ML20215D838

Forwards Draft SER Requesting Addl Info for Completion of Review of Util 840716 Submittal of Procedures Generation Package.Response Requested within 45 Days to Close Off Issue in Upcoming Sser

ML20215D838
Person / Time
Site:	Beaver Valley
Issue date:	12/03/1986
From:	Tam P Office of Nuclear Reactor Regulation
To:	Carey J DUQUESNE LIGHT CO.
References
TAC-62934, NUDOCS 8612170060
Download: ML20215D838 (25)

Text

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Decemb:r 3, 1986 Docket No. 50-412 DISTRIRUTION

[Q' NRC PDR P. Tam D. Miller Local PDR ACRS (101 Mr. J. J. Carey, Senior Vice President PAD #2 Rdg V. Benaroya Duquesne Light Company T. Novak . Gray File Nuclear Group OGC-Rethesda Post Office Box 4 E. Jordan Shippingport, PA 15077 B. Grimes J. Partlow

Dear Mr. Carey,

N. Thompson, DHFT

Subject:

Beaver Valley Unit 2- Draft Safety Evaluation on Procedures Generation Package, Confirmatory Issa 47 (TAC 62934)

By letter dated July 16, 1984, you submitted your Procedures Generation Package (PGP) for Beaver Valley Unit 2. Our review of the PGP is tracked under

-confirmatory issue 47. We have prepared the enclosed draft safety evaluation to document the partial completion of our review, and to serve as a request for additional information.

On receipt of this letter, your staff.may wish to discuss its contents with our reviewers. With or.without that discussion, we request an expeditious response from you' (preferably in less than 45 days) so that we can close off the issue in an upcoming SER supplement.

This information request affects fewer than 10 respondents; therefore OMB clearance is not required under P.L.96-511.

Sincerely, Peter S. Tam, Project Manager PWR Project Directorate #2 Division of PWR Licensing-A Office of Nuclear Reactor Regulation

Enclosure:

As~ stated cc w/o enclosure:

See next page Lfi$k')

W i1#r PM:PADR PTam:hW{

PD: PAD #2 LRubenstein 1 % /86 14./_b /86 14/ 3 /86 8612170060 861203 2 PDR ADOCK 0500

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Mr. J. .J. Carey

~* *0uquesne Light Company Reaver Valley ? Power Station CC:

Gerald Charnoff, Esq. Mr. R. E. Martin, Manager Jay E. Silberg, Esq. Regulatory Affairs

'Shaw, Pittman, Potts & Trowbridge Duquesne Light Company 2300 N Street, N.W. Beaver Valley Two Pro.iect Washinoton, DC 20037 P. O. Box 328 Shippingport, Pennsylvania 15077 Mr. C. W. Ewing, Quality Assurance Zort Ferkin Manager Assistant Counsel Quality Assurance Department Governor Energy Council Duquesne Light Company 1625 N. Front Street P. O. Box 186 Harrisburo, PA 15105 Shippingport, Pennsylvania 15077 John D. Burrows, P.E.

Director, Pennsylvania Emergency Director of Utilities Management Agency State of Ohio Room B-151 Public Utilities Commission

• Transportation & Safety Building 180 East Broad Street Harrisburg, Pennsylvania 17120 Columbus, Ohio 43266-0573 Mr. T. J. Lex ' Bureau of Radiation Protection Westinghouse Electric Corporation PA Department of Environmental Power Systems Resources P. O. Box 355 ATTN: R. Janati Pittsburgh, Pennsylvania 15230 P.O. Box 2063 Parrisburg, Pennsylvania 17170 Mr. P. RaySircar Stone & Webster Engineering Corporation BVPS-2 Records Management Supervisor P. O. Box 2325 Ducuesne Light Company i Boston, Massachusetts 07107 Post Office Box 4 Shippingport, Pennsylvania 15077 i

' Mr. J. Beall U. S. NRC John A. Lee, Esq.

• P. O. 181 Duquesne Light Company Shippingport, Pennsylvania 15077 1 0xford Centre 301 Grant Street M: . Thomas E. Murley, Regional Admin. Pittsburgh, Pennsylvania 15279 U. S. NRC, Region I -

631 Park Avenue King of Prussia, Pennsylvania 15229 l

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Enclosure 1

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Draft Safety Evaluation Report Procedures Generation Packaoe Reaver Valley power 9tation,ifnit No. P

1. INTR 0011CTION Following the Three Mile Island (TMil accident, the office of Nuclear Reactor Reculation developed the "TMI Action plan" (NI! REG-066n and N!! REG 0737) which required licensees of operating reactors to reanalyze transients and accidents and to upgrade emergency operating orocedures (F0Ds) (ftem I.C.11 The plan also required the MDC staff to develop a long-term plan that integrated and expanded efforts in the writino, reviewing, and monitoring of plant procedures (Tten I.C.41 NUREG-0894,

" Guidelines for the Preparation of Emergency Operatino Procedures," <:

represents the NRC staff's long-term program for upgrading E0Ds, and describes the use of a " Procedures Generation Package" (FGPI to prepare E0Ps. Submittal of the PGP was made a requirement by Generic Letter 8?-33, " Supplement I to NUREG-0737 - Requirements for Emergency Response Capab'ility." The generic letter requires each licensee to submit to the NRC a pGP which includes:

a (il Plant-specific technical guidelines (ii) A writer's guide (iii) A description of the program to be used for the validation of E0Ps liv) A description of the training program for the upgraded E0Ps.

This report describes the review of the Duouesne Light Company (DLC) response to the generic letter related to develoDment and implementation of E0Ps (Section 7 of Generic Letter 82-33) for the Beaver Valley Power Station. IJnit No. 2 (RVPS-2).

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.._g-Our review was conducted to determine the adecuacy of the orogram for

, preparino and implementino upgraded EADs. This review was based on NilREG-0800 (formerly N11D.EG-75/0871, Subsection -13.5.?, Standard Review Plan for the Deview of Safety Analysis Deports for Nuclear Power Plants.

Section 7 of this report briefly discusses the submittel, the NDI staff review, and the acceptability of the submittal. Section 3 contains the conclusions of this review.

As indicated in the following sections, our review determined that the procedure generation program has several it. ems that need to be satisfactorily addressed before the PRD is acceptable. The aoolicant should address these items in a revision to the PGD, or provide ,iustification for why such revisions are not necessarv. The revision of the PGP, and subseouentiv .

4 of the EAPs, should not imoact the schedule for the use of the E0Ps. The revision should be made in accordance with the RVPS-2 administrative procedures and 10 CFR 50.50 .

2. EVALUATION AN9 FINDINGS By letter dated .luly 16, 1984, the aoplicant submitted its PGP for RVPS-2. The PGP contained an introduction and the following sections:

Initial Emergency noeratino Drocedure Develnoment 8

Generation, Revision, Review and Approval of Emergency Operating Procedures

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Writer's Guide for Emergency Operating Procedures Writer's Guide for Emergency n oerating Procedures Background information Detailed Instructions for the Performance of Table-Top Validation

Detailed Instructions for the Performance of Control Room Walk-Throuah Validation netailed Instruction for the Derformance of EOD Validation on the Simulator Detailed Instructions for the Performance of E0P Veri #ication Training procram Description Reference Plant /RVPS Unit ? Plant Comparison A. Plant-Spec -ic Technical Guidelines (P-STG) "

We reviewed the P-STG program description to determine if it described acceptable methods for accomplishing the ob.iectives stated in NilREG-0899.

The applicant will use Westinghouse Owners Group ('40G' Generic Emergency Response Guidelines (EDGs), Revision 1, dated Seotember 1,1983, as the technical guidelines from which plant-specific E0Ps will be dra#ted. The applicant' identified the following source documents for use in generating E0Ps for RVPS-2:

Westinghouse Owner's Group ERGS, Revision 1, dated September 1,1983. y Westinchouse Owner's Group ERG Background Documents (Procedure-Specific and Generic Issuesl BVPS-2 Updated Final Safety Analysis Report BVPS-2 Technical Specifications RVPS-? Operating Manual Drevious E0P draft deviation sheets l

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As-built plant drawings (e.g., PAID, elementar1esi m Additional information as appropriate ,

• e Our review of the P-STG identified the following'roncer.ns:

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1. A good description of the organizational asoects o# preoaring the FDPS for the generic technical cuidelines is provided, and Section 5 provides a useful plant description with petailed differences between RVPS-? and the reference plant. However, all deviations from and additions (including plant-specific bracketed informationi to the generic technical guidelines shou d be documented. and an analysis of other technical justification supporting the deviations y and additions that are of safety significanch should be included.

Safety significant deviations or additions to the ERGS .and their justification should be included in the PGP. The E0P-ERF- Deviation Form (Figure 53.B-1) can be used to provide this information. 7t is noted that at the time of the PGP submittal, there had not been any deviations from the ERGS identified as having safety significance.

,nt With adequate resolution o# the above item, the RVPS-2 plant-specific technical guidelines program should accomolish the objectives states in N!!REA-0899 and should provide adequate guidandtsfor translating the Westinghouse Owner's Group EDGs into the RVPS-2 EODs. We will report 6 on the resolution of this item in a subsequent SE.% r R. Writer's Guide

ti We reviewed the writer's guide to determine if it described acceptable methods for accomplishing the ob.iectives stated in NllREG-0899.< The writer's guide provides administrative and technical guidance in the preparation of E0PS. Our review of the RVDS-? writer's cuide identified the.following concerns: .

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1. Cautions and notes provide operators with important supplemental  !

information concernino specific steps or secuences of steps in E0Ps.Section IV.E of the writer's quide,'which discusses cautions and notes, should be revised to address the following concerns:

a. Section IV.E.6 states that a note can contain a procedural transition "when absolutely necesserv." Notes are intended tn provide supplemental information to operators and should not contain instructions, directives, or operator actions. The writer's cuide should be revised to indicate that transitions are not acceptable in notes.

b. Sections,1.D.6, I.D.7, and I.9.8 of the Verification Evaluation Criteria Checklist, Table 53.B a, mention " precautions" as well as cautions. Precautions are not defined in the writer's guide.

If precautions are to be used in E0Ps, they should defined and specific formatting information should be provided.

c.Section IV.A.1.o instructs procedure writers to use a note to indicate inaccurate instrument readings. In Figure 53.R-5, a sample E0P page, a caution is used to indicate an inaccurate instrument reading. The writer's guide should be revised so ,

that examples and instructions are ennsistent.

d. Sections IV.E.4.d and IV.E.5.d state that " multiple statements included under a sinole descriptive headino shall be separately identified." These sections are unclear because (11 "multiole statements" and " single descriptive headings" are not defined, and (?) the writer's guide does not ornvide formatting instruc-tions for how these " multiple statements" should be separately identified. The writer's guide should be revised to clarify these points.

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2. Conditional and locic statements will be used in E0Ps to describe a set of conditions or a sequence of actions. These statements have the possibility of being confusing; thus it is important that the writer's guide provide explicit guidance for the use of these statements. The discussion of logic terms in the writer's quide should be revised with regard to the'#ollowing:

a.Section IV.0.1 includes NOT as a separate logic tem. Other than in coniunction with IF, it is not clear how NOT is to be used when writing E0Ps. Oniv the logic term TF NOT should be used in E0Ps.

b. Section TV.n.4.b discusses the inclusive and exclusive OR, and cives a format that "may be' used"' to specify the exclusive OR'.

So that operators are at all times certain of the meaning of the logic tem OR, the exclusive OR should always be famatted in the same manner. Thus, the writer's guide should give the format that should be used to indicate the exclusive OR.

c.Section IV.D.2 states that the use of AND and OR in the same action should be avoided. There are occasions, however, when it becomes necessary to combine these terms. The writer's guide should provide guidance and examples o# acceptable usage for these situations. (See NUREG-0899, Apnendix B for additional informationi,

d. Figure 53.R-7, a sample Symptomatic Response / Unexpected Conditions page, contains several errors in the use of logic terms: (11 the words "both" and "either" are used and emphasized as logic terms; (2) IF is used without THEN; (31 the word "if" is used as a logic term without being capitalized or underlined; and (di OR is emphasized with dashes, i.e., -0D . The use of logic terms in Symptomatic Response /linexpected Conditions should be revised to conform to the rules established in the writer's guide.

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e.Section IV.D.3 states the dual-column format,used in procedures " equates to the Togic IF NOT the action in the left column, TWEN follow the action specified in the richt column." In a dual-column format, an operator goes to the richt column if the expected response in the left column is not obtained; thus the implied logic is IF NOT the EXPECTEn DE3N)NSE in the left column, THEN follow the action in the right column. The writer's cuide should be revised to reflect this concern.

1. . . Sections IV,0.4.c and V.9.1.c instruct procedure writers tn use a comma after a conditional phrase. In the Response Not Obtained Column of Figure 93.B-5, no such comma follows the <

phrase "IF a RCP can .NOT be started.. . ." The writer's cuida should be revised so that examoles given are consistent with instructions'in the text.

3. Critical Safetv runction Status Trees provide important safetv information to operators.,Section VI.A.? of the writer's guide discusses Critical Safety Function Status Trees. This discussion should be revised to address the following concerns:

a.Section VI.A.2 gives CSF as the acronvm for Critical Safetv Function Status Tree. Table 53.B-3, the list of abbreviations and acronyms, gives CSF as the acronym for Critical Safety

, Function. The Critical Sa#ety Function is a set of conditions i that must be maintained to ensure plant safety. A Critical Safety Function Status Tree is a device used to monitor the Critical Safety Function. 9ecause the Critical Sa#ety Function i

and Critical Safety Function Status Tree are not the same thina, '

the same acronym should not be used to refer to both of them.

The writer's cuide should be revised to reflect this concern.

b.Section IV.A.b states that Critical Safety Fpnction Status Trees "should be formatted as presented in Figure 53.B-8."

The text of the writer's guide should be revised to provide specific formatting instructions for Critical Safety Function Status Trees,

c. The entire text of the sample Critical Safety Function Status Tree presented in Figure 53.R-A is capitalized. If all words are so capitalized, then capitalization cannot be used for emphasis; furthermore, text written in all capitals is more di#ficult to read than mixed cr:e. The writer's guide should be revised to state that capitoli7ation in Critical Safety Function Status Trees will conform to the rules established "

for E0Ps.

d.Section VI.A.9.c states that each Critical Safetv Function Status Tree shall be assigned "its own unique number," but does not describe a numbering system. So that orncedure writers are able to number Critical Sa#ety runction Status Trees in the proper manner, the writer's guide shou'd specifically describe this numbering system.

e. It is important that operators know the location of Critical y

Safety Function Status Trees within the E0Ps. The writer's guide does not provide this in#crmation. The writer's guide should be revised to specify the location of Critical Safety Function Status Trees.

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f. Color coding, line tyoes, and end symbols, which correspond to the degree of severitv within the Critical Safety Function Status Trees, are used in the status trees to provide distinction for the various paths. These symbols, which convey important information to operators, are not fully discussed in the writer's cuide. Although the examoles are consistent with the construction of status trees in the EDGs,Section IV.A.2.d should be revised to (1) discuss the meaning of the end symbols and (2) discuss the dearee of severity of color coding, line types, and end symbols as related to the Critical Safety Function Status Trees.

4 Section VI.A.l.b states that Symptomatic Resonnse/ Unexpected o Conditions will be written "in the format presented in Figure 53.R-7." The text of the writer's cuide should he revised to provide specific formatting instructions for Symptomatic Response / Unexpected Conditions.

5. The proper use of emphasis techniques can contribute to the understandability of procedures. The emohasis techniques discussed in the writer's guide should be revised with regard to the following:

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a. In Figure 53.R-5, expected responses of operator actions are capitalized. The writer's guide does not include instructions for such capitalization. If expected responses are to be capitalized, the text of the writer's guide should contain instructions to do so.

b'.Section V.C.1.a instructs procedure writers to underline "the ma,ior task defined in each steo." " Major tasks" are not defined in the writer's guide. Furthermore, such underlinino would conflict with the underlining of any loaic terms and would detract from the emphasis of the logic terms. For these reasons, we recommend such underlinino be avoided.

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c. The writer's guide instructs writers to use cap (11 "to in the following situations: d (21 "to emphasize of equipment operation" (Section V.9.1.f1; anifically the iten names and numbers on panels which areThe H l bl. spec overuse of concern in the procedure" (Section TV. .from emphasis of capitalization will detractFor these reasons, we re in mixed case.

capitalization not be used in these situations, i steps should d.

Section be circled. III.R.2.afli states that imm d s

immediate action step numbers should be circle .

sections of procedures 6.

Referencing of branching to other delays. procedures Sectionor tv,n We have can be disruptive and can cause unnecessary d branching.

of the writer's cuide discusses referencing an the following comments:

a h se " Refer n" for

a. Section to."

IV.G.3 discusses transition emphasis, f ncing, to

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Section IV.G.2.b instructs d writers, when cross-re "specify information as to proce ur d cific The writer's guide should be revised i to provi e spe We recommend formatting information for cross-referenc b beng.

included in that the step title and the entire step num erReactor C the reference, e.g., GO TO E-1, " Loss of Step 1.

t hment 5."

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Figure 53.R-5 includes the reference "GO TO At a 5" in accordance This example should be " REFER IV.G.3. TO Attachment with the ouidance provided in Section _

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d. To facilitate movement from one part of E0Ps.to another, l some method for easily identifying the sections or subsections of the EOD, such as tabbing, should be emploved. I 1

7. It is important that a consistent method of step numbering he used throughout E0Ps.Section III.A.4 states that " step numbering and indentation shall be'in the format presented in Fioure 53.B-5."

The text of the writer's cuide gives no further information on the numbering of steps. The writer's aufde should be revised to specifically describe a system of step numbering which will assion a unique number to each step and present the entire step number at each step level in E0Ps.

h R. Information should be cresented so that interruptions in the flow of information to operators are minimal. For this reason, action steps should be complete on one page. In Tigure 53.9-5, a samole E0P page, a _ step is broken at the end of the oaqe. The text of the writer's quide should be revised to indicate that all steps should be complete on one page, and Fiaure 53.9-5 should be revised to confonn with this requirement.

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9. Instructions should be written for the various types of action steps that an operator may take to cope with different plant situations. y The guidance provided in the writer's guides-for writing instruction steps should be revised as follows: "n

a. The writer's guide should state that instructions should be written as directives, i.e., in the imperative mode.

I b. The writer's guide should specifically discuss the definition l of and formatting for the following types of action steps:

(11 steps which verify an action; (21 steos for which a number of alternatives are eoually acceptable; and (3) steps performed concurrently with other steps. /See 1UREG 0809, Section 5.7, for additional informationi. -

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c.Section III.R.7.a.1 discusses inmediate action steps.

Immediate action steps are not de#ined in the writer's guide.

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The writer's guide should he revised so that immediate action steps are defined.

10. With regard to potential confusion, delay, and errors in execution of E0P steps, we have the following concerns:

a. E0Ps should be structured so that they can be executed bv the minimum control roon staffing reoutred by the Technical Specifications.

b. Instructions for structuring E0Ps should be consistent with.

• the roles and responsibilities o# the operators.

c. Action steps should be structured so as to, minimize the movement of personnel around the control room while carrying out procedural steps.

d. Action steps should be structured to avoid unintentional duolication of tasks.

e. E0Ps should be structured so that the control room supervisors 3

will be able to follow staff actions and monitor plant status.

(See NUREG-0899, Section 5.8, for additional information).

11. Vocabulary and syntax used in E0Ps should be readily understood bv both procedure preparers and operators. So that E0Ps can be clearly understood, the writer's ouide should be revised as follows:

a.Section IV.I.?.a and Table 53.R-? both include definitions of action verbs to be used in E0Ps.Section IV.I.2.a should reference Table 53.B-2 as an inclusive list o# action verbs acceptable for use in E0Ps.

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b. Section V.D.l.d instructs orocedure writers .to " define key words that may be understood in more than one sense." The use of words with more than one meaning could lead to operator confusion. This section should be revised to state that ambiouous terms will be avoided in Eno s , and that all terms reouiring definition will be defined in the list of acceptable terms.

c. Table 53.B-P includes the action verb " initiate," but states that "begin is pre # erred." "Begin" is not included in Table 53.B-?. Simpler, more common words are preferable in E0Ps.

" Initiate" should be deleted from table 53 R-? and "begin" substituted in its place. "

d. Table 53.R-? includes that action verb " throttle," but states that " control is preferred." " Control" is alto defined in Tabl'e 53.8-2. Redundant terminology in E0Ps could lead to operator confusion. If " control" is preferred, " Throttle" should be deleted from Table 53.R ?.

12. Acronyms and abbreviations used in E0Ps should be readily understood by both procedure preparers and noerators. So that E0Ps can be clearly understood, the writer's cuide should be revised as follows:

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a. Section V.F.4 states that " acronyms may be used if they are defined or commonly used." Only acronyms that have been specifically defined in the list of approved acronyms should be used in E00s. This section should be revised to state t' only acronyms from Table 53.R-3, the list of approved acronvns, may be used in E0Ps.

b. Section V.A.5 of Appendix R states that "some apornved acrnnvns and abbreviations are included in Table 53.R-3." Thi; se.*ica  %

%. ~tg should be revised to stated that all approved acrenv.ns 7.r- ei sg'. " b d o 9e V in Table 53.R-3. s @

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

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c. Section V.F.1 states that consiste.ncy in the use of abbreviations "should be maintained through the procedure."'

So that operators are at all times c'ertain of the meaning of an abbreviation, this section should be revised to state that consistency in the use of abbreviations will be maintained through all procedures.

d. Acronyms and abbreviations are bene #icial only if thev simplifv a complicated expression in an understandable manner. Many of the . acronyms in Table 53.8-3 do not apoear to be related tn the expression they stand for, e.g., NRI for Vibration Monitoring, ACS for Chilled Water System, and CHS for Chemical Volume Control System. The meaning of such acronyms could be unclear to "

operators. We suggest that such acronyms be defined so that there is a direct relationship between the acronym and the expression it stands for.

e. Many of the abbreviations in Table 53.B-3 stand for simple expressions, e.g., Pnl for Panel, Pp for Pump, Viv for Valve, Rrg for Bearing, and Cir for Cooler. Such abbreviations could be eliminated without increasing the complexity of procedures; furthermore, these abbreviations would be more easily understood by operators if written out. Ve suggest that such abbreviations  :

be eliminated and table 53.R-3 should be revised to include only abbreviations and acronyms that simplify complicated expressions,

f. Table 53.R-3 includes the acronyms " RAT" for Boric Acid Tank '

and "Batt" for Ratterv. The use of such similar acronyms in procedures could lead to operator confusion and should be avoided. Since the acronym "Batt" does not significantly simplify the word " Battery," we recommend that "Batt" be deleted from Table 53.8-3.

13. The proper use of punctuation can contribute to the understand-ability of procedures. Several sections in the writer's quide discuss the use of parentheses and brackets.Section V.B.1 should be revised with regard to the following:

a. An example in Section V.E.1.d uses parentheses to specify the rance of a calibration point. The text of the writer's guide does not contain instructions to use parentheses in this manner.

If parentheses are to be used in this manner, the instructions to do so should be provided.

b.Section V.B.l.f uses the acronym "PORV(s)." The writer's guide does not discuss the use of parentheses in this manner; thus,

• the meaning of this acronym is not clear. The writer's quide should be expanded to indicate the meaning of parentheses when used in this manner, or should provide for.an alternate technique for indicating multiple components.

c. An example in Figure 53.B 7 uses brackets to specify parameter values during adverse containment. The text of the writer's guide does not contain instructions to use brackets in this manner. If brackets are to be used in this manner, the text of the writer's guide should contain specific instructions to ,

do so.

14 Because of the stressful conditions under which E0Ps are used, a high possibility of error exists when any calculations or conversions of numerical data are reouired of operators. The following sections of the writer's guide, which deal with calculations and conversions, should be revised:

a.Section V.E.1.d states that acceptance values should be speci#ied such that addition and subtraction by the user are avoided "if j possible." The writer's guide should be revised to indicate

( that users should not be reoufred to add or subtract numbers i to determine acceptance values.

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b. Section IV.F.1 of the writer's cuide states.that charts and graphs should be presented instead of requiring the operator to perform a calculation "whenever possible." The writer's guide should discuss the specific situations where calculations are acceptable. Tf a calculation is reoutred, space for the calculation should be provided.

15. It is important that operators know where to find all instruments and controls referred to in E0Ps. The following sections should be revised with regard to this point:

a. Section IV.ii.l.a states that equipment and controls' will be identified in operatnr language which "may not always match

• engraved names on panels."Section IV.H.l.b states that Danel engravings should be quoted verbatim when the item is "specifica1'ly the item of concern in the procedure." To ensure that an operator is able to easily identify ecufoment and controls, the writer's guide should be revised to designate a preferred method for identifying equipment, controls and displays, and to provide guidance for its consistent use throughout the E0Ps.

b.Section IV.H.l.d instructs procedure writers to give both ,

benchmark and location information when referring to a conoonent that is seldom used or would be difficult to find.Section IV.l.2.a gives an example which includes benchmark information but not location infonnation. The writer's guide should speciff-cally discuss situations where it is appropriate to give benchmark information but not location information.

16. Figures and tables can assist operator in making decisions and locating information.Section IV.1 should be revised to address the followirrg concerns:

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a. Specific formatting information for figures ,and tables should be given in the writer's guide and examples provided.

b. It is important that operators know where printed operator aids are located within the E0Ps. .The writer's guide does not discuss-this issue. The writer's guide should be revised to specify the location of printed operator aids.

c.Section IV.1.2.a states that, in figures and tables, units of meas.ure will accompany all numbers. Operators should be able.

-to relate these numbers to control panel mar. kings. For this reason, the writer's guide should further state that units in figures and tables will correspond to control panel markings. .

5 17 Procedure writers should be given sufficient information in the writer's guide to produce procedures that are properly formatted.

So .that writers can produce properly formatted procedures, the following portions of the writer's guide should be revised.

a. Sections III.A.5 and III.A.6 discuss margins and borders, but do not discuss the size of margins or the position of borders.

The text of the writer's guide should be revised to include specific formatting instructions for margins and borders.

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b.Section III.A.7 gives the minimum spacing required between

steps and substeps. This section should be revised to include specific spacing requirements.

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c. The writer's guide does not discuss line spacing within the text of a step. The writer's guide should be revised to provide line spacing requirements.

d. The writer's guide does not discuss pitch size (e.g., pica or elite) in procedures. The writer's guide should be revised to provided pitch size requirements.

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e. Section-II.G.I refers procedure writers to Figure 53.R-3 for forrratting information for the E0P title page. So that writers can produce consistently formatted procedures, the text of the writer's gside should include specific formatting instructions for the E0P title page.

f.- Figure 53.8-5 shows the procedure name and number appearing on a sample E0P page; however, the text of the writer's guide does not state that the procedure name and number should be.

included on each E0P,page. So that operatnrs are certain at

all times of the procedure they are using, the text of the writer's guide should scecifically state that the procedure name-and number will be incl'uded on'each E0P page, and should 5 specify the location for this information.

18. It is important that operators use the correct procedure at a

. multi-unit site.Section III.A.1 States that the Unit desionation should be included only with the operation manual chapter, i.e.,

2.53.A. So that operators are at all times certain that they are using the correct procedure, we reconnend that the unit designation also be included with the facility desionation, i.e., RVDS-2.

19. Placekeeping aids can assist operators in keeping track of their g position within a procedure. These aids are of particular importance when performing steps or procedures concurrently, and in situations where the operator's attention is diverted. The writer's guide should be expanded to include a discussion of some type of placekeeping aid.

20. It is important that the quality of EOD copies (e.o., legibilitv, completeness, colorl approximates the quality of the original procedure to preclude operator difficulty in readino the E0Ps. The writer's guide should be expanded to address this point. (See NilREG-0800, Subsection 6.P.2, for further information.)

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... , 21. Recause E0Ps will be used in stressful situations, and un' der time constraints, they have to be accessible to operators and easily identifiable. The writer's guide should address the accessibility of E0Ps and techniques to distinauish them from other plant procedures.

With adequate resolution of the above items, the BVPS-2 writer's guide should. accomplish the ob.iectives stated in NUREG-0899 and should orovide adequate cuidance for translating the technical guidelines into E0Ps that will be usable, accurate, complete, readable, convenient to use and acceptable to control room operators. We will address these items in a subseouent SER.

C. Verification and Validation Program <

We reviewed the description of the verification and validation program to determine if it de~ scribed acceptable methods for accomplishing the ob.fectives stated in NUREG-0899. The PGP gives as ob.fectives for the verification and validation process that each E0P is:

a Technically correct in that it accurately reflects the generic technical guidelines.

Written correctly in that it accurately reflects the E0P writer's e

guide.

Usable in that the procedure can be understood and followed by trained operators without confusion, delays or errors.

Operationally correct in that there is a correspnndence between the procedure and the control' room / plant hardware, and that the language and level of information presented in the E0P is compatible with the minimum number, qualifications, training, and experience of the operating staff.

Capable of directing the operatina staff in managing emeroency conditions.

, r. .. 90-Our review of the BVPS-9 verification and validation program description identified the following concerns:

1. Sub.iect matter experts, procedure writers, and human factors experts should be involved in all phases of the validation process. rurther, the verification and validation team members should be specified by the PGP, not ,iust presented as options, i.e., Appendixes n E and c.

2. Particular attention should be paid to deviations from and additions to the generic technical guidelines that are of safety significance during the verification and validation programs. These verification and validation steps can be accomplished separately or as a part of the E0P verification and validation programs. The PGP should discuss s how the deviations from and additions to the ERAS are to be verified and validated.

3. The Verification Evaluation Criteria Checklist (Table 53.R-41 should be revised 'to include Section IT.E, Operator Information and Control Needs, from the E0P Verification Summary Sh'eet (Figure 53.8-18).

4. The validation program description states that table-top reviews, control room walk-throughs, and simulator exercises will be used, but does not adequately discuss the conditions under which each will be used. The validation program should be revised to address the following:

a. The validation program should be expanded to include a description of the criteria that will be used to select the scenarios to be run during the validation process. The criteria should be developed on the basis of what is needed to validate the procedures and should ensure that single, sequential, and concurrent failures are included. A review of the capabilities and the limitations of the simulator will then identify what can be validated on the simulator.

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b. -For the parts of the E0Ps that cannot be validated on the simulator, the criteria for selecting the additional validation that is needed and the methods to be used, such as a control room or plant walk-through, should be described.

5. The EODs will require a certain number of operators to carry out the various activities and steps as specified. The Initial Emergency Operating Procedure Development description,Section II.C.4, indicates that the E0Ps will be exercised, durino simulator exercises or control

. room walk-throughs, with the minimum control room staff size required by the facility Technical Specifications. Section 3, Appendix E, Subsections II.A.l.a. II.A.1.b.7, and II.A.? should be modified accordingly. o

6. The verification and validation program descriptions should include the criteria or methods that will be used for determining the need to reverify and revalidate an.v changes.in the E0Ps, resulting from either the verification and validation progran or from subseouent E0P revisions.

With adequate resolution of the above items, the BVPS-2 verification and validation program should accomplish the ob.iectives stated in NUREG-0899 and should provide assurance that the E0Ps adequately incorporate the guidance of the writer's guide and the technical guidelines and will guide the operator in mitigating emergency conditions. We will address these items in a subsequent SER.

D. Training Program We reviewed the description of the operator training program on the BVPS-?

upgraded E0Ps to determine if it described acceptable methods for accom-plishing the objectives stated in NUREG-0899. The following objectives are given for the RVPS-2 training program:

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To provide training to appropriate personnel on the updated E0PS, or subsequent revisions, prior to implementation.

- To provide [a knowledge of7 the technical basis of the uparaded E00s, including how plant systems, subsystems, components, etc.,

relate to the E0Ps, plus their function and use during transients and accidents.

To provide a working knowledge of the technical content o' the 50D which establishes the know-how to perform each step in all E0Ps so that E0P objectives are achieved.

To demonstrate the ability of individuals and crews to 9xecute the s upgraded E0Ps under operational conditions as modeled on the Beaver Valley Unit 1 simulator and achieve safe, stable or shutdown conditions.

To provide reasonable assurance that the methods used in training are adequate.

a Our review of the BVPS-? training program description for E0Ds identified the following concern:

1. If it becomes necessary, because o# the reasons discussed in Section II.D.3 of the training program description, to walk-through a simulation, the training program description should be revised to indicate that all operators will participate in the walk-through and that they will participate as a team.

With adequate resolution of the above item, the BVPS-2 trainino program should accomplish the objectives stated in NUREG-0899 and should result in appropriate training for the BVPS-2 operators on the upgraded E0Ps.

We will address this item in a subsequent SER.

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3. SulWARY The PGP should be revised to address the items described in Section ?

and resubmitted along with a sample 0* at least one Emergency Operating Procedura and its associated documentation (e.g., step deviation document, verification and validation documents). This sample procedure will not be reviewed for approval, but rather will be used as an indication of how the

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PGP is being applied to E0P preparation.

4. CONCLUSIONS t

Rased on our review, we conclude that the following items need to be resolved: ,

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1. plant-specific technical guidelines (Section ?A),

2. the plant-specific writer's guide (Section 2B),

3. validation (Section 2C), and 4 training (Section 2'n) s