1 MNPO APPROVAL FOR SIMULATOR-VALIDATION DELAY:
Signature /Date SCENARIO DESCRIPTION:
i i.
OBSERVER (S):
' REVIEWERS:
Title Name (Print) Qualification -
. ORIGINATOR:
Signature /Date MNPO CONCURRENCE:
Signature /Date AI-402C Rev. 5 Page 33
ENCLOSURLA (Page 2 of 2)
YALIDATION OF CONIRQL_. ROOM ACTIO_N5 (Cont'd)
DISCREPANCY / SUGGESTED SOLUTION RESOLUTION No discrepancies noted: O REVIEWER (S): Signature Date Revalidation required: Yes O No O R1 viewed By:
Manager, Nuclear Plant Operations Date AI-402C Rev. 5 Page 34
_ _ _ _- -_ ___-__ - __=__ _-_ - - ______ -
ENCLOSURE 5 (Page 1 of 3)
EYALUATION CRITERIA FOR PROCCDURE_VALIDAIl0N 1-T - Table-top validation W-T - Control Room walk-through validation S - Simulator validation IPWT - In-plant walk-through validation When "N/A" is indicated in any criterion cell, that particular criterion is not validated by the indicated validation method.
T-T W-T S IPWT CRITERIA YES NO N/A LEVEL OF DETAIL Sufficient information to pr'orm specified actions OOO N/A Alternatives adequately described OOO at decision points Labeling, abbreviations, and OOO location information sufficient All necessary information required O O O-to manage emergency condition present Contingency actions sufficient to address the symptoms OOO ?
t Procedures that are referenced or 0- 0 O t branched adequately des.ribed ;
UNDERSTANDABILITY I Easy to read OOO 7 Figures and tables accurate and OOO easy to read Values on figures and charts easily 00O determined &
Cautions and notes understandable and not excessive OOO N/A Status notes accurate and OOO !
understandable N/A Step sequencing is logically 000 compatible with rules of usage !
i N/A References and branches provide OOO smooth flow through procedure 1
AI-402C Rev. 5 Page 35
ENCLOSU.RE_5 (Page 2 of 3)
EVALUATION CRIIERIA 1 10lLERQC100RE_YALIDAILON (cont'd)
T-T W-T 5 IPWT CRITERIA YES NO N/A PLANT COMPATIBILITY N/A Speciiied actions can be performed [] [] []
in designated sequence N/A Information from plant instrumentation obtainable as
, [] ['] []
specified in procedure N/A Entry conditions are adequate to [] [] []
enable selection of appropriate procedure N/A All information or equipment [] [] []
required to manage the emergency / abnormal condition is specified N/A N/A Control Room instrLment readings [] [] []
and tolerances specified by procedure are consistent with displayed values N/A N/A N/A In-plant instrument readings and [] [] []
tolerances specified by procedure are consistent with displayed values N/A Special tools, keys and equipment [] [] []
specified by procedure are-available and functional N/A Nomenclature specified by procedure [] [] []
matches equipment identified by means of name or number nomenclature tag AI-402C Rev. 5 Page 36
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faCLQSDAE_1 i (Page 3 of 3)
EVALVAUQ!LCRUERIA EQfLERQCEDURLYAI10AILQN (cont'd) i j T-T W-T S IPW CRITERIA YES NO N/A ,
i OPERATOR COMPATIBILITY N/A Stepscanbelerformedwithin-any 000
, specified time intervals 4
N/A Steps shift i be performed by operating OOO
! N/A Actions assigned to specific 000 i
personnel are adequately j coordinated where necessary i
Step sequence can be followed by 000 i operating shift N/A Procedure branches entered at correct point OOO N/A N/A Necessary information not omitted OOO
, by branching I
N/A N/A N/A In-plant actions not hampered by 000 inaccessibility N/A N/A N/A In-plant environment such as lighting, temperature and noise OOO 4 levels do not hamper actions
~
, N/A Communications equipment available and adequate OOO N/A N/A N/A Location information prc,vided for OOO
, equipment infrequ sntly operated or difficult to locate
! COMMENTS:
2 I
4 4
AI-402C Rev. 5 Page 37
ERCLOSURE 6 RULES FOR CQNDUCIING_ SIMULATOR VALIDATIONS I 6.1- Originator:
o Can not be present in the simulator during validation, o can observe validation from the instre tor booth.
o Can participate in post scenario debrief.
6.2 Observers
o Can not offer any comment while validation is in progress, o can offer comment in the form of information during simulator freeze. However, can not actively participate in resolution to noted problems, o Can be involved in post scenario discussions to resolve discrepancies.
6.3 Reviewers
o Participate as normally would during simulator training with the exception that actions may not be taken outside the direction of the procedure. All rules of E0P-13 and operator memory items are expected to be followed, o Focus on performance of the procedure as written. Do not attempt to provide recommendations for improvement while the simulator is-not frozen, o If the procedure causes confusion or is not appropriate for the scenario, then request the simulator be frozen until the issue is resolved.
6.4 The simulator may be frozen to discuss performance aspects of the procedure.
6.5 The simulator may be backtracked-to work out resolutions to procedure problems,
=- -
AI-402C Rev. 5 Page 38
- f. HCL 01URE_Z (Page 1 of 2)
YALIDAl1Q.N-OF IN-PLANT ACTIONS PROCEDURE TITLE:
PROCEDURE NUMBER: REV NUMBER: PRR NUMBER:
VALIDATION REQUIRED: YES NO STEPS SPECIFYING IN-PLANT ACTIONS:
SCOPE OF VALIDATION:
OBSERVER (S): Name (Print) Qualification REVIEWERS: Name (Print) Qualification ORIGINATOR:
Signature /Date MNPO CONCURRENCE:
Signature /Date AI-402C Rev. 5 Page 39
i I
fELOSUBLZ (Page 2 of 2)
YAttoAIION_0E._IN. PLAN 1_AC110NS (cont'd)
DISCREPANCY /5UGGESTED SOLUTION RESOLUTION Y'
No discrepancies noted: O REVIEWT.R(5): Signature Date Revalidation required: Yes O No O Reviewed By:
Manager, Nuclear Plant Operations Date AI-402C Rev. 5 Page 40 (LAST PAGE)