ML20212C061

Rev 2 to Operations Mgt Manual Procedure OMM-006, Emergency Operating Procedure Writers Guide

ML20212C061
Person / Time
Site:	Harris
Issue date:	04/07/1986
From:	CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML18004A404	List: ML20212C055 ML20212C061
References
OMM-006, OMM-6, NUDOCS 8608080124
Download: ML20212C061 (59)

Text

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.t 082 CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT PLANT OPERATING MANUAL VOLUME 3 PART 1 PROCEDURE TYPEt OPERATIONS MANAGEMENT MANUAL NUMBER OMM-006 TITLE EMERGENCY OPERATINC PROCEDURE WRITER'S GUIDE REVISION 2 II 8 APR 1595 APPROVED M h4-N Date

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082 TABLE OF CONTENTS Section Page l

6

. 1.0 PURPOSE 6 l

2.0 REFERENCES

6 3.0 RESPONSIBILITIES 6 4.0 DEFINITIONS /A83REVIATIONS '

8 5.0 PROCEDURE ORGANIZATION AND FORMAT OU E0P WETWORK 8

51 CENERAL STRUCTURE OF EOF NETWORK Basis of EOF Networir, 8 ,

5.1.1 '

9 5.1.2 Use of PATH GUIDE Procedure 9

5.1.3 . Use of FOLDOUT Procedure 9 i 5.2 PROCEDURE ORGANIZATION AND FORMAT OF PATH PROCEDURES Designation and Nushering 9 5.2.1 Revision and Authorisation 9 l 5.2.2 '

Symbols and Format 9 5.2.3 10 5.2.4 Decision Symbol Action Symbol 10 5.2.5 10 5.2.6 Information/ Caution Symbot ,

10

~

5.2.7 Arrow Symbols j Connecting Lines 10 5.2.8 ,

Entry conditions 10 i 5.2.9 operator cautions 11 l 5.2.10 Preparing and Mounting Path Procedures 11 l 5.2.11 Revisions to Path Procedures 11 5.2.12 ,

l 5.3 PROCEDURE ORGANIZATION AND FORMAT OF END PATH AND FUNCTION RESTORATION PROCEDURES 11 5.3.1 Cover Page 11 5.3.2 List of Effective Pages 12 Procedure Body 12 5.3.3 Procedure Identification 12 5.3.4  !

Page Identification 13 5.3.5 5.3.6 Page Numbering 14 5.3.7 Identification of Revised Material 14 i

l 15 5.4 PROCEDURE OECANIZATION AND FORMAT OF PATHCUIDES Cover Page 15 5.4.1 i 15 l 5.4.2 List of Effective Pages Procedure Body 16 l 5.4.3 Procedure Identification 16 i 5.4.4 16 l 5.4.5 Page Identification '

Page Numbering 17 5.4.6 Identification of Revised Material 17 5.4.7 5.5 PROCEDURE ORGANIZATION AND FORMAT OF THE CRITICAL SAFETY 18 FUNCTION STATUS TREE PROCEDURES Designation 18 5.5.1 Revision and Authorisation 18 5.5.2 18 5.5.3 Format connecting Lines 18 5.5.4 Preparing and Mounting of Procedures 18 5.5.5 Revision to Procedures 18 5.5.6

' 19 5.6 PROCEDURE ORGANIZATION AND FORMAT OF FOLDOUT PROCEDURE

- 5.6.1 Cover Page 19 0001-006 Rev. 2- Page 2 of 45

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OS2

- TABLE OF CONTENTS (continued)

Section Page 5.6.2 List of Effective Pages 19 5.6.3 Procedure Body . 20 5.6.4 Procedure Identification 20 5.6.5 Page Identification 20 ,

5.6.6 Page Numbering 21 5.6.7 Identification of Revised Material 21

! 5.7 GENgEAL WRITING TECHNIQUES 22 5.7.1 Page Format 22 5.7.2 Step Numbering and Indenting 22 5.7.3 Step Sequencing 23 5.7.4 Caution Statements 23 5.7.5 Notes. .

23 5.7.6 Calculations 23 5.7.7 Referencing and Branching 24 5.7.8 Style of Espression 24 5.7.9 Instrumentation Values 25 5.7.10 Identification of Equipment, controls and Dispirys 25 5.7.11 Abbreviations, Letter Symbols and Acronyms 26 5.7.12 Level of Detail 26 5.7.13 Instruction Step Length and Content 27 5.7.14 Instruction Column 28 5.7.15 Response Not obtained Column 28 5.7.16 Use of Logic Terma 29 5.7.17 Use of Underlining 30 5.7.18 Component Identification 30 5.8 PRINTED OPERATOR AIDS 30 5.8.1 Units of Mer are 30 5.8.2 Figure, Table and Attachment Numbering 30 5.9 MECHANICS OF STYLE 31 5.9.1 Spelling 31 5.9.2 Hyphenation 31 5.9.3 Punctuation 32 5.9.4 Vocabulary 32 5.9.5 Numerical Values 33 5.10 TYPING FORMAT ' 34 5.10.1 Page Arrangement 34 5.10.2 Heading and Text Arrangement 34 5.10.3 Breaking of Words 34 .

5.10.4 Rotation of Pages 34 5.10.5 Printed Operator Aids ,

34 5.10.6 Table Typing Rules 35 5.10.7 Cautions and Notes 36 5.11 USE OF OPERATOR AIDS 36 5.11.1 Checkoffs 36 5.11.2 Supporting Haterial/ Background Material 36 5.12 MAINTENANCE OF E0P NETNORK 37 5.12.1 A Change to the Emergency Operating Procedures is Identified 37 ONN-006 Rev. 2 Page 3 of 45

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052 TABLE OF CONTENTS (continued)

> Section M 5.12.2 Generic Changes to the Emergency Response Guidelines 37 5.12.3 Processing an Emergency Operating Procedure Change 37 5.13 VERIFICATION AND VALIDATION PROGRAM FOR FUTURE CHANGES TO THE SEMPP E0P 38 6.0 ATTACHMENTS . 39 6.1 COVER PAGE 40

6. 2. PATH PROCEDURE EIAMPLE 41 6.3 PATE SYMBOLS 42 6.4 PAGE FORMAT 43 6.5 SAMPLE ACTION VERB LIST 44 f

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- LIST OF EFFECTIVE PAGES 3858 Revision No.

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M 06 Rev. 2 Pase 5 of 45

052 I

1.0 PURPOSE The purpose of this document is to provide administrative and technical guidance on the preparation of EOPs for the Shearon Harris Nuclear Power Plant. This writer's guide applies to the writing of

' all emergency operating procedures (EOPs). The information contained in the E0Ps should be compatible with the information contained in other plant procedures that support the EOPs.

2.0 REFERENCES

2.1 NUREC-0737, November 1980, " Clarification of the TMI-lction Plan Requirements." ,

2.2 NUREC-0737, Supplement 1, December 17,1983, "Requirtsments for Emergency Response Capability."

2.3 NUREC-0899, August 1982, " Guidelines for the Preparation of Emergency Operating Procedures."

2.4 INPO 82-017, July 1982, " Emergency Operating Procedures Writing Guidelines."

2.5 Westinghouse Owners Group Emergency Response Guidelines, High Pressure Version 2.6 AP-005 Procedures Format and Preparation j

2.7 AP-600 Plant Change Request e

3.0 RESPONSIBILITIES The Manager - Operations is responsible for ensuring that Emergency 2

Operating Procedures are written in accordance with the instructions  :

in this procedure.

4.0 DEFINITIONS / ABBREVIATIONS 4.1 CRITICAL SAFETY FUNCTION STATUS TREES The Critical Safety Function Status Trees have been developed to provide the operator with a systematic and explicit means for ,

determining the safety status of the plant for any emergency situation.

4.2 EMERGENCY RESPONSE CUIDELINES The Emergency Response Guidelines have been prepared by the

' Westinghouse Owner's Group (WOC) so E0Ps written from them can be used by an operator to mitigate the consequences of an emergency without first having to diagnose the event causing the emergency.

The Emergency Response Guidelines are based upon the requirements of

- NUREC-0660, Item I.C.1 and clarified in Item I.C.1 of NUREC-0737.

OMM-006 Rev. 2 Page 6 of 45

OS2 4.3 EMERGENCY RESPONSE GUIDELINES BACKGROUND DOCUMENT The Background Document has been prepared by the Westinghouse Owner's Group (WOC) as a suppcet document for the Emergency Response Guidelines. The Background Document was prepared for the following purposest

1. As a learning tiool.

2. To document the analysi.s and reasoning used in the development -  ;

of the Emergency Response Guidelines.

4.4 END PATE PROCEDURES The End Path Procedures (EPP's) are developed from the Event Specific Guidelines and the Emergency Contingency Action Guidelines. The End Path Procedures can be entered from the Path Procedures, Foldout Pages, oi Function Restoration Procedures.

. 4.5 FOLDOUT PAGES

~

Foldout pages are used-in the Emergency Operating procedure network.

consistent with the foldout page concept developed in the Emergency Response Guidelines.

4.6 FUNCTION RESTORATION PROCEDURES The Function Restoration Procedures have been developed to describe general operator actions necessary to respond to challenges to the plant critical safety functions. These procedures are normally entered via the critical Safety Functions Status Trees, although in certain cases it is possible to entse them directly from the Path Procedures or End Path Procedures.

4.7 PATE PROCEDURES The Path Procedures have been developed to provide the operator with systematic direction and diagnosis of symptoms following a reactor trip or safety injection.

4.8 PATH PROCEDURE GUIDES Path Procedure Guides are written to support the Path Procedures.

• The Path Procedure Cuides are the written basis for the Path Procedures and are written in the two-column format.

OMM-006 Rev. 2 Page 7 of 45

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OS2 5.0- PROCEDURE ORGANIZATION AND FORMAT OF E0P NETWORK 5.1 GENERAL STRUCTURE OF EOP NETWORK 5.1.1 Besis for the E0P Network h EOP network is based on the Westinghouse Owner's Group Emergency Response Guidelines (ERGS). N ERCS are a symptom-based procedure network which was developed as an integrated procedure network. h following items explain the use of the EOF network as an integrated network.

1

1. h E0Ps are an integrated procedure network with a common-entry point based on either a Reactor Trip or Safety i Injection. Once entering the E0P network, all further procedure transitions within the E0Ps will be specifically directed. N E0P network prioritises the operator actions and eliminates the situation where different EOPs amist be implemented concurrently.

2. N EOF network will direct the operator to different procedures depending on the event in progress (i.e., LOCA, SGTR, Spurious SI). Since different events will cause different procedure transitions to be made, the delineation of inusediate and subsequent actions is not made.

3. Verification of automatic actions for different events are covered by different methods depending on when in the overall transient the automatic actions might occur. Since the EOPs are an integrated procedure network which prioritises the operator's actions, the operator will be directed to check the automatic actions when appropriate.

4. h Westinghouse Owner's Group Emergency Response Guidelines identify three (3) procedures as having immediate actions. The three (3) generic procedures ares

! a. E-0, " Reactor Trip or Safety Injection"

b. ECA-0.0, " Loss of All AC Power"

c. FR-S.1, " Response to Nuclear Power Generation /ATWS" f All the actions identified generically as immediate actions are contained on the PATH-1 Procedure. All these actions are readily i available to the operator on the flowpath procedure and are not identified as immediate operator actions.

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f OMM-006 Rev. 2 Page 8 of 45

082 5.1 GENERAL STRUCTURE OF E0P NETWORK (cont.)

AL 5.1.2 USE OF PATH GUIDE PROCEDURES

~in The two-column equivalent procedures which contain the information l to back up the PATH-1 and PATH-2 procedures are included as part of l

' - the EOF network. The PATH-GUIDE procedures are intended to be used 1 during operator training on PATH-1 and PATH-2 procedures; however, they have been included in the EOP network.  !

5.1.3 USE OF POLDOUT PROCEDURE The EOF network will make use of a foldout page procedure as a ,

unique procedure applicable to only the EOF network. The foldout procedure will consist of the various foldout pages referenced in

.the E0P network. Each foldout page contains operator actions that are time independent _(i.e., the operator action should be performed whenever the given conditions'are satisfied). When a foldout page

' applies to an E0P, the applicable foldout page will be identified at the beginning of the EOP.

4 For the control room copy of the E0P's only, any applicable foldouts will be copied on the reverse side of all text pages of the l appropriate EPP's. For other copies of the E0P's all foldouts will j be placed behind the EPP's for reference. This method will provide esse of usage for the control room staff and minimise demands on the plants document reproduction facilities.

5.2 PROCEDURE ORGANIZATION AND FORMAT OF PATE PROCEDURES 5.2.1 Designation and Numbering Each Path Procedure shall be uniquely identified (see Figure 2).

This identification permits easy administration of the process of i

procedure' preparation, review, revision, distribution and operator

! use. There shall be site identification but no unit identification i for the path procedure. Each Path Procedure will be labeled with l

its associated Path Procedure number blocked in the upper left area l ,

(see Figure 2).

f 5.2.2 Revision and Authorization Each Path Procedure shall include the current revision number, ,

approval date and authorized signature. This information shall be located at the upper right of each path procedure (see Figure 2).

5.2.3 Symbols and Format i Path Procedures will utilise standard logic symbols arranged in a

" decision tree" path consisting of information, decision and action j steps designed to aid the operator in systematically responding'to the event in progress. Figure 3 illustrates the construction of symbols.

i .

l 0W-006 Rev. 2 Page 9 of 45 J--

052 5.2 PROCEDURE ORGANIZATION AND FORMAT OF PATE PROCEDURES (cont.)

5.2.4 Decision Symbol This symbol will contain a question which the operator'is to answer YES or NO. N question shall pertain to a plant parameter, setpointe, switch position, or system condition.

1 5.2.5 Action Symbol This symbol vill contain a specific action or verification to be performed by the operator.

5.2.6 Information/ Caution Symbol This symbol will contain information to assist the operators in diagnosing plant conditions. Information/ caution symbols may contain caution statements.

5.2.7 Arrow Symbols Arrows will be used to direct the. operator from one Path Procedure to another or from a Path Procedure to an End Path Procedure or from Path Procedures to a Function Restoration Procedure. Arrows will contain the lettering shown in the example in Figure 3 and may be i

visually " matched" by color-coding.

5.2.8 Connecting Lines h re shall be one basic line width used to guide the operator through the path procedure. N operator should follow this line always entering the symbols at the top and eziting the symbols at the side or bottom.

All lines are equally important. h y represent possible response of the plant for many situations on each path procedure.

No line shall cross or intersect on the path procedures, except where two or more enter the same symbol.

5.2.9 Entry condition h entry conditions for the entire E0P network will be one of the

• following

1. "ANY REACTOR TRIP OR SAFETY INJECTION ACTUATION" or

2. "ANY CONDITION REQUIRING REACTOR TRIP OR SAFETY INJECTION ACTUATION". 1 l

Once the entry condition is set, the operator enters PATH-1 Procedure.

. -i 0101-006 Rev. 2 Page 10 of 45

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OS2 1

i 5.2 PROCEDURE ORGANIZATION AND FORMAT OF PATH PROCEDURES (cont.) ,

4 5.2.10 Operator Cautions Operator cautions shall be included on the path procedures where appropriate. The caution will be enclosed by an information/ caution 4

symbol. It will be placed before the procedural step to which it

applies.

l 5.2.11 Preparing and Mounting Path Procedures Symbols and connecting lines will be professionally drawn using standard drafting instruments.

h path procedure will be mounted on styrofoam or other lightweight boards. Each board will be laminated or covered with a. lightweight plastic material.

5.2.12 Revisions to Path Procedure The revision process for the path procedure requirea the same administrative controls as all other emergency operating procedures.

5.3 PROCEDURE ORGANIZATION AND FORMAT OF END PATE AND TUNCTION RESTORATION PROCEDURES 5.3.1 Cover Page -

Every End Path Procedure (EPP) and Function Restoration Procedure l (FRP) shall have a cover page (see Figure 1). h primary purposes of this cover page are (1) to identify the procedure and (2) to

' identify the authorized revision. The cover page will contain the i following minimum information:

3

1. N full name of the plant.

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2. The procedure type followed by the abbreviation in parenthests. i

)

1 t

i 3. The procedure number.

i 4 The procedure title.

]

! 5. N intest revision number which applies to any part of the ,

l l procedure.

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6. h signature and title of the person approving the latest I revision.

7. h date on which the latest revision of the procedure was approved.

lt i

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0151-006 Rev. 2 Page 11 of 45

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082 5.3 PROCEDURE ORGANIZATION AND FORMAT OF END PATH AND FUNCTION RESTORATION PROCEDURES (cont.)

5.3.2 List of Effective Pages Each End Path Procedure and Function Restoration Procedure will contain a List of Effective Pages as an aid to procedure validation. The List of Effective Pages will list each page of the procedure versus the current revision number for that page. ,

consecutive pages bearing the same revision number may be grouped l together. l Examples LIST OF EFFECTIVE PAGES Page Revision 7 through 9 2  ;

10 through 16 4 l The List of Effective Pages will immediately follow the Cover Page. I 5.3.3 Procedure Body The body of the End Path Procedure (EPPs) and Function Restoration Procedure (FRPs) will be structured to include the following  !

sections:

1. Purpose

2. Operator Actions 5.3.4 Procedure Identification Proper identification of procedures is necessary to avoid errors in selection and implementation. Complete identification of a procedure includes its title, number and type. ,

1. Procedure Title

a. Each procedure will be given a title which accurately reflects its intended purpose. Within this constraint, procedure titles should be kept as short and concise as possible.

l

b. The procedure's title will be repeated at the top of each successive page after page 2. No other carry-over

- information will be supplied.

l OMN-006 Rev. 2 Page 12 of 45

082 5.3 PROCEDURE ORGANIZATION AND F0gMAT OF END PATE AND FUNCTION REST 0gATION PROCEDURES (cont.)

2. Procedure Numbers Each procedure will be assigned a unique and permanent number within its associated book or volume of the Plant Operating Manual. Whenever a procedure is deleted, the associated ~

procedure number will not normally be reassigned for the ensuing 2 year period. If reassignment is made within this ,

I period, consideration should be given to user retraining to avoid confusion or error.

3. Procedure Type The procedure type will be the title or abbreviations of the book or volume to which the procedure is assigned as determined by the Plant Operating Manual Master Indez.

5.3.5 Page Identification ,

Beginning with page 2, the botton of each page of each procedure will bear the procedure designation, current revision number and page number. .

1. Procedure Designation This will be a 2 part designation in the format E0P-III-III ,

XXI Procedure Number III: Procedure' Type Abbreviations o End Path Procedure - EPP o Function Restoration Procedure - FRP Examples:

a. E0P-EPP-005 - designates the fifth in a series of EOP End Path Procedures. , ,

b. E0P-FRP-H.3 - designates the third in a series of EOP Function Restoration Procedures addressing a Loss of Heat Sink (H).

2. Revision Number This information will be supplied in the format Rev. 00 0006-006 Rev. 2 Page 13 of 45

s 082 5.3 PROCEDURE ORGANIZATION AND FORMAT OF END PATE AND FUNCTION RESTORATION PROCEDURES (cont.)

Where "00" is the 1 or 2-digit number of the current revision for the associated page.

j

3. Page Number 4

The page number will appear in the formatt

, Page of j 5.3.6 Page Numbering Each page of each procedure will be numbered sequentially beginning with the Cover Page. The last page of each procedure will be identified as such with the annotation (FINAL PAGE) above or following the page number and the last page of instructions will have the word "-END " following the last instructional step. If~

l

pages are added to a procedure, a complete renumbering of all pages

will be accomplished.

! Likewise, when pages are deleted by revision, a renumbering of the j procedure pages will be accomplished.

5.3.7 Identification of Revised Material Revised material will be identified with a heavy vertical'bar in the 4

right-hand margin opposite the revised test. Vertical bars from any j previous revision to the same page will be deleted. .

j Marking of revisions will not normally apply to:

! o Page identification data o Cover page data 1

o List of Effective Pages o Deleted pages o Data shifted without modification of contents or sequence, as in data shifted to allow for insertion of a paragraph can ,

result in revised pages with no vertical marking.

o Correction of typographical or semantical errors 0006-006 Rev. 2 Page 14 of 45 n ~ __ _

082 5.4 PROCEDURE ORGANIZATION AND FORMAT OF PATE CUIDES 4

5.4.1 Cover Page Each PATE GUIDE shall have a cover page (see Figure 1). The primary purposes of this cover page are (1) to identify the procedure and (2) to identify the authorized revision. h cover page will contain the following minimum information:

1. h full name of the plant.

I 2. h procedure type followed by the abbreviation in parenthesis.

3. h procedure number.

4. The. procedure title.

5. h latest revision number which applies to any part of the procedure.

6. N signature and title of the person approving the latest revision.

7. h date on which the latest revision of the procedure was l approved.

5.4.2 List of Effective Pages I

Each PATE CUIDE will contain a List of Effective Pages as an aid to i procedure validation. h List of Effective Pages will list each page of the procedure versus the current revision number for that l

page. Consecutive pages bearing the same revision numb'er may be grouped together.

Examplet i LIST OF EFFECTIVE PAGES Page Revision

! 7 through 9 2 10 through 16 4 e

1 I N List of Effective Pages.will immediately follow the Cover Page.

. 0001-004 Rev. 2 Page 15 of 45 l -

082 5.4 PROCEDURE ORGANIZATION AND F0gMAT OF PATE GUIDES (cont.)

i

. 5.4.3 Procedure gody The body of each PATE GUIDE will be structured to include the following sections

1. Purpose

! 2. Entry Conditions (PATH-1 GUIDE only)

' 3. Operator Actions 5.4.4 Procedure Identification Proper identification of procedures is necessary to avoid errors in selection and implementation. Complete identification of a

procedure includes its title, number and type.

1. Procedure Title

a. Each procedure will be given a title which accurately i

reflects its intended purpose. Within this constraint, procedure titles should be kept as short and concise as possible.

b. The procedure's title will be repeated at the top of each successive page after page'2. No other carry-over information will be supplied.

1

2. Procedure Numbers I -

Each procedure will be assigned a unique and permanent number within its associated book or volume of the Plant Operating Manual. Whenever a procedure is deleted, the associated procedure number will not normally be reassigned for the ensuing 2 year period. If reassignment is made within this period, consideration should be given to user retraining to j avoid confusion or error.

3. Procedure Type l

The procedure type will be the title or abbreviations of the i

book or volume to which the procedure is assigned as determined by the Plant Operating Manual Master Indez.

1 5.4.5 Page Identification Beginning with page 2, the bottom of each page of each procedure will bear the procedure designation, current revision number and j page number.

l. Procedure Designation This will be a 2 part designation in the format 1

OMN-006 Rev. 2 Page 16 of 45

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032-i 5.4 PROCEDURE ORGANIZATION AND FORMAT OF PATE GUIDES (cont.) .

E0P-GUIDE-K where I will be the number of the PATH procedure to which it applies.

2. Revision Number This information will be supplied in the format Rev. 00 Where "00" is the 1 or 2-digit number of the current revision for the associated page.

3. Page Number The page number will appear in the format Page of 5.4.6 Page Numbering Each page of each procedure will be numbered sequentially beginning with the Cover Page. The last page of each procedure will be identified es.such with the annotation (FINAL PAGE) above or following the page number and the last page of instructions will have the word "-END " following the last instructional step. If pages are added to a procedure, a complete renumbering of all pages.

will be accomplished.

Likewise, when pages are deleted by revision, a renumbering of the procedure pages will be accomplished.

5.4.7 Identification of Revised Material Revised asterial will be identified wich's heavy vertical bar in the right-hand margin opposite the revised text. Vertical bars from any previous revision to the same page will be deleted.

Making of revisions will not normally apply tot o Page identification data o Cover page data o List of Effective Pages o Deleted pages j o Data shifted without modification of contents or sequence, as in data shifted to allow for insertion of a paragraph can

. result in revised pages with no vertical marking.

0006-004 Rev. 2 Page 17 of 45

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082 .

1 5.4 PSOCEDURE ORGANIZATION AND FORMAT OF PATE GUIDES (cont.)

- i o Correction of typographical or semantical errors 5.5 PROCEDURE ORGANIZATION AND FORMAT OF THE CRITICAL SAFETY FUNCTION STATUS TREE PROCEDURES 5.5.1 Designation N Critical Safety Function Status Tree (CSFST) procedure shall be -

_ uniquely identified. This identification permits easy administration of the process of procedure preparation, review, revision, distribution and operator use. There shall be site

• identification but no unit identification for the CSFST procedure.

5.5.2 Revision and Authorisation

$ h CSFST Procedure shall include the current revision number,

approval date and authorized signature. This information shall be

! located at the upper right of the procedure.

5.5.3 Format l h CSFST procedure will use a decision tree format designed 'to aid i the operator in systematically determining the status of the plant's

Critical Safety Functions and direct the operator to any Function Restoration Procedure needing to be implemented.

5.5.4 connecting Lines i

There shall be one basic line width used to guide the operator '

through the CSFST procedure.

l All lines are equally important. b y represent the many different conditions which the plant could be in.

j 5.5.5 Preparing and Mounting of Procedures CSFST procedures will be professionally drawn using standard

drafting instruments.

The CSFST procedure will be mounted on styrofoam or other lightwaight boards. h board will be laminated or covered with a lightweight plastic material. -

5.5.6 Revisions to Procedure j h revision process for the CSFST procedure requires the same 1

administrative controls as all other emergency operating procedures.

}

l l

l j 0006-006 Rev. 2 Page 18 of 45

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082 -

5.6 PROCEDURE ORGANIZATION AND FORMAT OF FOLD 0UT PROCEDURE

- 5.6.1 Cover Page h Foldout Procedure shall have a cover page (see Figure 1). The primary purposes of this cover page are (1) to identify the 1 procedure and (2) to identify the authorised revision. The cover l page will contain the following minimum informationt l

)

1. N full name of the plant. l

2. N procedure type followed by the abbreviation in parenthesis.  ;

I

3. N procedure number.

i 4. N procedure title.

5. The latest revision number which applies to any part of the procedure.

l 6. h signature and title of the person approving the latest revision.

i I 1 7. N date on which the latest revision of the procedure was

) approved.

5.6.2 List of Effective Pages N Foldout Procedure will contain a List of Effective Pages.as an aid to procedure validation. N List of Effective Pages will list each page of the procedure versus the current revision numbet for

that page. Consecutive pages bearing the same revision number may j be grouped together.

Examplet

! LIST OF EFFECTIVE PACES l P_sage, Revision I

4 7 through 9 2 i

' 10 through 16 4 I

h List of Effective Pages will immediately follow the Cover Page.

i i

OMM-006 Rev. 2 Page 19 of 45

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032 5.6 PROCEDURE ORGANIZATION AND FORMAT OF FOLDOUT PROCEDURE (cont.)

2 5.6.3 Procedure Body The body of the Foldout will be structured to include the following sections:

1. Purpose

2. Att w ats Each of the foldout pages used in the EOF network will be listed as an attachment to the Foldout Procedure.

5.6.4 Procedure Identification Proper identification of procedures is necessary to avoid errors in f- selection and implementation. Complete identification of a procedure includes its title, number and type.

! 1. Procedure Title

a. Each procedure will be given a title which accurately reflects its intended purpose. Within this constraint, procedure titles should be kept as short and concise as possible. .

, b. The procedure's title will be repeated at the top of each j successive page after page 2. No other carry-aver information will be supplied. .

2. Procedure Numbers l

j Each procedure will be assigned a unique and permanent number within its associated book or volume of the Plant Operating Manual. Whenever a procedure is~ deleted, the associated procedure number will not normally be reassigned for the ensuing 2 year period. If reassignment is made within this i period, consideration should be given to user retraining to

> avoid confusion or error.

3. Procedure Type The procedure type will be the title or abbreviations of the

• book or volumn to which the procedure is assigned as determined by the Plant Operating Manual Master Indez.

5.6.5 Page Identification i Beginning with page 2, the bottom of each page of each procedure will bear the procedure designation, current revision number and i page number.

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l 0006-006 Rev. 2 Page 20 of 45 l l

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032 i

5.6 PROCEDURE ORGANIZATION AND FORMAT OF FOLDOUT PROCEDURE (cont.)

l 1. Procedure Designation This will be a 2 part designation in the formatt E0P-FOLDOUT

2. Revision Number This information will be supplied in the format:

4 Rev. 00 Mbare "00"'is the 1 or 2-digit number of the current revision for the associated page.

i 3.- Page Number The page number will appear in the formatt Page of 5.6.6 Pass Numbering 1

f Each page of each procedure will be numbered sequentially beginning j

with the Cover Page. The last page of each procedure will be

identified as such with the annotation (FINAL PAGE) above or i following the page number and the last page of instructions will have the word "-gND " following the last instructional. step. If pages are added to a procedure, a complete renumbering'of all pages will be accomplished.

l Likewise, when pages are deleted by revision, a renumbering of the procedure pages will be accomplished.

5.6.7 Identification of Revised Material Revised material will be identified with a heavy vertical bar in the right-hand margin opposite the revised text. Vertical bars from any previous revision to the same page will be deleted.

Marking of revisions will not normally apply tot ,

o Page identification data o Cover page data o List of Effective Pages o Deleted pages o Correction of typographical or semantical errors I .

0001-004 Rev. 2 Page 21 of 45

.--_.,.--m n- . - - - ---~:-:1_ - - - - - _ -

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032 i

5.6 P30CEDURE ORGANIZATION AND FORMAT OF FOLDOUT PROCEDURE (cont.)

j o Data shifted without nodification of contents or sequence, as in data shifted to allow for insertion of a paragraph can result in revised pages with no vertical marking.

f 5.7 GENERAL WRITING TECHNIQUES The following section provides a set of standards which will be considered in the preparation of EOPs. In considering these guidelines, writers should keep in mind that some are more important I than others. The writer should always consider the conditions under which the procedure will be implemented, the time available for its implementation and the possible consequences of errors in implementation.

5.7.1 Page Format A dual-column format will be used. The left-hand column is designated for operator actions and the right-hand column is l

designated for contingency actions to be taken when the espected j

response is not obtained. A sample page format is presented in

• Figure 4. The general appearance of procedural pages contribute l significantly to comprehension and the elimination of confusion and 1 error. Information on pages will be displayed with minimum clutter, sufficient spacing between lines and adequate margins. Margins will be sufficient to ensure that binding will not interfere with reading the text and that subsequent reproduction will not. cut off any of j

the procedure content or page identification. .

i 5.7.2 Step Numbering and Indenting i Instructional steps must be readily identifiable by the user. Step i

numbering and indenting are both used to assist-procedure users in i keeping track of step sequence and subordination. The following  ;

i guidelines apply to numbering and indenting

1. Roara numerals will not be used in step numbering. l

2. The same step numbering and indcating scheme will be applied ,

consistently to all procedures.

3. The acceptable numbering scheme ist

] Alpha-numeric 1.

i a.

f 1)

)

! (a) i I Olet-006 Rev. 2 Page 22 of 45

---,-..w.-- ,--,----.,.-------.v cwe - * - ~ , - - - - ..-,ww -

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4 1

082 -

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5.7 GENERAL WRITING TECHNIQUES (cont.)

l 4. Numbering and indenting beyond the sublevels of the example l above should not be used. To do so leads to " vertical" reading and loss of continuity. If necessary, procedures should be reorganised to produce an acceptable number of sublevels.

) 5.7.3 step Sequencing i

Instructional steps will be presented in the sequence most appropriate for the situation. The steps should be presented in the order in which they must be performed..

5.7.4 Caution statements 4

Cautions shall estead across the entire page and shall be  !

I highlighted as shown in the Ezample CAUTION. This placement of cautions helps ensure that the procedure user observes the caution i

before performing the step. A caution cannot be used instead of an

) instructional step. It should be used to denote a potential hasard to equipment or personnel associated with, or consequent to the subsequent instructional step.

i i

Example CAUTION CAUTION Alternate water source for AFW pumps will be necessary if, CST level is low.

_____;.:.:. ._ . ____ __ eesowowe 5.7.5 Notes A note provides descriptive or explanatory information intended to i aid personnel in performing an instructional step. Notes do not contain action steps.

i I

Example NOTE i

j NOTEt RCPs should be run in order of priority to provide normal

! pressurtzer spray. . ,

5.7.6 Calculations 4

Mathematical calculations should be avoided in E0Ps. If a value has l

to be determined in order to perform a procedural step, a chart or .

graph should be used whenever possible. l 1

I l

t OMI-004 Rev. 3 Page 23 of.45 ao .

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032 -

5.7 CINERAL WRITING TECHNIQUES (cont.)

5.7.7 Referencing and Branching Referencing _' ;

ls Lmh

-_; an additional procedure or additional steps will used.

be used as a supplement to the procedure presently being Referencing other steps within the procedure being used, either future steps er completed steps, should be minimised. When only a few steps are involved in the referencing, the steps should be stated in the procedure wherever they are needed. To minimise potential operator confusion, branching will be used when the.

operator is to leave one procedure and use another procedure or step. Use the key words "go to". Therefore, the operator will know to leave the present step and not return until directed.

Use quotation marks to emphasize the title of the referenced or i

branched procedurel examples Go to EPP-20, "LOCA OUTSIDE CONTAIletENT" or go to Step 17. ,

5.7.8 style of Expression '

i Style of expression refers to the way in which instruction steps are written. Instruction steps will be written in a style that presents information in simple, familiar and clear manner. The following <

guidance should be followedt i 1. Use words that are common in ordinary conversation.

2.

User terms personnel are trained to use. and which are standard in the industry.

1

'3. Use action verbs that describe exactly what the user is to do.

Ensure that these verbs are understood and used consistently throughout the procedures. Samples of action verbs are given in Table 1. i

4. Capitalization shall be used in the End Path and Function I

Restoration Procedures for emphasis in the following casest

a. Logic terms will be capitalized and underlined.

3 b. Espected responses (left-hand column of instructions) are capitalised.

c.

I Titles of procedures will be completely capitalized whenever referenced within any procedure.

d.

Operator action steps may be capitalised for emphasis.

1 e.

4 Abbreviations are commonly capitalized. l l

I -

I .

j ONN-006 Rev. 2 Page 24 of 45 *

%_,--_7- -

_ - , . - - - - _ _.._..._,--.,2,,. - - - , , , , , , , _. _ . . , - . .-, - - _ , - - _ _ _ , _ _ . . , . , - - , -

O t

' 082 5.7 GENERAL WRITING TECHNIQUES (cont.)

When there are more than two objects of an action verb, list

->q g' 5. them below the instruction step rather than in the step.

Examplet

9. Open the following valves

a. ICS-240 i b. 13D-10

6. Avoid adverbs that have imprecise meanings.

I Examples use "every 5 minutes until ..."

rather than " frequently until ..."

7. Use short direct sentences. Establish a style of sentence, construction suitable for the procedure type and use it consistently.

j

8. Instructions steps will be limited to one required tion j wherever possible. CThe aver === should noc exceed W Where two actions are included in one step, use the connective AND l rather than two sentences.

5.7.9 Instrumentation Values .

4 When specifying instrumentation values, an appropriate range,

' tolerance, or limit will be used rather than a a single point value. Avoid the use of carats ($" 2) in specifying these ranges.

Instead, use phrases such as " greater than", "less than", and "between".

5.7.10 Identification of Equipment, controls and Display Nomenclature will be used which will assist personnel in quick i

' location or identification of equipment, controls and displays. Use a consistent system of identification which corresponds with component identifications posted on equipment and control panels.

4 Examples 4

8. Open charging Valve ICS-240 t

t J

0006-006 Rev. 2 Page 25 of 45

--~~ --

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t .

OS2 5.7 GENERAL WRITING TECHIQUES (cont.)

5.7.11 Abbreviations, Letter Symbols and Acronyms The use of abbreviations should be minimized because they may be confusing to those who are not thoroughly familiar with them.

Abbreviations may be used where necessary to save time and space and when their meaning is unquestionably clear to the intended reader.

Capitalisation of abbreviations should be uniform. If the abbreviation is comprised of lowercase letters, it should appear in lowercase in a title or heading. The period should be omitted in abbreviations except in cases where the omission would result in confusion.

Letter symbols may be used to represent operations, quantities, .

elements, relations and qualities. I l

An acronym is a type of symbol formed by the initial letter or I letters of each of the successive parts or major parts of a c.ompound t term. Acronyms may be used if they are contained in the Dictionary of Acronyms and Abbreviations for Shearon Harris.

i Abbreviations, symbols and acronyme should not be overused. Their use should be for the benefit of the reader. They can be benefici'al by saving reading time, ensuring clarity when space is limited and  !

communicating mothematic ideas.

i i

! 5.7.12 Level of Detail .

l i Escessive detail in E0Ps should be avoided in the interest of being i able to effectively execute the instructions in a timely manner.

The level of detail required is the detail that a newly trained and licensed operator would desired during an emergency condition.

i To assist in determining the level of EOF detail, the following i

general rules apply:

1

1. For control circuitry that executes an entire function upon i

actuation of the control switch', the action verb appropriate to the component suffices without further ampilfication of how to l

manipulate the control devical for example, "Close Feed Pump A Suction Valve." Recommended action verbs are at followst .

1

a. For power-driven rotating equipment, use Start, Stop.

For valves, use Open, close, Throttle Open, Throttle

^

b.

Close, Throttle.

c. For power distribution breakers, use Synchronise and i Close, Trip.

I i

• ONN-004 Rev. 2 Page 26 of 45

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082 5.7 CENERAL WRITING TECHNIQUES (cont.) .

2. Standard practices for observing for abnormal resulta need not be prescribed within procedural steps. For suample, observation of. noise, vibration, otratic flow, or discharge pressure need not be specified by steps that start pumps.

5.7.13 Instructional Step Length and Content Instruction steps will be short and exact. General rules to be used in meeting these objectives are as follows:

1. Instruction steps should deal with only one idea.

2. Short, simple, sentences should be used in preferences to long, compound, or compiez sentences.

3. Complex evolutions should be prescribed in a series of steps, with each step made as simple as practicable. ,

4. Objects of operator actions should be specifically stated.

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

5. Limits should be expressed quantitatively whenever possible (refer to subsection 5.9.5).

6. Mandatory sequence of steps is assumed unless otherwise stated.

7. Identification of components and parts should be complete.

8. Instruction content should be written to communicate to the user. .

9. Espected results of routine tasks need not be stated.

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

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

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

actions. Operator actions should be related to plant parameters.

12. When additional confirmation of system response is considered necessary, prescribe the backup readings to be made.

l l

l 0001-006 Eev. 2 Page 27 of 45

- _ . - ~ ~ . . .

i -.

OS2 -l l

l 5.7 CENERAL WRITING TECHNIQUES (cont.)

5.7.14 Instruction Column The left-hand column of the two-column format will contain the operator instruction steps and espected responses. The following rules are established for the instruction column, in addition to the _

general rules above.

1. Espected responses to operator actions are shown in ALL CAPITAL-LETTERS.

2. If a step requires multiple substeps, then each substep will have its own espected response.

3. If only a single task is required by the step, then the step contains its own EXPECTED RESPONSE.

'4 . Left-hand column tasks should be specified in sequence as if they could be performed in that manner. The user would i normally move down the left-hand column when the espected response to a particular step is obtained. l i

5. When the espected response is not obtained; the user is ,

espected to move to the right-hand column for contingency  !

instructions. .

5.7.15 Response Not Obtained Column The right-hand column is used to present contingency actions which are to be taken in the event tha't a stated condition, event, or task in the left-hand column does not represent or achieve the espected- i result. Contingency actions will be specified for all steps or I substeps for which the task requirement might not be specified. The following rules apply to the right-hand column

1. Contingency actions should identify directions to override automatic controls and to initiate manually what is normally initiated automatically. ,

2. Contingency actions should be numbered consistently with the espected response / action for substeps only. A contingency for a single-cask high-level step will not be separately numbered

• but will appear on the same line as its related step.

3. The user is espected to proceed to the next numbered step or substep in the left-hand column after taking contingency action in the right-hand column.

4. As a general rule, all contingent transitions to other guidelines take place out of the right-hand column.

0001-004 Rev. 2 Page 28 of 45 l

.. _.. -- ..i

082

• 7 . CENERAL WRITING TECHNIQUES (cont.)

5. If a contingency action cannot be completed, the user is .

expected to proceed to the next step or substep in the i left-hand column unless specifically instructed otherwise.

When writing the procedure, this rule of usage should be considered in wording subsequent left-hand column instructions.

6. If a contingency action must be completed prior to continuing, that instruction must appear esplicitly in the right-hand coluna step or substep.

5.7.16 Use of Logic Terms The logic terms AND, OR, NOT, IF, IF NOT, WHEN and THEN are often necessary to describe precisely a set of conditions or sequence of actions. When logic statements are used, logic terms will be highlighted by using capitalisation and underlining. All letters of '

the logic terms shall be capitalised and the words will be

. underlined.

The use of AND and OE within the same action shall be avoided. When AND and OR are used together, the logic can be very ambiguous.

Use other logic terms as follows:

1. When attention should be called to combinations of actions or conditions, the word AND will be placed between the description of each condition. The word AND will not be used to join more than tkree conditions. ,If four or more conditions need to be joined, a list formet shall be used.

2. The werd OR will be used when calling attention to alternative combinatiEs of conditions.

3. When action steps are contingent upon certain conditions or combinations of conditions, the step will begin with the words E or WHEN followed by a description of the condition or conditions (the antecedent), a comma, the word THEN, followed

' by the action to be taken (the consequent). WHEN is used for an espected condition. I_F,is used for an unexpected but possible condition.

4. Use of IF NOT should be limited to those cases in which thm

' operator must respond to the second of two possible conditions. IF should be used to specify the first condition.

5. THEN will not be used at the end of an action step to instruct the operator to perform the nest step because it runs actions together.

0031-006 Rev. 2 Page 29 of 45 s __ . _ _ _ - m

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082

. l 5.7 GENERAL WRITIyc TECHNIQUES (cont.)

5.7.17 Use of Underlining Underlining will be used for emphasis of logic terms, CAUTION headings and NOTE headings. Underlining may also be used if additional emphasis of action is needed.

i 5.7.18 Component Identification With respect to identification of components, the following rules are to be followed

1. Equipment, controls and displays will be identified in operator language (coasson usage) terms. These terms may not always match engraved names on panels but will be complete.

2. When the engraved names and numbers on panel placards and alarm windows are specifically the item of concern in the procedure, the engraving should be quoted verbatim and emphasized by using al capitals.

3. The names of plant system titles are emphasized by initial capitalization. When the word " system" is deleted from the title because of brevity and is understood because of the contest, the title is also emphasised by initial capitalization.

4. If the component is ieidos used or it is felt that the component would be difficult to find, location information should be given in parentheses following the identification.

5.8 FRINTED OPERATOR AIDS When information is presented using graphs, charts, tables and  !

figures, these sids must be self-explanatory, legible and readable '

under the expected conditions of use and within the reading precision of the operator.

5.8.1 Units of Measure Units of measure on figures, tables and attachments should be given for numerical values that represent observed or calculated .

results. A virgule (slant line) should be used instead of "per";

examples ft/sec, lbs/hr.

5.8.2 Figure, Table and Attachment Numbering Sequential Arabic numbers should be assigned co figures, tables and attachments in separate series and placed at the top of its associated page. The sequence should correspond with the order of chair reference in the text. The symbol "f" and abbreviation "No."

are unnecessary and should not be used. The number alone suffices.

l l

OMK-CD6 Rev. 2 Page 30 of 45

OS2 5.8 PRINTED OPERATOR AIDS (cont.) ,

Examples: Figure 1, Figure 2, etc.

. Table 1, Table 2, etc.

Attachment 1, Attachment 2, etc.

Page identification for attachments, figures and. tables should consist of the following information that identifies (1) procedure number, (2) attachment number, (3) page number and (4) revision number. Page numbering of attachments sho'uld meet the requirements i of Subsection 5.3.6.

1 5.9 MECHANICS OF STYLE 5.9.1 Spelling Spelling should be consistent with modern usage. When a choice of i spelling is offered by a dictionary, the first spelling should be l used. j

\

5.9.2 Hyphenation j Hyphens are used between elements of a compound word when usage l calls for it. The following rules should be followed for '

hyphenation.

1. When doubt exists, the compound word should be restructed to

avoid hyphenation.  ;

2. In compound numerals from twenty-one to ninety-nine; example

! one hundred thirty-four.

3. In fractions; examples one-half, two-thirds.

4. In compounds with "self"; examples 1 self-contained, self-lubricated.

5. When misleading or awkward consonants would result by joining the words; example: bell-like.

i 6. To avoid confusion with another word; examples: re-cover to prevent confusion with recover, pre-position to avoid confusion with preposition. .

! 7. When a letter is linked with a nount examplest X-ray, 0-ring, I-bolt, I-baam.

8. To separate chemical elements and their atomic weight; examples: Uranium-235, U-235.

l l

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! 0101-006 Rev. 2 Page 31 of 45 l

052 5.9 MECHANICS OF STYLE (cont.)

5.9.3 Punctuation Punctuation should be used only as necessary to aid reading and prevent misunderstanding. Word order should be selected to require a minimuin of punctuation. When eatensive punctuation is necessary for clarity, the sentence should be rewritten and possibly made into several sentences. Punctuation should be in accordance with the following rules:

1. Brackets Brackets shall be used to indicate values that should be used if adverse containment conditions are present.

i Examplet Verify RCS Subcooling - CREATER THAN 25'F [45'F]

2. Colon Use a colon to indicate that a list of items is to follow, for i

a===ple; Restore cooling flow as follows:

3. Comma Use of many cosames is a sign the instruction is too comples and needs to be rewritten. Therefore, evaluate the number of i

commas to ensure the instruction is not too comples.

I Use a comma after coMition phrases for clarity and ease of reading. -

Example WHEN level decreases to 60 inches, THEN start pump

4. Period Use a period at the end of complete sentences and for indicating the decimal place in numbers.

5.9.4 Vocabulary Words used in procedures should convey precise understanding to the ,

trained person. The following rules applyt

1. Use simple words. Simple words are usually short words of few syllables. Simple words are generally common words.

2. Use common usage if it makes tho' procedure easier to understand.

3. Use words that are concrete rather than vague, specific rather i chan general, familiar rather than formal, precise rather than

. blanket. .

0100-006 Rev. 2 Page 32 of 45

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

i 052 I

5.9 MECHANICS OF STYLE (cont.)

4. Define key words that may be understood in more than one sense.

5. Verbs with specific meaning should be used. Examples are listed in Table 1.

6. Equipment status should be denoted as follows:

a. Operable - Means that a system, subsystem, train, component, or device is espable of performing its specified function (s) and all necessary attendant instrumentation, controls, electrical power, cooling or seal water, tubrication or other auxiliary equipment required for the system, subsystem, train, component, or device to perform its function (s) are also capable of performing their related support function (s).

b. Operating - This word means that a system, subsystem, train, component, or device is in operation and is performing its specified function (s).

c. Available - This words mes.ns that a system, subsystem, train, component, or oevice is operable and can be used as desired; however, it need not be operating.

5.9.5 N:americal Values The use of numerical values should be consistant with the following rules .

1. Arabic numerals should.be used.

2. For numbers less than unity, the decimal point should be preceded by a zeros for examplet 0.1.

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

4. Acceptance values should be specified in-such a way that addition and subtraction by the user are avoided if possible.

This can generally be done by stating acceptance values as .

Limits. Examples: 510*F maximum, 300 psig minimum, 580*F to 600*F. Avoid using 2.

5. Engineering units should always be specified for numerical values of process variables. They should be the same as those ,

used on the control room displays, for examples psig instead of psi.

1

\

0001-006 Rev. 2 Page 33 of 45

. _ _ _ _ . . j

052 5.10 TYPING FORMAT 5.10.1 Page Arrangement

1. Page margins are specified to be 1% inch on the left-hand side, lh inch on the right-hand side, a nd 1 inch at the top and bottom.

2. Page identification information (refer to Subsection 5.3.5) will be in the bottom left corner.

3. The 84-inch edges shall constitute top and bottom of pages and text. Tables and figures shall be readable with the page so arranged. Rotation of printed matter should be avoided for emergency operating procedures. Refer to Subsection 5.10.4 if rotation is necessary.

5.10.2 Heading and Test Arrangement

1. Section numbers shall be typed at the left-hand margin.

2. Two line spaces shall be allowed between headings and respective text.

3. Three line spaces shall be allowed between steps whenever  ;

possible.

I

! l

4. Test will be typed using single line spacing.

5.10.3 Breaking.of kords Breaking of words (hyphenated and continued on the next line) shall be avoided to facilitate operator reading.

5.10.4 Rotation of Pages If pages need to be rotated, the following rules will be followed:

1. The top of ths page with rotated print is the normal left-hand edge.

2. The page margins do not rotate.

3. Page identification and numbering will not be rotated.

5.10.5 Printed Operator Aids Figures include graphs, drawings, diagrams and illustrations.. The following rules are establishedt

1. The figues number and its title are placed three line spaces above the figure field (refer to subsection 5.5).

. 2. The figure field must not violate specified page margins.

l l OMN-006 Rev. 2 Page 34 of 45 t ~ _ . - , . ~ -_ a- - --

052 5.10 TYPING F0gMAT (cont.)

3. The figure field should be of sufficient size to offer good readability.

4. The essential message should be clear; simple presentations are preferred.

5. Numbered grid lines should be bolder than unnumbered grid lines.

'"' Labeling of items within the figure should be accompanied by 6.

arrows pointing to the item.

i

7. The items within the figure should be oriented naturally insofar as possible. For example, height on a graph should be along the vertical ania.

8. In general, items within the figure should be labeled. Typed labels should be used. .

i 9. All lines in figures should be reproducible.

5.10.6 Table Typing Rules

1. Type style and size should be the same as that for the rest of the procedure.

2. The table number and title should be located above the table field and three line spaces below preceding text.

r r

3. A heading should be entered for each coluses and centered within the column; the first letter of words in the coluut headings

- should be capitalised.

Horizontal lines should be placed above and below the column 4.

headings; vertical lines, while desirable, are not necessary or required.

5. Tabular headings should be aligned as follows:- l

a. horizontally by estated entries 1

b. vertically by decimal point for numerical entries

c. vertically by first letter for word entries; however, run-over lines should be indenced three spaces

6. Double spacing between horisontal' entries suffices to segregate such entries; although horizontal lines may also be used if desired. If used, double horizontal lines should be used above and below the colunz headings.

0001-006 Rev. 2 Page 35 of 45

OS2 5.10 TYPING FORMAT (cont.)

7. There should not be a vacant cell in the table. If no entry is necessary, "N/A" should be entered to indicate not applicable.

5.10.7 Cautions and Notes All notes and cautions should be distinguishable from the rest of

. the text by using the following formatt

1. h heading CAUTION should be capitalised, centered and placed l two lines spaces below the preceding test.

2. The test of the caution should be block format with single line spacing. . h caution test will extend from margin-to-margin and two line spaces below the heading.

3. h test of the note should be block format with single line spacing. h note test is preceded by the word NOTE in capital letters and underlined. Note margins are the same as the page margin. N note text will begin two line spaces below the preceding step. +-

4. Cautions shall be.further highlighted by a line of asterisks one space above the heading and one line space below the last  ;

line of the test. ,

5. Isamples are presented in Subsection 5.7.4 ard 547.54 5.11 USE OF, OPERATOR AIDS Operator aids will be used to assist the operator in carrying out the required EOF action.

5.11.1 Checkoffs In light of the fact that the operator must have a method of keeping track of the current step of the EOP while they are performing the designated action; a set of mylar-coated path; procedures will be available in the Control Room with a grease pencil or water marker to checkoff the designated operation action. ,

5.11.2 Supporting Material / Background Material ,

Material needed to carry out actions in the EOPs, but which cannot be included, should be appended to it.

0181-006 Rev. 2 Page 36 of 45

052 5.12 MAINTENANCE OF EOF NETWOgK l

5.12.1 A Change to the Emergency Operating Procedures is Identified

1. If the change is a result of generic changes to the Emergency Response Guidelines, then go to Subsection 5.12.2.

i 2. If the MCs has been modified and a change to the Emergency Operating Procedures is needed, so to Step 3. Otherwise 30 to Subsection 5.12.3, Step 8.

3. A plant specific change to the Emergency Operating Procedures-is desired.

a. Evaluate the proposed change against the generic guidelines (Emergency Response Guidelines Executive Volume and Background Documents) to determine if-the intent of the generic guidelines is altered. If the generic intent is not altered, got to Subsection 5.12.3.

b. If the intent of th's generic. guidelines is altered, the proposed change must be-reevaluated to resolve the discrepancy between the generic' guideline and the proposed

1. change. The proposed change must be modified so that it

' does not alter the intent of the generic guidelines.

] 4. Go to Subsection 5.12.3.

5.12.2 Generic changes to the Emergency Response Guidelines l 1. Evaluate the effect of the generic change on the SHNPP Emergency Operating Procedure. If the generic change has no effect on emergency operating procedures, then perform the i

following:

a. Update the Emergency Response Guidelines.

b. Update the EOP Transition Document.

2. If the generic change affects the SHNPP Emergency Operating Procedures, then perform the following:

a. Update the Emergency Response Guidelines. .

b.. Go to Subsection 5.12.3.

5.12.3 Processing an Emergency Operating Procedure Change

1. Prepare the change using the following for guidance

- AP-005, " Procedures Format and Preparation" 2

- OMM-006, " Emergency Operating Procedures Writer's Guide"

- Emergency Response Guidelines, High Freesure, Revision 1 Version 0006-006 Rev. 2 Page 17 of 45

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OS2 5.12 MAINTENANCE OF E0P NETWORK (cont.)

2.- Determine if the proposed change affects the placement or removal of EAL Flags in the Emergency Operating Procedure network. If the EAL flags are affected, update the

" Explanation for Emergency Action Level Flags in SHNPP EOPs" document.

If the Critical Safety Function Status Trees will be changed,

~

3.

fill out a Plant Change. Request, per AP-400, to have the SPDS updated. The procedure version should be implemented with the I

SPDS.

4. Compare the proposed change to existing Emergency Operating i Procedures for consistency in style and format.

5. Perform a human factors evaluation of the proposed change to verify the change is acceptable.

6. Process the change in accordance with'AP-006, " Procedure Review and Approval".

7. Once approved, the change must be evaluated to see if any Verification and Validation is required. Refer to Section 5.13 and update the " Determination of Any Additional Verificatica and Validation" book as appropriate.

8. Update the applicable sections of the SENPP E0P Transition Document.

9. Determine if the change to the Emergency Operating Procedures has affected any instrumentation or controls previously .,

identified in the EOF Transition Document. If change adds, deletes or alters any instrumentation or controls, then the SHMPP Task Analysis Documentation must be updated.

5.13 VERIFICATION AND VALIDATION PROGRAM FOR FUTURE CHANCES TO THE SHNPP EOPS

1. The Operations Engineer is responsible.

2. Verification and Validation (V&V) is required when a change to a SENPP procedure alters the intent of the procedure. .

3. The V&V program should demonstrate the following objectives are satisfied:

a. That the.EOPs are technically correct, i.e., they j

accurately reflect the WOG Emergency Response Guidelines.

b. That EOPs,are written correctly, i.e., they accurately I reflect the SENPP Emergency Operating Procedure Writer's Cuide.

OMM-006 Rev. 2- Pase 38 of 45

l 052 1

5.13 VERIFICATION AND VALIDATION PROGRAM FOR FUTURE CHANCES TO THE SHNPP E0PS (cont.)

c. That E0Ps are usable, i.e., they can be understood and followed without confusion, delays, and errors.

d. That there is a correspondence between the procedures and '

the control room / plant hardware, i.e., control equipment / indications that are referenced are available (inside and outside of the control room), use the same designation, use the same units of measurement, and operate as specified in the procedures.

e. That the language and level of information presented in the EOPs are compatible with the minimum number, qualifications, training, and experience of the operating staff.

f. That there is a high level of assurance that the procedures will work, i.e., the procedures correctly guide the operator in mitigating transients and accidents.

4. The V&V program should make use of one or a combination of the following methods:

a. Simulator

b. Table-Top

c. Control Room Walk Through

5. The personnel involved in the V&V program should be Licensed Operators, Shift Technical Advisors, and Operations Engineering Staff.

6.0 ATTACHMENTS 6.1 COVER PACE 6.2 PATH PROCEDURE EXAMPLE 6.3 PATH SYMBOLS 6.4 PACE FORMAT 6.5 SAMPLE ACTION VERS LIST

)

OMM-006 Rev. 2 Page 39 of 45

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082 Figure 1: Cover Page EOrur Cea0LDes POWER & Lim Cowelff SE AAWI 543RIS IRIC12AR POWER FIdfrr PIdiff INERATDs utim&L )

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00st-006 Rev. 2 Page 40 of 45

052 Figure 2: Path Procedure Example esmesowniesumanicomenm.wr suviseen ag -

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052 Figure 3 PatitSymbols DEC4880N SYtsSOL goo YES A., .,

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-Page 43 of 45 I

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082 TABLE 1.0 SAMPLE ACTION VERS LIST ,

Verb Meanins/ Application Adjust To regulate or bring to a more satisfactory state, for example,

" adjust charging pump speed, as necessary".

Align- To place a system in proper or desired configuration for'an intended purpose, for example, " ALIGN the system for normal charging".

Allow To permit a stated condition to be achieved prior to proceeding, for example, " allow discharge pressure to stabilize".

Block To inhibit an automatic actuation. Example: " Block SI actuation".

Check To perform a physical action which determines the state of a variable or status of equipment without directing a change in status such as " check for satisfactory tube oil level".

Complete To accomplish specific procedural requirements, for example,

" complete valve checkoff list "A", " complete data report QA-1",

"complace steps 7 through 9 of Section 3".

Control To manually operate equipment as necessary to satisfy guideline requirements. Example: " Control pressuriser level".

Establish To make arrangements for a stated condition, for example,

" establish communication with control roce".

Initiate To begin a process (begin is preferred).

Isolate To close one or more valves in a system for the purpose of 1 separating or setting apart a complete system or a portion of the system from the rest, for example, " isolate interruptible instrument air header".

Inspect To measure, observe, or evaluate a feature or characteristic for comparison with specified limits; method of inspection should be included, for example, " visually inspect for leaks". .

Maintain To keep in an existing state, for example, " Maintain steam generator level in the narrow range".

Monitor Similar to " check", except implies a repeated function.

Open To change the physical position of a mechanical device, to the open position so that it allows an unobstructed position which permits access of flow, for example, "open valve ICS-240", or prevents passage of electrical current.

0006-006 Rev. 2 Page 44 of 45

_ _ _ , ,.y ,y .

o . s ~ . . . . . .

082 TABLE 1.0 (continued)

Verb Meaning / Application Place To put in a particular position, for example, " Place steam dump in pressure control mode".

Record To document specified condition or characteristic, for example,

" record discharge pressure".

Reduas To cause a parameter to decrease in value, for example, " Reduce '

steen generator pressure using PORVs".

Set To physically adjust to a specified value on adjustable feature, for example, " set turbine generator speed to 1800 rps".

Shut To change the physical position of a mechanical device to the shut position so that it prevents fluid flow or permits passage of electric current, for example, " shut valve ECV142".

Start To energise an electro-mechanical device by manipulation of a start switch or button, for example, " start ... pump".

Stop Opposite of start, for example, "stop ... pump".

Synchronize To make synchronous in operation, for example, " Synchronize the Diesel Generator to the (E) Bus".

Throttle To operate a valve in an intermediate position to obtain a certain flow rate, for example, " throttle valve ICS-240 to Trip To manually activate a semi-automatic feature, for example,

" trip breaker ...".

Vent To permit a gas or liquid confined under pressure to escape at a vent, for example, " vent ... pump".

Verify To prove to be true, exact, or accurate by observation of a condition or characteristic for comparison with an original or procedural requirement, for example, " verify discharge pressure".

0006-004 Rev. 2 Page 45 of 45

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Enclosure 4 DETAILED COMMENTS e

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GENERAL COMMENT

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1. Referencing and Branching

, The SHNPP,EOP network utili=es a. common entry point for all procedures,-with transitions to all other EDPs taking place out of the Path 1 Procedure. The system includes numerous transitions within and between all procedures. Therefore, it is particularly important that'the definitions and instructions provided in the writer's guide on referencing and hranching be clear and consistent. At present the guidance provided is not sufficient to ensure efficient movement in and between procedures by the operators. In addi ti on, the EOPs reviewed do not reflect implementation of the instructions which have been provided in the writer's guide on referencing and branching.

The-following aspects of referencing and branching should be addressed: t

a. The writer's guide should be expanded to include clear

. definitions of referencing and branching and examples of the use and format of each. .

j b. In order to sufficiently emphasize GO TO statements, we recommend that the words be'capitali:ed.

c. If it is necessary_to branch to a step in another procedure, the procedure number, procedure title, and the entire step number should be included in the reference, e.g., GO TO EPP-20, "LOCA OUTSIDE CONTAINMENT," Step 17.b.

d. Because transitions to other procedures or sections or procedures can be disruptive and confusing, some method for easily identifying sections ce subsections, such as tabbing, should be specified.

e. The writer's guide states that "as a general ruie," all-contingent transitions will occur from the right hand column. The writer's guide should specifically discuss the expected situations in which contingent transitions may occur from the left hand column.

f. A review of several of the SHNPP EOPs indicates that the guidance provided in the writer's guide on referencing and branching has not been consistently. applied. In addition to the use of the words "Go To," the EOPs use

" Reference," " Refer to," " Return to," and " ...using..."

The EOPs should be revised to correspond with the direction provided in the writer's guide.

2. Notes and. Cautions

j- V -

U.- s Cautions are1 statements used:in the EOPs to provide critical

. information about potentially ha ardous conditions and their consequences. Notes provide important' supplemental information intended.to aid personnel-in-performing an: action step. Both are extremely important.in'the clear presentation "of instructions and1information-to operators in,the EOPs.

ThecSHNPP provides accurate definitions 1of cautions'and notes.

in the writer's guide and. notes,Jhowever,.the following.

points.will need to be addressed to ensure that notes and cautions will be clearly and consistently -utilized inithe SHNPP EOP network:

a.- While the~ writer's guide indicates /that actions statements are not to be included in notes and cautions, a review of-'several EOPs evidences a number.of both cautions and notes.in which instructions are provided.

All notes and cautions should be evaluated for content and structure-and changes made'as necessary.

b. A number of caution statements were found~which did.not address a hazardous condition and/or did not-indicate

. consequences. These should be revised.

c. While the information provided in; notes is not'of t h e..

, critical nature of cautions, it.is'estremely;important to-execution of'the procedures. Thus, . emphasi s _ i s required

, to prevent the operator from overlooking the supplemental information. We recommend that1 notes be surrounded by lines, to differentiate from cautions while drawing attention to their content.

d. The information/ caution symbol utilized.in the flowcharts does not allow for differentiation between notes-and cautions. - Because ca'ution statements ' provide inf ormation -

used to-prevent actions-by control room operators which could injure personnel, damage equipment, or endanger public health and safety,.it is important theycbe distinguished from note (information) . statements, which provide less critical informati1on. The writer's guide should be revised so that-the symbols for informati:on-statements and caution statements are different, and so that caution statements are sufficiently-emphasized en flowcharts.

e. The writer's guide.should state that caution and' information statements will be placed on the;flowpath:

-directly before the step to'which.they-apply.

3. Accessibility / Availability

a. Because they will be used.in stressful situations and-under time constraints, EOPs must be accessible to operators and easily identifiable. The current system of:

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. -EOP. storage-and designation should be revised to include 1 prescribed storage location and some sort of clear visual

. difference, such as colored binders, to differentiate EOPs from other procedures.

b. It is important that operators know where to f jnd 'all equipment and controls referenced in the EOPs. Section 5.7.18 ()1) states that identification of equipment, controls and displaps "may not always match engraved names on panels but will be complete." Section 5.7.10 correctly instructs procedure writers to "use a.

consistent system of identification which corresponds with component identification posted on equipment and control panels." The writer's guide should be revised to.

be consistent with Section 5.7.10 and to indicate clear guidelines for including inf ormation on the location of equipment and controls.

4. Legibility The use of flowchart format for the Path Procedure EOPs raises serious legibility issues f or SHNPP. Despite the restriction of detail included on the' flowcharts,- the s. mount of information is still great and by its bulk restricts.the size of symbols and type appearing on the flowcharts.

_ However, in order to the flowcharts to be useful to-operators

~

in times of emergency, it is critical that they be formatted in a legible and clear manner. In this regard, the following

, issues should be addressed in the writer's guide:

a. The type size and symbol size to be used on the flow charts should be defined in the writer's guide.

Consideration should be given to the way the boards will be mounted or used and the environmental conditions, e.g., D.C. lighting.

b. The current use of all capital letters on the flowcharts restricts legibility. A mix of capital and lowercase letters provides a contrast that is much easier to read.

The writer's guide should be revised to indicate that a min of capital and lowercase letters will be used on the flowcharts.

c. The current single spacing of type on the flcwcharts, combined with the bulk of information, restricts the readability of.the procedures. Some way in which space can be provided between the lines-should be defined _in the writer's guide and EOPs prepared in accordance with the instructions. ,

SPECIFIC COMMENTS-t w

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1. Flowcharts .

. Utilization of flowcharts in the SHNPP EOP network is in conflict with a. number of human factors guidelines. In order to try to offset the problems raised by such use, the following aspects of flowchart design and productipn must be addressed * ,

a. When several flowpath lines run parallel to each other, operators may have difficulty following the correct line.

. SHNPP personnel have indicated that flowpaths leading to the same destination will be grouped together, with greater spacing between paths leading to different destinations. This intent must be e::plicitly indicated in the writer's guide.

b. The writer's guide should be expanded to include guidance for the use and formatting of foldouts with Path' Procedures.

c. Movement in flowcharts should correspond to natural reading movement of left-to-right and_ top-to-bottom. The

. writer's guide should include instructions to this effect and should also include directions to minimize upward and/or right-to-left movement. To aid the operator in

, situations where such unnatural movement is necessary, we recommend that some type of directional indicator be used on lines on the flowcharts.

d. The entry point into a flowchart should be clearly indentified so that operators enter the flowpath at the correct point. The writer's guide should be revised to include clear directions on the use of arrows as entry point indicators. In addition, it should be stated that every effort wil) be made to locate entry arrows in positions which correspond to natural reading movement, e.g., move the entry point of Path I to the upper left hand corner of the page.

e. Formatting instructions for the use of arrows as entry point indicators need to be provided in the writer's guide. Guidance on the site, color, the-use cf alpha characters on arrows, and the inclusion of precedure titles on the arrows should be provided. In addition, examples shown should be made consistent with-the directions included in the text of the writer's guide.

f. Decision symbols used on flowcharts should be consistent-in-size, color, and design. The writer's guide should be expanded to include explicit instructions on the location of the "yes" and "no" indicators on decision symbols including a commitment to use the same format in every possible situation (e.g., if the response if "yes,"

movement is down, if the response is "no," movement is to

c: s' the right).

m

g. Flowcharts cannot present as much detail as can be efficiently presented in written procedures. The writer's guide should specifically address the level of detail to be included or excluded in the Path Prcedures.

This level of detail should be adequate for a newly trained operator to use the Path Procedures, but not so great that the~ flowcharts are cluttered and unusable.

h. The writer's guide should be revised to specify the size of the boards on which the Path-Procedures will be printed.

2. Two-Column Format The two column format defined in the SHNPP writer's guide defines the lef t column as an instruction column including expected-responses, and defines the right column as the

" response not obtained" column presenting contingency actions which are to be taken if the expected result is not achieved in the left hand column.This structure is equivalent to the logic sequence, IF (lef t column expected response), THEN (proceed down left column instructions). IF NOT (lef t column expected response), THEN (right column).

A review of a sample of SHNPP EOPs evidenced a number of errors in the use of the two column format:

a. In many cases, an expected response was stated as " CHECK FOR FLOW." The expected response should.be shown as-

" FLOW" or " FLOWING" or a quantative-description of the state expected. The term " CHECK" is an instruction and should be used as such.

b. The instruction " CHECK IF" was found in several of the EOPs. The use of "IF" is unnecessary here, as it is built into the two column format.

c. A number of examples were found in the EOPs where the expected response to an action had not been included in the left column. The EOPs should be reviewed and these statements completed.

3. Writing Instruction Steps

a. Table 1.0 of the writer's guide is a list of acceptable verbs for use in the EOPs. It is critical to the operators' understanding of the procedures that a limited number 1of clearly defined action verbs be used in the EOPs. The EOPs reviewed utilized a great. number of verbs not found in Table 1.0, including "try," " perform," "co,"

" break," " continue," and " rack out." The EOPs and the m.

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, writer's guide should be revised so that'only. approved g

4 verbs _are used inuthe_ procedures.

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b. In some' cases, operators were instructed to perform an~

i. action "as necessary" or "as required.'" Guidabce needs to be provided. defining clearly when~ actions are' necessary or required.

c. Care must be taken to provide . complete instructionsJwhile-not. confusing-.the-operator with:an excess of detail.

Directions such as:"Use-_ f aulted;or. ruptured'-SG"' should be 1 expanded _toLindicate for what; purpose it should.be used.

4

d. In. order to clearly. communicate to-the operator what action is required and to minimize conf usion, instruction i steps should'be limited to one required action. The writer's guide should- be revi -ed.to this effect.

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e. The writer's guide should specifically. address the i definition of and. formatting for the following' types'of

, action steps: (1) steps-that. verify whether the j . objective.of a. task or a, sequence.of-actions has been achievedi (2) ~ steps of a.-continuous _or periodic nature; (3) steps for~which a number of hlternative actions are

b. equally acceptablet and (4) steps performed-concurrently with other steps..

Because of the confusion that.can resujt when logic terms.

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i are used in EOPs, examples'of.the cortrect.use of AND,-IF-i~ NOT,-IF....THEN, and IF....WHEN should be provided in the-writer's guide.

W- s . . c/.ES 1

1. The SHNPP writer's guide-lacks formatting _ instructions for.

the placement of procedure designation, revision number and.

page number on each page of the EOPs. Figure 4 of:the-writer's guide shows the page number located in the bottom f

right-hand corner _ of the page and the procedure designation and revision number located in the bottom left hand corner of a the page. _The text of the writer's guide should be. expanded to: include placement instruction for-those: items >and Ethe.

examples given should be consistents with the written directicns.

2.. To minimize confusion, delays, and errorscin'the' execution-of EOP' steps, the f ollowing concerns should be addressed in _ the- ,

writer's1 guide:

a. Action steps should'be structured to minimizeLthe physical interference between personnel moving around the control room while. carrying out procedure steps' .

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b. Action steps should be organized-and sequences so operators are_not overloaded or underutilized, e.g.,

alternate actions of turbine operator and reactor operator.

c. Actions steps should be structured to avoid unintentional duplication of tasks.

3. An example of each EOP network component (EPP, PPG,-etc.)

should be_ appended to the writer's guide. These should be consistent with the guidance of the writer's guide and could, therefore, be used to illustrate many, if not all, of the guidelines.

4. The writer's guide should provide a clear definition of each component of the EOP network that includes a description of what it is, when it is to be used, who uses it, its purpose, and how it will be used in the control room.

5. It is important that operators know where printed operator aids are located within the EOPs. The writer's guide should be expanded to include explicit directions for the location of printed operator aids in the EOPs.

6. To ensure that the flow of information from procedures to operators is uninterrupted, the writer's guide should state that each action step, caution, and note will be wholly contained on a single page.

7. The writer's guide does not clearly indicate whether each Path Procedure must be contained on a single board. While a review of the actual procedures indicates that Path Procedures are to be limited to a single board, the writer's guide should be expanded to include guidance on this point.

8. The writer's guide does not differentiate between the inclusive and exclusive OR. Although OR will normally be used in the inclusive sense, if priorities cannot be established among equally acceptable alternatives, then it will become necessary to use the exclusive OR. The writer's guide should be expanded to include instructions for the use of both the inclusive and the exclusive OR.

9. The writer's guide should state that instructions should be written as directives. i.e.. in the inperative mode. Several examples should be provided, such as " Start charging pumps" rather than " Charging pumps should be started."

10. In Figure 4, as well as in a number of the EOPs themselves, some operator actions are identified with bullets. There l are no formatting instructions in the writer's guide for the  !

use of bullets in this manner. The writer's guide should be j expanded to include explicit direction for the use bullets  !

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r in the EOPs.

' 11. .To ensure that-EOPs will at all times be legibile, the writer's guide should indicate that no part of the-EOPs will

, be handwritten.

.12. While the actual-CriticallSafety Function Status-Irees' evidence widespread use of; color, the directions.provided in l the writer's guide-for production'of the CSFSTs-do not' i address color usage. The writer's guide should.be expanded. '

+

' to -include directions for the preparation of - CSFSTs that is complete 1and explicit. '

13. In order.to assist the operator in verifying that_s/he is. ,

using the correct procedure, entry conditions should be stated at the beginning of each EOP. . While this may not be necessary for use of'the' flowchart EOPs at.SHNPP, the entry

, conditions should be added to the:beginning of;every ,

non-flowchart EOP and these directions added to.the writer's-l' guide.

. 14. The action verb'" align" is capitalized in the example given

in Table 1.0. The text of the writer's guide'contains no i'nstructions to capitalize action verbs. Table 1.0 should 4-be corrected. -

15. Table 1.0, the list of action verbs, includes the verb

" initiate," but states that "begin is preferred."- "Begin should be included in Table 1.0, and " initiate" dropped from 5 the table.

.i i , 16. Section 5.7.8 of the writer's guide states,'"when two i

actions are included in one step,'use the connective AND-rather than two sentences." The emphasis of' conjunctions as-

, . . logic terms could lead operators to- mistake a list for a logical sequence.- The writer's guide should specify that conjunctions should be formatted in a way.that;they cannot -

be confused with logic terms.

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17. 'Section 5.9.5 (4) of the writer's guide states that addition and subtraction by the user.should be avoided "if possible."'

The writer's guide should be revised to indicate that addition and subtraction should be avoided ~ at. all -times.

18. Sections 5.7.8 (4.d) and 5.7.17 of the writer's-guide state that capitalization and underlining "may" be used for additional emphasis. The overuse of emphasi s techni ques '

4 will detract from their effectiveness. The writer's guide

should discuss the situations in which each emphasis techni que i s to tne used.

19. Section 5.7.8 (5) of the writer's guide, instructs procedure 3 writers to list the objects of an action verb if there are

j. more than two objects. The example given identifies the.

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listed objects with' alpha characters.- . Operator: confusion could result when objects are: identified in'this way,.i;e.,

in the same-manner as:substeps.. The writer's guide should specify another means of_ identification (e.g.,-bullets) to eliminate this source of-confusion.

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TRAINING. PROGRAM t

1. 'The extensive.use of-flowcharts in the EOPs as described in the writer's guide reduces the amount of information that procedures can provide to operators. The training program

'must compensate for this lack of written.information, i.e.,-

the operators knowledge;of' plant procedures must be greater..

A training program description must~be provided which specifically describes how the' training program will maintain

-the high level of operator knowledge necessaryrforlthe;use of

-flowchart EOPs. This program _ description should address training for EOPs. distinct from training'on other plant-operating procedures.

2. The PGP should describe a program of. retraining to be used in-tne event of revision of EOPs, including explicit. designation of how the need for retraining is to be determined-(e.g.,

assignment of an individual to monitor revisions and retraining).

3. Although the PGP states that a simulator will: be used for operator training, the training program description should be expanded to address the following items:

c. Discuss the method to be used to train the operators in areas where the simulator is not'like:the. control room or-does not react like the plant,'and in parts of the EOPs that cannot be run on the. simulator._ .

b. Indicate the use of a wide. variety ofiscenarios including multiple: (simultaneous and sequential)

, failures, to fully exercise the EOPs on-the simulator and thus expose the operators to a~ wide: variety of.EOP uses. l 4.. The PGP should include a commitment to train every: operator- .)

on every EOP prior to EOP implementation-in the control '

room.  !

5. The training: program should . indicate that operators 1 will; perfcrm their. assigned. roles during' training;and that ,

operators will be trained as teams. j

6. The PGPLshould indicate that operators ~willibe evaluated after training and that all operators will be evaluated.

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! VERIFICATION / VALIDATION PROGRAM' i

1. The verification and validation program should1 include a-1

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system for insuring reverification and revalidation of EOPs after revision. .This. system should include specific means for determining when'the reverification / revalidation should take place (e.g., identifying an individual responsible for making the determination) and should address retraining'of operators in connection with'the plant EOP training program.

2. The verification and validation program indicates that a

. combination of'stmulator exercises, table topfreviews, and control room walkthroughs will' be used .in the verification and validation process. It should be expanded to indicate thapfhe simulator validation will be' exhaustive, utilizing scenarios that exercise every aspect of all of the-EOPs.

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3. The verification and validation program should be~ expanded to include a description'of the: criteria to'be_used to select the scenarios to be run during.the validation / verification process. These criteria should be based on what is needed to validate the procedures and.should ensure that' single, sequential, and concurrent failures are-included. :For parts of EOPs that cannot be validated on-the simulator, the criteria for selecting any additional. validation that.may be-needed should be specified.

4. The types of persons involved in the verification and' validation process (i . e. , engineers, procedure writers,.

operations personnel, and human factors experts) and the roles and responsibilities of these individuals should be specified.

5. Section ! of the verification and validation program discusses the comparison of EOPs with control room staffing.

This section should be revised to specifically stnte=th'at verification and validation will ensure.that EOPs are y x compatible with the minimum control room staffing.

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. 6. The verification and validation program description should describe the specific items (i . e. , provide checklists) that are to be verified and validated. This should include appropriate items from'both the plant specific technical

, guidelines and the. writer's guide.

7. .Particular attention should be paid to deviations ~from.and.

additions to the generic technical guidelines that are of safety significance during the verification and validation

-program. The verification and validation-program' description should discuss how the deviations and additions-are to.be.

verified and validated.

8. The verification and validation program should' include a description of the plan by which the adequacy of' control room instrumentation and controls will be determined and a description of the plan by~which'the correspondence between.

EOPs and control instrumentation will be' determined should be

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included (this may be done in conjunction with the Control

. Room Design Review).

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