SNRC-1472, Forwards Response to NRC 880415 Request for Addl Info Re Procedures Generation Package & Actual Procedures Package
| ML20151D405 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/15/1988 |
| From: | Leonard J LONG ISLAND LIGHTING CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20151D407 | List:
|
| References | |
| SNRC-1472, NUDOCS 8807250105 | |
| Download: ML20151D405 (42) | |
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[fg(*@ LONG ISLAND LIGHTING COM PANY SHOREHAM NUCLEAR POWER STATION P.O. BOX 610, NORTH COUNTRY RO AD + WADING RIVER. N.Y.11792 f
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JOHN D. LEON ARO. JR.
VICE PRE 11 DENT NUCLEAR OPER AftONS SNRC-1472 JUL 15 088 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Request for Additional Information Procedures Generation Package Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 ,
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Reference:
NRC letter from Walter Butler to John D. Leonard, s Jr., dated April 15, 1988 Gentlemen:
The attachments to this letter constitute LILCO's response to the subject Request for Additional Information (RAI). Attachment 1 contains an item by item response that directly corresponds to 4 each of your requests. Attachment 2 is the revised Procedures Generation Package (PGP). The PGP was revised to comply with Section 3 of the RAI and to be consistent with the responses contained in Attachment 1. Three append'.ces accompany Attachment
- 2. The first provides a copy of the SNPL Dlant Specific Techni-cal Guidelines which were derived from the BWROG Emergency Procedures Guidelines, Revision 4. The second consists of SNPS Station Procedure 21.009.02 entitled, "Technical Review of New or Revised Symptom Oriented Emergency Operating Procedures." The third appendix provides a copy of applicable office of Training Procedures. Finally, Attachment 3 provides a sample of an Emer-gency Operating Procedure (SP 29.023.01, "RPV Control Emergency Procedure") and its associated verification documentation.
}\o+S 8807250105 880715 DR ADOCK0500g{2 i .
' SNRC-1472 Page 2 Should you have any additional questions or require clarifi-cation, please do not hesitate to call my office.
Very truly yours,
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- < ~ ( g (g,Jrl ohn D. 'eonar ice President - Nu ear Operations JG:ck Attachments cc: W. T. Russell S. Brown F. Crescenzo l
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Attactment 1 3NRC-1472 Responses to NRC's Request for Additional Information SNPS Procedure Generation Package-A. Plant Specific Technical Guidelines
- 1. NRC Request The license should describe how operator information and control needs will be derived and used to specify instrumentation and control requirements. The P-STG should be based on the identification of plant systems and functions and, be supported by an analysis of operator tasks to identify operator information and control requirements. This description may be in the PGP, or in the Detailed Control Room Design (DCRDR) Program Plan., If the licensee addressed this item as part of the DCRDR, the licensee should state this (cross-reference) in the P-STG portion of the PGP.
LILCO Response
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The analysis of operator tasks, and the determination of information and control needs is described in the SNPS Detailed Control Room Design Review (DCRDR) Implementation Plan under Section 3.5.5, Methodology for Task Analysis. This plan has been submitted to the NRC under SNRC-1297, December 8, 1986,
- 2. NRC Request The licensee should submit all deviations from the Owners Group's Generic Technical Guidelines that are potentially safety significant (e.g., related to systems, functions, or methods), with justification for cach deviation. Examplcc cf devictions may bc fcund in SRP Sectior 13.5.2.
LILCO Response As required by NUREG 0737, Supplement No. 1, LILCO included "a description of the planned method for developing plant specific E0Ps from the generic guidelines" in the PGP. In order to satisfy this I. additional request for all deviations from the generic technical guidelines, LILCO has included with this submittal, a copy of the latest revision of the SNPS PSTG. The format of the PSTG includes a justification for any differences between the Emergency Procedure Guideline and the SNPS PSTG.
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B. Writers Guide
- 1. NRC Recuest Notes and cautions provide operators with important supplemental information concerning specific steps or sequences of steps in the E0Ps. The information on cautions and notes in Figure 1 3 and in Section 1.4.10 should be expanded and revised with regard to the following:
- a. iigure 1 3 implies that the sar.e symbol is used for both a caution and a note. Because caution statements provide information used to prevent actions by control room oper-ators that could injure personnel or endanger public health or safety, it is important that they be distin guished from notes, which provide less criticci infor- mation. Further, in Section 1,4/10 the symbol is used only for a caution and no symbol is designated for a note. This format discrepancy should be clarified; and some emphasis technique, such as a different symbol, should be used to distinguish cautions from notes to alert control room personnel to their more critical nature.
LILCO Response The Writer's Guide has been significantly revised. Figure 1 3 now exists as Figure 6-3. The caution and note sytbols now differ with the caution symbol being a yellow outlined hexagon and the note symbol being a circle. Section 1.4.10, now exists as Sections 6.12 and 6.13 of the revised Writer's Guide, and distinguishes the differences between cautions and notes.
Ib. NRC Recuest Section 1.4.10b describes the format and placement of the caution symbol but not for the note. This section should be expanded to include the format and the placement of a note symbol.
LILCO Response Section 1.4.10b now exists as Sections 6.12 "Cautions" and 6.13, "Notes". Section 6.13 includes the format and placement of a nota symbol.
Ic. NRC Recuest The Writer's Guide does not describe the format of the cautions and notes to be placed at the bottom of the flowchart or the numbering scheme to be used for each note and each caution. The Writer's Guide should be revised to specify the format for cautions and notes at the bottom of the flowcharts, how cautions and notes are to be numbered, and the emphasis techniques to be used.
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- s LILCO Resoonse Writer's Guide Sections 6.12 and 6.13 explain the numbering schemes of cautions and notes, plus describe format for cautions and notes at-the bottom of the flowcharts. Additionally, examples have been provided in each section.
Id. NRC Reauest Section 1.4.10 states that it is acceptable to express conditional actions in a note or caution. Notes are intended to provide supplemental information and cautions are intended to attract attention to essential or critical information in procedures; neither is intended to include any instructions, directions, or operator actions. The Writer's Guide should be revised to indicate that actions of any kind are not acceptable in notes and cautions.
LILCO Response Sections 6.12 and 6.13 state that actions are not acceptable in cautions or notes.
- 2. NRC Recuest Conditional and logic statements should be used in EOPs to describe a set of conditions or a sequence of actions. Because of their importance and complexity, it is important to provide explicit guidance for their use. The guidance provided in Sections 1.5.5 and 1.5.6 should be revised with regard to the following:
- a. The terms WHILE and BEFORE are not considered logic terms and are not in b'UREG 0899. Statements can be worded to avoid the use of WHILE and BEFORE as pseudo logic terms. The Writer's Guide should be revised to eliminate their use as logic terms.
LILCO Response Writer's Guide Section 1.5.5, now Section 4.5 addresses logic terms. The term WHILE by itself is not to be used as a logic or psuedo logic term and writers are instructed noc to use WHILE by itself in Section 4.5d. WHILE is used in the adjunctive sense along with the logic term IF to qualify retainment override steps which specifically address sequence of action type steps that are required by the BWROG EPGs. Explicit guidance for the use of the IF VHILE term is addressed in Section 4.5d, Section 1.5.6 now exists as Section 4.6 which contains the term BEFORE. The term BEFORE is used to define conditional statements specific to the BWROG EPGs which is interpreted by LILCO as a specific set of conditions re)ating to sequence and plant parameters j requiring conservative action. BEFORE is defined in Appendix B of l
s Revision 4 EPGs as "Any time prior to. Utilized where an event-independent margin is not appropriate or cannot be defined."
Explicit' guidance for the use of BEFORE is addressed in Section
.4.6d.
2b. NRC Reauest Section 1.5.Sc describes the use of the logic term OR. The logic term OR can be used in an inclusive sense and in an exclusive sense.
This section should be revised to provide instructions for formatting logic statements that include OR used in either sense, and when to use or not to use either.
LILCO Resoonse Section 1.5.5c now exists as Section 4.5c which provides instructions for formatting logic statements that include OR used in the inclusive and exclusive sense, as well as directions when to use or not to use either.
2c. NRC Recuest
.Section 1.5.11 states that logic terms are to be underlined for emphasis. It also allows other words to be underlined for emphasis. Logic terms should be uniquely emphasized so that they stand out in the text and are easy for operators to recognize. The Writer's Guide should be revised to exclude any other words to be *
, underlined for emphasis.
LILCO Response Section 1.5.11 now exists as Section 4.11 and still allows for both: 1) logic terms; and, 2) other types of information to be underlined, when appropriate for special emphasis. Besides being underlined, logic terms are further emphasized so that they stand out in the text of both prose and flowchart procedures.
In prose procedures, logic terms are farther emphasized by being:
- 1) in boldface type, 2) in all capitals, and 3) placed either to the lef t margin or in the center of the page. Since flowchart type is j
in all capitals, logic terms are further emphasized by being placed either to the extreme left margin or in the center of the step symbol. Flowchart type is not boldfaced because the type size would conflict with readability guidelines addressed in Section 6.19.
These additional emphasis techniques are unique to logic terms and
. ., were easy for operations to recognize during EOP Validation.
- 3. NRC Recuest l Section 1.5.7c discusses referencing and branching. It should state that the procedure title, and where applicable the entire step number, be included in a reference or branch; e.g., GO TO SP l
29.023.05 "TITLE", STEP WP-3.
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'o LILCO Response Section 1.5.7c, now as.Section 4.7c, discusses referencing and branching, which states details on procedure titles and procedure step numbers.
4 NRC Recuest Instructions should be written for the various types of action steps that an operator may take to cope with different plant situations.
- a. The Writer's Guide should define the following types of action steps: (1) steps that verify an action; and (2) steps which are performed continuously or periodically.
LILCO Response .
Section I.,4 of the Writer's Guide, "Types of Steps", provides guidance for the various types of action steps. Section 4.4b defines steps that verify an action, and Sections 4.4c and 4.4d respectively define steps that are performed continuously or periodically.
4b. NRC Recuest The Writer's Guide should define, describe the format of and provide examples of (1) steps for which a number of alternative actions are equally acceptable; (2) steps which diagnose a situation; and (3) steps which are time dependent.
LILCG Response Section 4.4 of the Writer's Guide defines, describes the format of, and provides examples for each of the following step types:
- 1) Steps for which a number of alternative actions are equally acceptable (Section 4.4e)
- 2) Steps which diagnose a situation (Section 4.4c Decison)
- 3) Steps which are time-dependent (Section 4.4b)
- 5. NRC Recuest Procedure writers should be given sufficient information to produce procedures that are correctly and consistently formatted. In order to ensure consistency throughout EOPs, instructions and examples in the Writer's Guide should be revised as follows:
- a. The Writer's Guide does state the size of the type for wording on the flowcharts, but not the size of the symbols used, line
e width, and arrow size. The Writer's Guide should specify the size of symbols, line width, arrow size and any other aspect of-the flowchart that would affect readability.
LILCO Resoonse "Readability Guidelines", Section 6.19, specifies the aspects of flowchart readability. Symbol siza is addressed ~in Section 6.19b, and line widths and arrow sizes are located in 6.19c.
Sb. NRC Recuest Because of the complexity of flowcharts, it is recommended that an example of a properly formatted flowchart be included in the Writer's Guide.
LILCO Response An example of a properly formatted flowchart is included in the Writer's Guide as Appendix B, "Sacple Flowchart Procedure."
- 6. NRC Recuest Section 1.5.10 provides guidance with respect to the verbs to use in the action steps. The number of verba listed however is limited and there may be other acceptable verbs the writers will want to use.
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The Writer's Guide should provide an inclusive list of acceptable and defined verbs available for use by the writers.
LILCO Response The Writer's Guide provides an inclusive list of acceptable and defined verbs in Appendix D, Recommended Action Verb List. Section 1.5.10, now Section 4.10, provides guidance to verb use.
- 7. NRC Recuest Because operators will use E0Ps in stressful conditions and under tine constraints, the procedures must be easily accessible to operators and sheuld be accurate and current at all times. The guidance provided in the PGP should address the following:
- a. The location of the flowcharts in the control room for easy and quick access by the operators.
LILCO Response Section 6.21 addresses the location and maintenance of flowcharts in the control room.
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6 7b. NRC Recuest The method by which the E0Ps are easily distinguishable from other i plant procedures.
LILCO Response Section 7.13 addresses Text EOP designation. Text E0Ps are bound in red plastic binders which separate them from other procedures bound in tan binders that are located in the control room procedure bookshelf.
- 8. NRC Recuest ,
To minimize confusioa, delay, and errors in execution of E0P steps, the following concerns should be addressed in the Writer's Guide:
- a. Action steps should be structured to be consistent with the roles and responsibilities of the operators.
LILCO Response "Step Sequencing", Section 4.2 addresses action step structuring with respect to operators rolos and responsibilities under Subsection e.
8b. NRC Reauest Action steps should be structured to enable the control room supervisor to follow staff actions and monitor plant status.
LILCO Resoonse Step Sequencing, Section 4.2 addresses action step structuring with respect to the control room Watch Supervisor and/or Watch Engineer.
- 9. NRC Recuest Section 1.4.2 of the Writer's Guide discusses the review and approval of the E0P flowcharts. This section should state who (by title) is authorized to review and approve the flowcharts. This information should also be indicated on the flowchart signature block.
LILCO Resoonse EOP Flow Charts are approved as an attachment to the corresponding Text EOP. The Text EOP signature heading is displayed on Figure 7- 1. The Flow Chart signature heading for all future Flow Charts will include the title of the Operating Engineer as the final approver of the Flow Chart.
- 10. NRC Recuest See'.4on 1.4.13 "Text Procedure Step Numbering Scheme" applies to text preparation and therefore should be moved from the flowchart section to the text preparation section of the Writer's Guide.
LILCO Response "Text Procedure Step Numbering Schemes" has been removed from the flowchart section of the Writer's Guide and now exists in Section 7.2 cnt'tled "Section/ Step Numbering".
- 11. NRC Recuest Section 1.7.5 discusses the emphasis and placement of cautions and the definition'an,d placement of notes, and states that notes should not contain instructions. However, there are other aspects of notes and cautions which need to be addressed,
- a. The Writer's Guide should provide a definition of cautions, state that they must be complete on a page and do not contain instructions.
LILCO Resconse Section 1.7.5, now Section 7.5, addresses cautions, provides a definition, and states relative requirements.
lib. NRC Reauest The Writer's Guide should describe how notes are emphasized (differently than cautions) and state that notes are complete on a page.
LILCO Response Section 7.6 addresses all requirements relative to notes within the text procedures.
11c..KRC Recuest Examples of notes and cautions which are consistent with the text shculd be provided.
LILCO Response Ewamples of cautions and notes that are consistent with the text are provided in Sections 7.5 and 7.6 respectively.
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11d. NRC Reauest The Writer's Guide states that cautions are placed adjacent to the step they refer to and notes should be placed as close as possible.
However, both notes and enutions should be placed directly above the step they refer to, so thuy can be read before the step is read.
L1LCO Response Both cautions and notes in the text procedures are identified by a box which is placed above the relative step on the text (right hand) page of the procedure. Each box contains the caution / note number that references the caution / note located on the backside of the proceeding page, or the left hand page. This format allows for the operators to read the procedure and reference the cautions and notes simultaneously, i g e, both are in front of the reader together.
Caution and note placements are adoressed in Sections 7.5 and 7.6 respectively.
- 12. NRC Reauest Logic statements are used in EOPs to describe a set of conditions or sequence of actions. Because of their importance and complexity, it is important to provide explicit guidance for their use. Section 1.7.4 of the Writer's Cuide addresses certain aspects of logic statements includir.g the use of the words IF, WHEN, THEN, IF NOT.
and AND; the use of a list format and the exclusion of AND and OR in the same action. Exemples are also provided. However, there are other aspects of logic statements which need to be addressed,
- a. The Uriter's Guide should discuss the use of AND and OR as logic terms versus conjunctions, and how logic terms are to be emphasized. See NUREG 0899, Section 5,6.10 and Appendix B for further guidance. .
LILCO Reseonse Section 4.5 discusses the use of AND and OR as logic terms versus conj unc tions . Section 1.7.4 is now Section 7.4 which discusses the
. uses of AND and OR for text procedures. Emphasis techniques for logic terms are also addressed in this section, as well as in Section 4.11.
i 12b. NRC Reauest I
The examples provided in Figure 1-13 are not consistent with the text. For example, the GOOD statements do not contain the word THEN and the logic terms used are not emphasized as they are in the text.
Examples of all types of logic statements, and those to avoid, i
should be provided in the Writer's Guide and they should he consistent with the guidance in the text.
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R LILCO hesoonse Figure 1 13 has been deleted from the Writer's Guide and replaced by specific examples for each type of logic statement. Each example is consistent with the text and is located in Section 7.4 after descriptions of the logic statement types.
- 13. NRC Recuest The Writer's Guide should state that vague verbs such as rapidly or slowly should be avoided, and should provide an inclusive list of verbs to be used in the EOPs.
LILCO Response Sections 4.3e and 4.10 of the Writer's Guide address the avoidance of vague verbs and.an inclusive lisc of recommended action verbs is
! provided in Appendix D. The terms rapidly and slowly are only stated when specifically used in the Emergency Procedure Guideline.
When used, thes5 terms are in.aa adverbial context with the specific action verb (for example, rapidly depressurize, slowly increase). For those procedure steps where these terms are located, the operator is trained to Lr.cw the quantitative ranges associated with each parameter within the step.
14 NRC Recuest During the execution of E0Ps it is often necessary to refer operators to other procedures or sections of procedures. Such referencing and branching can be disruptive and cause unnecessary-delays. To minimize disruptions and delays the Writer's Guide needs to address referencing and branching.
- a. The Writer's Guide should include a statement of commitment to minimize referencing and branching by providing criteria to be used when deciding if the steps should be included in the text or cross referenced.
LILCO Response Section 4.7b, "Referencing and Branching Guidelines", includes a committed statement to minimize referencing and branching and provides guideline, for determining step inclusion or cross-referenH ng.
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14b. NRC Raqun t The content and format of the reference / branch statement including step number, procedure /section title and number, and a consistent conventions such as CO 70 and REFER TO should be cpecified, i
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_LILCO Response Section 4.7c, "Referencing and Branching Format", specifies the content and format for reference / branch statements. This section addresses each of the following:
e Step Number o Procedure section/ title and number e Consistent convention specification LILCO does not use GO TO, but instead uses EXIT / ENTER for reference / branch conventions.
14c KRC Recuest ,
Examples of referencing and branching formats that are consistent with the text should be provided.
< LILCO Response Examples of referencing and branching formats consistent with the
. text are provided in Section 4.7c.
14d, NRC Recuest Some method such as tabbing for easily identifying sections or subsections in the E0P should be specified.
LILCO Response Tabbing is only used by LILCO for identifying specific procedures.
Each text procedure is tabbed for easy identification. Sections and subsections of procedures presently are distinguished by the numbering format within each procedure. In most cases, major sections or subsections of procedures that are performed concurrently with other sections / subsections within the same text
, procedure begin on new pages. Therefore adding tabs to procedural sections and subsections would cause confusion with already existing procedure identification tabs and is consequently not addressed in the Writer's Guide.
- 15. NRC Recuest The proper use of emphasis techniques makes the procedures easier to understand. The Writer's Guide needs to be revised to describe how
- various types of emphasis techniques such as cap!talization, boxes, etc., are to be used.
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LILCO Response Section 4.11 of the Writer's Guide, "Methods of Emphasis" describes the various types of emphasis techniques used.
- 16. NRC Reauest The Writer's Guide needs to include guidance for writing the various types of action steps that an operator may take to cope with differunt plant situations. The Writer's Guide should address the definition and format of the following types of action steps and should provide examples consistent with the text: verification steps, equally acceptable steps, recurrent steps, time dependent steps, concurrent steps, and diagnostic steps. See NUREG 0899, Section 5.7 for further information.
LILCO Reitan;f Section 4.4 of the Writer's Guide provides guidance for writing the various types of action steps. Definitions, formats, and examples consistent with the text are provided for the following types of action steps:
e Verification Steps Section 4.4b e Equally Acceptable Steps (Alternative Step) - Section 4.4e Section 4.4d e Recurrent Steps e Time-Dependent Steps - Section 4.4h e Concurrent Steps - Section 4.4f e Diagnostic (Decision) Steps Section 4.41
- 17. KRC Reauest Information should be presented so that interruption in the flow of information in an E0P is minimized.
- a. Action steps should be presented completely on one page.
LILCO Resoonse Section 7.3, Instruction Step Length and Content, part e, requires that action steps should be presented completely on one page.
17b. NRC Reauest Procedures and sections of a procedure should begin on a new page.
o LILCO Response Section 7.1 "Procedure Organization" identifies those procedure l sections and subsections that are required to begin on a new page.
17c. NRC Reauest A simple method for accessing attachments or appendices should be provided. Examples consistent with the text should be included.
LILCO Response Methodology for accessing attachments or appendices is provided in Section 7.11. No examples are provided since none currently exist that are consistent with text. This section was included for guidance to futur,e EOP revisions should attachments and/or appendices become necessary,
- 18. NRC Reauest It is important that a consistent method of section heading and step numbering be used throughout EOPs. The manner in which the text is organized and divided should be evident through the use of headings and a numbering system so that operators can keep track of )
where they are in the procedure and know how to move easily and quickly to other parts of the procedure. The Writer's Guide does provide a list of headings and state that a SNPS station procedure is used for section numbering, but it should also address the following:
- a. The methods of pagination should be specified. The total number of pages should be included in the pagination.
I LILCO Response ;
Methods of pagination are specified in Section 7.lg, "Page Identification", which includes requirements foi the total number of pages.
18b. NRC Reauest Step and section numbering, as applied to the dual column procedure format, should be specified. If an existing station procedure is referenced, a copy of the station procedure should be provided to the NRC.
LILCO Resnonse Stop and Section numbering are addressed in Section 7.2 which references procedure SP 12.006.01 "Station Procedures Preparation, l
9 Review, Approval, Change Review and Cancellation". A copy of this procedure is provided as an attachment to this submittal.
18e. NRC Recuesi Examples of the above topics, including section numbering, should be provided consistent with the text.
LILCO Response Exaaples of Step and Section Numbering can be found in Section 7.2, and a pagination example is provided in Figure 7 1.
- 19. NRC Recuest An inclusive list.of acronyms and abbreviations and their definitions should be provided in the Writer's Guide so that they are used consistently by both procedure preparers and operators.
LILCO Response Appendix E of the Writer's Guide provides an inclusive list of acronyms and abbreviations with definitions. This list is derived from procedure SP 11.011.01 "Standard Abbreviations."
- 20. NRC Recuest Figures and tables assist operators to make decisions and to locate information. Section 1.7.7 discusses the identification of figures and tables, but should also address their other aspects,
- a. The criteria for deciding when to use a figure or table should be provided.
LILCO Response Section 1.7.7, now Section 7.8, addresses the guidelines for determining when to use a figure or table and differentiates between what each type is used for.
20b. NRC Recuest The location of figures and tables within the E0P should be specified.
ILCO Response The location of figures and tables within the E0P are specified in Section 7.8d, "Figure and Table Location."
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- 21. EEG_Requegl It is important that the operators know where to find all of the instrumentation and controls that are referenced in the EOPs. Tha Writer's Guide should discuss the criteria for determining when the location of instruments and controls should be specified in the E0P, the format for this location information, and should provide an example consistent with the text.
LILCO Rescense Section 7.3 discusses various criteria applicable to specifying instrumentation and controls in the EOPs including location information. Additionally, an example consistent with the text is provided. In many steps within the EOPs, instrumentation and control location Js not referenced because there can be more than one method used to accomplish the same task. Each method used to accomplish a task could involve different instruments or controls (I6C) measuring the same parameters. Providing a list of all related I60 would be cumbersome and confusing to the operators and specifying particular I&C would be limiting for these circumstances.
- 22. NRC Recuest Consistent, well organized and well labeled E0Ps increase the ease with which operators understand and use the procedures. Section 1.7.1 of the Writer's Guide discusses procedure organization and lists the major section headings and general content of each.
However, the Writer's Guide should address the following:
- a. A cover page thould be used and the identiffing information on this page should be identified.
LILCO Response Section 7.la, originally Section 1.7.1, addresses identifying information on cover pages and provides an example consistent with the procedure in Figure 7-1, 22b. NRC Recuest
- b. The format of entry conditions should be specified. See NUREG-0899, Section 5.4 for further information.
LILCO Response l Section 7.1d of the Writer's Guide specifies the format of entry conditions. Section 2.0 of all symptom oriented text E0Ps contains a list of conditions under which each E0P is entered.
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- 23. NRC Reauest So that operators are always certain that they are using the correct procedure, the procedure should include identifying information in a consistent place on each page. The Writer's Guide should require that every page contain a block of information consistently placed on each page. This information should include a brief title or uniqus number, and revision number and/or date.
LILCO Resoonse All symptom oriented E0Ps shall have the procedure number, revision number and page number on each page. This is addressed with an example in Section 7.lg of the Writer's Guide.
24 NRC Reauest ,
The Writer's Guide should discuss the use of placekeeping aids (checkoffs) for all steps and substeps not just for steps with multiple objects as stated in paragraph 1.7.3e. Placekeeping aids can assist operators in keeping track of their positions within a procedure. These aids are of particular importance when performing steps or precedures concurrently, and in situations where the operator's attention is diverted.
LILCO Response Section 1.7.3, now Section 7.3 discusses the use of checkoffs (placekeeping aids) for all steps and substeps of the E0Ps.
Location of checkoffs is addressed and an example is given.
- 25. NRC Reauest The Writer's Guide should address the use of punctuation, capitaliz.ition, margins, line spacing, units of measure, numerals, tolerances, and how titles / nomenclature of instruments and controls are to be referred to. See NUREG 0899, Sections 5.5.7 and 5.6.3-5.6.8 for further information.
LILCO Response Various sections of the revised Writer's Guide addresses the specific concerns and guidelines addressed in NUREG-0899. Each area of concern and the related Writer's Guide section are listed below:
o Punctuation Section 5.4 o Capitalization, Section 5.5 e Margins, Section 7.10
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o Line Spacing, Section 7.10 o Units of Measure, Section 5.7 -
o Numerals, Section 5.7 e Tolerances, Section 5.6 e Titles / Nomenclature, Section 4.9
- 26. NRC Reggtal The PGP should address the issues of accessibility of procedures, their unique identification, and qual!'y of reproduction as the procedures must be easily accessible and readable to op.rators and should be uniquely. identified to distinguish them from other plant procedures.
LILCO Response Writer's Guide Section 7.13 addresses the issues of text procedure !
accessibility and identification. Section 7.12, Typing and !
Reproduction addresses reproduction quality so that procedures are easily readable to the operator. Section 6.21 addresses EOP i Flowchart location, and Sections 6.19 and 6.20 address readability guidelines for flowcharts.
- 27. NRC Recuest To minimize confusion, delay, and errors in the execution of E0P steps, the following issues shou!d be addressed by the Writer's Guide:
- a. Action steps should be structured so that they can be executed ,
by the minimum control room staffing required by the Technical L Specifications.
LILCO Resoonse Section 4.2, "Step Sequencing," provides guidelines to minimize confusion, delay, and errors in E0P step execution. Action step !
structure execution related to control room staffing is addressed in 4.2a.
- 27b. NRC Recuest .
Action steps should be structured to be consistent with the roles and responsibilities of operators, t !
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4 LILCO Resoonse Section 4.2e describes action step structuring requirements for operator roles and responsibilities.
J 27c. NRC Recuest Action steps should be structured to minimize the physical ['
interference of personnel in the control room (where technical guidelines permit). <
I LILCO Reseonse Sections 4.2b and c provide guidelines for action step structuring -
to minimize control room personnel physical interference.
27d. NRC Recuest i
Action steps should be structured to avoid unintentional '
duplication of tasks.
4 I LILCO Response Guidance for action step structuring to avoid unintentional task duplicatlon is found in Secticn 4.2d. i 27e. NRC Recuest .
I Action steps should be structured to enable the control room i supervisor to follow staff actions and monitor plant status. !
t' LILCO Reseense Section 4.2f describes step structure so that the Watch Supervisor
- and/or Watch Engineer can follow staff actions and monitor plant conditions.
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R C. Verification and Validation Program
- 1. NRC Request The verification and validation programs should specify that, at a minimum, plant operators, subject matter experts, procedure writers, and human factors experts will be involved in verification and validation. Although the PGP states that independent reviewers and operating crews will be used, the use of a wider variety of verifiers and validators will help to ensure that all aspects of E0Ps are completely and accurately verified and validated. The verification and validation program should also specify their roles and responsibilities.
LILC_0 Response The Shoreham Station Procedure SP 21.009.02, "Technical Review of New or Revised Symptom Oriented Emergency Operating Procedures", includes the requirements for the staffing of the verification and validation team. The team is to be made up of Operations section personnel (plant operators, E0P writers, and subject matter experts), Training / Simulator personnel and Human Factors personnel. The roles and responsibilities of each team member are as follows:
The plant operators will respond to the simulated accidents and transients both in the control room simulator or during tabletop reviews and slow paced walk and talk throughs. They will provide comments to the other validation team members on potential problems with the E0Ps.
The Operations E0P writers / subject matter experts will be familiar with the draft procedures and the design of the plant systems. They will be responsible to verify the E0Ps are are in accordance with the SNPS PSTG and to determine the success of the procedures in guiding the operators to the correct response.
Training / Simulator personnel will be primarily responsible for the running of the simulator. They will understand the capabilities of the software and hardware, and assist in the evaluation of the E0Ps success in mitigating accidents and transients.
The Human Factors Expert (HTE) will evaluate the E0Ps for adherence to the SNPS Writers Guide and for usability during the validation runs.
The HTE will determine whether the E0Ps are compatible with the minimum number, qualification, training and experience of the operating staff, as well as whether the Instrumentation and Controls (I&C) called out in the E0P are compatible with the 16C in the Control Room. This response is included in section 8.2 of SP 21.009.02.
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- 2. NRC Request The validation program should include the criteria for the selection of scenarios that will be used to exercise E0Ps. This criteria should ensure that the full set of E0Ps are validated to their fullest extent and should ensure that a wide variety of scenarios, including multiple (simultaneous and sequential) failures are included. The validation program should also contain a commitment to apply these criteria in developing scenarios for validation of E0P revisions.
LILCO Response
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-"-t sequences selected for validation will exercise the E0Ps to the fullest extent possible and will include multiple (simultaneous and sequential) failures that progress through the multiple paths of the E0Ps.
Significant revision to E0Ps (ie, revisions which alter: the sequence of operator actions,.the amount of required operator response, or clearly alter the original intent of the step.) will require revalidation and reverification. This response has been included in section 8.3 of SP 21.009.02.
- 3. NRC Request The validation program description states that the SNPS simulator will be used for the validation process. The description should state the method to be used to validate those parts of the E0Ps where the simulator does not react like the plant or cannot be run on the simulator.
LILCO Response In the event that the simulator is not capable of adequately modeling the Shoreham plant during certain portions of the validation scenarios, alttrrate muthods of valicetien as required by SP 21.009.02 (16, tablatop review, slow walk / talk through) will ensure the NUREG-0899 objectives are met.
- 4. NRC Request The PGP should specifically acdress the manner it which fcecback from th~e validation and verificatica process will be toed to address the accuracy, readability, completeness, and usability of the E0Ps. While a few of these points are noted on pages 9 and 10 of the validation plan, they should be specifically addressed in the verification and validation program descriptions.
L1LCO Response Feedback from the validation and verification process wi.11 be gathered by the validation team in the form of checklists and E0P Discrepancy Sheets. The team will ensure that any problems regarding the accuracy,
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-4 A r readability, completeness and usability discovered throughout the V6V process, are documented on an E0P discrepancy sheet.
Each E0P discrepancy sheet will be reviewed by the V6V team. The team will decide on the most appropriate solution for the discrepancy and if necessary will change the EOP in accordance with the E0P Writer's Guide. Significant revisions to the E0Ps (as defined previously) will require revalidation and verification to insure that a new discrepancy has not been created through the resolution of the first.
.The Operating Engineer shall assess the proposed resolution and determine whether or not revalidation is required. If satisfi 4 he will assign the originatur to incorporate the proposed resolution and execute the revalidation and verification as required. This response has been included in section 8'.3 of SP 21.009.02.
- 5. NRC Request The verification and* validation program should include the criteria or method that will be used to determine the need to reverify or revalidar.e any changes to the E0Ps, resulting from either verification and valication programs or from subsequent EOP revisions.
LILCO Response As stipulated in the response to NRC requests C.2, and C.4, significant revisions to the E0Ps resulting from either V6V Discrepancy resolutions or subsequent E0P revisions will undergo verification and validation.
The definition of "significant revisions" is a change which alters the sequence, or amount of required operator actf.on or clearly alters the intent of the original step (s). This response has been included in section 6.3 of SP 21.009.02.
- 6. NRC Request The E0Ps will require a certain number of operators to carry out the various activities and steps as specified. The validation program
. should clearly indicate that the EOPs will be exercised during simulator exercises or control room walk throughs with the minimum control room staff required by SNPS Technical Specifications.
LILCO Response The number of Operations personnel serving as the operating crew.
~during V&V walk throughs or simulator exercises, shall be limited to the Technical Specification minimum crew complement for Operational
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Condition 1, 2. or 3. This response has been included in section 6.2 of SP 21.009.02,
- 7. NRC Request Particular attention should be paid during the validation program to ueviations from and additions to the generic technical guidelines that
are of safety significance. These validation steps can be accomplished separately or as part of the validatian program. The PGP should discuss how the deviations from and add!~.lons to the generic guidelines are to be validated.
LILCO Response Deviations from and additions to the generic guidelines are validated in the same manner as steps which do not deviate from the EPG.
- 8. NRC Request The verification and validation program descriptions refer to the use of documentation such as checklists, discrepancy forts, completion forms, and validation documentation. These checklists, forms, records, etc., should be included in the PGP.
LILCO Response LILCO has included SP 21.009.02, Technical Review of new or revised Sytptom Oriented Emergency Operating Procedures, as an appendix to the PGP. This procedure contains the checklists, forms and records discussed in the PGP.
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D. Training Program ,
- 1. NRC Request ,
The PGP states that the FNPS simulator will be used for training. The E0P training program should address the followingt (a) Indicate the use of the simulator using SNPS technical i specification minimum control room staffing.
(b) Indicate the use of a wide variety of scenarios, including ;
multiple (stmultaneous and sequential) failures, to fully exercise '
(to the extent possible) the E0Ps on the simulator and thus expose '
the operators to a wide variety of E0P uses.
LILCO Response Training in use of.the E0Ps will be conducted for all licensed l operators on the Shoreham Control Room Simulator using multiple (simultaneous and sequential) failures. These scenarios will exercise
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l the E0Ps on a wide variety of E0P uses with operators in the simulator l performing their normal control room functions. The E0Ps will be t exercised using both 5 and 4 man crews. Tne normal shift complement j for SNPS is 5 licensed operators (one greater than the SNPS technical ;
specification minimum control room staffing). At times, a 4 man crew j will be used to exercise the E0Ps to ensure crews are familiar with their usage with only the minimum number of licensed operators per the Shoreham Nuclear Power Statien Te:hnical Specifications. This response 7 has been incorporated into a revision to the SNPS PGP. t i
- 2. NRC Request i The training program description should be expanded to include a I discussion of the method used to train operators in the areas where the cirulator does not react Itke the plant and in parts of the E0Ps that '
car not be run on the simulator. These areas would include differences between the simulator and the control room. ,
LILCO Response ,
The simulator is a full scope simulator which simulates the Shoreham l Nuc1 car Power Station transients as per the Shoreham USAR. Parts of the EOPs which can not be run on the simulator will be performed via ,
walkthroughs at Shoreham Nuclear Power Station. This response has been i incorporated into a revision to the SNPS PGP. i r
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- 3. . NRC Request l I
The training program should include a statement of commitment to train '
all operators on all E0Ps, including revised E0P1, prior to ,
implementing the E0Ps in the control room. ;
LILCO Response LILCO will train all operators on revised E0Ps prior to implementing the E0Ps in the control room. This training could take the form of l Night Order Reading for insignificant changes to E0Ps, or a complete f training effort for significant changes.
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Att:chment 2
The SNPS PGP consists of the followit- ations:
o Plant Specific Technical Guidelines e Writers Guide for E0Ps e E0P Verification & Validation Program o E0P Training Program F.-' section describes the approach which will be followed as part of the overall E0P Upgrade Plan required by Attachment 1 of the Shoreham Operating License.
This PGP has been developed in accordance with NUREG 0737. Supplement 1, Item 7.2b.
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_S110REHAll NUCLEAR POWER STATION Procedure Generation Package II. PLANT SPECIFIC TECilNICAL GUIDELINES The Plant Specific Technical Guidelines (PSTGs) will be developed by converting the B,iling Water Reactor Owners Group Emergency Procedure Guideline (BWROG EPG) into a Shoreham specific technical guidelines. The latest version of the BWROG EPG is currently Revision 4, which will be the source document for PSTG development. If subsequenc revisions are published by the BWROG at a later tims.
LILCO will evaluate the need to revise the PSTGs to the new document.
The methodology employed in converting the EPG to a Shoreham PSTG is as follows:
o Collect plant-specific source documents
- Shorehat Technical Specifications
- Shoreham Saf-ty Analysis Report
- As-built plant drawings
- Approved LiLCO Nuclear Engineering Departt.ent Calculations
- Shoreham Operating Procedures
- Other special studies deemed appropriate e Translate EPG steps to SNPS PSTG steps
- Delete systems / components not applicable to SNPS
- Add all plant specific parameters 2-b
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.. SHOREHAM NUCLEAR POWER STATION Procedure Generation Package e Justify all differences
- Include a short written justification for each deviation from the EPG e Include references from the source documents
- all plant specific parameters
- All justification for deviations The format illustrated in Figure 11-1 will be utilized for the PSTGs. The Guidelines will be maintained as a Quality Assurance document in accordance with Shoreham Station Procedure 21.009.01, "Preparation, Review, Approval and Control of Plant Specific Technical Guidelines". The current controlled version of the SNPS PSTG's are appended to this PGP.
The analysis of operator tasks, and the determination of information and control needs is described in the Detailed Control Room Design Review (DCRDR)
Implementation Plan. This plan has been submitted to the NRC under SNRC-1297, December 8, 1986.
The Shoreham PSTGs will be converted into Emergency Operating Procedures in accordance with the E0P Writer's Guide. Figure II-2 represents a simplified flow
-diagram showing how the BWROG EPG will be converted into the Shoreham E0Ps.
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, , SHOREHAM NUCLEAR POWER STATION Procedure Generation Package
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Si10RENAM NUCLEAR POWER STATION Flant specific Technical Guidelines Primary Containmer.t Control EPC Steps SP/T Honitor and control suppreeston pool temperature below [95'F (most limiting suppression pool temperature LCO)] using available suppression pool cooling.
When suppreselon pool temperature cannot be maintained below (93*F (most limiting suppression pool temperature LCO)l:
SP/T-l operate all available suppression root cooling lusing only those RHR pumps sot required to assure adequate core cooling by continuous operation in the LPCI model.
SP/T-2 Before suppression pool temperature reaches (the Boron Injection Initiation Temperature), (Figure N) enter [ procedure developed from the Rrv Control Guideline] at (Step RC-Il and execute it concurrently with this procedure.
SNr5 PSTG Stept SP/T Honitor and control suppression rool temperature belov 90*F using available suppression pool cooling. [f6)
When suppression pool tempereture cannot be maintained below 90'F.
SP/T-1 Operate all available suppression root conting using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LFCI mode.
SP/T-2 Before anppression pool temperature reaches the 110' F, enter ' I-procedure developed from the RPY Control Culdeline at Step RC-1 and execute it concurrently with this procedure.
Justification for Differences / References Most limiting suppression pool temperature LCO - Tech Spec Section 3.6.2.1 Boron injection Initiation Temperature - NED Appendiz C Calculation No. C-NFD-216 In order to simplify thf e procedure the most conservative C) ton Injection Initiation Temperature from the NED calculation was chosen. This eliminates the use of another j'}
graph while still maintaining the most conservative portion of it.
PSTG #3 Rev. I rage 5 Figure 11-1 4
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, , SHOREllAM NUCLEAR POWER STATION Procedure Generation Package III WRITER'S GUIDE FOR E0Ps The SNPS E0P kriter's Guide provides instruction on writing E0; ' good writing principles. The Writer's Guide promotes consistency & Ps independent of the number of E0? writers.
Information on the following topics is included in the SNPS E0P Writer's Guide:
e E0P Text Preparation
- Format
- Instruction Step Length and Content e Flowchart Preparation
- Logic Symbols
- Functional Flow and Branching
- Step Construction e Mechanics of Style
- Punctuation
- Abbreviations and Acronyms The Writers Guide is controlled as an appendix to Shoreham Station Procedure SP 21.009.02, Technical Review of New or Revised Symptom Oriented Emsrgency Operating Procedures. This procedure is appended to the PGP as Appendix 2.
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S110REllAM NUCLEAR POWER STATION Procedure Generation Package IV. E0P VERIFIC,ATION AND VALIDATION PROGRAM The'SNPS Stction Procedure SP 21.009.02, "Technical Review of New or Revised Symptom Oriented Emergency Operating Procedures" contains the specific procedural steps for performance of verification and validation of E0Ps. An abbreviated overview of the program is described below.
Verification E0P Verification will evaluate the written correctness and technical accuracy of the SNPS E0Ps. The verification process will also ensu.e that the human factors aspects presented in the Writer's Guide have been correctly applied.
The SNPS verification process will address the following specific objectives:
i e The E0Ps are technically correct, e The EOPs are written correctly, e The language and level of information presented in the E0Ps is compatible with the minimum number, qualification, training and experience of the operating staff, o There is a correspondence between the control room / plant hardware and the E0P.
e The E0Ps are usable.
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c Sil0REllAM NUCLEAR POWER STATION Procedure Generation Package The Verification plan is based on the guidance provided in NbREG 0899 and.INPO'83-004, "Emergency Operating Procedure Verification Guideline", and will utilize a combination of table top review and slow walk- and talk- through the procedures by independent reviewers and operating crews. The review will consist of the following reviews:
e ' Comparison of E0Ps with the requirements of the PSTGs.
o Comparison of the E0Ps with the requirements of the SNPS E0P Writer's Guide e Tabletop review of the E0Ps by SNPS Operations personnel to initially assess usability and compatibility e Comparison of control room Instrumentation and Controls (I&C) with the references to I&C made in the E0Ps The step-by-step comparison of the EOPs with the requirements of the SNPS PSTGs will ensure the completeness and technical accuracy of the E0Ps. Comparison of the E0Ps with the Writer's Guide will ensure written correctness and the incorporation of human factors engineering principles. The tabletop review by Operations personnel will identify _early any potential problems that control room crews might have in accepting and adapting to the upgraded E0Ps. The control room walkthrough of the E0Ps will check each reference to I6C in the E0Ps against j the control room labels displayed on the equipment. Additionally, units of measurement used in the procedures will be checked to ensure that they are
! consistent with those displayed on instruments.
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- . . ., SHOREHAM NUCLEAR POWER STATION Procedure Generation Package r
-The verification. process will be documented via checklists, discrepancy forms and' a completion recor'd, will' provide traceable history of the Verification effort.
Validation The SNPS E0P Validation Program will determine whether the actions specified in the E0Ps can be performed by trained operators to manage emergency conditions successfully. The validation process will evaluate the E0Ps against the following objectives:
e The E0Ps are usable: 1.e., they can be understood and fo]1 owed without confusion, delays and errors, o The presentation of language and level of information in the E0P is compatible with the minimum number, qualifications, training and experience of the operating staff.
e That there is a high level of assurance that the procedures will work: 1.e.,
the procedures guide the operator in mitigating transients and accidents.
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SHOREHAM NUCLEAR POWER STATION Procedure Generation Package The SNPS validation process is modeled after INPO 83-006, "Emergency Operating Procedures Validation Guidelines". It includes the four phases of preparation, assessment, resolution, and documentation. The preparation phase _will focus on the development of lists of expected operator actions and performance evaluation guidelines for the scenarios to be used in exercising the E0Ps. During the assessment phase, the scenarios will be run on the SNPS sirulator in real time and as a slow paced walk and talk through. The control room operating crew will use the E0Ps to restore-the plant to a safe condition. Based on a debriefing of the operators and an analysis of videotapes of the simulator runs, any procedure-related errors will te identified. The E0P discrepancies causing any errors will be listed, and resolutions will be developed during the resolution phase. Documentation produced during the process will be collected and organized during the documentation phase to provide a traceable history of the validation effort.
S110REllAM NUCLEAR POWER STATION Procedure Generation Package V6V Process Components NUREG-0899 V6V Objectives Verification Validation s.- Technically correct e Comparison of PSTG and E0Ps (TT)
- b. . Written correctly e Comparison of E0P Writer's Guide (TT) e Evaluation Criteria Checklist (IT)
- c. Compatible with mir.imum o Review by operating shift e Evaluation during number, qualification, complement in conjunction slow-paced walk-training and experience with tabletop review for throughs and real-of operating staff objective "d" (TT) time scenario exercises (WT & SIM)
- d. Usable o Review by operating e Evaluation during shift complement in slow-paced walk-evaluate readability, throughs and "real-completeness, accuracy, time" scenario and convenience (TT) exercises (WT & SIM)
- e. Correspondence exists e Comparison of control between procedures room instrumentation and control room / and controls (I6C) and plant hardware E0P references to 16C (WT)
- f. Guide operators in e Evaluation of "real-mitigating transients time" scenario and accidents exercises (SIM)
V6V Methods:
TT - Table Top - Individual or group evaluation WT - Walk-through - Step-by-step enactment of scenario operator actions without carrying out actual control functions SIM - Simulator - Control functions performed by operators in simulator Figure IV-1 Correlation between V6V objectives and Process
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. , Sil0REllAM NUCLEAR POWER STATION Procedure Generation Package V. E0P TRAINING PROGRAM A formal E0P training program will be developed to support implementation of the upgraded E0Ps. The E0P writer will interface with the Office of Training to ensure a supportive program. This description outlines the approach to be used to train licensed Shoreham operators on the upgraded E0Ps and to ensure the operators are informed and knowleigeable of any future changes to the E0Ps.
0perator Training on the E0Ps including revisions will be conducted prior to implementation in the main control room.
Training Program Goals The initial, overall training goal to E0P training program are as follows:
e to enable the operators to understand the structure of the E0Ps including the flowcharted version of the EOPs e -to enable the operators to understand the technical bases of the E0Ps a to enable the operators to have a working knowledge of the technical content of the E0Ps e to enable the operators to use the E0Ps under operational conditions In order to accomplish these goals, approved Office of Training procedures will be implemented to measure student performance and determine the need for remedial training. Pertinent Office of Training procedures are appended to this Procedure l Generation Package for completeness.
. , S110REllAM NUCLEAR POWER STATION Procedure Generation Package Initial Training'on Upgraded E0Ps The E0P training program will be established to instruct operators in the upgraded E0Ps.- It will consist of classroom instruction, simulator control room walk-throughs, and real time simulator exercises as follows:
o Classroom instruction sessions will be conducted. Included in the information to be precented during this section will be:
the logic behind the development of E0Ps
- the process used to deve op the E0Ps the E0Ps themselves, '.ncluding supporting technical and human-factors information e Simulator control room walk-throughs will be conducted. During this method of training, the team approach to using E0Ps will be stressed. This walk-through training will also concentrate on information flow and interactions of the operators in the control room, e Training on the E0Ps will be conducted for all licensed operators usin, j scenarios run on the Shoreham control room simulator. Training will be conducted with all operators performing their normal control room tuactions.
l This simulator training will utilize a wide variety of scenarios, including multiple (simultaneous and sequential) failures so as to exercise the E0Ps to their fullest extent possible. The training exercises will utilize both five s
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. . SHOREHAM NUCLEA3 POSER STATION Procedure Generation Package and four man operating crews. The normal shif t complems at fri the Shoreham control room is five licensed operators (one above the Tect.iical Specification minimum). In this way, the operaters will become familiar wi.'.h their roles for casualties when both normal and Technical Specification minimum crew members are available.
Additional training will be conducted whereby the members of a crew alternate responsibilities. This additional training is important to promote understanding of the other operators' responsibilities in the overall conduct of the actions leading to enhanced communications within the control room.
For those portions of the E0Ps which cannot be run on the SN'cS simulator, slow paced walk and talk throughs will be utilized to ensure the training goals are fulfilled.
Refresher Training All licensed operators will conduct control room walk-throughs and real time simulator exercises using the E0Ps during refresher training. The walk-throughs will be conducted on the Shoreham simulator.
Training on E0Ps will be conducted in such a manner that each crew conducts the l
walk-throughs with each operator simulating the actions that he normally would be responsible for during an emergency incident. Licensed operators not assigned to a shif t will participate in the walk-throughs as part of a control room crew.
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., .;,, SHOREHAM NUCLEAR-POWER STATION Procedure Generation Package The plant training and operations-staffs will participate in the development and execution of refresher training.- The training staff is responsible for developing the scenarios, observing and evaluating the walk-throughs, and critiquing the results. Any additional training needs will be determined from the performance of the operators.
The simulator-exercises will be varied sufficiently to ensure the operators do
.not develop a set patterc of response ct incidents but are able to respond to the symptoms as they develop.
Training on Revisions Training on minor procedure revisions will be conducted through a program of required readings (self-taught), preshift briefings, or lectures in the requalification program. Training on significant revisions will be conducted by the use of classroom instruction and walk-throughs in the control room or on the Shoreham simulator.
Inputs Into Training Program Changes Changes to supporting training material will be factored into updated lesson plans and student handouts. Operator feedback resulting from EOP verification, E0P validation, and training critique forms will be used to keep the training
. program and E0Ps current and relevant.
SHOREHAM NUCLEAR POUER STATION Procedure Generation Package Appendix 12.1 Plant Specific Technical Guidelines e
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