ML20214W011

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Rev 2 to Procedures Generation Package
ML20214W011
Person / Time
Site: Cooper Entergy icon.png
Issue date: 08/22/1986
From: Pilant J
NEBRASKA PUBLIC POWER DISTRICT
To: Long W
Office of Nuclear Reactor Regulation
References
CNSS865886, PROC-860822, NUDOCS 8706150047
Download: ML20214W011 (148)


Text

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, (' GENERAL OFFICE i

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CNSS865886 August 22, 1986 Mr. William O. Long, Project Manager BWR Project Directorate #2 Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

References:

1) Letter from J. M. Pilant to D. G. Eisenhut, Dated June 29, 1984, (NLS8400179), " Submittal of Procedures Generation Package"
2) Letter from William O. Long to J. M. Pilant, Dated June 20, 1986, " Request for Addition Information (RAD Procedures Generation Package"

Dear Mr. Long:

Subject:

Response to the Request for Additional Information on CNS EOP

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\ Procedures Generation Package In response to your request for additional information on the Cooper Nuclear Station E0P Procedures Generation Package (Reference 2), enclosed find the additional information requested in Attachment 1. Also enclosed is Revision 2 on the Procedures Generation Package (Attachment 2) which incorporates the information presented in Attachment 1.

If you have any questions relating to the additional information supplied or the Procedures Generation Package, please contact me.

Sincerely,

(<s h t . Pilant ,

l Manager, Technical Staff Nuclear Power Group l

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ADDITIONAL INFORMATION REQUESTED FOR THE CNS PROCEDURES GENERATION PACKAGE (PGP) 1.0 PLANT SPECIFIC TECHNICAL GUIDELINES 1.1 EMERGENCY CONTAINMENT VENTING The NRC in its Safety Evaluation Report for Revision 3 of the BWROG EPGs, listed the criteria for defining containment venting pressure as an open issue. The BWROG will address this containment venting issue generically in Revision 4 of the EPGs, estimated to be submitted for NRC approval in August, 1986. In Revision 4 to the BWROG EPGs, the primary containment pressure limit will be based on the lesser of:

Containment Ultimate Strength Vent Path Capability SRV or MSIV Operability The BWROG Decay Heat Removal Committee is developing a report to be e used in the development of plant specific emergency venting procedures. This report to ensure consistency with the latest revision of the EPGs, is to be reviewed by members of the BWROG EPC.

Subsequent to the approval of Revision 4 to the BWROG EPGs by the NRC and the guidance on plant specific venting procedures to be issued by the BWROG Decay Heat Removal Committee, NPPD will update the CNS E0Ps to Revision 4 and develop / revise necessary plant specific venting procedures. The bases used to develop the plant specific procedures for Revision 4 will account for decay heat removal capability, suppression pool swell and hydrodynamic loads, priorities for vent path selection, vent path operability, duct work failure, and effects on equipment because of duct work failure.

Currently, the CNS E0Ps are written following the generic guidelines for containment venting and the determination of primary containment pressure limits contained in Revision 3 of the BWROG EPGs. The Primary Containment Pressure Limit Curve has as its axes primary containment pressure and water level. The CNS curve specifies a primary containment pressure limit of 62 psig at normal primary containment water level. Because primary containment pressure instrument taps are located above the water surface and a higher containment water level increases hydrostatic head exerted upon submerged locations, the pressure limit is derated accordingly on the curve. The derating of the curve is discontinued once the water level of the primary containment reaches the level of the primary containment pressure instrument tap.

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The 62 psig limit is the design pressure limit for the primary containment and was chosen because it was felt that a higher limit could not be justified. The primary containment pressure limit was under discussion at this time by the BWROG EPC. There were thought to be concerns potentially more limiting than the structural capability of the primary containment which should be considered in developing the primary containment pressure limit. Thus, the 62 psig design pressure limit of the primary containment was chosen until more definitive criteria and requirements could be established. This information is now becoming available and gives added assurance that the value chosen for the CNS E0Ps is reasonable.

The report previously referenced, which is being developed by the BWROG Decay Heat Removal Committee, discusses an evaluation conducted to determine suppression pool swell and hydrodynamic loads caused by venting. The suppression pool level swell during the first 1500 seconds following venting of a Mark II containment was evaluated using a best estimate computer code, TRACB04. Calculated results indicated that for a 340,000 cf containment vented at 55 psig through a 24 inch line, the initial pool swell is about one foot, primarily from the downcomer clearing. The calculation shows e that subsequent flashing results in an additional pool swell of less than 3 feet which is accompanied by slow pressure oscillations of less than 1.5 psi magnitude. Based on these results, the impact on the containment load caused by containment venting falls within the containment design bases.

At the time the CNS E0Ps were being developed, no specific guidance was available on vent path selection. Only one vent path was choser.

for the CNS E0Ps and it is outlined in station procedure 5.3.7,

" Post Accident Venting Of Primary Containment". The vent path selected is one which vents the drywell using a one inch Atmospheric Containment Atmospheric Dilution (ACAD) system line which ties into a 24 inch line leading to the Scandby Gas Treatment (SGT) System filtering trains. This vent path was chosen for the following reasons:

Capability to automatically vent the containment at a specified rate of flow.

Capability to automatically vent the containment at a specified containment pressure.

Radioactive release would be minimized by filtering through the SGT System.

The CNS E0Ps and the plant specific venting procedure currently do 4 not have priorities established for vent path selection, and evaluations for vent path valve operability or duct work failure and Attachm:nt 1 i i

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N._ e its results on surrounding equipment have not been conducted. As previously stated however, based on the BWROG EPGs Revision 4 and the work of the BWROG Decay Heat Removal Committee, these concerns and other related containment venting concerns will be resolved when NPPD updates the CNS E0Ps to Revision 4 and develops or revises plant specific venting procedures.

1.2 DOCUMENTATION OF DEVIATIONS FROM BWROG EPG, REVISION 3 Deviations or additions from Revision 3 of the BWROG EPGs which were necessary in developing the CNS plant specific EPGs are documented and justification provided. This information is contained in the EPG Step Documentation. All plant specific values used in the CNS EPGs are documented in the EPG Plant Data Tables. The CNS PGP has been revised to include the EPG Step Documentation and the Plant Data Tables used for development of Revision 2 of the CNS EPGs and Revision 1 of the E0Ps which were implemented in August, 1985.

1.3 COMBUSTIBLE GAS CONTROL Combustible gas control is currently addressed in station procedure 5.3.7, " Post Accident Venting Of Primary Containment". This 4 procedure outlines the appropriate operator actions to be taken to control combustible gas mixtures inside primary containment.

Revision 4 to the BWROG EPGs will include a hydrogen control section. Subsequent to NRC approval of Revision 4 to the BWROG EPGs, NPPD will revise the CNS E0Ps to include the hydrogen control section.

2.0 PLANT SPECIFIC WRITER'S GUIDE 2.1 CONTROL ROOM STAFFING AND DIVISION OF RESPONSIBILITIES AS IT APPLIES TO THE USE OF E0PS The CNS E0P Writer's Guide has been revised to include information on and to address the following concerns relating to execution of E0P steps:

Structuring of E0Ps to ensure E0P steps can be executed adequately by the minimum shift complement.

Structuring the E0Ps to be consistent with the roles and responsibilities of control room operators.

Structuring E0P action steps so as to minimize movement of personnel in the control room while executing the procedural steps.

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  • Structuring E0P action steps to avoid unnecessary duplication of tasks.

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Attach; int 1 a,__p Structuring the E0Ps so that the Shift Supervisor and Control Room Supervisor can monitor required personnel action and be aware of plant status.

E0P simulator pre-validation previously conducted used as the validation participants the minimum number of licensed operators required by Technical Specifications for reactor operation at the time. Final E0P simulator validation used 4 licensed operators as participants which is currently the minimum number of licensed operators required by CNS Technical Specification for reactor operation. No problems related to the above concerns occurred during the E0P simulator pre or final validation.

2.2 SECTION 2.4.b PROCEDURE REVISIONS Station procedure 0.22, " Preparation, Review, and Approval of Emergency Operating Procedure Changes", specifically controls revisions to the E0Ps. This procedure details the process used to ensure revisions are properly implemented and approved. As part of the revisional process, justification for change is provided, conformancy with the Writer's Guide ensured, deviations from the EPGs documented, and verification / validation performed if required.

4 Operator training required on the revision is determined and conducted.

Station Procedure 0.4, " Preparation, Review, And Approval of Procedures", which is used for all other procedural revisions, requires that any station procedure affected by the revision of a specific procedure to be listed. Likewise, station procedure 3.4,

" Station Design Changes", requires procedures affected by a station design change to be listed. Any permanent modification to the control room or the plant in general is documented and done in accordance with Procedure 3.4. These procedural controls will ensure that the E0Ps are revised when affected by other procedural revisions or design changes. Technical Specification changes before implementation require review and approval by the Station Operations Review Committee (SORC). This review and approval process will ensure that the E0Ps are revised as necessary due to Technical Specification changes.

The E0P Writer's Guide has been revised to note the use of station procedure 0.22 for revisions to the E0Ps and to note that the E0Ps are to be revised if necessary based on other procedural changes, design changes, or Technical Specification changes.

2.3 SECTION 7. REPRODUCTION The quality of E0P reproduction is such that copies are legible.

4 The copies of the E0Ps which are distributed to the control room, the Technical Support Center (TSC), and Emergency Operations

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v Facility (EOF), are checked individually to ensure quality reproduction, proper page arrangement, and completeness of page information. The E0P Writer's Guide has been revised to state this.

Station Procedure 0.22 will also be revised to state this.

2.4 SECTION 6.2, PAGE ARRANGEMENT The Writer's Guide has been revised to address margin size in Section 7.2.

2.5 LIST OF EFFECTIVE PAGE REVISIONS The revision numbers on Pages 111, 43, and 44 of Revision 0, dated 4/25/84 of the Writer's Guide have been corrected.

3.0 VERIFICATION AND VALIDATION PROGRAM 3.1 E0P VERIFICATION AND VALIDATION PROGRAMS To ensure technical correctness of the ECPs, the CNS plant specific EPGs were subjected to verification and the CNS E0Ps subjected to both verification and validation.

The verification process of the plant specific. EPGs developed from the BWROG EPGs used the following evaluation criteria:

The CNS EPGs accurately includes only those steps, notes, and cautions which are applicable to CN3.

Deviations from the BWROG EPGs are justifiable and do not compromise the intent of the generic guideline (i.e., there are no deviations that are of safety sigt lficance) .

Data used to establish limits or values in the CNS EPGs are correct and obtained from the proper sources.

Calculations required to develop limits or values in the CNS EPGs have been verified by an independent engineering organization.

The CNS EPGs were verified by comparing them with the following source documents using the evaluation criteria stated above:

BEROG EPG, Rev. 31 CNS EPG Plant Data Tables CNS EPG Appendix C Calculation Report 4

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All discrepancies from the verification of the CNS EPGs, Plant Data Tables, Appendix C Data Tables, or Appendix C calculations were documented and resolutions provided/ approved. If reverification of a resolution was necessary, it was performed in a similar fashion as the original verification.

The verification process used for technical correctness for the E0Ps included a review to ensure that the overall EPG technical foundation (strategy) was not' changed in the EOPs by either elimination, addition, sequences, or alteration of information.

This was accomplished by comparing the E0Ps to the plant specific EPGs and the E0P step documentation which documented and provided justification for any deviations between the plant specific EPGs and the E0Ps.

A control room walk-through was also performed using the E0Ps to ensure:

Instrumentation was available to implement the actions in the E0Ps

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  • The action levels could be read on the installed instrumentation The action level units were in agreement with the installed instrumentation The nomenclature in the E0Ps were in agreement with installed nomenclature on the control room panels All discrepancies resulting from this verification were documented and resolutions provided/ approved. If reverification of a resolution was necessary, it was performed in a similar fashion as the original verification.

Subsequent to the verification of the CNS EPGs and E0Ps and resolution of discrepancies, a validation was performed on the E0Ps The validation process was used to determine if the actions specified in the E0Ps can be followed by trained operators to manage emergency conditions effectively. During validation, the E0Ps were checked for usability and operational correctness. The validation methods used for the EOPs were control room walk-throughs and the simulator. Discrepancies resulting from E0P validation were documented and resolutions provided/ approved. If reverification or revalidation was necessary based on a resolution, it was performed

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in a similar fashion as the original verification and validation.

Attachm:nt 1 It is felt that through the process of verification and validation as described above, the technical correctness of the E0Ps has been ensured. The PGP has been revised to include more detailed information on the verification and validation process used for the E0Ps.

3.2 ITEMS TO BE VERIFIED AND VALIDATED The Plant Data Tables, which lists all specific values or limits in the plant specific EPGs had each item listed subjected to verification. Appendix C Data Tables and calculations used to develop certain specific values or limits listed in the Plant Data Table were also verified. The CNS EPGs and E0Ps were subjected in whole to either verification or verification and validation. The CNS E0P Writer's Guide was verified in whole by the CNS Station Operations Review Committee, a Human Factors engineer, and a General Electric technical editor.

The PGP has been revised to include this information.

3.3 IDENTIFICATION OF PARTICIPANTS IN VERIFICATION AND VALIDATION PROGRAMS S Verification. The verification of the E0Ps was performed in steps:

1) Verification of the plant specific data used in the EPG and the Appendix C calculations. This verification was performed by personnel from the CNS Plant Operations and Engineering Departments to ensure the data was correct.
2) Verification of the Appendix C calculations. This verification was performed by General Electric engineers in San Jose who were knowledgeable on the calculational procedures.
3) Verification of the EPG. The criteria used for personnel selection for EPG verification specifically was to assign personnel for the verification who were familiar with CNS plant operation and individuals independent from the plant organization who were knowledgeable in the CNS E0P development.

An SRO from the Plant Operations Department and two General Electric E0P project engineers were chosen to perform the CNS EPG verification. The responsibilities of the EPG verification team members were to evaluate the CNS EPG with respect to the source documents used for development of the E0Ps, to document the review, and to document discrepancies found during the verification. The CNS Operations Manager then had the responsibility for ensuring resolutions were developed for the

, ~s discrepancies. The Operations Manager approved any necessary

) reverification.

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4) Verification of the E0Ps. The criteria used for selection of E0P verification personnel was to ensure reviewers had plant

. operating experience, understanding of plant hardware, and were knowledgeable of the CNS EPG and the CNS E0P Writer's Guide.

Personnel chosen for E0P verification were from the following organization or backgrounds.

General Electric Engineers General Electric Technical Editors Human Factors Engineering CNS Quality Assurance CNS Operations CNS Training General Electric engineers included the procedure writers and also engineers who were not directly involved in the E0P development, but were knowledgeable on E0P development.

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) The procedure writers were responsible for ensuring that the E0Ps were written correctly and conformed to the EPG and the format specified in the CNS Writer's Guide. In addition, they provided recommendations to the CNS Operations Manager for resolution of the verification discrepancies.

The responsibilities of the E0P Verification Team members were to check the E0Ps for written correctness and technical accuracy by comparing the E0Ps to the scurce documents, to document the review, and to document discrepancies found during the verification. The CNS Operations Manager then had the responsibility for ensuring resolutions were developed for the discrepancies and approved, and for specifying any necessary I reverification.

l Validation. Validation consisted of pre-validation during the i E0P development and a validation of the completed E0Ps. The validation of the completed E0Ps included the use of a simulator and control room walkthroughs. The criteria used in selecting a simulator for the final validation was to minimize any differences between the simulator and the CNS plant design.

Personnel selected for E0P simulator validation were assembled

[ separately into a validation team and the validation team l ,e-~s participants.

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Attachz:nt 1 The validation team was responsible for developing:

Evaluation Criteria Validation Scenarios Validation Participant Training Required Document and Validation Materials The validating team was also responsible during validation assessment to conduct pre-scenario briefings, observation and evaluation, using established criteria during the scenarios, post-scenarios de-briefings, and documentation of validation discrepancies.

Personnel selected for the validation team for E0P simulator pre-validation were GE E0P project engineers and a GE training instructor at the simulator used for pre-validation. Personnel selected for the validation team for the final validation were CNS Training and Operations personnel, a GE E0P project engineer, the GE simulator instructor who participated in the r~  ;'

pre-validation, and a Human Factors engineer.

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The validation participants were responsible for carrying out E0P actions in response to the simulator scenarios, and participating in pre and post-scenario de-briefings.

Validation participants consisted of three licensed operators for the pre-validation; and four licensed operators and two STAS for the final validation.

The PGP has been revised to include more information on the selection criteria and personnel to be used for E0P verification and validation.

3.4 USE OF SCENARIOS l The E0P validating team under guidance of the CNS Operations Manager l and with assistance from the Training Department developed scenarios according to the validation method chosen. Evaluation criteria were developed and detailed scenarios designed to guide validation participants through E0P steps such that the evaluation criteria were addressed. The criteria used for selection and development of initial E0P validation scenarios was as follows:

The full complement of E0Ps must be addressed including multiple failures (simultaneous and sequential).

Scenarios are in sufficient detail to account for the limitations of the validation method.

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V-Scenarios include appropriate background information, initial conditions, sequence of events, and anticipated responses.

It is identified where evaluation criteria are addressed.

Guidance should be given to maximize validating team performance.

Scenarios utilized by other utilities (and accompanying comments) should be reviewed for guidance.

If possible,.a " dry run" of the scenarios should be performed to indicate vhere refinement is required.

Scenarios should take into account differences between the simulator and the CNS control room.

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The PGP has been revised to provide more information on E0P validation scenario selection.

3.5 SIMULATOR VERIFICATION AND VALIDATION

(}. In order to. validate those iteis which were not adequately validated on the simulator or those itemte constituting differences between the simulator and the CNS control room, a control room walk-through validation was performed using the E0Ps. The control room walk-through validation was performed by a validation team and i

validation participants who, through the validation process simulated the actions outlined in each step of the EOPs, evaluated the E0Ps walkthrough using established validation criteria, and documented any discrepancies. Re wlutions for each discrepancy was i

provided/ approved and any reveri!Ication or revalidation performed i

if necessary.

l- The PGP has been revised to specify the method used for those

portions of the E0Ps which could not ba adequately validated on the l generic simulator.

3.6 PLAN FOR CORRECTING AND REVISING EOPs Changes necessary to the E0Ps resultant from the verification /

validation program, or from initial E0P training, were documented on j discrepancy sheets. Resolutions were then provided and approved.

l The CNS Operations Manager was responsible for determining the

( reverification or revalidation requirements based on the extent of j the change.

} Changes to the E0Ps, since implementation, have been done in

{ accordance with Station Procedure 0.22. The need for reverification I

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V) or revalidation of the EOPs because of a revision is determined by an E0P evaluator who is familiar with the E0Ps and the verification / validation program requirements.

The PGP has been revised to include this information.

3.7 COMPATIBILITY OF E0Ps WITH MINIMUM STAFFING The E0P validation program description in the PGP has been changed to indicate that E0P validation accomplished in simulator exercises or control room walkthroughs should use the minimum number of licensed operators for reactor operation as required by Technical Specifications.

3.8 CORRESPONDENCE BETWEEN E0Ps AND INSTRUMENTATION AND C0hTROLS The verification of the CNS EPGs and E0Ps included a control room walk-through with the E0Ps to ensure instrumentation and controls specified in the E0Ps were available in the control room. This walkthrough was previously described in Section 3.1.

In additL n to the walkthrough, a task analysis was performed on the

(N CNS E0Ps as part of the CNS Detailed Control Room Design Review

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) Program (DCRDR). More information on the DCRDR task analysis is contained in Section 3.9.

Both of these verification processes documented any discrepancies identified and resolutions were provided.

The PGP has been revised to include this information and discussion of the DCRDR task analysis.

3.9 CONTROL ROOM OPERATOR INFORMATION AND CONTROL NEEDS The DCRDR E0P task analysis was the method used to identify plant specific information and controls needs to be used as a basis for performing the tasks specified in the CNS E0Ps. This task analysis also verified that all instruments and controls needed for the E0Ps were available.

The DCRDR task analysis utilized the E0P procedures in the identification of plant systems and their functions during emergencies.

In performing the DCRDR task analysis, the entry conditions to emergencies and the operator tasks to control and mitigate the emergency conditions are taken to follow the E0Ps primary operator f -~s actions and any associated contingency actions. Each of the procedure steps, entry conditions or operator actions were listed in

(\s_- ) task analysis data sheets used by the DCRDR' team. Other columns of

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the task analysis data sheets relate to the specification cf the information and controls needs/ characteristics, control room inventory, and suitability assessment of the inventory against the identified needs.

In order to define the information and controls needs/ characteristics for the CNS E0Ps, a human factor engineering model was developed to simulate operators needs and instrument requirements and characteristics. Key steps identified for this j model were:

I E0P Phase' Control Room Needs Alerting - Annunciators Information - Indicating Meters

- Recorders

- Indicating Lights Initiating Actions - Switches (Pumps, Valves and Relays)

- Performing Calculations D - Communication Equipment

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  • Controlling Actions - Controllers For each of the control room hardware needs, specific engineering and human factors characteristics are required for the operator to correctly identify and execute the E0P steps. The characteristics are dependent on the hardware instrument, associated operator action, and the human factor interface with the instrument.

Engineering characteristics of instruments and specific human factor characteristics for operator interface with the instrument were determined and used in the E0P task analysis.

For each of the entry conditions and the E0Ps operator actions listed in the task analysis data sheets, the needs and characteristics of information and controls were completed in advance of conducting a control room task analysis walk-through.

These values were entered in the task analysis data sheets.

During the task analysis walk-through in the control room, the l'

operator read the task, then walked through-the task aspects at the control panel. The information and controls availability and specific characteristics were determined from the control room panels. The following specific characteristics were identified:

Equipment No., Panel No., Parameter, Range Setpoint and Controls' characteristics. This data was documented in the task analysis data

, sheets under the availability heading.

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Verification of the suitability of the control room inventory against the information and controls needs/ characteristic.was performed during the walk-through, and the decision was recorded in the task analysis data sheet. When the suitability criteria were not met, the reason was noted and the human engineering discrepancy was documented in the " Notes" column of the task analysis data sheets.

The PGP has been revised to include a discussion of DCRDR task analysis performed on the CNS E0Ps.

4.0 TRAINING PROGRAM 4.1- U_SE OF SIMULATOR EXERCISES During simulator training, the differences between the simulator and the CNS control room and the effect on performance of the E0Ps were-discussed. This was done prior to performing the training scenarios and during/following each scenario, if necessary.

A wide variety of scenarios was used during Simulator' Training on the E0Ps. The criteria used for simulator scenario selection was:

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\ ) To fully exercise each section of the E0Ps.

To include scenarios which encompass multiple failures.

The anticipated frequency of a certain malfunction at CNS.

The importance of a malfunction as related to a safety event or a malfunction that will cause a safety event.

Related industry operating experience.

Whether the Simulator Training is initial or requalification.

The frequency the evolution is conducted at CNS; i.e.,

infrequent evolutions should be included.

To include those control manipulations outlined in the March 20, 1980, letter from Harold Denton, Director o#

NRC, to all Power Reactor Applicants and Licensees, wt it would require the use of the E0Ps.

To cover those areas where the simulator differed from the CNS control room, and those areas of the E0Ps not adequately O

exercised at the simulator, control room walkthroughs and classroom scenarios were used for operator training. Similar criteria was used in selecting the scenarios for the classroom training.

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'LJ The PGP has been revised to include more description of E0P simulator scenario selection for training and control room walkthrough training.

4.2 USE OF CONTROL ROOM WALK-THROUGHS Simulator and classroom training on the E0Ps was given to all licensed operators, Shift Technical Advisors (STA's) and certain plant management personnel. The control room walk-through training was given to all licensed operators. Station operators were given walk-through training on duties they would be responsible for performing in the E0Ps.

Scenario exercises were not used during the control room walk-through training. Scenarios were used only in simulator and classroom training. Rather than exercising scenarios in the walk-through training, various items not considered adequately covered in the classroom and simulator training, were discussed in detail and instrument and controls related to these items noted while in the control room.

The PGP has been revised to include discussion of the above C information on walk-through training.

f N N') 4.3 INDICATION THAT ALL OPERATORS WILL BE TRAINED All licensed operators received E0P classroom, simulator, and walk-through training prior to the CNS E0P implementation in August, 1985.

The PGP has been revised to include this information.

4.4 INDICATION THAT OPERATORS WILL BE EVALUATED The operators' knowledge and performance of the E0Ps were evaluated in the initial E0P classroom and simulator training.

During operator requalification training, the operators' knowledge and performance of the E0Ps is also evaluated in simulator exercises and classroom training. E0P classroom training or E0P simulator exercises were repeated if deemed necessary based on evaluation of operators E0P performance and knowledge in the initial E0P training.

This is also true of requalification training used fer the E0Ps.

Training necessary for E0P revisions will include appropriate operator evaluation.

The PGP has been revised to include this information on operator

~s s evaluation during training.

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~J 4.5 TRAINING PROGRAM DESCRIPTION During the initial classroom and simulator training on the E0Ps, discrepancies and problems which were detected were documented on training discrepancy sheets. Resolutions were provided and approved for the discrepancies. The operators then received additional training on any changes that were made to the E0Ps. Any E0P reverification and revalidation necessary for implemented resolutions was performed. Discrepancies arising from E0P requal training or training required for E0P revisions will be documented and resolutions provided and approved. Requalification and revalidation of the E0Ps will be performed if necessary.

The PGP has been revised to include this information on training discrepancies and resolutions.

4.6 USE OF CLASSROOM INSTRUCTION The CNS Operations and Training Department will determine operator training needs based on the extent of the E0P revision. No major revisions have been made to the E0Ps since their implementation, but

,__ any major revision to the E0Ps would include not only E0P classroom

(' } training but also simulator and walk-through training. However, due to operational considerations and simulator availability, it may be

's j necessary in order to implement E0P revisions in a timely fashion, to provide initial training on the E0P revision in the classroom only. The classroom training would include a thorough discussion of the E0P revision and its effects, the bases for the revision, a review of Instrument and Control requirements related to the revision, and the use of scenarios and control room mock-ups, if necessary. Oparator knowledge and performance will be evaluated as part of the classroom training. This initial classroom training on the E0P revision would be supplemented later by simulator and walk-through training at the earliest opportunity.

The PGP has been revised to include discussion of training required for E0P revisions.

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Revision 2 i l- August 1, 1986  !

t i-l Note: Revision 2 to the PGP addresses NRC concerns based on their l review of the PGP and reflects

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1 e in general what has actually been performed as part of the CNS E0P program.

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.1 TABLE OF CONTENTS 4 ,

.SECTION Page I .I INTRODUCTION.............................................. 1

.II PLANT SPECIFIC TECHNICAL GUIDELINES....................... 5 1
- III_ ' WRITERS' GUIDE FOR E0Ps................................... 7 i

IV- .E0P VERIFICATION PR0 GRAM.................................. 8  ;

V E0P VALIDATION PR0 GRAM.........................,.......... 17 l

VI E0P TRAINING PR0 GRAM...................................... 22 .

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VII E0P REVISIONS AND REVIEW.................................. 25 i

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! A'ttachments -r 4-1 CNS EPG, Revision-1, May 3, 1985, Step Documentation t'

i l 2 CNS EPG, Revision 1, May 3, 1985, Plant Data Table J

l 3 Guideline for Preparation of Emergency Operating Procedure, j Revision 3, July 21, 1986- t i

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I. INTRODUCTION

[w Nj The purpose of the Procedures Generation Package (PGP) is to describe the development of the Cooper Nuclear Station (CNS)

Emergency Operating Procedure (EOPs). The PGP was developed to meet the intent and requirements of NUREG-0737, Supplement 1.

BACKGROUND The CNS E0Ps were developed following the generic Emergency Procedure Guidelines (EPGs), Rev. 3I, developed by the Boiling Water Reactor Owners Group (BWROG). The E0Ps are considered " symptom orientated" procedures which prescribe actions for conditions that might put the reactor in a degraded condition. Even if many failures are occurring, following the actions for existing plant symptoms will assure an operating path to best control the plant.

Operators are not locked into a specific " event" procedure. If the symptoms change, the operator turns to the appropriate section of-the E0Ps. ,

E0P STRUCTURE AND FORMAT The E0Ps are divided into five sections. The first section is a set of precautions that are applicable at all times. The next four sections are areas of plant operation that are to be constantly-monitored. The titles of these sections are:

G

  • E0P/C - Operator Precautions

~*)

provides a quick overall view of the actions the Operator is expected to take and can be utilized by the station STA or i management to follow the E0Ps. The flow charts show the inter-relationship between the procedures, as the E0Ps address the entire plant situation. The purpose provides a brief statement describing the objectives (s) of each E0P. The entry conditions include only those alarms, indications, operating conditions.

l automatic system actions, or the unique symptoms that tell the j Operator that he should enter an E0P procedure. Operator actions, l except in E0P-4, are stated in each E0P and each control subsection.

The control sections state the actions necessary to monitor and maintain particular parameters (e.g. level, pressure, power) and (g g) give direction to the Operator to mitigate degradation of plant L/ performance and restoring plant conditions to normal.

Page 1 of 25

l. ,

E0P SECTION DESCRIPTION s

EOP/C (Operator-Precautions) '

The purpose of SectioniEOP/Csis to provide the Operator

. -with a' list of cautions which are applicable at all times-when executing the E0Ps. These cautions are general-cautions and provide directions, information, and warnings applicable to the E0Ps as a whole. E0P/C consists of'nine Operator cautions and are located at the front of Section

.EOP-1.

!' ~

E0P-1-(RPV Contro'l) .

The purpose of Section E0P-1 is to provide the Operator

,- with the direction necessary to' maintain adequate core cooling, shut down the reactor, and cool down the RPV to b" shutdown conditions during the' presence of. symptoms indicating ~an emergency condition. The entry conditions

[. -of EOP-1 have the Operator monitor RPV water.. level, RPV pressure, RPV power level. and_drywell pressure. . If any _

~

4 one_of the acceptable limits are violated, the Operator is 4 directed to a series of initial' actions followed by the

. - three major control sections. The three control sections and-their: abbreviated designations are:

1. 'RC/L - RPV Control - Water Level
2. RC/T - RPV Control - Pressure
3. .RC/Q - RPV Control - Power Section RC/L rastores and maintains RPV water level within a satisfactory range, Section RC/P c'ontrols reactor pressure and cools down the RPV to cold shutdown conditions, and Section RC/Q shuts down the reactor.-

All three> sections are inter-related and therefore must be executed concurrently.

Barring further degradation of plant conditions, control Sections RC/L and RC/P will ultimately' direct the Operator to proceed to cold shutdown conditions =in accordance with normal operating procedures. Section RC/Q will direct the Operator to the scram procedure. If plant conditions cannot be stabilized, the Operator will be directed to various contingencies which will prescribe actions appropriate for more degraded conditions.

E0P-2 (Primary Containment Control) '

,The purpose of Section E0P-2 is to provide the Operator with the direction necessary to maintain primary containment integrity and protect equipment in the primary containment.

Page 2 of 25

The entry conditions to E0P-2 have the Operator monitor

_ suppression pool water level and temperature and drywell

-( } pressure and temperature. If any of these conditions are

\'

violated, the Operator is referenced to four control

. sections. These sections and their abbreviations are:

1. SP/T - Suppression Pool - Temperature Control
2. DW/T - Drywell - Temperature' Control
3. .PC/P - Primary Containment - Pressure Control
4. SP/L - Suppression Pool - Level Control Section E0P-2 seeks to preserve the integrity of the primary containment through concurrent control of four

, separate parameters (suppression pool. temperature, drywell temperature, containment pressure, and suppression pool water level). The four control sections correspond to r these four parameter, each beginning with normal control i methods and continuing through steps appropriate for

, progressively degraded conditions. As primary containment

! parameters degrade and threaten either primary containment

integrity or equipment within the primary containment, alternatn actions to control RPV parameters'are required in^ order to accompM 6 tL purpose of E0P-2. Once E0P-2 has been entered the Operator will remain in the procedure

[N until in accordance with Caution 1 and it has been (g)~

determined that an emerFency no longer exists, a E0P-3 (Secondary Containment control)

The purpose of Section E0P-3 is to provide the Operator with the direction necessary to protect equipment in the secondary containment, maintain secondary integrity, or e limit radioactive release from the secondary containment.

The entry conditions to E0P-3 have the Operator monitor secondary containment differential pressure, area temperatures, area radiation, Reactor Building exhaust plenum radiation, area water level, and Reactor Building rump alarm. The Operator is referred'to three control sections. Those sections and their abbreviations are:

1. SC/T - Secondary Containment - Temperature Control
2. SC/R - Secondary Containment - Radiation Control

!~ 3. SC/L - Secondary Containment - Level Control Normal systems and methods are used to maintain all three secondary containment parameters (area temperature, area radiation, and area water level) at or below their maximum normal operating values. If the value of the parameter

.( exceeds its maximum normal operating value, action is i

l-Page 3 of 25 f

l

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

taken to isolate all primary systems discharging into the secondary containment except those systems required to

/, shut down the reactor, assure adequate core cooling, and

)

k / suppress a working fire. If maximum safe operating values are exceeded in more than one area, emergency RPV depressurization is required.

, 'E0P-4'(Radioactive Release Control),

The purpose of Section E0P-4 is to provide the direction to limit radioactive release to areas outside of the primary and secondary containments.

The entry conditions to E0P-4 have the Operator monitor the effluent radiation monitor, site boundary radiation, and radiation release that would result in an alert.

There are no individual control sections, but rather three actions steps labeled RR-1, RR-2, and RR-3 where RR stands for Radioactive Release Control.

In E0P-4, discharges from primary systems are to areas outside of the primary and secondary-containment are isolated (if possible) to terminate or minimize any release. Depressurization of the RPV is required if the radioactive release rate cannot be controlled below the -

release rate which requires a General Emergency.

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! Page 4 of 25 l

II. PLANT-SPECIFIC TECHNICAL GUIDELINES

[' ^\ GENERAL s )

The CNS' plant specific EPGs were developed using the BWROG EPGs.

Subsequent to the development of the CNS EPGs, the E0Ps were written using the plant specific EPGs as guidance. The CNS EPGs were written to Revision 31 of the BWROG EPGs since it provided the best information available at this time for development of the CNS E0Ps.

Revision 3I includes improvements to Revision 3 which will appear in Revision 4 of the BWROG EPGs to be submitted for NRC approval in 1986.

EPG DEVELOPMENT The following plant-specific technical and source information was used in generation of the CNS EPGs:

CE/BWROG EPG, Revision 31 dated March 1984 USAR Technical Specifications Existing Emergency Procedures As-built plant drawings

[]

( /

Equipment manuals Emergency Operating Procedures Writing Guidelines (INPO 82-017)

Guidelines for the Preparation of Emergency Operating Procedure (NUREG-0899)

The CNS EPGs were developed by following the BWROG EPGs step-by-step adding plant specific information, details and nomenclature as required. The BWROG EPGs are generic to CE-BWR 1 through 6 designs in that they address all major systems which could be used to respond to an emergency. But because no specific plant includes all of the systems in these guidelines the guidelines are applied to individual plants by deleting statements which are not applicable or by substituting equivalent systems where appropriate. For example, since CNS does not have & HPCS, IC or SPMS systems, these were deleted. Likewise, CNS has a Mark I primary containment design and all actions applicable to a Mark II or Mark III primary centainment designs were deleted. Additionally, the BWROG EPGs contain in some cases a general category of system which is bracketed, (i.e., [other steam driven equipment]) or a bracketed list of systems, dependent on plant design, that potentially could be used for a given action.

The EPG Appendices provide the direction necessary to apply the bracketed information to the plant specific EPGs. Where a list of systems appropriate for a given action was identified, the

[a}

' _,/

corresponding CNS systems were incorporated into the E0Ps. In other cases where the best choice of systems was suggested, these were evaluated and the one or two most appropriate for CNS were used.

Page 5 of 25

The BWROG EPGs also contain brackets which enclose plant unique setpoints, design limits, pump shutoff pressures, etc. Parentheses within the brackets indicate the source for the bracketed variable.

[~~

^s '} The bracketed values for plant unique setpoints were obtained from

'/

the CNS technical and source information summarized previously such as the Technical Specifications. Some of the action levels and curves are calculated values based on the BWROG EPG, Appendix C,

" Calculational Procedures". Appendix C Data Tables were developed in order to provide the necessary plant information required to perform the Appendix C calculations. A list of the plant specific values required for the development of the CNS EPGs and E0Ps and the source of this data is documented in the EPG Plant Data Table '

(Attachment 2).

Agreement between the BWROG EPGs and the CNS EPGs is documented

.along with the basis for any changes in the EPG Step Documentation (Attachment 1). This documentation contains the draft CNS EPG step, the source BWROG EPG step, the identification of deviations between the two steps, and the basis for any deviations. Likewise, agreement with and differences between the CNS EPGs and CNS E0Ps is documented in a similar fashion. Any revisions to either the CNS EPG or E0Ps requires the step documentation process to be followed.

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Page 6 of 25

III. WRITER'S CUIDE FOR E0Ps

~,

i

/ GENERAL s )

'~'

The Writer's Guide (Attachment 3) provides detailed instructions on how to prepare E0Ps using sound writing principles. Its recommendations address all aspects of writing procedures from a human factors standpoint. Compliance with the CNS Writer's Guide helps ensure all E0Ps are complete, accurate, and readable to control room personnel. This also ensures conformity of format and style for future revisions to the procedures.

WRITER'S GUIDE CONTENT The CNS Writer's Guide consists of technical and administrative information which is used to generate concise and precise instructions with a uniform text arrangement.

General and specific guidance for preparation of the E0Ps is addressed in the Writer's Guide as follows:

Control room staffing and responsibilities Procedure designation and numbering Procedure organization and format

(';I Procedure preparation and content t

Mechanics of style Typing format Reproduction Binding The CNS E0P Writer's Guide was written using the rollowing documents for guidance:

Emergency Operating Procedures Writing Guideline (INPO 82-017),

developed by the Emergency Operating Procedure Implementation Assistance (EOPIA) Review Group and published by INPO Guidelines for the Preparation of Emergency Operating Procedures (NUREG-0899)

WRITER'S GUIDE VERIFICATION The Writer's Guide after development, was subjected to verification by the CNS Station Operations Review Committee, a Human Factors engineer, and a General Electric technical editor. This f-~s verification process was used to ensure the Writer's Guide provided

[ ) the proper specific administrative and technical guidelines to be

\ss_- / used in development of the E0Ps. Discrepancies identified in the review of the Writer's Guide were documented and the Writer's Guide revised as necessary.

Page 7 of 25

IV. EOP VERIFICATION PROGRAM

( GENERAL

)

~~~

E0P verification is the evaluation performed to confirm the written correctness of the procedure and to ensure that applicable generic and plant specific technical information has been incorporated properly. This evaluation also checks that the human factors aspects presented in the E0P Writer's Guide have been applied. The verification of the CNS E0Ps was performed in accordance with the

" Emergency Operating Procedure Verification Program". This program description was developed for the CNS E0Ps and meets the intent and requirements of INPO 83-004, " Emergency Operating Procedures Verification Guideline".

EPG VERIFICATION The E0P verification program encompasses the efforts necessary to support a comparative evaluation of the plant specific EPGs and E0Ps to the source documentation.

EPG EVALUATION CRITERIA The verification process of the plant specific EPGs developed from the BWROG EPGs used the following as the evaluation criteria:

The CNS EPG accurately includes only those steps, notes, and f }

i  !

cautions which are applicable to CNS.

Deviations from the BWROG EPGs are justifiable and do not compromise the intent of the generic guideline (i.e., there are no deviations that are of safety significance).

Data used to establish limits or values in the CNS EPGs are correct and obtained from the proper sources.

Calculations required to develop limits or values in the CNS EPGs have been verified by an independent engineering organization.

EPG SOURCE DOCUMENTS The CNS EPGs were verified by comparing them with the following source documents using the evaluation criteria above:

BWROG EPG, Rev. 3I CNS EPG Plant Data Tables CNS EPG Appendix C Calculational Report CNS EPG Step Documentation n

[ Prior to the verification of the complete CNS EPGs, the EPG Plant

'N,_, Data Tables, Appendix C Data Tables and the Appendix C calculations were subjected to verification. These documents were used in order to establish plant specific values, limits, setpoints, and action levels for the CNS EPGs.

Page 8 of 25

EPG VERIFICATION PERSONNEL

. , ,x

[ \ The criteria used for personnel selection for EPG verification was

' to assign personnel for the verification who were familiar with CNS s'~'/ plant operation and individuals independent from the plant organization who were knowledgeable of the E0P program, but not directly involved in CNS E0P development. An SRO from the plant Operations Department and two General Electric E0P project engineers were chosen to perform the CNS EPG verification. The responsibilities of these EPG verification team members were to evaluate CNS EPGs with respect to the above source documents, to document the review, and to document discrepancies found during the verification.

The verification of the Plant Data Tables and the Appendix C Data Tables was performed by personnel from the plant Operations and Engineering Departments. The Appendix C calculations were verified independently by G.E. E0P project engineers.

EPG VERIFICATION DISCREPANCIES All discrepancies from the verification of the CNS EPGs, Plant Data Tables, Appendix C Data Tables, or Appendix C calculations were documented. Resolutions were developed for the discrepancies and approved by the CNS Operations Manager. The Operations Manager also designated what reverification was necessary for each discrepancy.

79 f 1 E0P VERIFICATION

' '~ Subsequent to the development of the CNS EPGs, the E0Ps were written incorporating information from the CNS EPGs and following the Writer's Guide. As the E0Ps were prepared, differences between the E0Ps and the respective section of CNS EPGs were documented in the E0P Step Documentation. Included in the documentation is justification for any differences. The draft E0Ps with the EOP Step Documentation were forwarded to the CNS Operations Manager for E0P verification.

E0P VERIFICATION EVALUATION CRITERIA The E0Ps were evaluated for both written correctness and technical accuracy. This involved comparing the E0Ps with the source documents used for E0P development and following established evaluation criteria. The following criteria was used in the E0P procedure-general evaluation:

WRITTEN CORRECTNESS

1. Legibility
a. Are all margins correct on all procedure pages?
b. Are the text, tables, graphs, figures, and charts

[,r-s) legible to the evaluator?

'w d Page 9 of 25

2. E0P format consistency

~

[ h a. Do the following sections exist in the E0P:

\ /

Section 1 - TITLE Section 2 - ENTRY CONDITIONS Section 3 - OPERATOR ACTIONS

b. Is the operator actions section presented in a dual-column format?
c. Is the page layout consistent with the sample page format?
3. Identification information
a. Is the procedure title descriptive of the purpose of the procedure?
b. Does the purpose adequately state the procedure objective?
c. Does each page correctly and uniformly provide the following:

(1) procedure designator and number (2) revision number

)/ ]/ (3) Page _ of _ numbers s

%J (4) Date of latest revision

d. Does the procedure have all its pages in the correct order?
e. Are an approval sheet and a revision sheet the last two pages of the procedure?

TECHNICAL ACCURACY

1. Overall technical accuracy
a. Are overall E0P/EPG differences:

(1) documented (2) explained (3) justifiable

b. Is the overall EPG technical foundation (strategy) changed by the following changes in the E0P:

(1) elimination (2) addition (3) sequence (4) alteration

(,-~s\

\ss_- / c. If the overall strategy is altered, is an appropriate safety analysis generated?

Page 10 of 25

a -

The following criteria was used in the E0P step, caution, and

-. note-specific evaluation:

^[. *

-WRITTEN CORRECTNESS

1. Information presentation
a. Are instruction steps numbered correctly?
b. Are instruction steps constructed to comply with the following:

(1) . Steps deal with only one idea.

(2) Sentences are short and simple.

(3) Operator actions are specifically stated.

(4) Objects of operator actions are specifically stated.

(5) Objects of operator actions are adequately.

stated.

(6) If there are three or more objects, they are '

listed (and space is provided for operator check-off).

c. Are the following mechanics of style followed:

(1) = Punctuation and capitalization are proper.

(2) Abbreviations, acronyms and symbols are correct g and understandable to the operator, s] (3) Spelling and vocabulary are proper.

d. Do instruction-steps make proper use of emphasis and logic structure?
e. When an action instruction is based on receipt of an annunciator alarm, is the setpoint of the alarm identified?
f. Are precautions and cautions used appropriately?
g. Are precautions and cautions placed properly?
h. Are precautions and cautions constructed to comply with the following:

(1) They do not contain operator actions.

(2) They do not use extensive punctuation for clarity.

(3) They make proper use of emphasis,

i. Are notes properly used?
j. Are notes properly placed?

(%' k. Are notes worded so that they do not contain operator actions?

Page 11 of 25

1. Are cautions and notes typed properly?

(' N m. Are numerical values properly written?

% l

'# n. Are values specified in such a way that mathematical operations are not required of the user?

o. Is a chart or graph provided in the procedure for necessary operator calculations?
p. Are units of measurement in the E0P the same as those used on equipment?
q. Is the level of detail adequate?
r. Is a check off space provided for each instruction step?
2. Procedure referencing and branching
a. Do the referenced and branched procedures identified in the E0Ps exist for operator use?

2

b. Is the use of referencing in instruction steps minimized?
c. Are referencing and branching instructions correctly 7 worded?

\

's- 'J ' (1) " enter" (branching)

(2) " refer to" (referencing)

d. Do the instructions avoid routing users past important information such as cautions preceding steps?
e. Are the exit conditions compatible with the entry condition of the referenced or branched procedure?

TECHNICAL ACCURACY

1. Entry conditions or symptoms information
a. Are the entry conditions of the EPG listed correctly?

i

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

(1) appropriate entry conditions for which the E0P should be used j (2) not excessive

-s 2. Instructional step, caution, and note information i 1

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v/

Page 12 of 25 l

t

a. Does the E0P properly incorporate EPG:

I \ (1) actions

\V / (2) contingencies (3) sequencing

b. Are E0P/EPG differences:

(1) documented (2) explained

c. Is the EPG technical foundation (strategy) changed by the following changes in E0P steps, cautions, or notes:

(1) elimination (2) addition (3) sequence (4) alteration

d. Are correct, plant-specific adaptations incorporated for EPG:

(1) systems (2) instrumentations (3) limits (4) controls O (5) indications

(' -

e. Have licensing commitments applicable to E0Ps been addressed?
f. Are differences between the licensing commitments and the E0Ps or EPGs documented?
3. Quantitative information i a. Do the quantitative values, including tolerance bands, used in the E0P comply with applicable E0P source document?
b. Where EPG values are not used in the E0P, are l equations presented with sufficient information for l operator use?
c. When calculations are required by the E0P, are equations presented with sufficient information for operator use?

( 4. Plant hardware information

a. Is the following plant hardware specified in the E0P g available for operator use:

,j (1) equipment Page 13 of 25

(2) controls

,_; q (3) indicators (s ) (4) instrumentation

5. Referencing and branching:
a. Do instructions route users to the appropriate step?
b. Do instructions avoid reuting users past information such as cautions preceding steps?
c. Does any deleted or added material compromise the intention of the referencing or branching?

EOP SOURCE DOCUMENTS The E0P verification utilized the latest, approved revision of the source documents in the evaluation. The source documents were reviewed to ensure they were complete, current, and applicable. The following source documents were used in the E0P evaluation applying the criteria previously stated:

CNS E0P Verification Program Description CNS EPGs p,,

CNS E0P Step Documentation

(]\

/

  • CNS E0P Writer's Guide E0P CONTROL ROOM WALKTHROUGH VERIFICATION A Control Room walkthrough with the E0Ps was performed to ensure instrument and controls specified in the E0Ps were available in the Control Room. The E0P instrument and controls were checked in the walkthrough to verify:

Instrumentation was available to implement the actions in the E0Ps T*r.e action levels were within the range of the installed instrumentation The action levels could be read on the installed instrumentation The action level units were in agreement with the installed instrumentation The nomenclature in the E0Ps were in agreement with installed nomenclature on the control room panels E0P DCRDR TASK ANALYSIS

I km/ A task analysis was performed on the E0Ps as part of the CNS Detailed Control Room Design Review (DCRDR) program. This task Page 14 of 25

- - - - - ~ - __

analysis served as a verification on the E0Ps to ensure all information and controls needs for the E0Ps were available and were

/ \ properly human factored. The task analysis was performed by a Human (v / Factors engineer and CNS licensed operators.

The DCRDR task analysis utilized the E0P procedures in the identification of plant systems and their functions during emergencies. There are over 60 systems listed in CNS E0Ps, and their functions in controlling the reactor vessel, primary containment, secondary containment and radioactivity release are noted in the procedures.

In performing the DCRDR task analysis, the entry conditions to emergencies and the operator tasks to control and mitigate the emergency conditions are taken to follow the E0Ps primary operator actions and any associated contingency actions. Each of the procedure steps, entry conditions or operator actions were listed in task analysis data sheets used by the DCRDR team. Other columne of the task analysis data sheets relate to the specification of the information and controls needs/ characteristics, control room inventory, and suitability assessment of the inventory against the identified needs.

In order to define the information and controls needs/ characteristics for the CNS E0Ps, a human factor engineering model was detaloped to simulate operators needs and instrument requirements and characteristics. Key steps identified for this

(

/ ~'N 1 model were:

\

'v') E0P Phase Control Room Needs Alerting - Annunciators Information - Indicating Meters

- Recorders

- Indicating Lights Initiating Actions - Switches (Pumps, Valves and Relays)

- Performing Calculations

- Communication Equipment Controlling Actions - Controllers For each of the Control Room hardware needs, specific engineeting and human factors characteristics are required for the operator to correctly identify and execute the E0P steps. The characteristics are dependent on the hardware instrument, associated operator action, and the human factor interface with the instrument.

Engineering characteristics of instruments and specific human factor characteristics for operator interface with the instrument were determined and used in the E0P task analysis, For each of the entry conditions and the E0Ps operator actions lp) listed in the task analysis data sheets, the needs and (j characteristics of information and controls were completed in advance of conducting a Control Room task analysis walkthrough.

These values were entered in the task analysis data sheets.

Page 15 of 25

During the task analysis walkthrough in the control room, the

_s operator read the task, then walked through the task aspects at the

( \ control panel. The information and controls availability and

\ I

'~', specific characteristics were determined from the control room panels. The following specific characteristics were identified:

Equipment No., Panel No., Parameter, Range Setpoint and Controls' characteristics. This data was documented in the task analysis data sheets under the availability heading.

Verification of the suitability of the Control Room inventory against the Information and Controle needs/ characteristic was performed during the walkthrough, and the decision was recorded in {

the task analysis data sheet. When the suitability criteria were not met, the reason was noted and the human engineering discrepancy was documented in the " Notes" column of the task analysis data sheets.

E0P VERIFICATION PERSONNEL The criteria used for selection of E0P verification personnel was to >

ensure reviewers had plant operating experience, understanding of plant hardware, and were knowledgeable of the CNS EPG and the CNS E0P Writer's Guide. Personnel chosen for E0P verification were from the following organizations or backgrounds:

General Electric Engineers fN General Electric Technical Editor t ]

CNS Quality Assurance CNS Operations CNS Training Human Factors Engineer General Electric engineers included the procedure writers and also engineers not directly involved in the E0P development, but knowledgeable on E0P development.

The procedure writers were responsible for ensuring that the E0Ps were written correctly and conformed to the EPG and the format specified in the CNS Writer's Guide. In addition, they provided recommendations to the CNS Operationw Manager for resolution of the verification discrepancies.

The responsibilities of the E0P Verification Team members were to check the E0Ps for written correctness and technical accuracy by comparing the E0Ps to the source documents, to document the review, and to document discrepancies found during the verification. The CNS Operations Manager then had the responsibility for ensuring fg resolutions were developed for the discrepancies and approved, and for specifying any necessary reverification.

( .-

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Page 16 of 25

V. E0P VALIDATION PROGRAM The E0P Validation Program is an administrative process used to fN_,g} determine if the actions specified in the E0Ps can be followed by trained operators to manage emergency conditions effectively. The process applies to validation performed prior to incorporation of the E0Ps into the CNS Operations Manual, but can also be applied to revalidation, which is performed after revision of previously approved CNS E0Ps.

The CNS " Emergency Operating Procedure Validating Program" was developed to provide the necessary guidance for performing the validation. This validation program meets the intent and requirements specified in INPO 83-005, " Emergency Operating Procedures Validation Guideline".

During validation, E0Ps were checked for usability and operational correctness. Usability indicates the E0Ps provide sufficient and understandable information to the operator consistent with his level '

of training on the procedures. Operational correctness means the E0P instructions are compatible with plant responses, hardware, and the shift manpower.

VALIDATION METHOD SELECTION The CNS Operations Manager decided to what extent the E0Ps would be validated and the validation methods to be used. INP0 Guide 83-006,

( "EOP Validation Guideline", was used in the validation method

( selection. Validation methods chosen were generic simulator and

'N- 'j control room walkthrough. E0P simulator validation consisted of prevalidation at the simulator and subsequent final validation at the simulator. The criteria used in selecting a simulator for the final validation was to minimize any differences between the simulator and the CNS plant design. For those portions of the E0Ps which could not be adequately validated on the simulator, a control room walkthrough validation was performed to validate the E0Ps to the fullest extent possible.

SIMULATOR VALIDATION PERSONNEL Personnel selected for E0P simu*ator validation were assembled separately into a validation team and validation participants.

The validating team was responsible for developing:

Evaluation Criteria Validation Scenarios i Validation Participant Training Required Document and Validation Materials t

O i The validating team was also responsible during validation

\ss_- / assessment to conduct pre-scenario briefings, observation and

-Page 17 of 25

evaluation, using established criteria during the scenarios, s post-scenarios de-briefings, and documentation of validation

(' } discrepancies.

/

%j Personnel selected for the validation team for E0P simulator pre-validation were GE E0P project engineers and a GE training instructor at the simulator used for pre-validation. Personnel selected for the validation team for the final validation were CNS Training an! Operations personnel, a GE E0P project engineer, the GE simulator instructor who participated in the pre-validation, and a Human Factors engineer.

The validation participants were responsible for carrying out E0P actions in response to the simulator scenarios, and participating in pre and post-scenario de-briefings. Validation participants consisted of Operations and Engineering Department personnel.

During pre-validation, three licensed operators were participants which represented the minimum number of licensed operators required for reactor operations by Technical Specifications at the time.

During final validation, four licensed oeprators were participants which represents the number of licensed opearators required for reactor operation currently by Technical Specifications.

For any future E0P validation, the minimum number of licensed operators required by Technical Specifications should be used as validation participants.

f' j EVALUATION CRITERIA FOR SIMULATOR AND WALKTHROUGH VALIDATION

"# The validating team determined that the following evaluation criteria would be applicable in E0P simulator and/or walkthrough validation.

USABILITY

1. Level of detail
a. Is there sufficient information to perform the specified actions at each step?
b. Are the alternatives to be used based on plant conditions adequately described at each decision step?
c. Are the labeling, abbreviations, and nomenclature as provided in the procedure sufficient to enable the operator to find the needed equipment?
d. Is the procedure missing information needed to manage the emergency condition?
e. Are the contingency actions sufficient to correct the

,rs condition (Are any probable contingencies

( ) unaddressed)?

(/

Page 18 of 25

f. Are the titles and numbers sufficiently descriptive

,_ \ to enable the operator to find referenced and

branched procedures?

}

v

2. Understandability
a. Is the procedure easy to read?
b. Are the figures and tables easy to read with accuracy?
c. Can the value on figures and charts be easily determined?
d. Are caution and note statements and the manner in which they relate to procedure steps readily understandable?
e. Are the procedure steps readily understandable?
f. Is the layout and format of the procedure followable?

OPERATIONAL CORRECTNESS

1. Plant compatibility
a. Can the actions specified in the procedure be

(}

\

/

performed in the designated sequence?

b. Are there alternate success paths that are not included in the procedure? (Is there a better way to do it?)
c. Can the information from the plant instrumentation be obtained as specified by the procedure?
d. Are the available control room instrumentation and annunciators adequate for the operator to recognize '

the entry conditions?

e. Are the procedure entry conditions appropriate for the plant symptoms displayed to the operator?
f. Is information or equipment not specified in the procedure required to accomplish the task?
g. Do the plant responses agree with the procedure basis?
h. Are the instrument readings and tolerances stated in the procedure consistent with the instrument values displayed on the instruments?

gg 1. Are the instrument readings and tolerances specified

)

\_/

s by the procedure on remotely located instruments accurate?

..Page 19 of 25

l

j. Is the procedure physically compatible with the work

,s situation (too bulky to hold, binding would not allow

( them to lay flat in work space, no place to lay the

' _,,j x procedure down to use)?

k. Are the procedures easily identifiable and accessible where stored in the control room?
2. Operator compatibility
a. If time intervals are specified, can the procedure action steps be performed on the plant within or at the designated time intervals?
b. Can the procedure action steps be performed by the operating shift?
c. If specific actions are assigned to individual shift personnel, does the procedure adequately aid in the coordination of actions among shift personnel where necessary?
d. Can the operating shift follow the designated action step sequences?
e. Is the text of the procedure compatible with the

,_, operator's viewpoint and level of training?

(' \

(') f. Can the particular steps or sets of steps be readily located when required?

g. Can procedure branches be entered at the correct point?
h. Are procedure exit points specified adequately?

SIMULATOR VALIDATION SCENARIO SELECTION The simulator validating team, under the guidance of the Operations P.;.:ager and with the assistance of the Training Department, developed and modified scenarios to fit the appropriate validating method (s). Detailed scenarios were designed to guide the validation participants through E0P steps such that the evaluation criteria were addressed.

Criteria for selecting and development of E0P validation scenarios is as follows:

The full complement of E0Ps must be addressed including multiple failures (simultaneous and sequential).

Scenarios are in sufficient detail to account for the limitations of the validation nethod.

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  • Scenarios include appropriate background information, initial conditions, sequence of events, and anticipated responses.

Page 20 of 25

It is identified where evaluation criteria are addressed.

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j Guidance should be given to maximize validating team performance.

Scenarios utilized by other utilities (and accompanying comments) should be reviewed for guidance.

If possible, a " dry run" of the scenarios should be performed to indicate where refinemer.t is required.

CONDUCTANCE AND ASSESSMENT OF SIMULATOR VALIDATION The validating team conducted pre-scenario briefings which briefed the participants on the scope of the validation and how the assessment would be conducted. Participants were also briefed on initial plant conditions for each scenario. While the scenario was being executed the validating team observed the proceedings and noted expected versus actual responses to the E0P actions. The E0P validation evaluation criteria previously stated was utilized to control and direct the assessment.

Members of the validating team discussed with the scenario participants any comments or problems which may have been encountered in post-scenario briefings. Possible reasons for problems and potential solutions were presented and all discrepancies documented.

E0P CONTROL ROOM WALKTHROUGH VALIDATION V

In order to validate those items which were possibly not adequately validated on the simulator or those items constituting differences between the simulator and the CNS control room, a control room walkthrough validation was performed using the E0Ps. The control room walkthrough validation was performed by a validation team and validation participants. The validation team consisted of CNS Operations and Training Department personnel, a G.E. E0P project engineer, and a Human Factors engineer. The responsibilities of the validation team were to observe the validation participants in exercising the E0Ps, evaluate the walkthrough using the previously stated criteria, and to document discrepancies. The validation participants included four (4) CNS licensed operators and two (2)

CNS STAS. The validation participants were responsible for simulating all actions outlined in the steps of the E0Ps.

E0P VALIDATION DISCREPANCIES E0P validation discrepancies and comments were recorded on discrepancies sheets and forwarded to the CNS Operations Manager.

The Operations Manager was responsible for addressing and resolving all discrepancies, and for any reverification and revalidation of the EOPs if needed.

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%J Page 21 of 25

VI. E0P TRAINING PROGRAM f

N'j-CENERAL

-The initial E0P training was designed to support implementation of the E0Ps. The training was closely tied to the verification and validation of the.EOPs to ensure a supportive program. The underlying goals of both initial and requalification E0P training are to enable the operator to:

Understand the structure and technical bases of the E0Ps.

Develop a working knowledge of the E0Ps.

Use the E0Ps under adverse operational conditions.

The initial E0P training program provided additional operator input and helped to point out any problems with the new E0Ps. The resulting revisions added further refinement before final implementation. The initial E0P training effort consisted of classroom instruction, control room walkthroughs, and simulator exercises. Initial E0P training was required for all licensed operators and STAS; prior to the implementation of the E0Ps in August, 1985. In addition, certain management personnel were trained on the E0Ps.

INITIAL E0P CLASSROOM TRAINING

[N (v) In the initial E0P classroom training, lectures were presented based on the BWROG Emergency Procedure Guidelines, Appendix B "Duailed Discussion of Cautions and Operator Actions". This material was specifically~ tailored to the CNS plant and included the following information:

Logic behind E0P development The E0Ps themselves l

Application of E0Ps under multiple failure scenarios The initial E0P classroom training was five days in length and included the documentation of operators comments and E0P discrepancies.

INITIAL E0P SIMULATOR TRAINING Five days of E0P simulator training was conducted in order to thoroughly familiarize licensed operators, STAS, and plant management personnel with the E0Ps. During simulator training, the differences between the simulator and the CNS control room and the effect on performance of the E0Ps were discussed. This was done prior to performing the training scenarios and during/following each scenario, if necessary.

(

N Page 22 of 25

Scenarios were carefully chosen by using the following criteria:

[ To fully exercise each section of the E0Ps.

To include scenarios which encompass multiple failures.

The anticipated frequency of a certain malfunction at CNS.

The importance of a malfunction as related to a safety event or a malfunction that will cause a safety event.

Related industry operating experience.

Whether the simulator training is initial or requalification.

The frequency the evolution is conducted at CNS, i.e.,

infrequent evolutions should be included.

To include those control manipulations outlined in the March 20, 1980 letter from Harold Denton, Director of NRC to All Power Reactor Applicants and Licensees, which would require the use of the E0Ps.

INITIAL E0P CONTROL ROOM WALKTHROUGHS E0P control room walkthroughs were conducted to cover those items that could not be adequately covered in the classroom and simulator 79 training. The walkthroughs provided practical experience with the

( '" ) E0Ps and the team approach to the use of the E0Ps was stressed. The walkthrough training concentrated on:

Operator responsibilities Information flow Interactions of the operators in the control room These walkthroughs also served to cover those differences between the CN3 control room and the simulator used for training.

INITIAL E0P TRAINING DISCREPANCIES Discrepancies and comments detected during the training were documented on training discrepancy sheets. All training discrepav y sheets were forwarded to the CNS Operations Manager for resolution.

The need for reverification / revalidation or retraining was determined by the Operations Manager and conducted if nececcary.

EOP REQUAL TRAINING Annual licensed operator and STA requalification training includes adequate retraining on the E0Ps. This training includes three days n of classroom and simulator training. The criteria used for initial

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\.

E0P simulator scenario selection is utilized in choosing simulator exercises. All revisions to the E0Ps subsequent to E0P Page 23 of 25

implementation, and not covered by specific training conducted for E0P revisions, is included in the E0P classroom and simulatar requal 7

( ) training.

. l All personnel receiving training on the E0Ps are evaluated to verify their knowledge level is adequate. This evaluation was performed during initial training and will be performed during subsequent requal training.

During the classroom phase a written exam is administered to all trainees. Anyone securing a failing grade is required to receive additional training and then retake another exam.

Trainees are also evaluated during simulator training. The scenarios and operator actions to be taken during the scenarios are discussed as needed to ensure operator understanding of the correct actions to be taken, based on the E0Ps. If necessary, scenarios are repeated to ensure the operators have a full understanding of the E0Ps.

TRAINING FOR E0P REVISIONS The CNS Operations and Training Department determines operator training requirements based on the extent of the E0P revision. Any major revision should include not only E0P classroom training, but also simulator and walkthrough training.

[]

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j If control room walkthroughs cannot be performed due to operational considerations or simulator training cannot be scheduled immediately, due to simulator availability, then other training methods will be used to ensure the operators receive adequate training on the revised E0Ps. This could include:

Additional classroom training.

A thorough discussion of the E0P revision, its affects, and the bases for the revision.

A review of Instrument and Control requirements.

Extensive use of scenarios in classroom discussion.

Walkthroughs using control room mockups.

This training will be followed by simulator and control room walkthroughs when it can be scheduled.

The training to be conducted on minor revisions to the E0Ps would as a minimum include E0P control room walkthroughs and the required reading of the E0P revision by all licensed operators.

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Page 24 of 25

- . . . . . . . _ . . _ _ . _ . . . . _ _ _m.__ ___ -. . - _ . - . _ _ _ . - . _ . _ _ - . _ . _ . _ - _ . _ . - - - _ _ . . _ _ . . . _ .

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VII.- EOP REVISIONS AND REVIEW I Station procedure 0.22, " Preparation, Review and Approval of t Ts . Emergency Operating Procedure Changes", specifically controls revisions to the E0Ps and the review process-for current .

applicability of the E0Ps. This procedure details the process used i to ensure revisions are properly implemented and approved. As part j- .of the revisional process, justification for change is provided,  !

, conformancy with the Writer's Guide ensured, deviations from the EPGs documented, and verification / validation performed if required.

Operator training required for the revision is determined and

-I conducted.

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P g2 1 cf 21 Attachment 1 STEP DOCUMENTATION Draft Document: CNS EPG, Rev. 1, 5/3/85 Source Document: BWROG EMERGENCY PROCEDURE GUIDELINES, REV. 31, March 1984 DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO Table I Table I X Deleted systems not utilized by CNS. Added CNS approved abbreviations and acronyms.

,ry

) C #1 C #1 X Included appropriate pro-cedure designations.

C #2 C #2 X C #3 C #3 X

<:s C #4 C #4 X C #5 C #5 X Deleted " Containment temp-erature" (not applicable to Mark I).

Included current method at CNS for determination of drywell and suppression pool temperatures.

\

Writer: .h tw Date (8[b[

Pcg2 2 cf 21 Attachment 1 STEP DOCUMENTATION CONTINUATION SHEET DRAFT SOURCE DEVIATION STEP FROM SOURCE BASIS FOR DEVIATION STEP YES NO C #6 C #6 X 1. Drywell temperature as cal-culated in Caution #5 is also appropriate for in-dication of temperature near the level instrument reference legs.

2. Values in the table were determined by GE in Append-dix C calculations.

C #7 C #7 X Listed the CNS heated and cold reference leg instru-ments.

(. C #8 C #8 X C #9 C #9 X 1. CNS does not have HPCS.

2. HPCI and RCIC take suction from the emergency conden-sate storage tank.
3. Utilized technical spec-ifications for the inter-lock setpoints.

C #10 C #10 X Changed ECSS to CSCS to be consistent with CNS usage.

C #11 C #11 X Changed: ECCS to CSCS f LPCS to CS i

1 Draft Document: _ CNSEPG,Rev[1 5/3/85 Writer: mf w Date h7 6

\

. -. ~. . =- .

E*

Attachmsnt 1 l STEP DOCUMENTATION CONTINUATION SHEET' f 1

. n

\

DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO C #12 C #12 X Reworded caution to account for two different minimum speed limits.

C #13 C #13 X C #14 C #14 X C #15 C #15 X Included CNS SRV opening sequence.

C #16 C #16 X Bracketed phrase deleted-there are no low RPV level

' interlocks on the steam

, (g tunnel coolers.

C #17 C #17 . X C #18 C #18 X C #19 C #19 X No automatic trip associated with SLC pumps at CNS.

C #20 C #20 X C #21 C #21 X " Suppression chamber" is i referred to as " torus" at CNS.

j C #22 C #22 X C #23 C #23 X Draft Document: n CNS EPG. Re . 1 5/3/85 Writer: j u Date hh7

g2 21 Attachm:nt 1 STEP DOCUMENTATION CONTINUATION SHEET

.n

\

DRAFT SOURCE DEVIATION ,

STEP STEP FROM SOURCE BASIS FOR DEVIATION -

YES NO C #24 X [

C #24 C #25 C #25 X [

f C #26 C #26 X J

RPV CONTROL GUIDELINE ,

i Heading Heading X Added procedure designator [

(EOP-1).  ;

Purpose Purpose X j

. i Entry X Utilized technical speci-l j

(d'j t Entry Conditions Conditions fications for setpoints.  ;

t X  ;

RC-1 RC-1 i

, Note #1 Note #1 X RC/L RC/L X ,

RC/L-1 RC/L-1 X Included DG initiation con- i firmation as it is a rela-tively important automatic action at CNS.

I Note #2 Note #2 X RC/L-2 RC/L-2 X 1. No HPCS at CNS.

2. Utilized technical spec-ifications as setooints.

i l Draft Document:n CNS EPG. Re .1 5/3/85 k' rite r s (M R Date b!b f 6

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r.

Pags 5 of 21 Attachm:nt 1-STEP DOCUMENTATION CONTINUATION SHEET DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO Note #3 Note #3 X Note #4 Note #4 X RC/L-3 RC/L-3 X Included appropriate CNS procedure number.

RC/P RC/P X Note #5 Note #5 X RC/P-1 RC/P-1 X No IC at CNS.

Note #6 Note #6 X O Note #7 Note #7 X

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RC/P-2 RC/P-2 X 1. No IC at CNS.

2. Included list of steam-driven equipment.
3. The appropriate switch position to prevent use of the SRV pneumatic supply is AUTO.

Note #8 Note #8 X l

l I

Draft Document: f- CNS EPG. Rev 1 5/3/85 Writer: W4

~

Date S/8 /B 5' _ __

d t

Att:chn nt 1 STEP DOCUMENTATION CONTINUATION SHEET  ;

'V DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES N0 i

RC/P-3 RC/P-3 X Included appropriate CNS value for maximum suberitical banked rod position. Wording changed

'to or beyond position 02' to reflect actual meaning and calculation of the maximum suberitical banked rod position, RC/P-4 RC/P-4 X Note #9 Note #9 X See above for discussion of control rod position.

RC/P-5 RC/P-5 X Included CNS procedure

([])

( v number.

RC/Q RC/Q X Note #10 Note #10 X 1. Included CNS scram pro-cedure numbers.

2. See above for discussion of control rod position.

RC/Q-1 RC/Q-1 X Phrase is applicable to CNS-there is no inadvertent isolation by placing the mode switch to SHUTDOWN.

RC/Q-2 RC/Q-2 X Bracketed phrase is appli-cable to CNS as the TG may technically be on-line with MSIVs shut (prior to reverse power trin).

[n) Draft Document: n CNS EPG. Rev. 1 5/3/85 Writer: I t _

Date 8 /97 0

Pcg2 7 cf 21 Attcchment 1 STEP DOCUMENTATION CONTINUATION SHEET t t f

's. /

DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO RC/Q-3 RC/Q-3 X Note #11 Note #11 X RC/Q-4 RC/Q-4 X The Boron Injection Initiation Temperature graph calculation-al procedure has not yet been developed, thus the single temperature (110*F) is utilized.

All possible alternate systems for boron injection are listed.

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' 6'As'h RC/Q-4.1 RC/Q-4.1 X RC/Q-4.2 RC/Q-4.2 X RC/Q-4.3 RC/Q-4.3 X Included CNS scram procedure numbers.

RC/Q-5 RC/Q-5 X RC/Q-5.1 RC/Q-5.1 X Included appropriate CNS fuse and valve numbers.

RC/Q-5.2 RC/Q-5.2 X RC/Q-5.3 RC/Q-5.3 X RC/Q-5.4 RC/Q-5.4 X See p. 6 for a discussion of control rod position.

A l ) Draft Document: .CNSEPG.Rev./ 5/)/85 Writer: u/ Date f/8[8 7

Pcg3 8 cf 21 Attachment 1 STEP DOCUMENTATION CONTINUATION SHEET

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R..J DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO RC/Q-5.5 RC/Q-5.5 X RC/Q-5.6 RC/Q-5.6 X 1. Included appropriate CNS valve numbers.

2. See p. 6 for a discussion of control rod position.

Primary Containment Control Guideline Heading lleading X Added procedure designator (EOP-2)

Purpose Purpose X r]

kL' ) Entry Entry Conditions Conditions X 1. Deleted containment temper-ature entry condition (not applicable to Mark I).

2. Utilized technical speci-fications for setpoints.
3. Deleted primary containment hydrogen concentration as an entry condition. H 2

control will be implemented after Revision 4 of the BWROG EPG is approved.

Note #1 Note #1 X Deleted Section CN/T and PC/H.

SP/T SP/T X

[o Draft Documentt Writer:

m CNS EPG, Rev.

oru t_a 5/3/85 Date f!O!b f 0

F g2 9 cf 21 Attachment 1 STEP DOCUMENTATION CONTINUATION SHEET m

'O DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO SP/T-1 SP/T-1 X No time interval for SORVs specified at CNS. Thus, the operator is referred to the Abnormal Procedure.

SP/T-2 SP/T-2 X SP/T3 SP/T-3 X See p. 7 for discussion of boron injection temperature.

SP/T-4 SP/T-4 X DW/T DW/T X

[ ,

((v ) DW/T-1 DW-T-1 X Note #2 Note #2 X DW/T-2 DW/T-2 X Drywell temperature, as cal-culated in Caution #S, is appropriate for indication of temperature near the cold reference leg instrument vertical runs.

DW/T-3 DW/T-3 X The step is written to reficct the following:

1. Rated drywell spray flow rate is appropriate for the CNS containment.

em

( ) Draft Document: fpSEPC.Rev.!1 5/j/85 Writers _n u , _

Date f[b!8,7

8' "'

Attachment 1 STEP DOCUMENTATION CONTINUATION SHEET r

(t DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO

2. It is only possible to exceed the capacity of the torus to reactor building vacuum breakers by spraying the drywell.

Thus, only torus temper-ature and pressure need to be checked prior to initiating drywell sprays.

None Section CN/T X Section does not apply to Mark I containment.

PC/P PC/P X 1. Specified the primary con-tainment pressures as (f( applicable to CNS.

2. Note that " suppression chamber pressure" is called " torus pressure" at CNS.

PC/P-1 PC/P-1 X Included available systems to control containment pressure (Drywell coolers and SBGT) and operating procedure references.

None Note #3 X Note is not applicable for a Mark I containment with Torus to Reactor Building vacuum breakers.

Draft Document _ CNS EPG, RO. 1 5/3/85 Writer: Date b!h [

0

Pago 11 of 21 Attcchment 1 STEP DOCUMENTATION CONTINUATION SHEET

. m f

. DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO PC/P-2 PC/P-2 X Wrote step as applicable to CNS containment (Mark I).

PC/P-3 PC/P-3 X See DW/T-3 (p.12).

PC/P-4 PC/P-4 X The Pressure Suppression Pressure gives enough add-itional margin to justify its use.

PC/P-$ PC/P-5 X The Primary Containment Design pressure gives e enough additional margin to justify its use.

(\s- - PC/P-6 PC/P-6 X See DW/T-3 (p.12). l t

PC/P-7 PC/P-7 X Included CNS procedure l

number.

! SP/L SP/L X SP/L-1 SP/L-1 X 1. Included CNS data and ,

procedure number. l

2. Wrote step as applicable for CNS - does not have SPMS.

SP/L-2 SP/L-2 X f

SP/L-3 SP/L-3 X CNS does not have SPMS.

t

! Note #3 Note #4 X i

i Draft Documentt , CNS EPG, Rev/Tl 5/3/85 l Writer: 4.q uA_ Date (!b/8 I

(/ l

CE2 "'

Attcch: nt 1 STEP DOCUMENTATION CONTINUATION SHEET

(\s DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO SP/L-3.1 SP/L-3.1 X SP/L-3.2 SP/L-3.2 X See DW/T-3 (p.12).

None Section PC/H X Deleted primary containment hydrogen control section from Primary Containment Control, 11, control will be implemented after Revision 4 of the BWROC EPG is approved.

Secondary Containment Control Goldeline liending Heading X Added procedure designator Purpose Purpose X Entry Entry conditions Conditions X 1. IIVAC cooler differential temperature not monitored at CNS.

2. Changed terminology for sumps from floor drain sumps to Reactor Building sumps.

Note #1 Note il X 1. Setpoint technical speci-fications utilized.

2. Temperature limitation not required due to no secondary containment mornym.

Draf t Docuroents ,_ cns trc. nev A t sjn/gs Writers u u Date 5 S/9f v

83 # I Attachment 1 STEP DOCUMENTATION CONTINUATION SIIEET

/ \

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v DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO Note #2 Note #2 X Note #3 Note #3 X SC/T SC/T X SC/T-1 SC/T-1 X SC/T-2 SC/T-2 X SC/T-3 SC/T-3 X SC/T-4 SC/T-4 X SC/T-5 X SC/T-5 SC/R SC/R X SC/R-1 SC/R-1 X SC/R-2 SC/R-2 X SC/R-3 SC/R-3 X SC/L SC/L X Changed terminology for sumps from floor drain sumps to Reactor Building sumps.

SC/L-1 SC/L-1 X SC/L-2 SC/L-2 X SC/L-3 SC/L-3 X n

Draft Documentt ,0NS EPG, Rey, /) $/3/8$

k'rit er t i <t m , __

Dato ([$[d [

0

Pcg3 14 cf 21 Attcch::nt 1 STEP DOCUMENTATION CONTINUATION SilEET l ])

v DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO Table 1 Table 1 X CNS values entered, individual area breakdowns are indicated and area water levels and sump levels combined into their matching areas.

Radioactivity Itelease Control Gu;.deline

!!cading  !!cading X Added procedure designator (E0P-4)

Purpose Purpose X Entry Entry Conditions Conditions X (O/

r RR-1 RR-1 X RR-2 RR-2 X Contingency #1 licading Heading X Note #1 Note #1 X None Cl-1 X Step deleted - CNS does not have an IC system.

Cl-1 Cl-2 X Applicable CNS motor driven pumps and alternate injection subsystems listed.

( [) Draft Documents _ __ CNS FPG. Rev./1 5/1/85 Writers (u - Ao Date b/N f l 6

Pass 15 ef 21 Attachment 1 STEP DOCUMENTATION CONTINUATION SHEET I

N DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO Numbering of this and sub-sequent steps changed due to deletion of IC step.

Cl-2 Cl-3 X Note #2 Note #2 X Cl-3 Cl-4 X C1-4 Cl-5 X Cl-5 Cl-6 X C1-6 Cl-7 X ON Cl-7 Cl-8 X 1. Bracketed phrase was deemed appropriate for CNS - prefer to utilize CS prior to injecting with service water.

2. No HPCS at CNS.

Note.f3 Note #3 X None Alternate X Deleted - not appropriate Format for for dual column format.

Steps Cl-3 through Cl-8 Draft Documentt ,- CNS EPG. Rev.Al 5/3/85 Writers to da n Date S/S [

v

P g3 16 cf 21 Attcchment 1 STEP DOCUMENTATION CONTINUATION SHEET 7-(V)

DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO Contingency #2 Heading Ileading X C2-1 C2-1 X None C2-1.1 X Deleted - No IC at CNS.

C2-1.1 C2-1.2 X C2-1.2 C2-1.3 X Altered step to include

, appropriate CNS parameters and deprensurization I

systems.

( Note #1 X

\ <

Note #1

%)

02-2 C2-2 X Contingency #3 Ileading Ileading X Note #1 Note #1 X C3-1 C3-1 X Deleted IC instructions.

i Note #2 Noto #2 X Contingency #4 Ileading Ileading X Draft Docunent ,cNS rpo. Itcy. A 5/3/85 wrsteri ($w [ M[4-u. _ Date M8/8 C U

Pcg3 17 cf 21 Attcchment !

STEP DOCUMENTATION CONTINUATION SHEET

  • l

\

I(L ) l V

DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO C4-1 C4-1 X C4-2 C4-2 X 1. No llPCS at CNS.

2. RPV pressure for rated CS flow is given in terms of differential pressure (RPV to torus).

C4-3 C4-3 X Contingency #5 lleading liceding X

" C5-1 C5-1 X C5-2 C5-2 X Head vents included in listing as they vent to Drywell Sump (not the torus).

C5-3 C5-3 X C5-4 c5-4 X C5-5 C5-5 X LPCs changed to CS to be consistent with CNS usage.

C5-6 C5-6 X See above CS-6.1 C5-6.1 X See above Draf t Docurnent s _cNs 1:pc. Revd I s/3/85

.,,t.,, con ..t. mar V

P g318 ef 21 ,

Attechment 1 STEP DOCUMENTATION CONTINUATION Si!EET  ;

r ~h i (N%j) i DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO C5-6.2 C5-6.2 X C5-6.3 C5-6.3 X 1. LPCS changed to CS to be consistent with CNS usage.

2. SRV reopening pressure applies due to SRV type.

C5-7 C5-7 X C5-8 C5-8 X CNS operating procedure number indicated.

Contingency #6 A) w/

llending lleading X C6-1 C6-1 X 1. No motor driven feedwater pumps at CNS. ,

2. No IC or llPCS.

C6-2 C6-2 X See p. 6 for discussion of control rod position.

C6-2.1 C6-2.1 X Noto #1 Note #1 X C6-2.2 C6-2.2 X 1. No motor driven feedwater pumps at CNS.

2. No itPCS.

ON ) Drnft Documents ,cNs Epp. Hey, ti $/3/85 _

(

Writers to /A x v. Dato SM E U

r Paga 19 cf 21 Attcchment i STEP DOCLHENTATION CONTINUATION SHEET l

rs

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DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES NO l

3. Included list of appli-cable alternate injection t

subsystems.

l C6-2.3 C6-2.3 X C6-2.4 C6-2.4 X See p. 6 for discussion of control rod position.

C6-3 C6-3 X C6.3.1 C6-3.1 X Injection system list

! modified as appropriate for CNS.

f

( / C6-3.2 C6-3.2 X

%J C6-4 C6-4 X Injection system list modified as appropriate for CNS.

1 C6-5 C6-5 X C6-5.1 C6-5.1 X Drywell temperature as cal-culated in Caution #5 is appropriate to indicate temperature near the cold reference leg instrument vertical runs.

Note #2 Note #2 X C6-5.2 C6-5.2 X l

l Draft Document .A l S/3/85

!Ns CNS I EPG.

g kov,//

l Writer:

g A.w AQho Date C[El/8 7 U

Pcg3 20 cf 21 Attcchment 1 STEP DOCUMENTATION CONTINUATION SHEET gS kv' )

DRAFT SOURCE DEVIATION STEP STEP FROM SOURCE BASIS FOR DEVIATION YES K0 C6-5.3 C6-5.3 X C6-6 C6-6 X Contingency #7 Ileading IIcading X Note #1 Noto #1 X C7-1 C7-1 X 1. Technical specifications utilized for setpoints.

2. See p. 7 for discussion

/~ on boron injection temperature.

( v]) 3. Flow stagnation water level is bounded by the TAF, thus that value will be utilized until the calculationn! procedure is further developed.

Note #2 Note #2 X Note #3 Note #3 X See C7-1  ;

C7-2 C7-2 X llPCI and LPCI both inject '

outside the core shroud and are appropriate for this step.

C7-2.1 C7-2.1 X O Draft Documentr _ bS EPG. Rev. A 5/3/85 Writer 64u .

+,o .

Date 7/%/8 P 0

L____.___..____ _ _ _ _ _ . _ . _ _ _ _ _ _ . _ _ _ . _ _ . _ _

I Attcchment !

STEP DOCUMENTATION CONTINUATION SHEET

7. s

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/

\

DRAFT SOURCE Di!VIATION STEP STEP FR1H SOURCE BASIS FOR DEVIATION YES NO C7-2.2 C7-2.2 X 1. IIPCI and LPCI are appropriate for the first part of this step as they both inject out-side the core shroud.

2. The list of alternate injection subsystems is ,

included.

3. IIPCS deleted - none at CNS.

Note #4 Note #4 X r]

C7-3 C7-3 ) See p. 6 for discussion of control rod position.

Noto #5 Note #5 X C7-4 C7-4 .( Included appropriate CNS procedure number.

[G) Draft DocumentI CNS FPC Hev./) 5/3/85 Writer: 40 ;T g. Datn ([b/$ 7' C

Att*chme7.t 2 PLAlff SPECIFIC EPC vat,UES, L1 HITS, CURVES AND INFORMATION PLANT: COOPER NUClf.AR STATION EPC RLV. 3T EPG Typ*

g; lEPC Description) Step Page of item (What to in Brackets) No. No. Cont. Value Source

1. Temperature (i.e. from a C86 1*6 All Average of Plant Operations specific sensor or loca- TE SOSA,B.C.D, and E Department tion) near the instrument reference les vertical run (one for each ref.les)
2. Temperature and Indicated C#6 I6 Temp. Indic. App.C (2.0) level that the level Level instrument becomes unre-liable for thes
a. Shutdown Range Level any 98.19 in. App.C
h. Wide Range f.evel 212'F 115.80 in,
c. Narrow Ran,ge Level 306'r 20.04 in,
d. Fuel Zone Range Level 547'F 169.08 in.
3. Range of the Followinst C86 16 All Instruments (Level):
a. Shutdown Range 0 +400 in. Tech tipecs,
b. Wide Range 150**60 in. Figure 2.1.1,
c. Narrtw Range 0 +60 in. p. 10
d. Fuel Zone 100 +200 in.

4 Level instruments having C87 16 All See Table 1, Page 2 lleated Reference Lege S. Level Instruments having C#7 16 All See Table 11, Page 3 Cold Peference Legs

6. NPS11 requirements for Ces 18 All Curve See Pages 4 and S RIIR /LPCI 7 NPSil requirreents for C#8 18 All curve See Pages 6 and 6 LPCS M. NPSil requirements for Cd8 18 All NA IIPCS 9 flurpression Pool liigh C#9 1R All 2.S in. Tech 8 pees, p. 57 Water Level suction interlock (for lif'CS or llPCI & RCIC)
10. Condensate Storage Tank C89 lR All 0 in. Tech 8pecs, p. 56 low level suction interlock
11. Drywell Pressure Cell 18 All 2.0 pata Tech Specs, p. S4 which initiates ECCS s

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Attachment 2 i'

NPSil REQUIREMENTS FOR RilR/LPCI AND LPCS I Items 6 and 7 J

C Torus Prennure V Ps NPSil Req. O psig 5 psig 10 psig

0 1500 spe 3.0 psig 14.0 ft 201'F 219'T 233*F f 2950 2.5 14.0 199 217 231 4750 1.4 17.0 188 210 225 lj 4850 1.2 18.0 184 207 224 i

l.it! Torus Pressure l

J V Pe NPSil Req. O palg 5 pets 10 pata 0 1950 spm 4.5 pets 23.5 ft 190'F 211'F 226'F i l l 4M10 4.25 23.5 1R8 210 225.5 l l

! $775 4.0 23.3 187 209 225 I

I j 6740 1.75 24 185 207 223.5 l I

1 l 7700 3.5 25 181 205 222 a400 3.3 26 in 2a2.5 220 i

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Attactunent 2 4

  • Item 6 250 FIGURE 1-1 240 LPCI NPSH REQUIR[MENTS p 230

% 10 PSIG e .

< 220 '

a 210 g N 5 PSIG N

200 l

t

/-~

' o lC i

~

x 1' , ,  %

10 0

,x 0 PSIG 0 1 2 3 4 ,

S 0 7 8 9 LPCI Puup Ft OW lx 1000 Cf'M)

,

  • TORUS PRCSSURE wilH POOL AT NORMAL WAl[R ((VCL O

l' '.

' - JJ 4

5

Attcchment 2 Item 7 250 I I rc.,RE 1-2 CS NPSH REQUIREMEN1S 240 p 230 -

10 P510 * ~

y 4 220 t-20 A

$ PSG

~ .

200 0 PSIG 18 0 17 0 0 1

  • CS PUMP FLOW IX 1000 CPM)
  • 10RUS PRESSURE WITH POOL AT NORMAL WATER LEVEL o

I

  • Page 6

{

Att:chsent 2 PLANT-SPECIFIC EPC VALUES, LIMITS, CURVES AND INFORMA1 ION PLANT: COOPER NUCLEAR STATION EPG REV. 3I' f ,.s

( \ EPC Type Ng  ! [EPC) Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source

12. IIPCI Minimum Turbine C#12 I-9 All 2050 RPM OP 2.2.33, p.10 Speed Limit
13. RCIC flinimum Turbine C#12 1-9 All 2200 RPM OP 2.2.67, p. 8 Speed Limit
14. RPV Cooldown Rate LCO C#13 1-9 All 100'F/hr Tech Specs, p. 132 C#17 I-9 RC/P-3 RC-7 C5-6.3 C5-1
15. HPCI or RCIC low pressure C#14 I-9 All isolation setpoint Cl-3 Cl-2 (higher of) Cl-7 Cl-4 Setpoint for HPCI: 100 psig Tech Specs, p. 56 Setpoint for RCIC: 50 psig Tech Specs, p. 58
16. SRV Opening Sequence C#15 I-9 All C,A,E,H,C,F,B,D See Page 8 17 Determine if phrase C#16 I-9 All Not applicable No interlocks on applies: [ ventilation steam tunnel system andl coolers per (Ref. App. B 5-11) B&R 2020

/ s k )

18. SLC tank low level C#19 I-10 All None OP 2.2.74, p. 9 trip (pump) (Manually trip (Ref. App. B5-14) at 1% level)
19. Elevation of Bottom of C#23 1-10 1 16 ft. 6 in. See Page 9 MK I Internal Suppression SP/L-3.2 PC-13 Chamber to Drywell (2 pl)

Vacuum Breaker, less SP/L-3.2.2 PC-14 Vacuum Breaker Opening Pressure in it. of H 0

20. Cold Shutdown RPV Control RC-1 All Coolant temperature Tech Specs, p. 5 Conditions Purpose <212'F
21. RPV Water Level - Low RPV Entry RC-1 A11 +12.5 in. Tech Specs, p. 28 level scram setpoint Cond.

RC/L-2 RC-2 RC/L-2 RC-3 Cl-5 C1-3 C7-2 C7-2 C7-3 C7 4 C7-3 C7-5 O

V Page 7

Attachment 2 SRV OPENING SEQUENCE 4 Item 16 4

  • No SRV opening sequence at CNS at present (old one removed when LLS installed).

i

  • Suggest: C, A, E,11, C, F, B, D Basis:

i

, 1. All eight SRVs are utilized to uniformly distribute energy in the torus.

. 2. Minimizes possibility of SORV.

1- 3. 14calized venting avoided.

4 Sequent repeatable. ,

1,

5. SRVs nearest RHR suppression pool cooling discharge used first.

e ,

! NOTE: This sequence was verified an approved on 5-4-84. This is documented in E0P prevalidation  !

(submitted March 31, 1985), discrepancy sheet #3.

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Attschment 2 ELEVATION OF BOTIM OF MK I INTERNAL SUPPRESSION CHAMBER Item 19 Elevation of bottom of MK I suppression chamber to drywell vacuum breaker less opening pressure.

N

Reference:

Burns & Roe Drawing 4260 ' ,

Center line of 20" vacuum breaker = 880'10\"

nerefore, bottom of vacuum breaker = 880'\"

Torus center line = 876'7\"

Torus radius = 14'45" n erefore, suppression chamber bottom elevation - 862'3" nerefore, height of vacuum brealc, r = 880' "-862'3"

= 17'9\"

Vacuum breaker pressure = .5 psia = 1.15 ft H O Therefore, valve required = [17'9\"-1.15]ft = 16.642 ft H 0

= 16 ft 6" (accuracy on LR-1A) i Page 9

Att ctment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMATION PLANT: COOPER NUCLEAR STATION EPG REV. 3I

,~ ,

(, EPG Type

\j [EPG] Description Step Page of

-Item (What is in Parentheses) No. No. Cont. Value Source

22. High RPV Pressure Scram RPV Ent RC-1 All 1045 psig Tech Specs, p. 23 Setpoint Cond.
23. High Drywell Pressure RPV Ent Cond. RC-1 All 2.0 psig Tech Specs, p. 28 Scram Setpoint PC Ent Cond. PC-1 C7-1 C7-1 (2pl)

C7-2 C7-2

24. APRM Downscale Trip RPV Ent Cond. RC-1 All 2.5% Tech Specs, p. 28 RC/Q-3 RC-8 C7-1 C7-1 C7-1 C7-1A C7-2 C7-2
25. Determine if phrase RC/L-1 RC-2 All Applies DG initiation applies: [ Emergency relatively diesel generatori important-all CSCS (Ref. App. B6-12) pumps powered from emergency busses.
26. RPV Water Level - RC/L-1 RC-2 All +58.5 in. Tech Specs, p. 56 High Level Trip Setpoint C7-2 C7-2

(^))

(v C7-3 C7-4

27. RPV Pressure range for All system operation fort
a. Condensate /Feedwater RC/L-2 RC-2 0-1800 psig 2 68-12-1 System &
b. CRD System RC-3 0-1650 psig 2 66-31-26
c. RCIC C7-2 C7-2 & 50-1200 psig TM 66-31-108
d. HPCI/HPCS C7-3 150-1238 psig IM 66-31-3

, e. LPCS 0-340 psig TM 66-31-33

f. LPCI 0 268 psig TM 66-31-4
28. Top of Active Fuel RC/L-2 RC-3 All 352.56 in. Tech Specs, (3 pl) above vessel zero Fig. 2.1.1, p. 10 Cl-7 Cl-4 Cl-8 Cl-4, (equivalent to C4-3 C4-1 -164.19 in, below C7-2 C7-3 instrument zero) l (2 pl)

C7-2.2 C7-4 (3 pl)

C7-3 C7-5 l (2 pl) i

( .

(j Page 10

Attachment 2' PLANI-SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMATION PLANT: COOPER NUCLEAR STATION EPG REY. 3I j~~3

, \ EPG Type b [EPG] Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source

29. Number of SRV's RC/P RC-4 All 6 USAR, Table IV-4-1 dedicated to ADS (2 pl)

C2-1.2 C2-1 C4-1 C4-1

30. RPV Pressure at which RC/P-1 RC-4 All 935 psig Dome pressure at all turbine bypass valves 25% rated per DEH are fully open diagram
31. Heat Capacity Temperature RC/P-1 RC-5 All Curve App.C (3.0)

Limit SP/T-4 PC-2A

32. Suppression Pool Load RC/P-1 RC-5 All Curve App.C (4.0)

Limit SP/L-3 PC-12

33. Lowest SRV Lifting RC/P-2 RC-6 All 1080 psig USAR, Table IV-4-1 Pressure (nominal)
34. Elevation of top of SRV RC/P-2 RC-6 All 5 ft. 6 in. EDS Dwg VR-P-W3 discharge device (in C2-1.2 C2-1 above torus terms of Suppression bottom Pool Water Level) gg i i Determine if [CLOSE) RC/P-2 RC-6 All No SRV switch posi-(b') 35. is appropriate termi- tions are AUT0/

nology (switch position) OPEN. (use AUTC)

36. Determine applicable RC/P-2 RC-6 All SJAE OP 2.2.55

[0ther steam driven A0G preheater. OP 2.2.58 equipment] for use in A0G 3rd stg air eject.0P 2.2.58 controlling RPV pressure RFPT OP 2.2.28 below SRV setpoint Gland Seal OP 2.2.75 (Ref: App. B6-38) RHR steam condensing OP 2.2.69

.m s.,

.w Page 11

-Attrchment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMATION PLANT: COOPER NUCLEAR STATION EPG REV. 3I

( ) EPG Type N / [EPC] Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source

37. Maximum subcritical RC/P-3 RC-7 All Position 02 App.C banked withdrawal post- RC/P-4 RC-8 calculational tion (Ref App. B6-43) (2 pl) procedure RC/Q-5.4 RC-11 RC/Q-5.6 RC-12 (2 pl)

C6-2 C6-1 C6-2.4 C6-3 C7-3 C7-4

38. Cold Shutdown Boron RC/P-3 RC-7 All 432.29 lb. App.C (5.0)

Weight RC/Q-4.2 RC-9A

39. Determine if phrase RC/Q-1 RC-8 All Applies Tech. Specs, p. 52-applies: [ Confirm no MSIV closure due or place the to placing mode reactor mode switch in switch in SHUIDOWN.

SHUTDOWN]

(Ref. App. B6-52)

40. Determine if phrase RC/Q-2 RC-8 All Applies OP 2.4.2.33 - no applies [and the autematic turbine

,/~ 'N MSIVs are open] trip due to MSIV

'(%/) (Ref. App. B6-53) closure.

41. Boron Injection Initia- RC/Q-4 RC-9 All 110*F App.C (6.0) tion Temperature SP/I-3 PC-2 (of Suppression Pool) C7-1 C7-1 C7-2 C7-2
42. Develop list of alt. RC/Q-4 RC-9 All CFD See Page 13 systems (and procedures) MC/RF for injecting Boron into HPCI the RPV (i.e., CRD, HPCS, RCIC RWCU, Feedwater, HPCI, RER RCIC, Hydro Pump, etc. CS RWCU
43. - Fuses which de-energize RC/Q-5.1 RC-10 All 5A-F18A,E,C,C(Panel 9-15) CE Dwg.

RPS scram solenoids (2 pl) SA-F18B,F,D,H(Panel 9-17) 791E256 Rev.5 Sheet 1

, #^N

[ \

\

l Page 12 k

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

t Attachment 2 i ALTERNAIE SYSTEMS FOR BORON INJECTION f

Item 42 i

, The following systems are possible for boron injection.

1

1. Condensate /Feedwater - makeup to condenser from CST i 2. CRD - suction from CSI i
3. HPCI - suction from ECST i
4. RCIC - suction from ECST
5. LPCS - suction from CST per OP 2.2.9, p.6
6. RHR - suction from CST per_ OP 2.2.54, p.12 i
7. RWCU - boron can be introduced to F/D (with precoat removed) via precoat tank. >

i i

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6 Page 13

. _ _ , . , . ~ , _ , .. . _ , . , , . _

- - _ m - . - - . - . _ _ .

Attachment 2 -

PLANT

  • SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMAIl01 PLANT: (X)OPER NUCLEAR STATION EPG REV. 3I

. ,.3 EPC Type

( }

,/ [EPGl Description Step Page of Item (What is in Parentheses) No. No. Cont, Value Source 44 Scram Air Header Supply RC/Q-5.1 RC-10 All IA-985 Visual inspection Valve (2 pl)

45. Scram Air Header Vent RC/Q-5.1 RC-10 All IA-1601 Visual inspection Valve (2 pl)
46. HCU Accumulator Charging RC/Q-5.2 RC-11 All CRD-29 B&R 2039 Water Header Valve (2 pl)

RC/Q-5.5 RC-12

47. CRD withdraw line vent RC/Q-5.6.1 RC-12 All CRD-157 OP 2.2.8, p. 10 valve (3 pl)

< PRIMARY C0KIAINMENT CONTROL GUIDELINE

48. Most limiting suppression PC Entry PC-1 All 95'F Tech Specs, p. 159 pool temperature LCO Cond.

SP/T-2 PC-2

49. Higher of
a. Drywell temperature PC Entry, PC-1 All 150*F USAR, Table V-2-4 LCO Cond.

DW/T-1 PC-3 185'F

( b. Maximum normal operating temperature See Page 15

50. Containment temperature PC Entry PC-1 III NA LCO Cond.

CN/T-1 PC-5

51. Maximum Suppression PC Entry PC-1 All 91,100 Ft Tech Specs, p. 159

. Pool Water Level LCO Cond. (+1.5 in on PC-LI-12)

SP/L-1 PC-10 (2 pl)

SP/L-3 PC-12 i

, )

, -%j Page 14

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

- Attachment 2 4  !

MAXIMUM NORMAL OPERATING TEMPERATURE Item 49.b 4

1 1' 'A four year review of operating logs (Document No. 6.2.4.1, Att. A) indicated that the highest temperture recorded on 1E-505A through E was 171*F.

3 A 10% margin was added to this to prevent inadvertent entry into E0P-2.

4 The maximum normal operating temperature was thus rounded off to 185'F.

l i-I 4

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i Page 15 l I


,w,_ ____.__ - - - - ,- - -

Attachment 2 PLANI-SPECIFIC EPC VALUES, LIMITS, CURVES AND INIX)RMATION PLANT: (X)OPER NUCLEAR STATION EPC REV. 3I

[ EPC . Type

\- , [EPCJ Description. Step Page of

(~.h t is'in Parent!. eses) Cont. Value Source

' Item - F.r. ~ " '% No. _

52. Minimum Suppression Pool PC Entry PC-1 All 87,650 ft' Tech Specs, p. 159 Water Level 140 Cond. (-2.5 in. on PC-LI-12)

SP/L-1 PC-10 (3P1)

SP/L-2 PC-11

53. High Hydrogen Alarm ' PC PC-1 All 3.6% OP 6.3.1.9, p. 2 Setpoint (for Primary Entry Containment) Cond.
54. Optional Plant Specific SP/T-1 PC-2 All None OP 2.4.2.3.1 time interval (Ref t App. B7-8)
55. .Drywell temperature near DW/T-2 PC-3 All See item #1 the cold reference les C6-5-1 C6-4 instrument vertical runs (Ref App. B7-21) 56.- RPV Saturation Temp- DW/T-2 PC-3 All Curve App C (7.0)'

erature CN/T-4 PC-5 Lower of:

f5 57.' DW/T-3 PC-4 .All

.( a. Maximum temperature at which ADS qualified (2 pl) 281*F USAR, VII-4.3.3

b. Drywell design temp- 281'F USAR, V-2,3.2 erature (Ref. App. B7-28 & 29)

-58. Determine if phrase DW/T-3 PC-4 -I/II Applies Drywell sprays

-applies: [ suppression PC/P-3 PC-6 can be throttled, chamber temperature and PC/P-6 PC-9 drywell pressure are SP/L-3.2.1 PC-13 below the Drywell Spray PC/H-4.5 PC-23 Initiation Pressure PC/H-6.5 PC-25

' Limit] PC/H-7.2 PC-26 (Ref. App. B7-23 thru B7-28, B7-47, B7-70)

59. Determine if phrase DW/T-3 PC-4 I/II Applies Prevent recircula-applies: [ shut down PC/P-3 PC-6 tion pump and recirculation pumps PC/P-6 PC-9 drywell cooler and drywell cooling SP/L-3.2.1 PC-13 damage, fans and] PC/H-4.5 PC-23

_(Ref. App. B7-28) PC/H-6.5 PC-25 PC/H-7.2 PC-26

'. \.

Page 16

Attachment 2 PLANT-SPECIFIC EPC VALUES, LIMITS, CURVES AND INFORMATION FIANT: COOPER NUCLEAR STATION EPC REV. 3I

,~ .

Type

~

EPG

[EPC] Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source

60. Determine if phrase DW/T-3 PC-4 I/II NA App C (8.0) applies: Irestricting . PC/P-3 PC-6 flow rate to less than PC/P-6 PC-9 720 gpm (Maximum Drywell SP/L-3.2.1 PC-13 Spray Flow Rate Limit)] SP/L-3.2.2 PC-14 (Ref. App. B7-23 to 28) PC/H-4.5 PC-23 PC/H-6.5 PC-25 PC/H-7.2 PC-26
61. Drywell Spray Initiation DW/T-3 PC-4 I/II curve App C (9.0)

Pressure Limit PC/P-3 PC-6 PC/P-3 PC-7 PC/P-6 PC-9 SP/L-3.2.2 PC-14 PC/H-4.5 PC-23 PC/H-6.5 PC-25 PC/H-7.2 PC-26

62. Maximum'Drywell Spray DW/T-3 PC-4 I/II Rated App C (8.0)

Flow Rate Limit PC/P-3 PC-6 PC/P-6 PC-9 SP/L-3.2.1 PC-13

( SP/L-3.2.2 PC-14

( PC/H-4.5 PC-23 PC/Il-6.5 PC-25

63. Containment design CN/T-2 P-4 T'I NA temperature (2 pl)
64. Determine if phrase CN/T-2 PC-4 III NA applies: [ suppression PC/P-2 PC-6 chamber pressure is PC/H-2.3.1 PC-18 above 1.7 psig (Mark PC/H-3.2.1 PC-21 III Containment Spray PC/H-4.2 PC-22 Initiation Pressure PC/H-5 PC-24 Limit)] PC/H-6.1 PC-24 PC/H-7.1 PC-26
65. Mark III Containment CN/T-2 PC-4 III NA App C (10.0)

Spray Initiation PC/P-2 PC-6 Pressure Limit PC/H-4.2 PC-22 PC/H-6.1 PC-24 PC/H-7.1 PC-26

66. Containment temperature CN/T-4 PC-5 III NA near the cold reference leg instru-A ment vertical runs

(

Page 17

-Attachment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMATION PLANT: COOPER NUCLEAR STATION EPG REV. 3I

-m

} EPG Type N / [EPGl Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source

67. Determine if phrase PC/P-1 PC-6 All Applies Drywell coolers applies: Operate [the can be considered following systems as a containment required pressure control
  • Containment Pressure system.

cc t. trol systems. Use can tainment pressure control system operating procedure.]

(Ref. App. B7-43)

68. Determine if phrase PC/P-1 PC-6 III NA applies: [and dryv,:11 purgel (ref. App. B7-44)
69. Maximum Noncondensible PC/P-1 PC-6 All 212*F BWROG EPG, Rev. 2 Evacuation Temperature Appendix B,
p. B7-44.
70. Determine if phrase PC/P-1 PC-6 III NA applies: [If while executing the following

('

!s N

f-steps suppression pool sprays have been initiated, when suppres-sion chamber pressure drops below 0 psig, tetuinate suppression pool spraysl

71. Determine if phrase PC/P-2 PC-6 III NA applies: [the Pressure PC/P-4 PC-7 All Applies Additional
Suppressien Pressurel operating margin (Ref. App. B7-51) provided justifies its use.
72. Determine if phrase PC/P-? PC-6 I Applies Mark I containment applies: [17.4 psig (2 pl) at CNS (Suppression Chamber Spray Initiation Pressure)]
73. Suppression Chamber PC/P-2 PC-6 All 16.36 psig App C (11.0)

Spray Initiation (2 pl)

Pressure

74. Pressure Suppression PC/P-2 PC-6 All Curve App C (12.0)

Pressure PC/P-4 PC-7 r%

v Page 18

_ . - __ _ _ .._ _ . _ . _m-.

Att:chment 2 i

PLANT-SPECIFIC EPC VALUES, LIMITS, CURVES AND INFORMATION PLANT: (X)OPER NUCLEAR STATION EPG REV. 3I

,e EPG Type 1 (EPC] Description Step Page of

  • - Item (What is in Parentheses) No. No. Cont. Value Source
75. Determine if phrase . PC/P-2 PC-6 I/II Applies Mark I containment applies: (suppression PC/P-6 PC-9 at CNS pool water level is PC/H-4.2 PC-22 below 24 ft 6 in. PC/H-6.1 PC-24 (elevation of suppres PC/H-7.1 PC-26 sion pool spray nozzles))

(Ref. App. B7-46)

76. Elevation of suppression PC/P-2 PC-6 I/II 26 ft. 9 in. B&R 4260, Rev 7 pool spray nozzles PC/P-6 PC-9 above torus (if applicable) PC/H-4.2 PC-22 bottom (ref. App. B7-46) PC/H-6.1 PC-24 PC/H-7.1 PC-26
77. Determine if phrase PC/P-5 PC-8 All Applies Additional applies: Ithe Primary operating margin Containment Design provided justifies Pressure] its use.

(Ref. App. B7-55)

78. Primary Containment PC/P-5 PC-8 All Curve App C (13.0)

Design Pressure C6-6 C6-5

(

(* 79. Primary Containment PC/P-6 PC-8 All Curve App C. (14.0)

Pressure Limit 4

80. Determine if phrase SP/L-1 PC-10 III NA applies: ISuppression pool makeup may be augmented by SPMS]

(Ref. App. B7-61)

81. Determine if phrase SP/L-1 PC-10 III NA applies: 123 ft. 9 in. (2 pl)

(SPMS initiation SP/L-3 PC-12 setpoint plus suppres-sion pool water level increase which results from SPMS Operation)).

(Ref. App. B7-62)

82. SPMS initiation SP/L-1 PC-10 III NA setpoint plus suppres- (2 pl) sion pool water level SP/L-3 PC-12 increase which results from SPMS operation.

(Ref. App. B7-62)

O U

Page 19

Att chment 2 PLANT-SPECIFIC EPC VALUES, LIMITS, CURVES AND INIVRMATION PLANT: COOPER NUCLEAR STATION EPC REV. 3I Ih EPG Type

\ [EPC] Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source

83. Determine if phrase SP/L-1 PC-10 III NA applies: [19 ft. 11 in.

(minimum suppression pool water level LCO)]

(Ref. App. B7-62) 84 lleat Capacity Level SP/L-2 PC-10 All Curve App C (15.0)

Limit

85. Determine if phrase SP/L-3 PC-12 I/II Applies Mark I containment applies: [12 ft 6 in.

(maximum suppression pool water level LCD)]

86. Iower of: I
a. Maximum Primary SP/L-3.2 PC-13 104.25 ft App C (16.0)

Containment Weter SP/L-3.2.3 PC-14 Level Limit

b. Elevation of bottom SP/L-3.2 PC-13 I Duplicate See #19 of Mark I internal (2 pl) suppression chamber to drywell vacuum O breakers, less vacuum f \ breaker opening pressure

\ in feet of water.

87. Determine if phrase SP/L-3.2.2 PC-14 I Applies Mark I containment applies: [17 ft. 2 in.

(elevation of bottom of Mark I internal suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water).

l l

l l

l I

i i

[^T b

I l

Page 70

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

Attachment 2 PLANT-SPECIFIC EPC VALUES, LIMITS, CURVES AND INTDRMATION PLANT: COOPER NUCLEAR STATION EPG REV. 31

. ,m Type

} EPC N !EPC) Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source

88. Determine if phrase applies: [ respective] PC/H PC-15 All (4 pl)

PC/H-2.1 PC-17 (2 pl)

PC/H-2.3 PC-18 (2 pl)

PC/H-3.2 PC-21 PC/H-5 PC-24 (4 pl)

PC/H-6 PC-24 (4 pl)

PC/H-7 PC-26

89. Minimum detectable PC/H-1 PC-15 All 0.2% by volume USAR, V-2-22 hydrogen concentration (2 pl)

PC/H-2.1 PC-17 PC-H-3 PC-20

90. Elevation of the bottom PC/H-1.2 PC-16 All 28 ft. 9 in. B&R 4260, Rev. 7 of the suppression (2 pl) chamber vent PC/H-4.3 PC-22 l<^ (2 pl)

PC/H-6.2 PC-25

- (2 pl)

91. Determine if phrase PC/H-1.2 PC-16 All applies: Ito atmospherel PC/H-1,3 PC-16 PC/H-4.4 PC-23 PC/H-6.3 PC-25
92. Determine if phrase PC/H-1.3 PC-16 All applies: (nitrogen) PC/H-4.4 PC-23 PC/H-6.3 PC-25
93. Determine if phase PC/H-1.3 PC-16 All I

applies: [ containment PC/H-4.4 PC-23 l and] PC/H-6.3 PC-25 I

l i

I l

\

l f

l l

Page 21 i

Attachment 2 PLANT-SPECIFIC EPC VALUES, LIMITS, CURVES AND INIVRNATION PLAhT: COOPER NUCLEAR STATION EPG REV. 31 l' / .x EPC Type

\ss ,,j [EPC] Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source

) .94 Determine if phase PC/H-2.1 PC-17 All applies [RPV pressure is below the Primary Containment Pressure Limit and either)

95. Higher of PC/H-2.2 PC-18 All
a. mintmum hydrogen PC/-3.1 PC-20 NA No recombiners concentration at CNS for recombiner operation <
b. Minimum detectable Duplicate - See #89 hydrogen concent-ration
96. Lower of t PC/H-2.2 PC-18 All
a. Maximum hydrogen PC/H-2.4 PC-19 KA No recombiners concentration for PC/H-3.1 PC-20 at CNS recombiner opera- (2 pl) tion PC/H-3.3 PC PC/H-4 PC-22 rx
b. Lowest hydrogen PC/H-2.5 PC-19 concentration which PC/H-4 PC-22 can support a de-flagration 97 Lower of PC/H-2.2 PC-18 All
a. MaxLmum oxygen PC/H-2,3 PC-19 NA No recombiners concentration for PC/H-3.1 PC-20 at CNS recombiner opera- (2 pl) tion or PC/H-3.3 PC-21 PC/H-4 PC-22
b. Iowest oxygen concentration which can support a deflagration
98. Minimum hydrogen con- PC/H-2.3 PC-18 All NA No ignitors at CNS centration for which PC/H-3.2 PC-21 ignitors recombine hydrogen and oxygen

'N 4

4 Page 22

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

Attcchment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMATION PIANT: (X)OPER NUCLEAR STATION EPC REV. 3I

,,.-s y EPC Type

{

[EPC) Description Step Page of Item (What is in Parentheses) No. No. Cont. Value Source 99 Determine if phrase- PC/il-2.5 PC-19 All applies: [When dry-well hydrogen con-centration reaches 6% (lowest hydrogen concentration which can support a de- ,

flagration) and dry-well oxygen concent-ration reaches 5%

I (lowest oxygen con-centration which can support a deflagration)]

I 100. Determine if phrase PC/H-4 PC-22 l applies: [When

.,I hydrogen concent-l ration in either the drywell or the'supp-a ression chamber reaches [6% (lowest hydrogen concentration which can support a deflagration)I [8%

(maximum hydrogen con-centration expected when ignitors are function-ing properly) but only) 101. Maximum hydrogen concent- PC/H-4 PC-22 All NA No ignitors at CNS ration expected when ignitors are function-ing properly t

i O

(

s Page 23

Attachment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMATION PIANT: COOPER NUCLEAR STATION EPG REV. 31 _

l 8 EPG Type

lEPC) Description Step Page of Item (khat is in Parentheses) No. No. Cont. Value Source 102. Determine if phrase PC/ll-4 PC-22 All applies [or the dry-well and suppression chamber oxygen concent-rations below 5% (maxi-mum oxygen concentration for recombiner operation or the lowest oxygen con-centration which can support a deflagration whichever is lower)I 103. Determine if phrase PC/ll-6 PC-24 All applies: lor the dry-well and suppression chamber oxygen concent-rations below the (respectivel Oxygen Deflagration Overpres-sure Limits as follows]

SECONDARY CONIAlh1ENT CONTROL CUIDELINE 104 Secondary containment Oper. SC-2 All 100 mr/hr Tech Specs, p. 63 IIVAC isolation setpoint Actions (2 pl)

SC/T-2 SC-3 105. Determine if phrase Oper. SC-2 All Not applicable No sprays in applies lonly when the Actions secondary space being evacuated containment is below 212*F) 106. 1 - Operating Table 1 SC-5 All (See Values of Secondary thru Pages Containment Parameters SC-8 25-28)

Page 24

l TABLE 1 '

Operating Values of Secondary Containment Parameters k*ATER LEVELS  ?

i Sump Haximum Haximum HIGH- Normal Safe Secondary' Containment HIGH Operating Operating Parameter / Location (3) Alarm Value Value

- Sump A/NW Quad 34"II) < Sump HIGH- 6'( } f HIGH Alarm

- Sump B/NE Quad 34"( < Sump HIGH- 4'( }

HIGH Alarm .

- Sump C/SW Quad 33"U) < Sump HIGH- l' HIGH Alarm nJump D/SE Quad 42"(l) < Sump HIGH- 4'( }

/ HIGH Alarm

- Sump E/SE Quad 24"II) < Sump HIGH-HIGH Alarm

- Torus Compartment Area Level None 0" ' 15 (3)

Sources:

1. OP 2.3.2.20 l 2. USAR X - 14.3.3 j 3. Buoyancy ef fect on torus at 15'

}

(See Page 27) i I O

! Page 25 i

~

TABLE 1 Operating Values of Secondary Containment Parameters

  • AREA TDiPERATURES Maximum Normal Maximum Safe
  • Area Ternerature Alarm Operatine Value Operating Value

('F) (*F) (*F)

RWCU 2

- RWCU Pump A Room. E 938' 150, 150 ,' 200 2

- Reactor Suction Area, W 950' 140, 140, 200 2

- RWCU Pump B Room. E 938' 150, 150, 200 2

- RWCU HX Room, S 960' 140, 140, 200 2

- RWCU Phase Separator Room, S 938' 140, 140, 200 2

- Torus Area, SE 896' 140 140j 200 2

- Torus Area, W 896' 140,y 140, 200 2

- Tunnel Area , W 906 ' 150 150 200 RCIC And CS

' 3 4

- CS Room, SE (VBd-R) 160, 160, 200 4

- CS Room, NE (VBd-R) 160 3 160 3 200 4

- RCIC Quad Area, SW 859' 175 3 175 3 200 4

- RCIC Quad Area, N 859 ' 175, 175, 200

- Torus Area, NE 859 ' 175' 175' 200 4

- Top Torus, ENE 175 175 3

200 4 Steam Tunnel 5

- Tunnel Area - Line A 200' 200' 220

[7'N\ - Tunnel Area - Line B 200 200 I

220 5 k - Tunnel Area - Line C 200 I

200 I

220 5

- Tunnel Area - Line D 200 I

200 I

220 5 1:PCI 3 3 6

- DW Access Room Area, S 910' 175, 175, 200 6

- Torus Area, WSW 888' 175, 175, *00 6

- RHR Ouad, SW E 78 ' 175, 175, - 200,

- HPCI Room, E 878' 175' 200" 160 3 175'3 160 2006

- HPCI Room (VBd-R)

RHR g 7 7

- RHR HX 1A Room, 931' 1607 1607 200f

- RHR HX 1 A Room, 903 ' 160, 160, 200,

- Terus Area, NNW 865' 160' 160' 200" 7 8

- Torus Area, NW 885' 160, 160 200

- RRR HX IB Room, 931' 160, 160', 200%

- RHR HX IB Room, 903 ' 160; 160', 200%

- Torus Area, SW 900' 160' 200" 16 % 7 200 8

- Torus Area, SW 890' 160, 160

- RHR Room, NW (VBd-R) 160' 200" 16% 7 200 8

- RHR Room, SW (VBd-R) 160 160

(

rs V)

[

Page 26

t Sources:

- [- 1. I&C Files: MS-28 h

2. USAR VII-3-2
3. GEK9688, Vol. V
4. USAR VII-3.23

[

, - 5. Alarm setpoint is 200', 220* chosen as acceptable margin between two 5

action levels I 6. USAR VII-3.24

7. 21A 1481 4

[ 8. Not specified. Chosen to be compatible to other systems.

' Torus Area Maximum Safe Operating Value Burns & Roe Elevation 859'9" - floor of torus area

_ 2066 Elevation 876'7 " - centerline of torus Appendix C. Data - l'10" below torus centerline - minimum operating torus level i

876' 7 "

!( l'10"

874' 9" - Elevation of minimum suppression pool level

~

If level in torus area exceeds this, would have buoyancy effect on the torus;

therefore, maximum safe level in torus = 874'9h"
859'9" l Level above. torus floor = IS' "

l

- Note: Since LI-900 only reads 0-15', maximum safe operating level is 15'.

i Page 27 l

i

. t RADIA  : LEVELS Secondary Containment Maximum Normal Maximum Safe Parameter / Location Operatine Value Operating Value Area Radiation Level (mr/hr) (ar/hr)

- Fuel Pool Area (Refueling Alarm) NA NA

- Fuel Pool Area 50 100

- New Fuel Area 25 100

- RWCU Precoat Area 500 1000

- RWCU Sludge And Decant Puep Area 50 500

- TIP Index Area 500 1000

- TIP Drive Mechanical Area 40 100

- CRD Equipment Area, S 50 100

- CRD Equipment Area, N 60 100

- HPCI Pump Room 50 100

- RHR Pump Room, SW 50 100

['

- RHR Pump Room. NW 60 100

- RCIC/CS Pump Room, NE 50 100

- CS Pump Room, SE 50 100 Sources:

1. Operational experience and instrumentation range limitations (Design change request initiated to increase range of area rad monitors)

Page 28

Attachment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INIVRMATION PLANT: COOPER NUCLEAR STATION EPG REY. 31

(.

'( j) w [EPC) Description Item (What is in Parentheses)

EPG Step Page Type of Value No. No. Cont. Source CONTINGENCIES CONTINCENCY #1 107. Determine alternate Cl-2 Cl-2 All injection subsystems i.e, C6-3.1 C6-3 RHR service water cross- C6-4 C6-4 Applicable EP 5.2.10 tie C7-2.2 C7-4 Fire System NA None at CNS Interconnections with NA Single unit plant other units ECCS keep-full systems Applicable OP 2.2.7 SLC (test tank) Applicable OP 2.2.74 SLC (boron tank) Applicable OP 2.2.74 108. RPV pressure at which Cl-3 Cl-2 All 340 psig See Page 30 LPCS shutoff head is reached.

109. ADS initiation setpoint Cl-3 Cl-2 All -145.5 in. Tech Specs, p. 59 110. Determine if phrase Cl-8 Cl-4 All Applies Preference to

\ applies: (if no HPCS utilize CS prior s or LPCS subsystem is to injecting operating) service water in (Ref. App. B8-25) the RPV.

NOTE: Page Cl-5 contains an alternate format for steps Cl-3 through Cl-8.

For information required see # 16, 22, 29, 109-111.

CONTINCENCY #2 111. Minimum number of C2-1.3 C2-1 All 3 App C (17.0)

SRV's required for C6-1 C6-1 emergency depressur- C6-3.1 C6-3 ization C6-3.2 C6-3 112. Determine if phase C2-1.3 C2-1 All Applies SRV type (Target applies: [and RPV C5-6.3 C5-1 Rock) requires RPV pressure is at least pressure to open 50 psig (Minimum SRV valve.

Re-opening Pressure) above Suppression chamber pressure]

113. Minimum SRV Re-opening C2-1.3 C2-1 All 50 psig App C. (18.0)

Pressure C5-6.3 C5-1 f%

Page 29 l-

Attachment 2' RPV PRESSURE AT WHICH LPCS SIRTIOFF HEAD IS REAClED I i Item 108 i ,

i

References:

1. CS Preoperational Test (6E-12)
2. General Electric Drawing 161F282BC i

Actual head curves plotted per Reference 1 indicates the following CS shutoff heads:

l l Pump 1A - 925 ft. H 0 i

l Pump 1B - 910 ft. H 0 -- utilized for calculation (conservative direction)

I j Since the "RPV pressure for which the CS shutoff head is reached" is the desired value, the static height

! of water from the injection valve to the discharge of the pump must be subtracted (thus, RPV pressure and ~E

[ height of water column = pump discharge).

I Therefore, desired value = [(910 - 87.1) x .433484 pela) - 14.7 l

Reference 2

! = 342 psig i .

, t l (Rounded of f to 340 psig for readability on pressure instrumentation - conservative direction.) l f

, i i l 4 e i I l  !

l <

h l

t i

i L

e i

I i

l l

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e Page 30 ,

i

.am-- -e.,-- __me

Attachment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INIVRMATION PLANT: UOPER NUCLEAR STATION EPC REV. 3I

.,m j EPG Type j Item (What is in Parentheses)

(EPC] Description Step No.

Page No.

of Cont. Value Source 114. Dete:1 sine (Other steam C2-1,3 C2 1 All See #36 driven equipment) that can be used to depresa aurire the RPV.

! CONTINCENCY #3 115. Minimum Zero - C3-1 C3-1 All -111.7 in. App C (19.0)

Injection RVP Water (below TAF)

Level 116. Minicium Single SRV C3-1 C3-1 All 700 psig App C (25.0)

Steam Cooling Pressure CONTINGENCY #4 I

117. Iower of: C4-2 C4-1 All

a. RPV pressure for 113 paid CE 257HA792,Rev. 7 rated LPCS flow (RPV-torus op) Sheet 4
b. RPV pressure for NA HPCS flow (O s CONTINCENCY #5 Applies i

4 118. Determine if phrase C5-2 C5-1 All CE 719E415BB-vents applies: (RPV head to Drywell (

l vental Equipment Sump I (Ref. App. B12-5) 119. Minimum Number of C5-3 C5-1 'All 1 App C (20.0)

SRV's required for Alternate Shutdown Cooling 120. Minimum Alternate C5-6.1 C5-1 All 89 psig App C (20.0) l a Shutdown Cooling RPV Pressure f

121. Maximum Alternate C5-6.2 C5-1 All 282 psig App C (20.0)

Shutdown Cooling RPV Pressure 1

l

' Page 31

Attichment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INIVRMATION PIANT: COOPER NUCLEAR STATION EPC REV. 3I

(~m\ (EPG) Description EPG Step Page Type of item (What is in Parentheses) No. No. Cont. Value Source 122. Higher of: C5-7 C5-1 All

a. RPV NITIT 40'F USAR IV-2-19 b.
b. Head tensioning Ilmit 80'F Tech Specs, p. 133 (X)NTINCENCY #6 123. Minimus Alternate RPV C6-2.1 C6-1 All Table - # of App C. (21.0)

Flooding Pressure C7-2.1 C7-3 open SRVs vs Flooding Pressure 124. Minimum Number of SRVs C6-2.1 C6-1 All 1 App C. (21.0) for which the Minimum C6-2.2 C6-2 Alternate RPV Flooding (3 pl)

Pressure is below the C6-2.3 C6-2 lowest SRV lifting pres C7-2.1 C7-3 sure 125. Determine if phrase C6-2.2 C6 2 All Applies LPCI injected into applies: [LPCI] recirculation loops (i.e. outside core shroud)

/ 126. Deter 1mine if the follow C6-2.2 C6-2 All See #107

( ing systems are appli-cable for flooding the RPV:

RilR service water cross-tie Fire System Interconnections with other unite ECCS keep-full systems 127. Minimum RPV Flooding C6-3.1 C6-3 All 50 psig App C (22.0)

Pressure C6-3.2 C6-3 C6-5.2 C6-4 Page 32

Attachment 2 PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMATION PLANT: COOPER NUCLEAR STATION EPG REV. 3I 9 Item

[EPC] Description (What is in Parentheses) 128. Maximum Core Uncovery EPG Step No.

C6*5.3 Page No.

C6-4 Type of Cont.

All Value Curve Source App C (23.0)

Time Limit

+

CONTINCENCY #7 129. Flow Stagnation C7-1 C7-1A All -164 in. App C Water Level C7-2 C7-2 130. Determine if systems C7-2 C7-3 All are applicables C7-2.2 C7-4 (IIPCI] Applies Injects to IV Piping (LPCI) Applies Injects to recircu-(Ref. App B14-15 B14-19) lation loops (both outside core shroud) 131. Ilot Shutdown Boron C7-3 C7-4 All 303.69 lb. App C (25.0)

Weight e

e Page 33

PLANT-SPECIFIC EPC VALUES, LIMITS, CURVES AND INFORMATION-PLANT: COOPER NUC1 EAR STATION EPG REV. 3I

, [AE 4

EPC Type k  : [EPC Description)

Item (What is in Brackets)

Step-No.

Page No.

of Cont. Value Source

1. Procedure for Determin- C-5 I-6 All. Average of 4 Plant Operations-ins Bulk suppression __ highest suppression Department Pool Water Temperature pool temperature indications on Panel P-3.
2. Procedure for Determin- C-5 I-6 All Average of Plant Operations ing Drywell Atmosphere TE 505A,B,C,D and E Department Average Temperature on Panel VBd-H.

3.. Procedure for Determin- C-5 I-6 III NA ing Mark III Contain-ment Atmosphere Average Temperature

4. Plant Procedure steps RC-1 Box RC-1 All RC/L, RC/P, Corresponding to RC/L, Cl-4 Cl-3 RC/Q RC/P, and RC/Q (6 Pl.)

C4-3 C4-1 C6-6 C6-5

5. Procedure developed from RC/L-1 RC-2 All Contingency #7 Contingency #7 Cl-1 Box Cl-1 C6-2 Box C6-1 I 6. Procedure developed from RC/L-1 RC-2 All Contingency #6 Contingency #6 (2 Pl.)

RC/L-3 RC-4 (2 Pl.)

C1-1 Box C1-1 (2 Pl.)

C2-1.3 C2-2 C7-1 Box C7-1

7. Procedure developed RC/L-2 RC-3 All Contingency #1 from Contingency #1
8. Procedure developed from RC/L-2 RC-3 All Contingency #5 Contingency #5 RC/P-4 RC-8 C7-3 C7-5
9. Procedure for cooldown RC/L-2 RC-3 All OP 2.1.4 Station Operating to Cold Shutdown Con- (2 Pl.) Hanual ditions RC/P-5 RC-8 C5-8 C5-1 C7-4 C7-5 (2 Pl.)

10 Plant Procedure step for RC/L-3 RC-3 All RC/P-5 RC/P 5 C7-4 C7-5 Page 34

PLANT-SPECIFIC EPG VALUES, LIMITS, CURVES AND INFORMATION PLANT: (DOPER NUCLEAR STATION EPG REV. 3I

[/w}

N / (EPC] Description EPC Step Page Type of Item (What is in Parentheses) No. No. Cont, Value Source

11. Procedure developed from RC/L-3 RC-4 All Contingency #2 Contingency #2 (3 Pl.)

C3-1 C3-1 (2 Pl.)

12. Procedure developed from RC/P-1 RC-5 All Contingency #3 Contingency #3
13. Sampling procedures for RC/P-2 RC-7 All OP 2.2.66.E Station Operating RWCU blowdown Manual 14 Plant Procedure step for RC/P-2 RC-7 All RC/P-2 RC/P-2 Box
15. Scram Procedure RC/Q RC-8 All OP 2.1.6 Station Operating (2 Pl.) OP 2.1.7 Manual RC/Q-4.3 RC-9A OP 2.1.8
16. Plant Procedure steps RC/Q-3 RC-9 All RC/Q-4, RC/Q-5 for RC/Q-4 and RC/Q-5
17. Plant procedure step for RC/Q-5.2 RC-10 All RC/Q-5.6.1 step RC/Q-5.6.1 RC/Q-5.5 RC-12

(

18. Plant procedure step for RC/Q-5.3 RC-11 All RC/Q-5.2 step RC/Q-5.2
19. Plant Procedure step for RC/Q-5.3 RC-11 All RC/Q-5.5.1 step RC/Q-5.5.1 PRIMARY CONTAINMENT C0ffrROL CUIDELINE
20. Plant Procedure steps Oper. PC-1 All SP/T,DW/T, for SP/T, DW/T, (CN/I), Actions PC/P, SP/L, PC/H PC/P, SP/L and PC/H
21. Procedures developed SP/I-4 PC-2A All E0P-1 from the RPV Control DW/I-2 PL-3 Cuidelines DW/T-3 PC-4 CN/T-3 PC-5 SP/L-2 PC-11 SP/L-3 PC-13 SC/T-4 SC-3 SC/R-2 SC-3 (2 Pl.)

SP/L-2 SC-4 RR-2 RR-1 Cl-4 Cl-3

] (6 Pl.)

I C2-2 C2-2 C4-3 C4-1 C6-2 Box C6-1 C6-6 C6-5 C7-4 C7-5 Page 35

PLANT-SPECIFIC EPC VALUES, LIMITS, CL'RVES AND INFORMATION PLANT: (DOPER NUCLEAR STATION EPC REV. 3I

,/~m

(' j EPG _

Type

/ (EPC] Description Step- Page of

-Item (What is in Parentheses) No. No. Cont. Value Source

22. Plant Procedures step SP/T-4 PC-2A All RC-1 for step RC-1 DW/T-2 PC-3 DW/T-3 PC-4 CN/T-3 PC-5 SP/L-2 PC-11 SP/L-3.1 PC-13 SC/T-4 SC-3 SC/R-2 SC-3 (2 Pl.)

SP/L-2 SC-4 RR-2 RR-1

23. Plant Procedure steps for DW/T-1 PC-3 All DW/T-2, DW/T-3 steps DW/T-2 and DW/T-3
24. Plant procedure for PC/P-1 PC-6 All OP 2.2.40 Station Operating operating Containment (Drywell Cooling) Manual Pressure Control Systems

, 25. Plant procedures for PC/P-1 PC-6 All operating

/m

( a. SBCT OP 2.2.73 Station Operating

}

( b. Drywell purge NA Manual

26. Plant procedure for con- PC/P-7 PC-9 All EP 5.3.7 Station Operating tainment venting Manual
27. Sampling procedure for SP/L-1 PC-10 All OP 2.2.69 Station Operating discharging SP water Manual
28. Plant procedure step for SP/L-1 PC-10 All SP/L-3 step SP/L-3
29. Plant procedure step for SP/L-3 PC-12 All SP/L-3.1, SP/L-3.2 steps SP/L-3.1 & SP/L-3.2
30. -Plant procedure steps for PC/H PC-15 All EPC steps PC/H-6.1 through 6.4
31. Plant procedure number PC/H-1.1 PC-16 All for Sampling Procedure PC/H-4 PC-22 for determining radio-active release rate
32. Plant procedure steps for PC/H-1 PC-16 All EPC steps PC/H-2 and

(

[N PC/H-3 1

Q ))

33. Plant procedure step for PC/H-2.6 PC-19 All EPC step PC/H-4 Page 36

PLANT-SPECIFIC EPC VALUES, LIMITS, CURVES AND INFORMATION PLANT: COOPER NUCLEAR STATION EPG REV. 3I

.g

/^s EPG Type

~ N,

[EPGl Description Step Page of

Value Source

' Item (What is in Parentheses) No. No. Cont.

- 34 Plant procedure steps Oper. SC-2 All SC/T, SC/R, for steps SC/T, SC/R Actions SC/L

.and SC/L

35. Plant procedure step Cl-3 Box Cl-2 All Cl-2 for step Cl-3 Cl-7 Cl-4 (2 Pl.)
36. Plant Procedure developed Cl-8 Cl-4 All Contingency #4 from Contingency #4 NOTE: Page Cl-5 contains an alternate format for steps Cl-3 though Cl-8.

For information required - See 4, 21, 31, 32.

37. Plant procedure step for C2-2 C2-2 All PC/P-3 step RC/P-3
38. Plant procedure step for C6-2 Box C6-1 All RC/P-4 step RC/P-4 C6-6 C6-5 39 Plant procedure step for C6-5.1 C6-4 All C6-6 step C6-6

(' A)

, Plant procedure for step 'C6-5.3 C6-4 All C6-3

'j 40.

C6-3

41. Plant procedure step for C7-2 Box C7-2 All C7-2.1 step C7-2.1 C7-3 C7-5

, 42. Plant procedure step for C7-2 C7-2 All C7-1 step C7-1 (3 Pl.)

C7-2.2 C7-4 l

l i

i l

i I

1 r

p Page 37 l.

Summary of Changes to CNS E0P Writer's Guide Made by Revision 3, 7/21/86 Page/ Location Change Page 1 and 2, Section 2 Added this as a new section which outlines Control Room staffing and responsibilities for E0Ps.

Page 2, Section 3.2 Added statement noting necessity to change E0Ps based on other document changes if needed.

Page 2, Section 3.4 Changed the requirement to have revisions to the E0P Writers Guide done in accordance to Procedure 0.4. SORC review and approval only is needed for a revision.

Page 31 Section 8 Added statement to proofread copies of E0Ps distributed to Control Room, Technical Support Center, and EOF individually.

,,/)

< j O) w_./

Rev 3 11 7/21/86

-)

TABLE OF CONTENTS

~/~'s- Section Page f I

\_ v /

1 PURPOSE AND SCOPE .................................. 1 2 CONTROL ROOM STAFFING AND RESPONSIBILITIES.......... 1 3 DESIGNATION AND NUMBERING .......................... 2 3.1 PROCEDURE DESIGNATION ......................... 2 3.2 APPROVAL OF E0Ps .............................. 2 3.3 SECTION NUMBERING OF E0Ps ..................... 2 3.4 PROCEDURE REVISIONS ........................... 2 3.5 PAGE IDENTIFICATION AND NUMBERING ............. 3 4 FORMAT ............................................. 3 4.1 PAGE FORMAT ................................... 3 4.2 SECTION ORGANIZATION .......................... 4 4.3 SUBSECTION DESIGNATION ........................ 4

N 4.4 INSTRUCTION STEP NUMBERING .................... 5 fL j) 5 PROCEDURE PREPARATION .............................. 6 5.1 INSTRUCTION STEP LENGTH AND CONTENT ........... 6 5.1.1 SPECIAL OPERATOR INSTRUCTIONS .......... 8 5.1.2 PRIMARY ACTION COLUMN .................. 9 5.1.3 CONTINGENCY ACTIONS .................... 9 5.1.4 SUPPLEMENTAL INFORMATION ............... 9 5.2 USE OF LOGIC TERMS ........................... 10 5.3 CONDITIONAL STATEMENTS ....................... 11 5.4 USE OF CAUTIONARY INFORMATION AND NOTES . . . . . . 12 5.5 CALCULATIONS ................................. 13 5.6 USE OF UNDERLINING ............................ 13 5.7 REFERENCING AND BRANCHING TO OTHER PROCEDURES OR STEPS .......................... 14 5.8 COMPONENT IDENTIFICATION ..................... 15 5.9 LEVEL OF DETAIL .............................. 16 5.10 PRINTED OPERATOR AIDS ........................ 18 fss

[v ) 5.10.1 UNITS OF MEASURE . . . . . . . . . . . . . . . . . . . . . 18 Rev 3 111 7/21/86

TABLE OF CONTENTS s

s (Continued)

\

'Section Page 5 PRINTED OPERATOR AIDS (Continued)................... 18 5.10.2. TITLES AND HEADINGS ................... 18 5.10.3 FIGURE, TABLE AND ATTACHMENT NUMBERING ............................. 18 6 MECHANICS OF STYLE ................................. 19 6.1 - SPELLING ...................................... 19 6.2 HYPHENATION ................................... 19 6.3 PUNCTUATION ................................... 20 6.4 VOCABULARY .................................... 21 6.5 NUMERICAL VALUES .............................. 22 6.6 ABBREVIATIONS, LETTER SYMBOLS,AND ACRONYMS .... 23 6.7 CAPITALIZATION ................................ 24 (s_ '7 TYPING FORMAT ...................................... 24 7.1 GENERAL TYPING INSTRUCTIONS ................... 24 7.2 PAGE ARRANGEMENT .............................. 25 7.3 HEADING AND TEXT ARRANGEMENT .................. 25 L '7.4 BREAKING OF WORDS ............................. 26 j 7.5 ROTATION OF PAGES ............................. 26 i 7.6 PRINTED OPERATOR AIDS ......................... 27 7.7 SPECIAL OPERATOR INSTRUCTIONS, CAUTIONS, l

AND NOTES ..................................... 28

7.8 USE OF FOLDOUT PAGES .......................... 31 7.9 USE OF OVERSIZED PAGES ........................ 31 7.10 USE OF REDUCED PAGES .......................... 31 4

8 REPRODUCTION ....................................... 31 1

9 BINDING............................................. 31 10 REFERENCES ......................................... 32 Rev 3 iv 7/21/86 L

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

TABLE OF CONTENTS (Continued)

Section Page APPENDIX 1 - GLOSSARY ........................................ 33 APPENDIX 2 - APPROVED ABBREVIATIONS .......................... 39 APPENDIX 3 - APPROVED ACRONYMS ............................... 40 APPENDIX 4 - NUMERICAL LISTING OF CNS EMERGENCY OPERATING PROCEDURE SECTIONS .............................. 42 '

t' APPENDIX 5 - PAGE FORMAT ..................................... 43 i

s h

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Rev 3 v 7/21/86

1 PURPOSE AND SCOPE gy ks ,) This document is designed to provide specific administrative and technical guidelines for preparing Cooper Nuclear Station (CNS)

Emergency Operating Procedures (EOPs). This Writer's Guide will ensure that each procedure is readily understood by the operator and is yet sufficiently comprehensive to be acceptable to the CNS Operations Department.

2 CONTROL ROOM STAFFING AND RESPONSIBILITIES 2.1 STATION SHIFT COMPLEMENT The minimum station shift complement as stated in CNS Technical -

Specifications, Section 6.1.3, and Station Procedure 2.0.3,

" Control Room Conduct And Manning", shall apply to the number of personnel required to carry out specific actions, concurrent actions, and any other responsibilities deemed necessary and stated

./N in the E0Ps. The E0Ps shall be structured so that they can be

__,, effectively executed by the minimal station shift complement.

1 2.2 ROLES AND RESPONSIBILITIES OF CONTROL ROOM OPERATORS The roles and responsibilities of Control Room operators as stated in Station Procedure 0.2, " Station Organization And Responsibility", shall apply to the use of the E0Ps. The E0Ps shall be structured and procedural steps written to follow these established roles and responsibilities to ensure Control Room personnel operate as a team when carrying out actions required by the E0Ps.

2.3 REQUIRED ACTIONS BY CONTROL ROOM OPERATORS The E0Ps shall be structured and procedural steps written to ensure that sequential actions, concurrent actions, and any other stated actions can be carried out efficiently. The E0Ps shall be I

s_, structured and written so to minimize or prevent physical conflicts Rev 3 Page 1 of 43 7/21/86

i between Control Room personnel and to avoid unnecessary duplications of tasks. ~In addition, the E0Ps shall be written to

'y ensure that the Shift Supervisor and Control Room Supervisor can effectively monitor personnel action and be aware of plant status.

3 DESIGNATION AND NUMBERING 3.1 PROCEDURE DESIGNATION The E0Ps are part of CNS Procedure 5.8. Each E0P shall be a section of the procedure and shall be uniquely identified by a number which identifies the type of section (i.e. E0P 2 identifies the section as Emergency Operating Procedure Section Number 2) and a descriptive title to designate the scope of the section (i.e.

PRIMARY CONTAINMENT CONTROL).

3.2 APPROVAL OF E0Ps O Each E0P is a section of CNS Procedure EP 5.8. The E0Ps shall-be reviewed and approved in accordance with CNS Procedure 0.22.

The E0Ps shall be revised if necessary based on other procedural changes, design changes, or Technical Specification changes.

3.3- SECTION NUMBERING OF E0Ps.

A sequential number shall follow the E0P section designator.

Example E0P-2 Sequence Number Procedure Designator 3.4 PROCEDURE REVISIONS

a. Revisions to this Writer's Guide shall be reviewed and

/ approved by the Station Operations Review Committee (SORC).

Rev 3 Page 2 of 43 7/21/86

b. Revisions to Emergency Operating Procedures shall be made in (7 accordance with this E0P Writer's Guide and CNS Administrative i \

\ / Procedure 0.22.

c. A sequential number following the abbreviation "Rev" shall be used to designate the revision level of each page of the procedure.

Example: Rev 1, Revision Level Abbreviation

d. When a revision is made to the procedure, the revision number for the procedure will be changed to the next higher number.

3.5 PAGE IDENTIFICATION AND NUMBERING Each page of a section shall be identified by 1) the Emergency Operating Procedure Section designator and number, 2) the revision

(/ number, 3) the page number, and 4) date of the revision. Each page of a section shall indicate the total number of pages in the section specified as "page of ". This information shall be located at the bottom of each page, as shown in Appendix 5. Facing pages shall carry the same page identification information as the previous page. They shall be subnumbered, utilizing the letter "A" (i.e. Page 7A of 53), in sequence. If there is no information on the facing page it shall be labeled "THIS PAGE IS INTENTIONALLY BLANK" in the center of the page.

4 FORMAT The following format is to be applied consistently for all the CNS Emergency Operating Procedure Sections.

4.1 PAGE FORMAT O \

/

\vl A dual-column format shall be used. The left hand column is designated for primary operator actions. The right hand column is Rev 3 Page 3 of 43 7/21/86

designated for contingency actions (to be taken when the expected f

t

'~'s\

response is not obtained) and for supplemental information. A

\ s _ ,,/ sample page format is presented in Appendix 5.

4.2 SECTION ORGANIZATION The following headings will be used for all CNS Emergency Operating.

Procedure Sections:

TITLE -- The title shall be centered at the top of the first page of the section. The title shall be in all capitals and shall be underscored. The title should be descriptive of the purpose of the section.

PURPOSE -- The purpose is a brief statement describing the objectives of the section.

ENTRY CONDITIONS -- The entry conditions shall include only I

/N I those alarms, indications, operating conditions, automatic

\s~_ / system actions, or other unique symptoms that the operator is to use in deciding to use the section.

OPERATOR ACTIONS -- The operator actions shall be short, concise, identifiable instructions. These instructions will give appropriate directions to the operator in order to mitigate further degradation of plant performance and restore plant operation to the point that normal operating procedures can be used.

4.3 SUBSECTION DESIGNATION

a. Emergency Operating Procedure Subsections, developed from the Emergency Procedure Guidelines (EPGs) will be identified by a letter prefix included in the Subsection Heading and step numbers as follows:

O)

(J Rev 3 Page 4 of 43 7/21/86

T

1. The first two letters indicate the area of control.

7 -~3 The letters used and the area of control shall be:

'( )

Qt RC = RPV Control SP = Suppression Pool DW = Drywell PC = Primary Containment SC = Secondary Containment RR = Radioactivity Release

2. The third letter indicates the parameter which is controlled in the specified area. A virgule (slant line) should be used between the first two letters and the third letter; examples: SP/L-1, RC/Q-2. The letters used to denote the controlled parameters shall be:

L = Level P = Pressure

,/} Q = Power s _,) T = Temperature R = Radiation H = Hydrogen

3. Attachments to the E0Ps shall be designated as A1, A2, etc.
b. Subsection headings (e.g. RC/L, PC/H) shall be centered and in all capitals. The heading shall be underscored.

Procedures developed to support the E0Ps (e.g. Alternate Methods for Injecting Boron into the RPV) shall be written in accordance with reference C.

4.4 INSTRUCTION STEP NUMBERING l

i j Instruction steps in a subsection shall be numbered and indented as j (v follows:

l Rev 3 Page 5 of 43 7/21/86

RC/P-1. Confirm...

,r') a. Check...

) 1) If...

Due to the narrow width of the column for procedure steps in a dual column format, if possible avoid using the 1) level of indenting to eliminate wasted space.

5 PROCEDURE PREPARATION 5.1 INSTRUCTION STEP LENGTH AND CONTENT Instruction steps should be concise and precise. Conciseness denotes brevity; preciseness means exactly defined. Thus, instruc-tions should be short and exact. This is easily stated, but not so easily achieved. General rules to be used in meeting these objec-tives are as follows:

a. Instruction steps should deal with only one idea.

G

b. Short, simple sentences or phrases should be used in preference to long, compound or complex sentences. As a rule, sentence length should not exceed 15 words.
c. Complex evolutions should be prescribed in a series of steps, with each step made as simple as practicable.
d. Objects of operator actions should be specifically stated. This includes identification of exactly what is to be done and to what.
e. For instructional steps requiring operator actions, space will be provided on the lef t margin of each column for operator checkoff as an aid in keeping track of his place in the procedure (see Appendix 5 and Subsection 7.3 Item

/O f).

. (w)

Rev 3 Page 6 of 43 7/21/86

f. Limits should be expressed quantitatively whenever 7- ss possible (refer to Subsection 6.5).

( )

g. Mandatory sequence of steps is assumed unless otherwise stated. Where necessary identify those sections, procedures, or series of steps, which need not be followed in sequence or when concurrent operations are to be performed. When concurrent execution of steps is required it will be identified using a special operator instruction (see Subsection 5.1.1).
h. Identification of components and parts should be complete (see Subsection 5.8).
i. User instructions should be written in the form of a command.
j. Expected results of routine tasks or evolutions need not

. , /"'g be stated.

/

vs

k. When actions are required based upon receipt of an annunciated alarm, list the setpoint of the alarm for ease of verification.
1. When resetting or restoring an alarm or trip, list the expected results immediately following the reset or restoration if it would be beneficial to the operator.
m. When considered beneficial to the user for proper under-standing and performance, describe the system response time associated with performance of the instruction.
n. When system response dictates a time frame within which the instruction must be accomplished, prescribe such time frame. If possible, however, avoid using time to initi-ate operator actions. Operator actions should be related jN to plant parameters.

lV]

Rev 3 Page 7 of 43 7/21/86

/

o. The basis or reason for an action should not be included j' N in the instruction. If additional information is neces-h _,j/ sary to clarify an action, it shall be placed in the supplemental information column or on the facing page, p.- When additional confirmation of system response is considered necessary, prescribe the backup reading to be made,
q. If an operator will be required to perform actions in specified manner or observe the specific indications, a note should precede the step in order to advise the operator of those actions or observations which he will be required to perform following the initial action.
r. If several (more than two) options are available to the operator in order to carry out the desired instruction, they shall be placed in list format. Bullets shall be g/N used to distinguish each item. If order is important, it

( ,,, will be stated in the instruction.

5.1.1 Special Operator Instructions Special operator instructions are used to indicate changes in the expected flow of a procedure by indicating:

i

a. A requirement for concurrent execution of multiple steps
b. One or more contingent actions which remain applicable while

! executing a series of subsequent steps Special operator instructions will be enclosed in a box formed using asterisks in order to differentiate them from Cautions. See l subsection 7.7 for an example.

i l O i

, Rev 3 Page 8 of 43 7/21/P6 t

5.1.2 Primary Action Column

(

x / The left-hand column of the dual column format will contain the operator instructional steps. The following rules are established in addition to the general rules in subsection 5.1.

a. Expected indicc ions should be presented in this column.
b. Operator actions in this column should be appropriate for the expected indications.

5.1.3 Contingency Actions Contingency steps will be placed in the right-hand column (see Appendix 5).

Contingency actions are operator actions that should be taken in the event a stated condition, event or task does not represent or achieve the expected results. The need for contingency action occurs in conjunction with tasks involving verification, observa-

\v tion, confirmation and monitoring.

Contingency actions shall be specified for each circumstance in which the expected results or actions might not be achieved. The contingency actions should identify, as appropriate, directions to override automatic controls and to initiate manually what is normally automatically initiated.

Once an operator is directed to take action in the contingency action column, an instruction will be placed at the end of the contingency action to direct the operator where to proceed to in the E0P.

5.1.4 Supplemental Information The right-hand column and the facing page shall be used to provide supplemental information such as setpoints, equipment and indicator v locations, etc. not necessary to carry out the primary operator Rev 3 Page 9 of 43 7/21/86

actions but may aid the operator. If the information is brief and

, ,A there is room, the information should be placed in the right hand kv column.

The facing page shall be used when there is a lot of supplemental information (i.e. a list of items such as values that the operator must " check" or " verify").

The facing page shall also be used to provide a flowchart or logic diagram of operator actions, if needed to clarify operator actions.

Flowchart information shall be formatted in a manner similar to instructional steps.

} 5.2 USE OF LOGIC TERMS The logic terms AND, OR. IF, IF NOT, WHEN, and TilEN are often necessary to describe precisely a set of conditions or sequence of actions.

,a 4 Emphasis shall be achieved by using capitalizations and underlin-ing. All logic terms shall be underlined so that all the condi-tions are clear to the operator.

When these words are not used as logic terms they will not be capitalized or underlined. For examplet (IIPCI or RCIC) or two limit values (6 ft. and 10 ft.).

The use of AND and OR within the same action shall be avoided.

When AND and M are used together, the logic can be very ambiguous.

Use other logic terms as follows:

I.

a. When attention should be called to combinations of conditions, the word AND shall be placed between the description of each condition. The word AND shall not be used to join more than t j two conditions. If three or more conditions need to be joined, a list format shall be used.

Rev 3 Page 10 of 43 7/21/86

b. The word OR shall be used when calling attention to alterna-tive combinations of conditions. The use of the word OR shall

]

(v) always be in the inclusive sense. To specify the exclusive "0R," the following shall be used: "either A O_RR B but not both." If three or more conditions need to be joined, a list format shall be used.

c. When action steps are contingent upon certain conditions or combinations of conditions, the step shall begin with the word E or WHEN followed by a description of the condition or conditions (the antecedent), a comma, the word TilEN, followed by the action to be taken (the consequent).
d. WilEN is used for an expected condition. WHEN implies a "moni-toring" or " wait" function.
e. E is used for an unexpected but possible condition existing at the present time or at the time this' step is reached. E is not meant to include "at any time in the future."

/]

f. Use of E NOT should be limited to those cases in which the operator must respond to the second of two possible condi-tions. If,should be used to specify the first condition.
g. TilEN shall not be used at the end of action step to instruct the operator to perform the next step because it runs actions together.

5.3 CONDITIONAL STATEMENTS The following guidelines should be followedt

a. Write conditional statements so that the description of the condition appears first, followed by the action instruction, fw Rev 3 Page 11 of 43 7/21/86

k

b. If three or more conditions must be described before an action

( is directed, list the conditions separately from the action k]

instruction.

c. Emphasize the logic words by underlining, for example, g.....

THEN....

d. See Appendix 5 for examples.

5.4 USE OF CAUTIONARY INFORMATION AND NOTES

Cautionary information can be considered in two fundamental cate-gories
those that apply to the entire procedure and those that apply to a portion or a specific step of the procedure. Those that apply to a portion of a procedure are called " CAUTIONS" and are placed in a box immediately before the procedural steps to which they apply. Those that apply.to the entire procedure are called

" PRECAUTIONS" and are covered in operator training or included in a A general procedure for ready reference. Precautions do not need to be placed in a box.

In general, a CAUTION shall extend across the entire page and shall i be highlighted as shown in the Example CAUTION (see Sub-section 7.7). This placement of cautions helps ensure that the procedure user observes the caution before performing the step in either column. A caution shall not be used instead of an instruc-tional step. It should be used to denote a potential hazard to equipment or personnel associated with a particular step. Each i caution statement shall be wholly contained on a single page. A caution must appear on the same page as the step to which it applies except as noted in paragraph 7.7.f.

A NOTE is used to present or remind the operator of explanatory or descriptive information that is intended to aid the operator to perform the instructional step. A note should present information only, not instructions, and should be located prior to the applic-able action step.

t Rev 3 I Page 12 of 43 7/21/86

It is permissible to separate the note from the applicable step to 7 s begin a new page as long as the note appears in sequence before the i )

N j step.

In general, a note shall extend across the entire page and will be highlighted by indentation three spaces from the margins shown in the Example NOTE (see Subsection 7.7). Notes shall be further highlighted by centering three asterisks (with one space between asterisks) one-and-a-half line spaces above and below the note.

Caution and note statements should be short and concise. If a caution or note applies only to steps in the Primary Operator Action column or only to steps in the Contingency Action column the caution or note shall be placed in that column.

5.5 CALCULATIONS Mathematical calculations should be avoided, especially in Emer-

/';1 gency Operating Procedures (EOPs). If a value has to be determined e

(~__ /

in order to perform a procedural step, a chart or graph should be used whenever possible (e.g. preparation of sodium pentaborate solution). The necessary space should be provided within th ,

instruction or on attachments, along with the conversion factors to obtain the answer in correct units.

i 5.6 USE OF UNDERLINING Underlining will be used for emphasis of logic terms, CAUTION and NOTE headings, and first level section headings.

The following examples illustrate what shall be underlined.

a. Underline logic terms: I F, WHEN AND OR BUT IF NOT

/

O i NI Rev 3 Page 13 of 43 7/21/86

b. Underline titles of first-level section headings.

G RC/L RPV WATER LEVEL CONTROL

c. Do not underline action which is all capitalized:

EMERGENCY RPV DEPRESSURIZATION IS REQUIRED

d. Underlining may be used to alert personnel to important words or phrases:

any do not all concurrently except 5.7 REFERENCING AND BRANCHING TO OTHER PROCEDURE, SECTIONS, OR STEPS Referencing implies that an additional procedure, section, or steps

'~'

7 .

in the same procedure should be used as a supplement to the steps j presently being used. Referencing other steps within the section being used, either future steps or completed steps, should be minimized. When only a few steps are involved in the referencing, the steps should be restated in the section wherever they are needed.

To minimize potential operator confusion, branching shall be used when the operator is to leave one section or step and use another section or step. The words " exit" and " enter" will key the operator to leave the present step and not return until directed.

The words " proceed to" will be used to direct the operator to continue at the specified step within the same section. The words

" Return to" will be used to direct the operator to return to a previous step in the same section.

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Rev 3 Page 14 of 43 7/21/86

Following the section number, the section title shall be enclosed g] in parentheses to emphasize the title of the referenced or branched (j section; example: Enter E0P-1 (RPV Control) at Step RC-1.

When the actions to be taken are located in a specific subsection-f the branched section or procedure, the step where the operator should enter shall be stated rather than just the subsection or procedure number and titic; example: Enter OP-2.2.9 (Core Spray) at Step C.2.

When subsections of a section are executed concurrently, the refer-enced subsections shall be tabbed to assist the operator in locat-ing the material. Tabbing shall also be used when the operator is instructed to continue on or return to a step in the section which is several pages away from the instruction. The words " continue in this procedure at Step ... (TAB 6)" and " return to Step ...(TAB 2)"

shall be used for these instructions. Tabs will be numbered sequentially, based on their physical location in the section.

, 5.8 COMPONENT IDENTIFICATION (LJQ}

For identification of components, the following rules apply:

a. Equipment shall be identified in operator language (common usage) terms. These terms may not always match engraved or placarded names on equipment, but will be complete.
b. 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 empha-sized by using all capitals. In addition, the location of the item shall be given by the panel number (and grid coordinates for annunciators) enclosed in parenthesis.
c. The names of plant system titles are emphasized by capitaliz-ing the first letter of each word in the title. The word

/ " system" should be deleted from the title in the interest of C/ brevity.

Rev 3 Page 15 of 43 7/21/86

d. If the component is seldom used or it is felt that the compo-g] nent would be difficult to find, location information should

/ be given in parentheses following the identification.

5.9 LEVEL OF DETAIL Too much detail in operating procedures, especially E0Ps, should be [

avoided in the interest of being 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 desire, especially in an E0P, during an emergency condition. Instructions shall consist of a series of steps and, if desired, substeps.

These steps shall be written in the form of a command (i.e. tell the operator to do something). The substeps should consist of a more detailed procedure for accomplishing a major step.

To assist in determining the level of detail, the following general rules apply:

LJ

a. Action verbs are placed in instructional steps to denote a particular action that the operator must perform. Common action verbs and their application are provided in the Glos-sary (Appendix 1). Action verbs such as " Energize" or

" Increase" will not be used in writing E0Ps because they can cause oral communications problems.

i b. To standardize those applications for which specific termi-nology should be used, the following guidelines apply:

1. For power-driven equipment use Start, Stop.
2. For valves use Open, Close, Throttle Open, Throttle Close Thrattle Locired Open, Locked Closed and Locked Throttle.

.D (d)

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Rev 3 Page 16 of 43 7/21/86

3. For power distribution breakers and electrical supply

,7% switches use Close and Open or on and Off, being con-kj sistent with the labeling used on the subject circuit breaker / switch.

4. For indicating lights use On and Off.
5. For annunciators use Alarm and Reset.
6. For control circuitry that executes an entire function upon actuation of the control switch, the action verb appropriate to the component suffices without further amplification of how to manipulate the control device e.g. Close M0-4601 SUCTION VALVE (on Panel 1C04).
c. For control switches with a positional placement that estab-lishes a standby readiness condition, the verb " Place" should

, g be used along with the engraved name of the desired position.

G' Positional placements are typically associated with establish-ing readiness of automatic functions and are typically named AUTO or NORMAL: for example, " Place the core spray pump control switch in AUTO."

d. For multiposition control switches that have more than one position for a similar function, placement to the desired position should be specified; for example, " Place DIESEL FIRE PUMP selector switch to TEST NO. 2."
e. Standard practices for observing abnormal resulta need not be prescribed within procedural steps. For example, observation of noise, vibration, erratic flow or discharge pressure need not be specified by steps that start pumps.

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LJ Rev 3 Page 17 of 43 7/21/86

5.10 PRINTED OPERATOR AIDS

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When information is presented using graphs, charts, tables and figures, these aids must be self-explanatory, legible and readable under the expected conditions of use and within the reading pre-cision of the operator.

Printed operator aids (graphs, etc.) applicable to a page of text should be presented on the backside of the preceding page (facing page) where it is available while reading the text. When this is not practical, printed operator aids should be presented as attach-ments; for example, when several graphs are applicable to a page and cannot be placed on the facing page. Reference to tables and figures should be by the figure or table number. For example:

Maintain pump discharge flow in accordance with Figure 5.

5.10.1 Units of Measure f Units of measure on figures, tables and attachments should be given

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( for numerical values that represent observed, measurement data or calculated results. A virgule (slant line) should be used instead of "per"; examples: ft/sec, lbs/hr.

5.10.2 Titles and Headings Capitalization should be used for titles of tables and figures, titles of tables and figures within text material, and column headings within a table.

5.10.3 Figure, Table and Attachment Numbering Sequentini arabic numbers should be assigned to figures and tables  ;

in a separate series for each E0P. The sequence should correspond with the order in which they are first referenced in the text. If the same figure is used again later in the same E0P, it will retain N the original figure number. The symbol "#" and abbreviation "No."

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

Attachments will be numbered nequentially as A1, A2, etc.

Rev 3 Page 18 of 43 7/21/86

Examples: Figure 1-1. Table 1-2, etc. (for E0P-1)

Figure 2-1. Table 2-2, etc. (for E0P-2)

[]/ Attachment A1, Attachment A2, etc.

Page identification for attachments should consist of information that identifies (1) procedure number. (2) attachment number, (3) page number. (4) revision number, and 5) revision date. Page numbering of attachments should meet the requirements of Subsection 3.5.

Subsection numbering for attachments should be in accordance with Subsection 4.3.

6 MECilANICS OF STYLE 6.1 SPELLING Spelling should be consistent with modern unage. When a choice of

( spelling is offered by a dictionary, the first spelling should be ,

used.

6.2 IlYPilENAT10N liyphens are used between elements of a compound word when usage calls for it. The following rules should be followed for hyphen-atton.

a. When doubt exists, the compound word should be restructured to avoid hyphenation.
b. liyphens should be used in the following circumstances:
1. In compound numerals from twenty-one to ninety-ninel examples one hundred thirty-four.
2. in fractional exampless one-hnif, two-thirds.

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Rev 3 Page 19 of 43 7/21/86 3

3. in compounds with "self"; examples self-contained, p self-lubricated.
4. when the last letter of the first word is the same vowel as the first letter of the second word -- as an alterna-tive, two words can be used; examples fire-escape or fire escape.
5. when misicading or awkward consonants would result by ,

joining the words; examples bell-like.

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6. to avoid confusion with another wordt examples re-cover '

to prevent confusion with recover, pre-position to avoid confusion with preposition. ,

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when a letter is linked with a noung examples

7. X-ray, 0-ring. U-bolt. I-beam.
N 8. to separate chemical elements and their atomic weights i

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Q examples: Uranium-235, U-235. '

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6.3 PUNCTUATION punctuation should be used only as necessary to aid reading and prevent misunderstanding. Word order should be selected to require a minimum of punctuation. When extensivo punctuation is necessary for clarity, the sentonce should be rewritten and possibly made l into several sentences. punctuation should be in accordance with the following rules.

a. Do not use brackets.
b. Use a colon to indicate that a list of items in to follow, for example Hostore cooling flow as follows:  !
c. Usn of many comman is a sign the instruction in too complex and needs to be rewritten. Thornfore, evaluate the number of

\ commas to ensure the instruction is not too complex.

Rev 3 page 20 of 43 7/21/86

Use a comma after conditional phrases for clarity and ease of G reading. Example: WHEN level decreases to 60 inches, THEN start pump ....

d. Parentheses shall be used to indicate alternative items in a  !

procedure, equipment numbers, procedure titles and to set off referenced figures, tables, appendices, attachments, etc.

e. Use a period at the end of complete sentences and for indicat-ing the decimal place in numbers.

6.4 VOCABULARY Pords used in procedures should convey precise understanding to the trained person. The following rules apply,

n. Use simpic words. Simple words are usually short words of few syllables. Simple words are generally common words.

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j b. Use common usage if it makes the procedure easier to under-stand,

c. Use words that are concrete rather than vague, specific rather than general, familiar rather than formal, precise rather than blanket. Avoid specialized or abstract words for which substitute words may be used.

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

sense. ,

e. Verbs with specific meaning should be used. Examples are Ifated in Appendix 1 (Glossary).
f. Equipment status should be denoted as follows:
1. Operable / Operability -- These words mean that a system, nubsystem, train, component or device is capable of f]

C) performing its intended function (s) in its required Rev 3 Page 21 of 43 7/21/86

manner. Implicit in this definition'is the assumption' 7' 'N that all necessary attendant instrumentation, controls, i \

N s ,,/ normal and emergency electrical power sources, cooling or-seal water, lubrication or other auxiliary equipment required for the system, subsystem, train, component or device to perform its function (s) are also capable of performing related support function (s).

2. Operating -- This word means that a system, subsystem, train, component or device is in' operation and is per-forming its intended function (s) in its required manner and that "Out of Service Cards" or other conditions do-not prevent it from maintaining that service.

4 l 3. Available/Available for injection -- These words mean j that a system, subsystem, train, component or device is i operable and can be used on demand as desired; however, it need not be operating.

t k __/ 4. Line up for injection / Lined up for injection -- These words mean that a system or subsystem is operable with all valves (except possibly one injection valve) in i position for introducing its process fluid in its intend-ed flow path; however, it shall not be operating unless so stated.

l l 6.5 NUMERICAL VALUES f

f The use of numerical values should be consistent with the following rules:

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a. Arabic numerals should be used.

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b. For numbers less than unity, the decimal point should be

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i preceded by a zerog for example: 0.1.

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c. The number of significant digits should be equal to the number

'~'N of significant digits available from the display. The oper-

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'x j ator should not be required to read an indicator to an accur-acy greater than one-half of the smallest graduation on the indicator.

, d. Acceptance values should be specified in such a way that addition and subtraction by the user is avoided if possible.

This can generally be done by stating acceptance values as limits. Examples: above 95'F, below 150 psig; 580* to 600*F.

For calibration points, statement of the midpoint and its lower and upper limits for each data cell would accomplish the same purpose; for example: 10 mil 11 amperes (9.5 to 10,5).

Avoid using 1.

e. 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 exampic: psig instead

/9 of psi.

f. For numbers less than zero, a minus sign should precede the number (e.g. -1.2).

6.6 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. The full meaning of the abbreviation, other than the abbreviations listed in Appendix 2, should be written in before the first use of the abbreviation and whenever in doubt. Consistency should be maintained throughout the procedure.

Capitalization of abbreviations should be uniform. If the abbrev-

,/N g intion is comprised of lowercase letters it should appear in

(___/ lowercase in a title or heading. The period should be omitted in Rev 3 Page 23 of 43 7/21/86

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~3( ' abbreviations except in cases where the omission would result in

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'^ i t, confusion.

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Letter symbols may be used to represent operations, quant.ities,

, elements, relations and qualities. <

4 4 s- An acronym is a type of symbol formed by the initial letter or UU,'; letters of each of ths successive parts or major parts of compound term. Acronyms may be used if they are defined or approved for use. Appendix 3 lists those acronyms approved for use at CNS.

Abbreviations, symbols and acronyms should not be overused. Their use should be for the benefit of the reader. They can be benefi-cial by saving reading time, ensuring clarity when space is limited and communicating mathematical ideas.

! 6.7 CAPITALIZATION Capitalize the first letter of each word of specific systems or f /S/ system components, logic terms (see section 5.2), section headings I

N __/ (see section 4.3), titles of figures and tables (see subsection 5.10.2). Capitalization may also be used when special emphasis is required (i.e. EMERGENCY RPV DEPRESSURIZATION IS REQUIRED.)

7 TYPING FORMAT r

i 7.1 GENERAL TYPING INSTRUCTIONS Thefy11owinggeneralrequirementsaretobefollowed:

a.  ; Paper size should be 8 x 11 inches.

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b. White, bond paper.

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c. A' Prestige Elite, 12 pitch, typewriter element is to be used.

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7.2 PAGE ARRANGEMENT

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( a. Page margins for normal pages are specifie( in. Appendix 5 (refer to Subsection 3.5). To prevent difficulty in reading information on facing pagea~(i.e. 7A of 25), the right hand margin for these pages shall be at least 1 ", where possible.

'The left hand margin for facing pages shall be at least " to prevent loss of naterial when reproduced,

b. Page identification information is described in Subsection 3.5 and centered as shown in Appendix 5.

, c. The 8 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.

Refer-to Subsection 7.5 if rotation is absolutely necessary.

7.3 HEADING AND TEXT ARRANGEMENT

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/ Block style, as illustrated in Appendix 5, is to be used. First-level subsection headings shall be in full capitals with a full underscore, second-level subscetion he.adings shall be in full capitals and third-level headings shall have the first letter of each word capitalized and the heading shall be underscored (refer to Subsection 4.3 for numbering).

a. The title shall appear at the top margin, centered on the page, shall be in full capitals with an underscore. Three line spaces shall be allowed between the title and the first-level section heading,
b. Three line spaces shall be allowed between headings and the respective text.
c. Three line spaces shall be allowed between paragraphs and O steps.

Rev 3 Page 25 of 43 7/21/86

, . . _ _ _ _ , . _ _ , _ _ , _ - _ _ , - - . . __ ,- - _ . _ --_-. _ _ - ~ _ . --_._

. ~ . . . _ _ _ _ __

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-d.. Text:will be typed using'one-and-a-half line spacing.

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, 3s ,, f e. St'rt a a page for the following conditions:

.1. AtLthe start of a new section of the' procedure; for-example, DW/T MONITOR AND CONTROL DRYWELL TEMPERATURE.

2. So that.a' CAUTION appears on the same page as the step to L

which it applies.

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! 3. So that an action step or substep is wholly contained on i a single page. If substeps must be continued onto the next page, repeat the step number at the top of the left

. . r and right column followed by the word continued (i.e.,

-A2-2. (Continued)).

f. A line two spaces long shall be placed in the left margin

.adja'centito the step or substep number in each column to allow

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% the. operator to checkoff completed steps.-.One space shall be

,_j allowed between the checkoff line:and the step number; for

- example, __ PC/P-1.

7.4 . BREAKING G WORDS i ' Breaking of words should be. avoided to facilitate operator reading.

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i .7.5 ROTATION OF PAGES I

I If pages need to be rotated, these rules shall be followed.

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i. a '. The top of the page with rotated. print is the normal left-hand P edge.
b. The page margins do not rotate.

i c. Page identification and numbering will not be rotated.

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7.6 PRINTED OPERATOR AIDS ry Operator aids include graphs, drawings, diagrams, and illustrations. The following guidelines are established for typing figures which consist of graphs, drawings, diagrams and illustrations:

a. The figure number and its title are placed within the figure,
b. The figure field should be of sufficient size to offer good readability but should not violate specified page margins (6 "

x 9").

c. The essential message should be clear; simple presentations ,

are. preferred,

d. Grid lines of graphs should be no more than 10 lines per-inch; numbered grid lines should be' bolder than unnumbered grid-O x-)

e..

lines.

Labeling of items within the figure should be accomplished by arrows pointing to the item.

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

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g. In genercl, items within the figure should be labeled.-If handwritten labels are used, they should be printed using all capitals, with letters and numbers at least 1/8-inch high.
h. All lines in figures should be reproducible.

Tables should be typed using the following rulca:

a. Type style and size should be the same as that for the rest of s the procedure (see 7.1.c).

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b. The table number and title should be located above the table

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,- field and three line spaces below preceding text.

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c. A heading should be entered for each column and centered within the column; the first letter of words in the column headings should be capitalized.
d. Horizontal lines should be placed above and below the column headings; vertical lines, while desirable, are not necessary or required.
e. Tabular headings should be aligned as follows:
1. horizontally by related entries
2. vertically by decimal point for numerical entries
3. vertically by first letter for word entries; however,

/'~' T run-over lines should be indented three spaces k~ ,_s/

f. One and a half spaces between horizontal 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 column headings.

g.- There should not be a vacant cell in the table. If no entry is necessary, "N.A." should be entered to indicate not appli-cable.

7.7 SPECIAL OPERATOR INSTRUCTIONS, CAUTIONS AND NOTES All special operator instructions, cautions, and notes should be distinguishable from the rest of the text by using the following format.

a. If applicable, the heading (" NOTE" or " CAUTION") should be j/ }

(/ capitalized, centered and placed three line spaces below the preceding text.

Rev 3 Page 28 of 43 7/21/86

b. The text of the special operator instruction, caution, or note

<~~N should be block format, line-and-a-half spaced. The Caution

,/ text shall begin three spaces from the left-hand margin of the step it applies so the vertical line of the box lines up with the step number and shall begin one-and-a-half line spaces below the heading. The text for Special Operator Instructions and Notes will begin five spaces from the left-hand printed margin.

c. The right-hand margin of the text for a special operator instructions and a note should be five spaces to the left of the right-hand printed margin. The right-hand margin of the text of the caution should be three spaces to the left of the right-hand printed margin so the vertical line of the box appears at the right-hand printed margin.
d. A special operator instruction and a caution shall be further highlighted by enclosing them in a box three spaces above the heading or text and one-and-a-half spaces below the last line

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kv/ of-the text. Asterisks will be used to form the box by special operator instructions. Straight lines will be used to form the box for a caution,

e. A note shall be highlighted by three asterisks (*) with one space between asterisks and centered one-and-a-half line spaces above and below the note,
f. A caution must appear on the same page as the step to which it applies. Start a new page if necessary add sentence on attached sheet. If a large number of cautions, special operating instructions and/or notes are applicable to one step and space limitations preclude putting the information entirely on the same page as the applicable step, it is permissible to put the caution, special operator instructions, and/or notes on the facing page, with a caution before the

,/ mN applicable action step referring the operator to this

. information.

Rev 3 Page 29 of 43 7/21/86

g. The following examples illustrate Special Operator Instruc-

s tion, CAUTION, and NOTE format:

1. Example Special Operator Instruction:

(text)------

  • Execute steps SC/T, SC/R and SC/L concurrently *

(text)-------

2. Example NOTE:

(text)-----------

NOTE f

Injection from RHR will not occur until Reactor pressure is less than 195 psig.

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-(text)---------

3. Example CAUTION

(text)

CAUTION

, Do not throttle HPCI cn; RCIC systems below 2100 rpm.

(text)-- - ---------

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Rev 3 Page 30 of 43 7/21/86

7.8 USE OF FOLDOUT PAGES ks ,/~ When used, a foldout page is treated as a single page. It should follow the same format as a standard page except the width is different. The page should be folded so that a small margin exists between the fold and the right-hand edge of standard pages. This will reduce wear of the fold.

7.9 USE OF OVERSIZED PAGES Oversize pages should not be used. They should be reorganized or reduced to a standard page. If this cannot be done, a foldout page should be used.

7.10 USE OF REDUCED PAGES Reduced pages should be avoided whenever possible. Final size of reduced pages should be standard page size. Reduced pages should

'N be readable.

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%v' 8 REPRODUCTION Reproduction will be done on a standard copier duplexed so that the "A" pages will be on the back of the page with the same number.

Quality of copies should be ensured so the E0Ps are clearly legible. Copies of E0Ps distributed to the Control Room, TSC, and EOF should be checked individually for legibility, proper page arrangement, and for completeness of page information.

9 BINDING For control room use, each E0P will be placed in a separate binder and conspicuously marked so that it is readily identifiable as an emergency procedure. Separate binders are necessary since these procedures will be used concurrently. E0P-3 and 4 may be placed in g~'N 3 the same binder. Each binder will have at least one ribbon book ksm ,,/I marker attached for use as an aid in marking the operator's place in the procedure.

Rev 3 Page 31 of 43 7/21/86

10 REFERENCES La. Updated Safety Analysis Report, Cooper Nuclear Station, Chapter 1.

b. ANSI /ANS-32, American National Standard Administrative Con-trols and Quality Assurance for- the Operational Phase of Nuclear Power. Plants, 1981.
c. Administrative Procedures, Cooper Nuclear Station, No. 0.4.
d. Emergency Operating Procedures Writing Guidelines, INPO, July 1982 (INPO 82-017).
e. NUREG-0899,-Guidelines for the Preparation of Emergency Operating Procedures, Rev. S. June 4, 1982.

Rev 3 Page 32 of 43 7/21/86

APPENDIX 1

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GLOSSARY t i

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Word Application Activate Formally institute special activity / function. To place into operation.

Align Place systems or components (e.g. valves and breakers) in proper positions for accomplishing specified function.

Allow To permit a stated condition to be achieved prior to proceeding (e.g. " allow discharge pressure to stabi-lize").

Check To determine the present status of a plant parameter or component and compare with a procedural requirement.

_-o Close Mechanically:

To change the physical position of a mechanical device so that it prevents physical access or fluid flow (e.g.

"close HPCI-97").

Electrically:

To change the physical position of an electrical circuit breaker to permit passage of electrical current (e.g.

"close circuit breaker SSlF").

Complete To accomplish specified procedural requirements (e.g.

" complete valve checklist A", " complete data report QA ",

" complete Steps 7 through 9 of OP 2.2.33").

Comparison A comparing or being compared.

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'W APPENDIX 1 GLOSSARY i\s (Continued)

Word Application Confirm To observe an expected condition or characteristic without being specific as to the method (e.g. " confirm .

. . pump operation").

Decrease Do not use because of oral communication problems. 'Use-

" lower" in lieu of " decrease."

Deenergize- Remove power. supply. Should not be used; use Open.

Depress Refers to pushbutton operation.

- /'~' Discrepancy Disagreement or inconsistency.

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Energize Supply power. Should not be used; use Close.

Ensure Take necessary/ appropriate actions to guarantee proper component operation, instrument reading, etc., as speci-fled.

i Establish. To make arrangements for a stated condition (e.g. "estab-lished communication with control room").

Execute To do or perform the instructed action or steps.

Implement Commence a required program or series of procedures.

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l Increase Dc1 not use because of oral communication problems. Use

" raise" in lieu of " increase."

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) -Take actions to begin a process.

l ./ Initiate Rev 3 Page 34 of 43 7/21/86

t-APPENDIX 1 GLOSSARY 4 (Continued)

Word Application Inspect To measure, observe or evaluate a feature or character-istic for comparison with specified limits; method of inspection should be included (e.g. " visually inspect for leaks").

Isolate Remove from service by closing off the flow path.

Local Take action outside the control room at equipment or local operating station.

Limitation Specific parameter not to be exceeded (violated).

i s___,) Maintain Take appropriate actions to prevent fluctuation / changing.

Manual Operator action which activates a function which is Initiation normally initiated automatically due to plant conditions.

Manual Trip Operator action to activate a Reactor Trip or stop an operating piece of equipment such as a pump.

May Possibility, permission or contingency.

Monitor To observe a stated parameter or function for significant changes. This does not mean an operator continuously 4 watches the parameter, but be aware of changes to keep the operation under control.

Notify Inform specified personnel.

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Y APPENDIX 1 N GLOSSARY

( (Continued)

Word' Application Open: Mechanically:

-To change the physical position of a mechanical device, such as a valve or door,-to unobstructed position that permits a fluid flow or access.

Electrically:

To change-the physical position of an electrical circuit

~ breaker to prevent the passage of electrical current.

Per As specified in or by named procedure. Infers referenc-ing the document is optional.

M-

,.1 Place . Physically position a switch to the specified location.

Proceed' Go to.specified area. In case of procedures,~ discontinue use of present procedure.

~ Qualified Competent or fit. An operator is qualified when his qualification card is complete.

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Rack In Put an electrical circuit breaker in place by physically connecting it to its associated power source.

Rack Out Remove an electrical breaker from its associated power source by physically disconnecting it.

I Rack to Test Position an electrical circuit breaker to the " TEST" position.

s Record- To document specified condition or characteristic (e.g.

" record discharge pressure").

Rev 3 Page 36 of 43 7/21/86 L

p APPENDIX 1

/^'N GLOSSARY I\ }

j (Continued)

Word Application Refer Use as a supplement. Perform applicable actions of cited procedure and return to the controlling procedure.

Regulate Control or restrict. ,

Restore and To bring a specified parameter back under control or Maintain within specified limits and keep it within those limits.

Rotate Turn a rotary multi-position switch to the required position. In reference to pumps, hand rotate before energizing.

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s Secure Remove from service. Take appropriate action to prevent return to service.

Set To physically adjust to a specified value an adjustable feature (e.g. " set diesel speed to . . . rpm").

Shall Infers mandatory requirement.

Shift Specifies changing mode of operation.

Should Denotes a recommendation (preferred or desired method).

Shut To move so as to close, Do not use.

! Stabilize To bring a specified parameter unde. control with any fluctuaticns controlled.

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f APPENDIX 1 u^ GLOSSARY (Continued)

Word Application Start To originate motion of an electric or mechanical device directly~or byLremote contro11(e.g. " start .. . pump").

Stop To terminate operation (e.g. "stop . . . pump").

Terminate- To stop flow to a specified location. This allows re-

. Injection directing flow to another location without tripping the pump.

Throttle To operate a valve in an intermediate position'to obtain

/a certain flow rate (e.g. " throttle valve-RHR-MO-38A to

. . .").

Trip Do not use.except when the circuit breaker opens' auto-matically. Use "open" in lieu of." trip" when possible'.

Vent To permit a gas or liquid confined under pressure to escape at a vent (e.g. " vent . . . pump").

Verify To determine if in proper condition / status in a specified manner and place in proper condition / status if not found in proper condition / status.

Rev 3 Page 38 of 43 7/21/86-L

APPENDIX 2 APPROVED ABBREVIATIONS Abbreviation Abbreviated Word or Phrase AC Alternating Current Btu British Thermal Unit C centigrade cc cubic centimeter Ci Curie DC Direct Current dp differential pressure F fahrenheit ft foot gal gallon gpm gallons per minute Hg mercury

,,/ '^; hp horse power k_

x hr hour in. inch kW kilowatt lb pound min minute mrem millirem mr milliroentgen MW megawatt N nitrogen 2

psia pounds per square inch (absolute) psig pounds per square inch (gauge)

R roentgen rem roentgen equivalent man rpm revolutions per minute see second V volt

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( _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _

APPENDIX 3

N APPROVED ACRONYMS i

i Q)

Acronym Definition ACAD Atmospheric Containment Atmosphere Dilution System ADS Automatic Depressurization System A0G Augmented Off Gas APRM Average Power Range Monitor ARM Area Radiation Monitor ATWS Anticipated Transient Without Scram BPV Bypass Valve CRD Control Rod Drive CS Core Spray CSCS Core Standby Cooling System CST Condensate Storage Tank DEH Digital Electro-Hydraulic System

[ DG Diesel Generator (j ECST Emergency Condensate Storage Tank E0P Emergency Operating Procedure EPG Emergency Procedure Guidelines FPC Fuel Pool Cooling HCLL Heat Capacity Level Limit HCLL Heat Capacity Level Limit HCU Hydraulic Control Unit HPCI High Pressure Coolant Injection HVAC Heating, Ventilating and Air Conditioning HX Heat Exchanger IA Instrument Air IRM Intermediate Range Monitor LCO Limiting Condition for Operation LOCA Loss-of-Coolant Accident LPCI Low Pressure Coolant Injection LPRM Local Power Range Monitor i MC Main Condensate System (j MCC Motor Control Center MSIV Main Steamline Isolation Valve NDTT Nil-Ductility Transition Temperature Rev 3 Page 40 of 43 7/21/86

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APPENDIX 3 g '~~] APPROVED ACRONYMS k, / (Continued)

Acronym Definition NPSH Net Positive Suction Head OG Off Gas PCIS Primary Containment Isolation System RBM Rod Block Monitor RCIC Reactor Core Isolation Cooling REC Reactor Building Equipment Cooling RF Reactor Feed RFPT Reactor Feed Pump Turbine RHR Residual Heat Removal RMCS Reactor Manual Control System RPV Reactor Pressure Vessel RPIS Rod Position Information System

/~N RSCS Rod Sequence Control System RW Radwaste RWCU Reactor Water Cleanup RWM Rod Worth Minimizer SBGT Standby Gas Treatment SDC Shutdown Cooling SDV Scram Discharge Volume SJAE Steam Jet Air Ejectors SLC Standby Liquid Control SORV Stuck-Open Relief Valve SPLL Suppression Pool Load Limit SRM Source Range Monitor l

SRV Safety / Relief Valve TAF Top Active Fuel (352.56" above vessel bottom)

TB Turbine Building l TEC Turbine Building Equipment Cooling TG Turbine Generator N TIP Traversing In-Core Probe

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! (See Burns and Roe Drawing No. 2001 for instrument identification acronyms.)

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( Page 41 of 43 7/21/86

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' APPENDIX 4 .,

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NUMERICAL ~ LISTING OF CNS EMERGENCY PROCEDURE SECTIONS c

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,l E0P/C - Emergency Operating Trocedures -- General Operator Precautions ,

E0P-l ' -

Reacto'r Pressure Vessel (RPV) Control i

E0P-2 - Primary Containment Control  ;

i E0P-3 - .' Secondary Containment Control [

f Radioactive Release Control 'i; E0P-4 -

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L 4-s w- - m w w-m e e w.w =, +ns.

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APPENDIX 5

() PAGE FORMAT

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F 1"

SP/T SUPPRESSION POOL TD(PERATURE CONTROL m

y g., ;I PURPOSE This emergency instruction provides the direction necessary to restore and maintain suppression pool temperature belov 95'T in order to main-tain primary containment integrity and protect equipment in the primary containment.

Triple spaced (typical)

ENTRY CONDITIONS th line spacing Suppression pool temperature is greater than 95'F. (typical)

OPERATOR ACTIONS

= 3 3/8" Centingency Action &

Pricary Orerator Action Supelerental Inforcation

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/

l 1

,_ SP/T-1. Monitor and control sup- SP/T-1. None j pression pool temperature.

i U SP/T-2. Close any stuck open SRV. SP/T-2. E any stuck open SRV

! cannot he clcsed i I within tvc cir.utes, 2 spaces TEIN perfert the

.- fellovirg actions:  :

r 5 sp. (cinitue) l i" .

I _a. Close bcth recircula- M I " I"j""

l N tien flev control '

valves until eitter an {

A T*y. UFSC ALAU: is <

l space rf

. received CR the rinitut -fa y .

valve pesitten, 0*, is

_ attained.

I; I

T '

E0P-2 - b" Rev 0

'F' oate g Pase 1 of _

1 4 E-e m r u - m -

u .:. w m m m . . 1.; m m . w s m . m .

1 Rev 3 l k __ ... . _ _ _ _ _ _ _ _ _ _ _ _