ML20086S716
| ML20086S716 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/01/1984 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20086S719 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 1030, NUDOCS 8403050107 | |
| Download: ML20086S716 (35) | |
Text
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TOLEDO
%s EDISON AcaAno P. CnOUSE Docket No. 50-346 u, %,,
ru.a License No. NPF-3 Serial No. 1030 March 1, 1984 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Eisenhut:
Toledo Edison submitted schedules for completing each of the basic require-ments of Supplement 1 to NUREG 0737, Requirements for Emergency Response Carability, within our letters dated April 15,1983 (Serial No. 933) and July 11, 1983 (Serial 968).
Attached is Toledo Edison's' submittal of the Procedures Generation Package, per the above mentioned schedule and your Confirmatory Order dated February 21, 1984 (Log No. 1456).
Very truly yours, RPC:JRL:SCW:lk:lrh Attachment cc: DB-1 NRC Resident Inspector
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8403050107 840301 FPDR ADOCK 05000346 l i\
PDR THE TOLEOO EOISON COMPANY EOISON PLAZA 300 MAOISON AVENUE TOLEOO, OHIO 43652
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1 PP0CEDURES GENERATION PACKAGE FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 TABLE OF CONTENTS TITLE PAGE 1.0 Introduction 1 2.0 Upgraded E0P Preparation 1 2.1 Reference Material 1 2.2 E0P Procedure Preparation 2 2.3 Procedure Review and Approval 3 3.0 Description of E0P Verification 3 4.0 Description of E0P Validation 4 5.0 Description of Operator Training on E0P's 5 APPENDIX 1: ATOG Procedural Guidelines, Part 1 and Part 2 APPENDIX 2: AD 1805.00, Procedure Preparation and Maintenance APPENDIX 3: Resume of Michael J. Derivan
1.0 INTRODUCTION
This package represents Toledo Edison's response to the NUREG 0737 Sepplement I requirement for the submittal of a Procedures Generation Package. The schedule for this submittal is in accordance with our April 15, 1983 response to NUREG 0737 Supplement 1 (Serial No. 933).
Toledo Edison plans to implement the upgraded Emergency Operating Procedures (EOPs) during the 1984 Refueling Outage, which is currently scheduled to begin in September. In order to accomplish this goal, operator training is scheduled to begin June 25, 1984. This submittal
-includes the following sections which describe the plan for the development and implementation of the upgraded E0Ps at Toledo Edison.
Section Title 2.0 Upgraded E0P Preparation 3.0 Description of E0P Verification 4.0 Description of E0P Validation 5.0 Description of Operator Training on E0Ps 2.0 UPGRADED E0P PREPARATION 2.1. Reference Material The development of the upgraded E0Ps was based on several reference documents which are described below. The most important of these was the Abnormal Transient Operator Guide-lines (ATOG).
Toledo Edison's ATOG (attached as Appendix 1) are plant specific guidelines prepared as a part of the same program that developed the Oconee Unit III ATOG. A Safety Evaluation Report (SER) has been issued by the NRC on the Oconee Unit III ATOC. Toledo Edison continues to work with the B&W Owners Group in resolution of comments on the SER.
Toledo Edison's ATOG consists of two parts. Part 1 provides the basic procedure including Davis-Besse plant specific information. Part 2 is explanatory text which provides support-ing information for Part 1. The structure of the E0Ps is based on Part 1 of the guidelines, while Part 2 was used primarily as reference material.
Other reference material used in the development of the E0Ps include the following:
- 1) the SER on the Oconee Unit III ATOG
- 2) input from continuing work by the B&W Owners Group on upgraded E0Ps
- 3) the Davis-Besse Updated Safety Analysis Report (USAR) o n
- 4) the existing Davis-Besse emergency procedures and system operating procedures
- 5) the Davis-Besse as-built drawings
- 6) the Davis-Besse Procedure Writers Guide (attached as Appendix 2) 2.2 E0P Procedure Preparation A key factor in the preparation of the Davis-Besse E0Ps was the selection of the procedure preparers. While other individuals helped with the development of supporting procedures and other selected activities, the primary responsibility for the prepara-tion of the procedures went to Mr. Michael Derivan (a brief resume for Mr. Derivan is enclosed as Appendix 3).
Mr. Derive' is exceptionally well qualified for the development of the Davis-Besse E0Ps. He has been directly involved in the development of AT0G and the resolution of the Oconee Unit III ATOG SER items as a member of the B&W Owners Group Operator Support Committee. He was involved in the development of the INPO Emergency Operating Procedure Writing Guidelines and prepared the Davis-Besse Emergency Procedures Writers Guide which was incorporated into a Station Administrative Procedure.
Together with his past operational and training background, this experience makes him uniquely qualified to write the Davis-Besse E0Ps.
Mr. Derivan is also participating on the Davis-Besse Control Room Design Review project team, and has been involved in the design and development of the Safety Parameter Display System.
This involvement helps maintain the proper integration of these activities.
To prepare the Davis-Besse E0Ps, Mr. Derivan started with Part 1 of the ATOG, supplemented by the various references listed in Section 2.1. As he wrote the procedure, he prepared an Emergency Procedures Bases Document identifying any signifi-cant deviations from the Part 1 guidelines. This report is a primary input to the E0P verification program.
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The format and style of the E0Ps were directly influenced by the Davis-Besse Procedure Writers Guide in order to incorporate good human factors criteria. The E0Ps incorporated NRC comments as provided in the Oconee Unit III ATOG SER whenever possible and appropriate. The existing Station emergency and system operating procedures were used to provide detailed information in support of the ATOG steps which provided a higher functional level of information. Where the ATOG identified new functional activities not previously described in existing procedures, the detailed information was developed using the appropriate technical information, such as the USAR and Station as-built drawings.
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D 2.3 Procedure Review and Approval The E0Ps will undergo the normal Davis-Besse review and approval process as required by Technical Specifications. This process will be significantly supplemented by the verification and validation programs for-the E0Ps. The verification and valida-tion activities are discussed further in Sections 3 and 4, respectively. Problems with the E0Ps identified during the verification and validation and operator training will be rectified by the normal procedure review and approval process.
3.0 DESCRIPTION
OF E0P VERIFICATION The primary purpose of the verification program is to evaluate the E0Ps to ensure compliance with the following objectives:
- 1. That the E0Ps are technically accurate by way of proper incorporation of Davis-Besse specific Abnormal Transient Operating Guidelines (ATOG) and plant-specific information from other E0P source documents.
- 2. That the E0Ps are written correctly by way of following the guidelines set forth in the Davis-Besse Procedure Writers Guide.
In order to accomplish the first objective, an independent review of the E0Ps will be undertaken to compare the E0Ps with the ATOG. The review will assess whether the entry conditions or symptoms used for directing when to use the E0Ps are correct; the action steps, cautions, notes, and detailed information are consistent with E0P source documents; and, the quantitative information provided in the E0Ps are accurate and traceable to E0P source documents.
In addition to the above mentioned reviews, a separate Toledo Edison review will be performed and documented by Engineering personnel familiar with the concepts of ATOG. ihis review will use the Emergency Procedures Bases Dccument as a primary input in comparing the E0Ps to the ATOG.
Additional technical review, not specifically ATOG based, will be conducted as a part of the normal procedure review and approval process. A special Station Review Board meeting will be conducted specifically for the review of the E0Ps. This review will evaluate the procedures based on the members' plant experience and knowledge of basic ATOG philosophical concepts.
Consistency between the E0Ps and the Procedure Writers Guide and the appropriateness of the level of detail in the procedures will be evaluated as a part of the special Station Review Board meeting.
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4.0 DESCRIPTION
OF EOP VALIDATION The purpose of the validation program is to evaluate the E0Ps to ensure compliance with the following objectives:
- 1. That the language, level of information presented in the E0Ps, and operator decisions and tasks specified in the E0Ps are consistent with the qualification, training, and experience of the operators to allow for correct and timely response to plant emergency conditions.
- 2. That the E0Ps are written and logically arranged so that they can be readily underatond and successfully implemented in the Control Room without confusion, delay, or errors.
- 3. That there is a high level of assurance that the operator tasks and plant response, as specified in the E0Ps, will guide operators in successfully mitigating transients and accidents.
- 4. That there is compatibility between the E0Ps and the Control Room / plant hardware so that controls, equipment, indications, and annunciators referenced in the procedures are available in the plant (inside and outside of the Control Room), have the same designation, use the same units of measurement, and operate as specified in the procedures.
- 5. - That the operator tasks required by the E0Ps are within the capability of the minimum Control Room staff.
In order to assess compliance with the first three objectives, a simulator validation exercise will be performed. The use of the E0Ps to respond to key plant transients will Le evaluated by a shift of licensed operators and other observers at the B&W Simulator in Lynchburg, Virginla. While the B&W Simulator layout is not the same as the Davis-besse Control Room, the operators are very familiar with the simulator and are aware of the differences. Their knowledge of the simulator will allow them to use simulator controls and instrumenta-tion, while using a Davis-Besse specific procedure. Since the simulator does closely model the transient response of Davis-Besse, the operators and observers will be abic to validate that the E0Ps can be understood, logically followed, then implemented successfully.
In addition, it will establish that the plant responds as specified in the E0Ps, that there is a high level of assurance that the E0Ps will work, and that the level of information contained in the E0Ps are consistent with the qualification, training, and experience of the operators.
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The specific applicability of the E0Ps to the Control Room and the adequacy of the shif t manning level will be validated by procedure walk-thrus on a Control Room mockup, and if necessary, in the Control Room. During these walk-thrus, an independent verification of the plant hardware outside of the Control Room / Control Room mockup as specified in the E0Ps will be made. The procedure walk-thrus will be performed in two parts. The first walk-thrus will be performed as part of the Control Room Design Review Validation Program which uses the E0Ps as a primary program input. A second check of the procedure usability in the Control Room will be provided during operator walk-thrus on the Control Room mockup as a part of their training activities. Although this activity is not considered an essential portion of procedure validation, the operator walk-thrus will neverthe-less provide an excellent feedback from the operators and an additional check of the procedures.
5.0 DESCRIPTION
OF OPERATOR TRAINING ON E0Ps The objectives of the initial operator training program for the E0Ps are as follows:
- 1) to assure that the operators understand the structure, scope, and content of the E0Ps
- 2) to assure that the operators understand the technical bases of the E0Ps and are aware of the process used to develop them
- 3) to enable the operators to use the E0Ps under various simulated emergency conditions To satisfy these objectives, the operator training will be conducted in two parts. The first of these will consist of a one week classroom presentation on the ATOG structure and i.echnical bases. The presenta-tion will include, where appropriate, walk-thrus on the Davis-Besse Control Room mockup. Part 2 of the ATOG will be a primary input to this training.
The second part of the operator training will consist of a one week course at the B&W Simulator in Lynchburg. Thia training will allow the operator to use the E0Ps in a broad range of simulated emergencies.
This training will significantly enhance his understanding of the E0P structure and use.
a aA. .n=m be ~s 4
APPENDIX 1 o
ATOG PROCEDURAL GUIDELINES PART 1 AND PART 2 (3 BINDERS ATTACHED)
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APPENDIX.2 AD 1805.00, PROCEDURE PREPARATION AND MAINTENANCE
- SECTIONS 4, 9, AND APPENDIX A
- (THIS REPRESENTS THE DAVIS-BESSE PROCEDURE K'RITERS GUIDE) o <
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o AD 1805.00.23 1
- 4. GENERAL FORMAT 4.1 The content of procedures will vary depending on the type of procedure and the specific case. General formats are found in Enclosures 2 through 13, 22, and 24 of this procedure; however, they may need to be modified to meet a specific case. Section Heads are responsible for ensuring that the specific procedure meets established guidelines, such as found in Step 3.1.
Emergency and Abnormal Procedures should follow the guidelines given in Appendix A, Emergency and Abnormal Procedures Writers Guide.
For non-routine and non-repetitive procedures (i.e.,
procedures to be used once to perform a specific joo, such as by vendor) need not follow the general formats provided.
4.2 Each procedure will have a title page (Enclosure 1). The title page identifies the type of procedure and the title of the procedure. It also provides a record of the procedure's preparation, approvals, and revisions.
4.3 Procedure numbers are in accordance with the Test and Procedure Index numbering system. The identification for each procedure will consist of two letters, followed by a four digit number, a decimal point, a two digit number, a decimal point, and the revision number, SP 1104.05.3.
Non-routine and non-repetitive procedures (used once to perform a specific job) may use the MWO number as the procedure number.
The identification number will appear on the upper right hand corner of each page. Note that the revision number only applies to that particular page, thus different pages in the same procedure may have different revision numbers.
The revision number is left off the title page since its revision is indicated in the record of revisions section.
4.4 The sections of a procedure are to be identified with only numeric characters. Major sections will be numbered sequentially from 1. If the major section has subsections requiring labels, they will be numbered from 1 following the major section number and a decimal point (e.g. ,1.1 or 6.15). Further subsections should be numbered in like manner, from 1, following another decimal point (e.g.,
2.4.7 or 5.11.16) . No more than two (2) decimal points should be used (3 numbers). It is not necessary to number all sentences, paragraphs, items or a list, etc. If numbers must be assigned further subdivisions, use 1, 2, 3, . . .as necessa ry. If the numbering of a step is not important, the use of a bullet (*) prior to the step rather than a number is permissible.
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4.5 Number the pages of the procedure in consecutive order beginning with the page containing the first numbered section (e.g. , Purpose, Symptoms, Objective) . The number should be placed at the top center of the page as it would appear in a notebook (i.e., the number should be in the same place even if the information on the.page is rotated as in a graph or figure.
On the last page of each procedure, the word END will be typed and underlined at the bottom to indicate the procedure is. complete.
t 4.6 Any portion of an approved procedure that is incomplete, l .
i.e., contains (later), shall be listed by the number of the section or subsection containing the (later) on the page immediately following the title page. The responsible Section Head, during subsequent revisions, will update or remove the later sheet. Those affected portions of a procedure containing (laters) will not be implemented until the (laters) are removed.
4.7 Append any materials which are neither included in the body of the procedure _nor immediately available in the Control Room, but which are essential to carrying out the procedure. Appended materials are to be called " enclosures"
" attachments", tables", " appendix", etc., and are to be located at the end of the procedure. Arrange appended materials in numerical order.
4.8 Additional guidelines for procedure content and style are provided in Section 9, Standards for Procedure Writing.
All procedures must-meet the content requirements of ANSI N18.7 and ANSI N45.2.
4.9 Technical Specification items will-be so noted in parentheses within the body of the procedure.
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- 9. STANDARDS FOR PROCEDURE WRITING l This section provides guidelines useful in developing and j
refining procedures. The guidance is based on good human factors principles and is useful in reducing confusion in the use of procedures. The use of this guidance is most important in developing and revising procedures for those activities most adversely affected by confusing procedures. For example, Emergency Procedures which may be used under potentially stress-ful conditions, would benefit more from this guidance than an Administrative Procedure, which may be read slowly and carefully.
The Section Head is responsible for determining the extent which these guidelines are incorporated into the development or revision of a given procedure. ihe use of these guidelines should be considered in the development of all new procedures.
Incorporation of these guidelines into existing procedures should be considered at the time of the procedure's periodic review.
9.1 Written Procedure Stepr Steps in procedures should not be presented in a paragraph form consisting of several action statements along with explanations, descriptions, notes, cautions, and conditional information associated with the actions. The result is often a complex grouping of information that must be unraveled by the user before it is understandable.
Reading speed and comprehension of written instructions are improved and the probability of error is reduced if instructions are presented in well structured, short, concise sentences or fragments. Write short and concise instructions with a clear meaning.
9.1.1 Sequencing Technical necessity, plant layout, and/or instru-ment arrangement should be considered in sequenc-ing tasks and action steps. In general, the following guidelines apply.
- Write action steps in the crder in which they are to be performed or verified to have occurred.
- Consider Control Room and/or plant layout when sequencing steps. If sequence is not important, order steps so that a left-to-right or right-to-left flow can be followed along the control board or a logical path followed through the plant.
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- ' Procedure steps should normally be followed in the numbered sequence provided. If sequence is not important, it should clearly indicate that sequence is not important in some other manner.
9.1.2 Conditional Statements In some instances, the performance of an action depends upon the presence of several conditions or combinations of conditions. Describing them together can result in confusing, complex sentences.
The instructions should be simplified by listing the conditions and by proper use of logic words IF, AND, OR, THEN, NOT, IF NOT, and WHEN. Use of capitalization and underlining of the logic terms is an effective aethod of emphasis which is helpful to the user in recognizing the contingency action.
The conditional statements should appear first, before the action statements. If, instead, an action instruction precedes the description cf the condition (s), there is an increased probability that the user will perform the action without noting the qualifying condition (s).
9.1.3 Nonsequential or Recurrent Steps Some operator actions may be required during performance of a task, but not at a specific point in the sequence of steps. For example, some steps may be performed when a certain temperature or level is reached, but not before.
Some operator actions may need to be repeated at various - inte rvals. If the intervals are easily specified (for example, following specified steps), repeat the step at each point at which it is to be performed. If the intervals are not specific, describe conditions which require repeating the step.
Locate nonsequential or recurrent steps at the first possible point at which they may be required.
Write nonsequential or recurrent steps so that the operator clearly understands when the action is to be performed.
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~For example:
When tank level reaches 62 inches, close
. isolation valve.
Or:
Monitor every five minutes until temperature stabilizes.
9.1.4 Time-Dependent Steps
.Some operator actions are required at specified time intervals, or.sometime after an action has taken place. In writing time-dependent steps, specify the time intervals as precisely as possible.
Give the operator information about the time.
r interval involved and the action to be taken.
For example:
After five minutes, reinitiate boration.
. 9.1.5' Equally Preferable Steps Where any one of several alternatives is acceptable, describe the action to be.taken, listing the alternatives below.
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t For example:
- 4 Close one of.the following valves:
- Isolacion)
Or:
9.2.2 Fill the RC by aligning valves as follows, depending on the Bleed Holdup Tank to be used.
- For Bleed Holdup Tank 3B:
L Open 3CS-56 (Bleed Transfer Pump 3B Discharge)
AD 1805.00.23 6'
- For Bleed Holdup Tank 3A:
Open 3CS-46 (Bleed Transfer Pump
- 3A Discharge) 9.1.6 Sentence Structure Sentence structure affects the rate at which a sentence is read and understood. The following i guidelines will-aid in developing sentences which are quickly read and easily understood.
- Use short sentences. More than 20 words is too long; approximately 10 words is preferred.
- Write action steps as simple command statements.
, Use the structure which follows:
ACTION VERB OBJECT
- OBJECT MODIFIER For example:
Verify _ Reactor Trip:
- All rod bottom lights lit
- Neutron flux decreasing
- Use the same sentence style for main steps as well as substeps.
- Write instructional or procedural steps as imperative statements; i.e., as direct command ~ statements. (Passive statements may be used for emphasis in precautions, cautions, or notes. See below.)
For example:
This - Open Valve AB.
Not this - Valve AB is opened.
- Write instructional or procedural steps as positive statements. Generally, positively I- stated sentences are more readily: comprehended.
For example:
This - Cover container when not in !
use.
Not this - Do not leave container uncovered when not in use.
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- Use only one main thought per sentence. Do not combine unrelated actions or thoughts into a compound sentence. However, a compound sentence which combines related actions or thoughts is acceptable.
For example:
Direct C&HP to take a chemical sample AND verify that Tech Specs are not
- i. violated.
- Rewrite complex sentences with three or more coordinate clauses as several shorter, simpler sentences.
For example:
This - Open AB Valve.
Increase tank pressure to 1500 PSIG.
Close XY Header Valve.
Not this - Open AB Valve, increase tank pressure to 1500 PSIG, AND close XY Header Valve.
- For instructional or procedural steps, use the understood "you" as the subject of each sentence. When a step is written, such as
" check steam generator levels," the understood subject-is the Control Room operator reading the procedure.
Where actions stated in the procedure are to be performed by someone other than the procedure user, ideutify the performer of the action.
i For example:
Direct C&HP to take a chemical sample.
- When the verb, or action, has three or more objects, list them separately.
For example:
Close the following block valves:
- 3RC-169 (Loop 3A Hi Point Vent Block)
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- 3RC-19 (Loop A High Point Vent)
- 3RC-138 (Loop 3B Hi Point Vent Block)
- 3RC-38 (Loop B High Point Vent) 9.2 Cautions and Notes 9.2.1 Caution statements should be used to alert an operator to conditions that could result in a safety hazard, equipment damage, or loss of an important system function. They should not be used just to provide added information.
9.2.2 Note statements are included to provide informa-tion to the operator concerning specific steps or specific sequences of steps. Notes generally should contain information which is of use in interpreting step information or making a decision.
9.2.3 Caution statements and notes should be located in the procedure in the order which the information i:s needed. If the user needs the information l
prior to performing the step, the caution should be placed ahead of the applicable step. This should insure the information is taken into consideration prior to performing the step.
9.2.4 Caution and note statements should be emphasized by the word CAUTION and NOTE typed in all capital letters and underlined, 9.2.5 If a caution or note applies to only one step, include the step number. For example:
CAUTION 2.3 If a caution or note applies to more than one step, do not' include step numbers.
9.2.6 Caution and note statements should be as brief as possible while still including essential informa-tion.
9.2.7 Do not write required action ~ steps in caution or note statements. If an action is always required, write-a step not a caution or note. Conditional action steps may be included, however.
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For example:
CAUTION 5.1 If HPI flow cannot be verified, symptoms should be monitored fcr inadequate core cooling.
9.2.8 Caution statements should be placed entirely on one page with the applicable step. Notes may run over to the following page if necessary.
9.2.9 Do not use methods of emphasis within cautions.
For example, do not capitalize and underline the words "if", "then", "not", etc. Do capitalize procedure titles, and capitalize the first letter of each word in specific nomenclature, system names, etc.
9.3 Document References Referring within and between procedures should be kept to a minimum. .It is better to reproduce small sections than to reference them.
-9.3.1 Use "go to" when the reader will discontinue use of the first procedure and stay in the r'eferenced procedure.
9.3.2 Use " refer to" when the reader will be returning to the first procedure.
9.3.3 -If possible, identify the specific place of entry at least by section number into the document referenced.
.For example:
Go to SP 1104.05, Containment Spray System, Section 4.
9.3.4 When_possible, arrange "go to" steps so that the user moves forward in the same procedure or exits the procedure altogether.
9.4 Vocabulary The vocabulary used in procedures should be easily read and understood by Control Room operators.
9.4.1 Use short, commonly found words. Common words of not more than two syllables are preferred.
However, this does not apply to industry terms, which are' commonly used or technical words which are required to define or clarify the subject.
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AD 1805.00.23 10 9.4.2- Use specific.words that precisely describe the task or action of the operator. Avoid ambiguous
- instructions such as " check frequently" or " throttle slowly". Where possible, use specific intervals '
or guidelines. ;
9.4.3 Do not use contractions such as " don't" or "can't".
Instead, use "do not" or "cannot".
9.4.4 Avoid the use of synonyms. Always use the identical word or . term- for a given subject or action. The following items should be standard usage.
- For power driven rotating equipment (pumps, fans, compressors, etc.), use START - STOP -
LOCK 0UT.
- For valves, use OPEN - CLOSE - THROTTLE OPEN
- THROTTLE CLOSE - THROTTLE - 3 way valves require the use of SHIFT.
- For power distribution breakers, use SYNCHRONIZE
- CLOSE - TRIP.
- For system level instructions when it is necessary to manually activate an automatic '
system or where pump and valve operation is
[ required, use the following terms. -
- TRIP, RESET T
Used for systems such as RPS or SFRCS,
! i.e., trip the reactor, trip SFRCS, ,
reset the SFRCS.
ACTUATE, SHUTDOWN-Used as in actuate HPI and means to open the valves and start the pumps.
J Used as in actuate AFW or shutdown AFW and means valve and pump operation is e
required.
- ISOLATE, RETURN...TO SERVICE Used as in isolate letdown, return letdown to service.
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- The use of shall, will, should, and may are as follows:
- SHALL - Mandatory requirement;
- WILL - Mandatory requirement;
- SHOULD - Non-mandatory, preferred, or desired method;
- MAY - Acceptable or suggested method.
9.5 Identification of Equipment, Controls, and Indicators Use nomenclature that will assist the operator in accurately and quickly identifying equipment, controls, and indicators.
Equipment should be identified in operator language (common usage) terms. These terms may not always match engraved names on panels or the valve's formal name in the valve book.
NOTE: Formal equipment names such as those found in the valve book or on engraved labels should normally match common usage terminology. Following the effort to re-label Control Room indicators and controls most of this' inconsistency should dis-appear;Lsome such discrepancies will always exist, however.
. 9.5.1 The preferred sequence will be equipment name, equipment number, switch number (if needed), and location (if needed).
For example:
Start CCW Pump 1-1 using local switch NP0431 in the CCW pump room.
9.5.2 Reference to indicators will use the same sequence except the switch number is not' applicable.
9.5.3 Switch number and location information should only be given if it.is actually needed, i.e., a disconnect switch on an Auxiliary Building panel. If the step is to be~ performed outside the Control Room, the location information may more likely be needed.
9.5.4 References to annunciator alarms will use the exact form as engraved on the annunciator window.
9.6: . Abbreviations, Acronyms, and Symbols Only those abbreviations, acronyms, or symbols which are unambiguously recognized by operators should be used.
Generally, avoid abbreviating words, phrases, or names unless the system or component is frequently and commonly
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'12 referred:to by an abbreviated form. If an undefined abbreviation is used, it must be identified the first time it is-used.
NOTE: Following the effort to re-label Control Room indications and controls, an updated list of abbreviations and acronyms will exist which will be consistent with common usage. Use of abbrevia-tions or acronyms should then be consistent with that list.
9.7 Plant Instrumentation Values 9.7.1 Use the units of measurement which actually appear on the instruments specified.
9.7.2 Use units of measurement familiar to the operator.
9.7.3 . Instrumentation values should be provided with a tolerance or limit band using the same units of measurement as those displayed on the instrument and compatible with the operator's ability to read _
the instrumeut.
For example:
Use this - Maintain RCS pressure between 2100 and 2200 PSIG Not this - Maintain RCS pressure at 2155 PSIG t 50 PSIG.
9.7.4 Graphs supplied with procedures should be compatible with the instructions in the procedure. The units and increments on the graph should be the same as the units and increments of the instruments read in using the graph. The graph should also be constructed and usable to the precision required by the procedure.
9.8 Capitalization'and Underlining Capitalization and underlining may be used for emphasis or attention. Use them as described below. Avoid their use in situations other'than those described.
9.8.1 Write the following items in all capital letters:
- Procedure titles (on the procedure title page)
- Annunciator nomenclature
AD 1805.00.23 L- 13
- Other words or phrases which are uniquely significant in determining or classifying operator actions (not necessary).
9.8.2 Capitalize and underline the following only if necessary to assure clear meanin;;
- THEN
- AND 2R
- UNLESS
- Any negative such as NOT, NEITHER, or NOR
- NOTE (always when making a note statement)
- CAUTION (always when making a caution statement)
- END (always when indicating the end of a.
procedure) 9.8.3 All letters of words in the heading of a section are in capital letters, and the entire heading is to be underlined (e.g., 2. TEST EQUIPMENT).
9.8.4 The first letter of each word in the heading of a subsection is to be capitalized (e.g., 2.1 Portable Voltmeter).
9.8.5 The names of specitic components or systems should be capitalized (e.g., Reactor Coolant Pump 1-1 or the Reactor Coolant System). When using general terms, the component names need not be capitalized (e.g., the reactor coolant pumps).
9.9 Punctuation Generally, standard American English rules for grammar and punctuation should be used. Avoid the use of punctuation and sentence structure leading to long, complex sentences.
9.10 Reproduction / Typing 9.10.1 When procedures are typed, there should be a one inch margin all around the page.
AD 1805.00.23 14
, 9.10.2 Avoid ending a page in the middle of a ster or l -substep whenever possible. Caution statements
!' should always be on the.same page as their associa-ted step.
9.10.3' Procedures such as Administrative Procedures or others where the logging of data is not involved
( should be printed on both sides of the paper +.o conserve paper and file space.
m AD 1805.00.23 15 EMERGENCY AND ABNORMAL PROCEDURE WRITERS GUIDE While all procedures can benefit by the Emergency and Abnormal
-Procedures by their nature, they require special attention. More than any other procedures, Emergency Procedures and Abnormal Procedures are likely to'be used in stressful situations. Consequently, attention to human. factors considerations during the preparation of these procedures is very important. This appendix provides additional information and emphasis on those human factors considerations deemed most important in preparation of Emergency and Abnormal Procedures.
The guidelines within this appendix should be used whenever possible, but strict adherence to these principles is neither required nor desired, since good procedure design is a matter of considerable compromise.
- 1. PROCEDURE TITLE The procedure title should be short and descriptive enough to
. permit the operator to easily identify the procedure and the emergency or abnormal condition for which the procedure is applicable. The procedure' title should also include the entry conditions (or scope) of the procedure if possible.
GOOD EXAMPLES: Rx-Turbine Trip Load Rejection BAD EXAMPLES: Station Blackout (this procedure actually covers a loss of normal AC power)
Turbine Plant Cooling Water System Emergency Operation of NSS Component Cooling Water Failure
- 2. SYMPTOMS The symptoms should-be unique to the emergency or abnormal condition described by the title while still allowing for the
' fact that vtveral conditions may share some-common symptoms.
Only the major symptoms directly related to the required procedure entry conditions should be listed. All the secondary systems related to the plant response should not be listed. If the
_ procedure entry conditions were not clearly defined by the procedure title they should be clearly defined in the symptoms section.
- Entry conditions may include alarms, indications, automatic actions, etc. Lor'a statement identifying the entry conditions (e.g., loss of instrument air entry conditions can be identified
~
by stating under the symptoms section. Loss of instrument air is defined as a confirmed reading of 75 psig on Control Room instrument air header pressure indicator PI 810.
Appendix A Page 1 of 10
AD 1805.00.23 16
- 3. AUTOMATIC ACTIONS The aut'omatic actions should be unique to the emergency or abnormal condition described by the title while still allowing for the fact that for a given procedure they may be multiple.
Only the major automatic actions should be listed, not the subsets of the major items. (e.g., If turbine trip is listed as an auto action it is not necessary to list the starting of all the various oil pumps associated with the turbine trip.)
- 4. FORMAT AND LEVEL OF DETAIL Emergency and abnormal procedures directing steps that must be accomplished in a timely manner may be the standard single column procedure format if the level of detail required for the steps does not result in long sentences or paragraphs. If a single column format is used the procedure should not be the type where the operator is actually reading more information than performing steps. Abnormal procedures for unusual circum-stances with steps that are meant to be supplemental guidance rather than timely action steps may be better suited to single column even if the steps are long. In this type procedure, the user should read all the guidance, and putting it in a two column format might lead to some information not being read.
Emergency and abnormal procedures may also be a two column format. This format can solve several of the problems associa-
' ted with writing procedures where a high degree of detail may have to be available for lesser experienced operators, for very infrequent operations, or for training, but is not required by the largest group of intended users most of the time (ie.
trained and experienced operators).
In a two column format, the left hand column will briefly state the objective to be accomplished or "what" to do. This credits a trained operator with having the knowledge of "where," "how,"
and "why" most of the time. This column should contain little, if any "where," "how,"_ and "why" information and no NOTE statements.
All CAUTION statements should appear in this column.
The right hand column is then used to expand the objective in the left column and can contain any explanitory information that may be required by the broad spectrum of users or readers. All NOTE statements should be in the right column. CAUTION statements may be in this column.
For example, if the left hand column step says to verify AFW is actuated, the corresponding right hand column step can give the information on checking pump discharge pressure, flow, valve positions, SG 1evels etc. This should allow most operators to proceed through the procedure smoothly accomplishing the objec-tives without being slowed by reading information they already know, but the information will be available if they have tempor-arily forgotten a detail. See example 3, 5.
Appendix A Page 2 of 10
~'
AD 1805.00.23 17
-5. . WRITTEN PROCEDURE STEPS Write short and concise instructions with a clear meaning.
Action steps in emergency and abnormal procedures should not be presented in a paragraph form consisting of several action statements along with explanations, descriptions, notes, cautions and conditional information associated with the actions. The result is often a complex grouping of information that must be unraveled by the operator before it is understandable. Reading speed and comprehension of written instructions are improved and the probability of error is reduced if instructions are presented in well structured, short, concise sentences or fragments.
Ordinarily, a step should contain a single action verb. The more actions a step contains, the more likely it is that an action will be overlooked. Generally if there are three or more objects of an action verb they should be listed rather than imbedded in a sentence.
Using this method the. steps for even a very complex evolution can be written as a series of short concise' sentences or sentence fragments. . This should allow the operator to readily move through the procedure accomplishing the objectives and should minimize the probability of omitted actions because too many were imbedded in a single paragraph. See example 3, 5.
Additional guidance on sentence structure and content is available in Section 9.1 of this procedure.
- 6. CONSISTENCY OF TERMIN0 LOGY It is important that consistency of terminology be maintained throughout all emergency and' abnormal procedures so the operator does not have the burden of interpretating the meaning of the words along with performing the procedure steps. Specific instructions on the use of consistent terminology is provided in Section 9.4
- 7. IDENTIFICATION OF EQUIPMENT, CONTROLS, AND INDICATORS Use nomenclature that will assist the operator in accurately and quickly identifying equipment, controls, and indicators.
Equipment should be identified in operator language (common usage) terms. These terms may not always match engraved names on panels or.the valves formal name in the valve book.
For action steps the method of presenting the required identifying information~ depends on the procedure format, whether single or two column type and on where the step is performed, either inside or outside the control room.
Appendix A Page 3 of 10
6-AD 1805.00.23 18 T
The preferred sequence will be equipment name, equipment number, switch number (if needed), and location (if needed).
For example:
Start'CCW pump 1-1 using local switch NPO431 in the CCW pump room.
Reference to indicators will use the same sequence except the
~
. switch number is not applicable.
Switch number and location information should only be given if it is actually needed, ie. a disconnect switch on an aux building panel. Switch number and location should not be given for control room operated equipment except in the right hand column of a two column format. If the step is to be performed outside the control room the location information may more likely be needed.
References to annunciator alarms will use the exact form as ,
engraved on the annunciator window. See example 3, 5.
- 8. CHECK 0FF PROVISIONS Special checkoff provisions are not required in emergency and abnormal procedures. An operator who feels the need to checkoff his place can always mark the margin or x-over step numbers as he goes.
- 9. STEP NUMBERING, IDENTIFICATION AND SEQUENCING All action and instructional steps should be numbered so as to be readily identifiable by the operator and also to maintain proper sequencing of~the steps. A numbering system should be maintained that shows the proper subordinate level of steps without the indentation causing loss of too much writing space.
This is especially important when using the two column format
~
.which inherently limits the indentation that can be accomodated.
All steps will always be done in the numbered sequence unless clearly identified otherwise in the procedure. See example-3.
- 10. CAUTIONS AND NOTES
.The proper use of cautions and notes is especially important in emergency and abnormal procedures. Proper guidance for their use is provided in Section 9.2. See examples 5, 3. ,
J h:
Appendix A Page 4 of 10 '
- E AD 1805.00.23 19
- 11. CONDITIONAL STATEMENTS Use a consistant format for presenting conditional instructions ensuring that the action statement follows the conditional statement.
Emergency and abnormal procedures require that many decisions be made based on symptoms and indications. These contingency or conditional decisions must be written into the procedure to clearly. identify to the user the conditions that must be satisfied prior to.taking the required operator action. This information can be presented most clearly when the opening statements containing the conditional symptoms use the logic words IF, AND, OR, M , IF NOT, and WHEN.
The conditional statements should appear first, before the
- action statements. If, instead, an action instruction precedes the description of the condition (s), there is an increased
. probability that the operator will perform the action without noting the qualifying condition (s).
f
[ In some instances, the performance of an action depends upon the l presence of several' conditions or combinations of conditions.
l
-Describing them together can result in confusing, complex sentences. The instructions should be simplified by listing the conditions and by proper use of logic words IF, AND, OR, THEN, j' - NOT, IF NOT, and WHEN.
Use of capitalization and underlining of the logic terms is an
(- effective method of emphasis'which is helpful to the user in recognizing the contingency action. See example 1, 2, 3, 5.
- 12. PLANT INSTRUMENTATION VALUES.
Instrumentation values should be provided with a tolerance or limit. band using the same units of measurement as those displayed on the instrument and compatible with the operator's ability to read the instrument.
Emergency conditlons can distort an operators ability to distin-guish " slow" from " fast," "large change" from "small change," or perform mental arithmetic to calculate tolerance bands. In a single column procedure format giving guidance such as " maintain
' sufficient," " insure adequate" or " maintain greater than" requires the operator to mentally establish limits himself at one or.both ends of these open ended statements. A two column format will~ allow use of these terms in the left hand column with the tolerance band given in the right hand column.
Tolerance bands and instrument values should always be stated as a conservative value with a precision of one half the distance between instrument markings. See example 1, 2, 3.
Appendix A Page 5 of 10
AD 1805.00.23 20
- 13. COMPUTER DRIVEN OPERATOR AIDS Computer driven operator aids have many capabilities which can aid the operator in emergency situations. They also have the capability of displaying information with much greater precision than the normal control room instruments. Emergency procedures may make use of computer operator aids but the instrument values used in the procedure should be based on the precision of the normal control room instrumentation. This should insure the operator will be able to use the emergency procedure if the computer driven operator aid is lost.
EXAMPLE 1
, Maintain RCS pressure at 2155 PSIG i 50 PSIG by taking manual-control of the pressurizer heaters at the Auxiliary Shutdown.
Panel, if necessary.
In this example the operator must perform mental arithmetic to get l the desired pressure band. Also the ability to read the extra 5 PSIG on the wide range pressure indicator at the Auxiliary Shutdown Panel is doubtful.
The step also contains a conditional statement where the action statement preceeds the conditional information. When presented in this order there is increased likelyhood the action will be performed without reading the conditional information. The step could be rewritten as follows.
Maintain RCS pressure from 2100 PSIG to 2200 PSIG. If necessary, take manual control of the pressurizer heaters at the Auxiliary Shutdown Panel.
EXAMPLE 2 Trip the reactor when OTSG startup range level drops to 25.6 inches and carry out Reactor / Turbine Trip Emergency Procedure, EP 1202.04.
In this example the action statement preceeds the contingency statement and the instrumentation value is not readable on the control room indicator to the tolerance value given. The step could be rewritten as follows:
If OTSG Startup Range Level drops to 26 inches, then trip the reactor and carry out Rcsctor/ Turbine Trip, EP 1202.04.
Appendix A Page 6 of 10
~
AD 1805.00.23 21 EXAMPLE 3
- 3. IMMEDIATE OPERATOR ACTIONS 3.1 ~ Shut RC Letdown Coolers Inlet Isolation Valves, MU 2B.
3.2 Shut MU Flow Control Valve, MU32.
3.3 Shut RCP Total Seal Flow Control Valve, MU19.
3.4 Do NOT change power level.
- 4. SUPPLEMENTARY ACTIONS NOTE: Check Emergency Plan Activation, EI 1300.01, to determine if Emergency Action Levels have been exceeded.
41 Loss of Makeup Pump 4.1.1 Start the standby MU pump if MU tank level is greater than 10 inches'or if MU3971, MU pump suction valve, is aligned to the BWST.
4.1.2 Open MU Flow Control Valve, MU32, to increase pressurizer level >160" (preferably 200").
4.1.3 When pressurizer level returns to >160 inches (preferably 200") place Pressurizer Level Control-1er LIC RC14, H/A selector station in "AUT0" and open Letdown Coolers Inlet Isolation Valve, MU2B.
4.1.4 Reestablish RCP seal flow by opening RCP Total Seal Flow Control Valve,IEJ19. Open MU19 slowly to prevent a pressure shock to the pump seals.
Once proper seal flow has been established, return the Total Seal flow Control Valve, MU19.
H/A Selector Station to "AUT0".
4.1.5 If the standby pump does not start, shut down the plant and provide makeup as per Section 4.6.
4.1.6 In Modes 5 and 6: As a minimum, one makeup pump in the ' Boron Injection Flowpath required OPERABLE pursuant to specification 3.1.2.1 shall be-OPERABLE and capable of being powered from an OPERABLE essential bus.
4.1.7 In Modes 1 - 4: At least two makeup pumps shall be operable.
Appendix A Page 7 of 10
AD 1805.00.23 22 This example contains several problem steps:
- The immediate operator actions could be simplified if common usage-terms were used instead of more formal control board nameplate type identifiers. Also the term " shut" is not consistant with "close" which is used in mot.t other
- emergency procedures.
- Step 4.1.1.contains an action step stated prior to its contingency.
- In Step 4.1.2 and 4.1.3 the desired pressurizer level is given with an open ended tolerance and the actual level the operator is supposed to maintain is not clear.
- Step 4.1.4 uses the non-specific instruction " slowly" which doesn't have the same meaning to all operators.
- -
- Steps 4.1.6 and 4.1.7 are not action steps at all and should either be rewritten as action steps or moved to the 1 discussion section.
- Use .of the two column format can improve several of these problem areas.
- 3. IMMEDIATE OPERATOR ACTIONS 3.1 Isolate letdown with MU2B.
3.2 Isolate makeup with MU32.
3.3 Isolate seal injection with MU19.
3.4 Do not change power level.
- 4. SUPPLEMENTARY ACTIONS
]
-NOTE: Check Emergency Plan Activation, EI 1300.01, to-
- determine if Emergency Plan Action Levels have been
~
exceeded.
ACTIONS DETAILS
- 4.1 Loss of Hakeup Pump 4.1.1 4.1.1 If MU' pump suction source is ade- Adequate MU pump suction is avail-quate, able
- with MU3971 aligned to the MU Then; start the standby MU pump. Tank,& MU Tank Level greater than If not go to Step 4.6. 10 inches. OR with MU3971 aligned to the BWST.
a Appendix A Page 8 of 10
L .
AD 1805.00.23 23 4.1.2 Return the following systems to service.
- 1. Seal injection 4.1.2.1 CAUTION: Increase total seal injection flow XXXXXX...... in 8 to 10 gpm increments over a 2 min time period and then return MU19 to AUTO.
ACTIONS DETAILS
- 2. Makeup 4.1.2.2 Adjust makeup flow as necessary to return pressurizer level to 200" and then return MU32 to AUTO.
Do not increase makeup flow in steps large enough to starve the seal injection header.
- 3. Letdown 4.1.2.3 When pressurizer level control is restored, return letdown to service by opening MU2B.
4.1.3 NOTE:
XXXXXX......
Consult Tech Specs on MU Pump and Boron Injection Flowpath operability.
EXAMPLE 4 4.11 Verify Breakers HX11A, HX11B, HX01A, HX01B, HX02A, HX02B are OPEN.
In this example six action items have been presented in a line fo rmat. This format increases the potential of overlooking a step.
Also the standard terminology for the breaker position should be tripped.
4.11 Verify the following breakers are TRIPPED.
HX11A .HX11B HX01A FX01B HX02A HX02B Appendix A Page 9 of 10
e AD 1805.00.23 24 EXAMPLE 5 1.4.8 When " Reactor Coolant Average Temperature (as per TR-RC7 or TI-RC7 on the Control Room "ICS and Reactor Control" panel C-5707) stabilizes and begins to approach approximately 550'F and control of pressurizer 1cvel has been recovered, set the pressurizer level setpoint at the present pressurizer level using "PRZR LEVEL" LIC-RC14. Normally, this will be somehwere between 100" - 200". Also, if desired, return the letdown to service and shift uakeup pump suction back to makeup tank. The second makeup pump should be off by this time.
CAUTION: Two makeup pump operation for over 1/2 hoi could damage the seal return cooler. If for any reason the second makeup pump is still desired after 1/2 hour, place the second seal return cooler in se rvice.
In this example four action items based on three contingencies are presented in paragraph form. Location information is also presented for indication and controls, which a trained operator would not normally need. This all leads to a very lengthy step.
The CAUTION statement also has some problems. First it is poorly placed in the procedure. Since the second MU Pump is shutdown based on plant response, the time limit could be exceeded before the caution is read. The caution should be placed in the procedure at the point the second MU Pump is started to insure the operator sees the caution prior to the time limit being exceeded.
The second problem with the caution statement is it directs an operator action. 7 is increases the probability the action step will be overlooked.
Procedures that require this depth of detail should be written in a two column format. The multiple contingency statemen'. could be rewritten using logic terms into a format more easily read as follows:
1.4.8 WilEN both of the following conditions are indicated:
- 1. Tave within the post trip range of 550 to 555*F.
- 2. Control of pressurizer level has been recovered.
THEN perform the following steps:
- 1. Set pressurizer level setpoint at present pressurizer 1_ vel.
- 2. Return letdown to service.
- 3. Shift MU pump suction back to MU tank.
- 4. Stop the second MU pump.
Appendix A END Page 10 of 10
gg ,, .
e O
APPENDIX 3 RESUME OF MIC11AEL J. DERIVAN b
' IE '
s o
Michael J. Derivan Mr. Derivan has over 17 years of experience in the naval and commercial nuclear industry with extensive experience in plant operations and train-ing. He presently holds and maintains a Senior Reactor Operator License on Toledo Edison's Davis-Besse Unit One.
Mr. Derivan's previous assignments have included positions as Operator Instructor at a U.S. naval nuclear training facility, Shift Foreman, Operations Supervisor, Licensed Operator Requalification Instructor, and Nuclear Operations Training Supervisor. His present position of Operations Technical Coordinator includes responsib111ty for writing the upgraded emergency operating procedures from the B&W Abnormal Transient Operating Guidelines (tTOG).
He is presently and has previously been associated with the B&W Owners Group Operator Support Committee. INPO Emergency Operating Procedures Implementation Assistance (EOPIA) Review Group, and Florida Power Corpora-tion Nucleat Safety Task Force for Crystal River Unit Three.
_