ML20213A036

Rev 1 to Davis Besse Emergency Procedure Verification & Validation Program

ML20213A036
Person / Time
Site:	Davis Besse
Issue date:	03/31/1987
From:	TOLEDO EDISON CO.
To:
Shared Package
ML20212R417	List: ML20212R414 ML20213A031 ML20213A036
References
PROC-870331-01, NUDOCS 8704270355
Download: ML20213A036 (42)

Text

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s. . , ,

a RESPONSE TO NRC DRAFT SAFETY EVALUATION REPORT-CONCERNING THE PROCEDURE.

GENERATION PACKAGE FOR DAVIS-BESSE NUCLEAR POWER' STATION' UNI! 1 ENCLOSURE 2-Davis-Besse Emergency Procedure Verification and Validation. Program Revision 0 March 1987 N

8704270355 870420 PDR ADOCK 05000346

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i-TABLE OF CONTENTS f 1Page>

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-1.0 - INTRODUCTION. . . . . . . . .. . . . .. .. . . . . . . .. 1-1.1 - Purpose. . . . . . . -. . . . . . . . . . . . . . . .. . I 1.2 . Scope. . . . . . . . . . . . . . . . . . . . . . . ... -1 1.3- Definitions. . . . . . . . . . . . . . . . . . . . . .. 1 i 2.0 TECHNICAL VERIFICATION. . . .. . . . . . . . . ... . . . . 3 2.1 Objective. . . . . . . . . . . . . . . . . . . . . . . . 3 t

2.2 Applicability. . . . . . . . . . . . . . . . . . . . . . 3~

, H2.3 Method . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.4 Personnel Needs. . . . . . . . . . . . . . . . . . . . . 4 2.5 Facilities Materials . . . . . . . . . . . . . . . . . . 5 t'

2.6 Specific Instructions for Performing Technical Verification . . . . . . . . . . . . . . . . . 5 3.0 EDITORIAL' VERIFICATION. . . . . . . . . . . . . .. . . . . . 7 3.1 Obj ective. . . . . . . . . . . . . . . . . . . . . . . . 7 3.2 Applicability. . . . . . . . . . . . . . . . . . . . . . .7 3.3 Method . . . . . . . . . . . . . . . . . . . . . . . . . 7 6

3.4 Personnel Needs. . . . . . . . . . . . . . . . . . . . . 7 3.5 Facilities / Materials . . . . . . . . . . . . . . . . . . 8 4 3.6 Specific Instructions for Performing.

Editorial Verification . . . . . . . . . . . .: . . . . . 9' 4.0 VALIDATION. . . . . . . . . . . . . . . . .... . . . . . . . 10 .

4.1 Objective. . . . . .. . . . . . . . . . . . . . . . . . 10-4.2 Applicability. . . . . . . . . . . . . . . . . . . . . . 10'

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. TABLE OF' CONTENTS (Continued)

Page 4.3 Meth'od . . . . . . . . . . . . . . . . . . . . . . . . . 10-4.4 -Selection of Validation'Hethod . . . . . . . . . . . . . 11 4.5' Specification of Scenarios . . . . . . . . . . . . . . . 12 4.6 -Personnel Needs. .................... 13 4; 7' Facilities / Materials . . . . . . . . . . . . . . . . . . 16 4.8 Specific Instructions for Performing

. Simulator Validation . . . . . . . . . . . . . .. .. . 16 4.9 Specific Instiuctions for Performing Walk - Through Validation. . . . . . . . . . . . . .. . 18 5.0 ASSESSMENT AND RESOLUTION . . . . . . . . . . . . . . . . . . 20 5.1 Objectives . ...................... 20 t

5.2 Applicability. ..................... '20 5.3 Personnel Needs. . . . . . . . . . . . . . . . . . . .. 20-5.4 Materials. . ..... . . . . . . . . . . . . . . . . . 21 5.5 Method . ... ....... . . . . . . . . . . . . .. 21 ATTACHMENT 1: TECHNICAL VERIFICATION CHECKLIST. . . . . . . . .. 22 ATTACHMENT 2: EDITORIAL VERIFICATION CHECKLIST. . . . . . . . . . 28 ATTACHMENT 3: GUIDELINES FOR EP VALIDATION OBSERVATIONS'. . . . . ' 32-ATTACHMENT 4: VALIDATION CHECKLIST. . . . . . . . . . . . . . . . 34-ATTACHMENT 5: VALIDATION COMMENT FORM . . . . . . . . . . . . . . 37 ATTACHMENT 6: SCENARIO DEVELOPMENT SHEET. . . . . . . . . . . . . 39

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. 1.0:~1NTRODUCTION

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1 - 1.1 cPurpose:

This document describes the program that will be,used to imple -

- . ment, revisions of_EP 1202.01,- RPS, SEAS,;SFRCS-. Trip or SG Tube

. Rupture'(EP). ;This program'is modeled after the guidelines for

.w . emergency; operating' procedure verification-and validation- -

[ developed under the sponsorship offthe Institute of Nuclear

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Power Operations:(INPO 83-004,_ March 1983;;and INPO 83-006,.

,. . July 1983). It is consistent with the Nuclear Regulatory _

Commission's guidance for emergency operating procedure prepara-

- tion contained'in NUREG-0899 (August 1982).

1.2 Scope.

-The Emergency Proce' dure Revision Verification &' Validation (EP V&V) Program addresses the following activities

• Technical-Verification (Section'2.0)-

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• Editorial Verification (Section 3.0)

• Validation (Section 4.0)

• Assessment and Resolution (Section 5.0)

'Each activity is defined in terms of objective,~ applicability, method, personnel needs, facilities / materials, and specific--

instructions for performing the activity. This program will be

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applied to the EP.

1.3 Definitions i'

1. ATOG - B&W generated Abnormal Transient Operating j Guidelines.

l- 2. Davis-Besse ATOG (DB ATOG)-- B&W generated documentation of

the method for responding to transients, accidents'and' restoring safety functions. It-is based on-consideration of the Oconee Unit 3 ATOG; plant-specific ~ equipment charac-teristics; operating and safety limits.

3. EP Basis Document - Toledo Edison' generated documentation.

It provides the procedure writer with necessary background

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information.and justification for each step or revision to each step in the EP. The EP Basis Document will be main--

n- tained to reflect the latest revision of EP 1202.01.

i 4. Emergency Procedure (EP) - Davis-Besse Emergency Procedure, l EP 1202.01, RPS, SFAS,-SFRCS TRIP-or SG-TUBE RUPTURE. The.

EP directs operator actions necessary to mitigate the.

consequences of transients and accidents.

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.  :. 5 . .EP Source Documents - Documents or records upon which the EP is based.

6. Technical Verification - A review of thEPe that. verifies proper incorporation of. generic and/or plant-specific technical information from EP source documents and plant hardware.

7. EP Validation - The evaluation performed to determine if the actions specified in the EP can be followed by trained operators to manage the emergency conditions in the plant.

- 8.  ; Editorial. Verification - The-evaluation performed to

, confirm the written correctness of the EP. This review verifies.the proper incorporation of Writer's Guide requirements.  :;

9. Symptom - A plant characteristic that directly or indirect-ly indicates plant status.

10. Technical Basis Document (TBD) - This is.the B&W Owners Group Emergency Operating Procedures-Technical Basis Document (Doc. No. 74-1152414). This documentation.identi-fies the technical basis; the equipment or systems to be operated and the operator actions necessary to mitigate the-consequences of transients and accidents and to restore safety functions as they apply to B&W Nuclear Steam Supply Systems.

11. Writer's Guide - A set of. guidelines concerning written presentation of the EP. 'It is designed-to ensure.that the EP can be read and understood easily, rapidly and precise--

ly. The Writer's Guide contains specifications for the organizational structure of procedures, writing style, use of terminology, and other matters that affect the legibili-ty and intelligibility of procedures. At Davis-Besse, the-phrase " Writer's Guide" refers-to the Davis-Besse Procedure Writer's Manual: Volume IV, Operatians Procedures Guidelines.

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2.0 TECHNICAL VERIFICATION

.2.1- Objective The objective of technical verification'is to ensure that the Emergency Procedure-(EP) accurately reflects the: Emergency

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Operating Procedures Technical Basis Document (B&W Doc.

No. 74-1152414); EP. Basis Document;'DB ATOG;fand other source'

. documents. Technical. verification will include:

• Verification of.the: correctness, completeness.and compli '

ance of the. revised plant-specific information' merged with

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the Technical Basis Document'(TBD).

• Verification of the correctness, completeness'and compli-ance of the resultant EP revision with the plant-specific.

technical guidelines'(DB ATOG) and the EP Basis Document.

• Verification'of the compliance of the EP revision with.

applicable operating,' system and administrative procedures.

Technical verification will also address the' objective of ensuring.that the level of'information~and detail provided in the EP is consistent with.the qualifications, training, and experience of the operating staff. -(This objective'will also be addressed-in other activities of the EP V&V Program.)

2.2 Applicability The Technical verification activity will be performed on'all revisions of the EP before approval for use.

When a step, section,.or attachment to the EP is revised, technical verification steps will be performed to ensure:

(a) That the revision is correct from a technical standpoint; (b) That procedure revisions reflect technical source-dat'a; ,

(c) That the EP Basis Document is maintained up-to-date; and r (d) That all procedure revisions are written using the Writer's Guide.

2.3 Method Technical verification is a " tabletop analysis" activity. It '!

will be done by. comparing the EP to the TBD, DB-ATOG, EP Basis Document and to data from other sources such as the Updated Sefety Analysis Report (USAR).

A checklist'will be used to ensure that key points of comparison-are covered consistently. Discrepancies.will'be documented,:

assessed and resolved as described in Section 5.0.

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4 R v. 0 2.4 Pe'rsonnel Needs-The following personnel will participate in the technical verification of the EP. Minimum qualifications and responsibil ~

ities.for members of the Technical Evaluation Team are listed for each personnel. category identified below.

1. V&V Coordinator a'. Qualifications:

Experience as a Senior Reactor Operator and/or

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currently in the SRO-license training program at .

Davis-Besse.

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Thorough knowledge of the EP and associated documentation Thorough knowledge of Davis-Besse plant systems-Authority to schedule technical verification activities and assign duties to personnel.

b. Responsibilities:

Determine secpe of verification Schedule activities, facilities and personnel Ensure that copies of EP, reference documents and materials are available Conduct pre-verification briefings, as necessary, to explain the overall purpose of the EP .V&V Program and the specific activity of technical verification Coordinate and participate in technical verifica-tion activities Ensure that documentation of activities is properly completed.

2. Technical Evaluators (Minimum of 2, in addition to the V&V Coordinator. .They will be personnel who did not participate in writing the procedure.)

a. Qualifications:

One will have experience as a Senior Reactor Operator and/or currently in the SRO license training program at Davis-Besse.

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One will have. experience as a Reactor Operator

and/or currently in the RO license training' program ~ a t ' Davis-Besse.

b. Responsibilities:

Perform technical' verification using the EP V&V Program Perform other duties related to' technical verifi-cation as directed by V&V Coordinator.

2.5 Facilities / Materials

• Work room with table space to accommodate the participants and a place to store reference documents and other materials

• A copy of the TBD

• A copy of the latest EP, including previous revisions as required

• A copy of the EP Basis Document

• A copy of the DB ATOG

• Access to EP source documents j

• Copies of the Technical Verification Checklist, Attachment 1.

2.6 Specific Instructions for Performing Technical Verification

1. V&V Brief participants on the following:

Coordinator

a. Purpose and scope of overall EP V&V Program

b. Participants and their roles

c. Steps of technical verification

d. Use of the Technical Verification Checklist.

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2. Technical. _ Conduct Technical Verification.'

-Evaluation p '

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a. 'For each ::evision lof the'EP, perfona a comparison'of.the TBD, DB-ATOG, and EP.

Basis Document with the revised EP,~

using the Technica1LVerification'

y. Checklist.s This will be done in group sessions.

One evaluator will'be assigned to complete the. Technical Verification Checklist (Attachment 1). _Each partic-

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-ipant shallLcomplete a Document Review

' Form (ED 6864/ED 6864A).

b. Verify the accuracy of the- revised plant specificLinformation in the EP.by comparison to source data.

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- 3. V&V Review' Technical Verification Checklist-

'Coordihetor items for assessment and resolution or designt activity.

s. Review all checklist responses.

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b '. .nsure all Document Review Forms are.

cc.' ole te .

4. V&V AssembleChe'e(listsandDo'umentReviewc a Coordinator' Forms for documentation file and for assess-

{ ment and resolution of V&V comments.

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I 7 Rsv. 0 3.0 ' EDITORIAL VERIFICATION 3.1.' Objective The' objective of editorial verification is to ensure.that~

revisions fto the Emergency Procedure _ (EP) are written using- the.

~ Davis-Besse Procedure Writers Manual, Volume IV,10 perations-

Procedures Guidelines (Writer's Guide). This activity..will_en-

-sure that the-EP is written consistently, clearly and succinctly.

Content, style and format specifications will be reviewed.

Editorial verification will also check that the.EP is written in a vocabulary familiar to the-operators.

3.2 Applicability The editorial verification activity will be performed on EP revisions before approval for use.

When a step, subsection or attachment to the EPLis revised, F

editorial verification steps will be performed to ensure all-procedure revisions are written using the Writer's Guide and are typographically correct.

3.3 Method Editorial verification is a " tabletop" activity. . Revisions to the EP will be reviewed to ensure compliance with the Writers'

, Guide.

Attachment 2, Editorial Verification Checklist, will be used to

perform the Editorial Verification.'_Any discrepancies found during the review will be documented on a Document Review Form

, (ED 6864/ED 6864A) for assessment and resolution described in Section 5.0.

3 . '+ Personnel Needs

The qualifications and responsibilities of the. personnel re-( quired to conduct the editorial verification are listed below

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l 1. V&V Coordinator

a. Qualifications: ,

Experience as a Senior Reactor Operator _and/or currently in SR0 license training program at Davis-Besse.

Thorough knowledge of the Writer's_ Guide, and the EP.

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Authority to schedule editorial verification.

- activities and assign duties to personnel.

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b. Responsibilities Schedule activities, facilities, and personnel Ensure that copies of the EP, reference documents and materials, Writer's Guide and checklists are

.available Coordinate and supervise editorial verification activities Ensure that all documentation of activities is properly completed.

2. Editorial Evaluator (s) (minimum of 1)

Will be a person (s) who did not participate in writing the.

EP revision.

a. Qualifications:

Is a Qualified Reviewer in accordance with AD 1805.04, Qualified Reviewer Program,

b. Responsibilities Perform the verification of written correctness and completing the required checklist.

Prepare written comments to identify and explain any deviations from the Writer's Guide, or other information presentation problems areas, found in the EP.

Through the V&V Coordinator, resolve any ques-tions about written correctness that may require input from operations personnel.

3.5 Facilities / Materials

• Work room with table space to accommodate the participants and a place to store reference documents and' materials

• A copy of the proposed revision of the EP and the Writer's Guide

• Copy of the Editorial Verification Checklist.

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9 REv. 0 3.6 Specific Instructions for Performing Editorial Verification

1. Editorial Complete Checklist and Evaluator document comments:

a. For the EP, complete an Editorial Verification Checklist.(Attachment 2).

Identify any section or step

.that does not conform to criteria in the Checklist on a Document Review Form.

2. V&V Coordinator Review Checklist and comments:

a. Ensure the Editorial Verifi-cation Checklist is properly completed including name of evaluator and procedure revision number.

b. Review completed checklist to ensure all items were re-viewed and that locations of .

discrepancies.in the EP are identified.

c. Assemble all Checklists for documentation and later assessment and resolution of comments.

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10- 'Rav. 0 4.0 Validation 4.1' Objective

-The. objective of validation is to ensure that the actions specified in the EP can be followed by trained operators to manage emergency' conditions in the plant. Validation addresses the operational usability of the EP and compatibility _with plant responses, hardware, and shift staffing.

4.2 Applicability The' validation activity will be-performed on the revised EP prior to approval for'use. The revised EP must be validated.

when:

• The revision arises from a plant equipment change.(hardware or_ software) that alters the_ functions ,or response charac-teristics of a system or subsystem, or alters interrela-tionships between systems or subsystems.

• The revision arises from a change in a SafetyLSystem Initiation or Logic that alters the' functions or response-characteristics of a system or subsystem, or alters inter-relationships between systems or subsystems.

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• The revision arises from a change in plant equipment that could affect radioactive release control or that raises an-environmental question not previously addressed.

• The revision alters cues for operator actions or the expected results of operator actions.

• The revision alters the sequence of operator actions.

Validation should be preceded by Technical and Editorial Verification. Validation is not required for minor editorial revisions to the EP as this is covered by Technical and Editorial Verification activities.

4.3 Methods Methods of validation include:

1. Simulator -- Control Room personnel perform the procedure on a simulator for an observer team. This will be done for.

the EP insofar as the emergency conditions addressed by the EP can be simulated.

2. Walk-Through -- Control Rota personnel perform a step-by-step enactment of-the EP for an observer team, without actually executing control actions. This will be done if required-for those sections of the EP: that cannot be adequately _

simulated; when revisions are made to a limited portion of the EP; or when revisions to the EP need to be compared to actual Control Room equipment or environment.

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For Simulator or Walk-Through Validation, . scenarios willinormal-ly be prepared. LA scenario is a structural plan'of parameter and plant symptom: changes. 'Its purpose is to provide the cues needed to guide the path of-performance. This is necessary since there are decision points in:the EP where the appropriates course-of action depends on plant conditions (which may be

. variable). Revisions to a limited portion of the EP may not

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require the use of a scenario'to validate the' operational j

useability of'the EP.

. 4.4 Selection of Validation Method Either Simulator and/or. Walk-Through' Validation methods may be

used to validate revisions to the EP.

1. Selection of Simulator Validation Simulator validation is the preferred-method. . Simulator

validation allows the operators to perfona actions in real time with plant responses similar to those'of the actual plant. When the computer models-on the' simulator do;not-allow certain scenarios to be performed, or when most -

actions in the EP are. performed outside the Control Room, l, walk-through validation activities should be performed.

Some additional guidelines for the selection of simulator j validation are given below:

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'* Simulator validation is desirable when the EP and j - several bra'nch procedures (Abnormal Procedures, AB's 4_ or Plant Procedures, PP's) are to be. validated. The l- scenario selection should be made.to represent the

. _ array of functions which validate. transitional routing '

. between procedures.

• Simulator validation is desirable where major' EP routing revisions occur (one section'of the EP directs the operators to other sections). Enough of the EP should be validated to ensure that the' transition from section to section is operationally correct.

• If the revised EP directs the operators to go to another procedure and perform it concurrently, the' feasibility of this should be examined using a simulator.

• The revised EP should be validated using a simulator if it requires close coordination 'of actions by ,

different operators.

• The revised EP should be validated using a simulator

if it involves multiple failures or problems.

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2. Selection of Walk-Through Validation A Walk-Through Validation may be performed,~ in lieu of simulator. validation, when the simulator does not adequate-

. ly model Davis-Besse Plant responses or when-revisions are made to a limited portion of the EP. .The following are examples of cases where a Walk-Through Validation is appropriate:

• Setpoint change for instrumentation which affects one system or subsystem operation.

• Addition or removal of an alarm which affects an individual component or parameter.

• Changes within one section where sequence and timing of operations is inconsequential.

• Addition or removal of a controller or display which affects one system, subsystem, or route in the EP.

• Changes in one Attachment, Flowchart, or Specific Rule.

• Changes that are not permanent (i.e., Plant conditions require an amendment for a fixed period of time).

• Equipment specification changes affecting only one section of the EP.

4.5 Specification of Scenarios Attachment 6, Scenario Development Sheet, will be used to specify scenarios to be performed. A brief purpose statement should be written to specify the conditions under which the EP is assumed to be performed and the path to be followed through the EP.

Each scenario description should cover the path from EP entry conditions to the point at which the plant is placed in a. stable condition.

At least one scenario should be written for each path or section of the EP to be validated.

The scenario description should include the following:

• - Conditions prior to procedure initiation - Include plant mode, power level (e.g., full power), and the status of system and major components that will arfect or be affected by events. Unless otherwise stated, systems will be assumed to be in normal lineup and operating -status.

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• . Initiating ~ event - This is'a~ statement oflwhat-causes;the operators to. enter the procedure. ' Include the' underlying-cause 'and the major symptoms : observable. in the Control Room f(e.g., unisolable small-break LOCA inside Contuinment;

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decrease in Pressurizer Level and pressure resulting;in an-

.RCS Low Pressure alarm),

• ' Subsequent Events - Identify the major operator actions and plant changes (plant factors requiring operator action and' plant response to operator. action).

When.different action paths may be chosen in executing the' EP,.specify'the path to be.followed in the validation

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exercise. State any. assumptions about plant variables that underlie the action path. chosen.

If- branching _ to another procedure is part of lthe. scenario,.

specify the procedure and point of entry in the " subsequent.

events." Also, if applicable, specify when a return to.the EP occurs and where it-is reentered.

• Final conditions - Specify the plant status at the end of-the scenario. Also, specify the status of systems and major components affected by the events of the scenario.

(e.g., Reactor trip, all Control' Rods. inserted, cooldown and secondary plant shutdown in progress; Pressurizer Level 100 inches and rising).

If the EP will be validated on-aLsimulator,.the scenario-should be reviewed by a simulator instructor to ensure that if is feasible as written. Also, there may be plant-response delays, or long periods = required to bring. plant conditions to a desired state, during which operator.

actions would be essentially repetitive. Such delays ~may-be eliminated. The.stop and restart points should be identified so that they may be programmed in advance. The scenario description should be annotated to 'show when tiine .

slicing is to be used and to identify the stop and' restart cues. (Time slicing' occurs _when plant-responses or events are accelerated or 'a different set of plant: conditions are to be assumed).

4.6 Personnel Needs The following personnel will participate in validation-activi-ties. Minimum qualifications and responsibilities'are listed j for each personnel category identified:

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J1. .V&V Coordinator p a. Qualifications-

. Experience as a Senior Reactor 0perator and/or-

, ' currently in.the.SRO license training program at~

_ Davis-Besse.-  !

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- Thorough knowledge of the-EP and associated documentation.

Thorough knowledge _of Davis-Besse_ plant systems.

' Authority to schedule _ simulator sessions'and 1

Control Room activities.

Authority to schedule and a'ssign dutiesoto

- personnel.

i b. Responsibilities-

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Schedule activities, facilities and personnel.

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Ensure that' copies of the EP, reference documents and materials are available.

Conduct pre-validation. briefings to explain -the -

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overall purpose of the EP V&V Program and ~the

. validation activities.

Coordinate and supervise validation activities.

Perform the duties:of a validation observer.

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i Ensure that all documentation of-activities ~is

[ properly completed.

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2. Validation Exercise Participants

a. Qualifications

. SRO - experience as a Senior Reactor Operator

! and/or currently in the_SRO license training-program at Davis-Besse.

R0 - experience as a Reactor Operator and/or currently. in the R0 ' license training program at -

Davis-Besse.

b. Responsibilities 1

Fulfill the roles: assigned by_the~V&V Coordinator.

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.- Participate in implementation of the EP either in simulator or walk-through activities.

Complete Validation Checklist and Validation Comment Forms.

3. Observers (minimum of two)

a. Qualifications One observer should be an Operations Specialist with the following minimum qualifications:

Minimum of 4 years operations experience atl Davis-Besse.

Knowledge of procedure' development and the EP V&V program.

Experience as a Senior Reactor Operator and/or currently in the SR0 license training program at

, Davis-Besse.

Thorough knowledge of Davis-Besse plant systems.

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One observer may be a Human Factors Specialist with the following minimum qualifications:

Two years experience in the application of human factors in the nuclear power industry.

Experience in procedure development and/or conduct of EP V&V in accordance with NRC and INPO guidance.

One observer may be from the Davis-Besse Training Department with the following minimum qualifications:

Knowledge of the EP and related documentation.

Thorough knowledge of Davis-Besse plant systems.

Familiarity with the EP V&V Program.

b. Responsibilities Observe assigned operators using the EP and referenced procedures.

Complete the Validation Checklist and Validation Comment Forms. ,

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16 R v. 0 Assist the V&V Coordinator in explaining and implementing EP validation' requirements and documenting results.

4. Simulator Instructor (necessary for simulator exercises only)

a. Responsibilities Initialize the simulator as required by the scenario.

Operate the simulator.

Play the roles of all personnel outside the Control Room.

Support the simulator validation activity as assigned by the V&V Coordinator.

4.7 Facilities / Materials

• Designated time periods on the simulator or in the Control Room or Control Room mockup, as appropriate.

• Copies of the EP and referenced procedures to be evaluated.

• A copy of Attachment 3, Guidelines for E0P Validation Observations, for each observer.

• Copies of the Attachment 4, Validation Checklist, for validation exercise participants and observers.

• Copies of Attachment 5, Validation Comment form, for each participant and observer.

• Copies of Attachment 6, Scenario Development Sheet, to be used during the validation activity.

, 4.8 Specific Instructions for Performing Simulator Validation

1. V&V Brief participants on the following:

Coordinator

a. Purpose and scope of validation process.

b. Steps of simulator validation.

c. Responsibilities / assignments of each participant.

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' d. . Scenario (s) toLbe performed.

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e. Information to be'. recorded on forms.

2. Simulator. Prepare the simulator.

Instructor

i. a. Establish initial conditions according 4 ~to-the scenario. -

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b. . Plan / program _stop points and restart ~ +

points if applicable to the scenario.

[ 3. All Perform validation exercise.

Participants . ,

a. Control; Room personnel execute;proce-j dural steps according to scenario,-as.

. they would be done in actual;perfor--

mance,. including:

• Use of telephone, announcing system,~ or other communications

equipment.

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• Normal communications between:

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Centrol Room personne1~ .

• Use of ~ job performance aids as-

required by ths EP.

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• Use of plant. equipment operators and other outside personnel (roles.

j performed by simulatorfinstruc-j tor), as required by,the scenario.

t

b. Simulator instructor monitors and controls simulator and acts as "other personnel" when required.

c. Observers watch performance and record 8

comments.

!- 4. Conduct review-session after performance of All .

i Participants Leach scenario. i j a. Discuss any questions that: arose during

observation..

1 i b. Discuss the use of the Validation ,

Checklist and Validation Comment Form '

j (Attachments-4 & 5).

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'18' Rsv.' 0

c. .Have each participant _ independently complete Attachment 4, Validation Checklist,' and Attachment 5, Validation Comment: Form.

d. ' Collect:all checklists and forms.

5. V&V _

Ensure forms'are completed correctly. '

Coordinator or Designee -

a. Review all. comments written by observ-ers and participants.

b. Verify all comments are identified by the scenario and the~ person making the comment.

4.9 Specific-Instructions for Performing Walk-Through Validation

1. V&V Brief participants on the following Coordinator

a. Purpose and scope of validation process.

b. Steps of' walk-through validation.

c. Responsibilities / assignments of each' participant.

d. Scenarios to be' performed - review each in relation to the EP just'before it is to be performed. Discuss action cues and assumptions about parameter changes that will guide,the course of action.

2. All Perform walk-through exercise.

Participants

a. V&V Coordinator reviews scenario with participants,

b. Shift Supervisor-or Assistant Shift Supervisor verbalizes cues.

c. V&V Coordinator directs phasing of activity.

d. Control Room personnel enact the EP according to scenario, pointing out controls and displays used.

k 19~ Rsv. O q

.3. All Conduct' review session after- performance' of

. Participants' each scenario.

1 3 a. Discuss any questions. that arose during observation.

b. Discuss the use of the Validation Checklist and. Validation Comment. Forms '

'(Attachments 4 & 5).

- c. Have each. participant independently.

complete.

Attachment:

4 and Attacbeent 5.4

'd. Collect all complet'ed checklistsLand forms. '

~

4. V&V' Ensure" forms and checklists are completed Coordinator correctly.

or Designee

a. . Review lall comments written by observ- 3 ers an participants.

b. Verify all comments are identified byr the scenario and the person making 'the' comment.

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'20 R:v. ' 0 f 5 5.0': Assessment and Resolution ~

lui assessment will be performed to determine the disposition of the, findings.from~ technical verification, editorial' verification, and

. validation for each revision to the EP. Changes to be made to'the EP and associated documentation will be'specified as part of the assess--

ment and resolution activity, taking into account any recommendations made'during the preceding.V&V activities.

- 5.1 Objectives The objectives of assessment and resolution are:

• To ensure that all questions that arise during review-activities'are resolved.

• To ensure that any changes to correct or enhance the EP will be consistent with the TBD, EP Basis Document, Writ-er's Guide, and EP source documents.

• To ensure that the EP Basis Document will be updated.

• To provide documentation of the d'isposition of EP V&V ,

comments.

5.2 Applicability The Assessment and Resolution activity will be' performed on EP revisions before approval for use.

When a step, subsection or attachment-to the EP is revised, the assessment and resolution activities'will be performed to ensure comments generated during Technical and Editorial Verification and Validation activities are resolved.

5.3 ' Personnel Needs The V&V Coordinator will direct and participate in all assess-ment and resolution activities. The V&V Coordinator will be responsible for ensuring clear documentation of the disposition of all findings.

The assessment and resolution team will. include a minimum of one additional person with the following qualifications:

I

• Knowledge of the EP and associated documentation

.)

• Thorough knowledge of Davis-Besse plant systems

'l

• Familiarity with the EP V&V objectives and requirements.

- _ - __ _ L_ _--__-_____:_--

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21~ R v. 0

'5.4 Materials

• A complete documentation. package from technical verifica-tion, editorial verification, and validation.

• A copy'of the revised EP, TBD,-EP Basis Document, Writer's Guide and EP source documentation.

• - A Concurrence with Comment' Resolution Form,,ED 7599.

'5.5 Nethod

'The assessment' team will review all. discrepancies and all.

comments and questions that were. identified during Technical Verification, Editorial Verification, and Validation. The disposition of each item will be recorded on the Comment Form.

Findings and questions from Editorial' Verification are noted in the comments column of the Document Review Sheet. For each of these. comments, it should be. determined-if changes to the text:

or flow chart are required. Actual changes should be marked on copies of the procedure.

For each comment from the Technical Verification or Validation activities', a disposition should be made and recorded in the appropriate ~ resolution columns.

If it is determined that no change should be made in response to an item, the reason should be noted in the appropriate resolu .

tion columns. If a particular disposition cannot be specified, the item and the follow-up action should be described.

In addition, all changes to be made will-be marked on a single copy of the EP. This ensures that changes will be made-in an integrated way, so that their possible effects on each other, and on other parts and steps of the procedure, will be taken into account.

Procedures referenced in the EP should also be. checked to determine whether the proposed revision requires that a change

~

or revision also be made to a referenced procedure. Any changes needed in associated documentation or in a' referenced procedure should be roted in the appropriate. resolution columns.

When all dispositions have been completed, a Concurrence with Comment Resolution Form will be completed and'all-participants submitting comments shall sign the form. This will indicate their comments have been satisfactorily resolved. The Concur-rence with Comment Resolution Form (s) will be attached to the.

V&V documentation package.

tempi e/254 l

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[

x Rav. 0 R22 ATTACHMENT 1: TECHNICAL VERIFICATION CHECKLIST-

EP 1202.01 Rev.

Procedure Section(s) or Step (s) '

Applicable Technical Basis Document Sections:

Date of Technical Verification:

Technical Verification Team:

Name: Experience: Function:

R0 SRO Technical Evaluator R0 SR0 Technical Evaluator SRO V & V Coordinator Attachment 1 '

Page 1-of 6

)

I

23' Rsv. 0~

JATTACHMENT'1: TECHNICAL VERIFICATION CHECKLIST INSTRUCTIONS A member of the Technical Verification Team sh'all complete each item on.this-checklist. 'An N/A shall-be placed on those items that do not apply ~to-the EP revision. Any "Yes". answers should have a corresponding comment placed on a Document Review Form'unless appropriate justification has been provided in the EP Basis Document.

SECTION 1.0

~ 1.0 Compare each' revised section/ step of the EP to the corresponding section/ step of the TBD and answer the following questions:

a. Could the revision reduce operator ability to identify symptoms used to determine upsets in heat transfer, as specified in the TBD?'

' Yes No -N/A'

b. Could the revision reduce operator ability to identify and control excessive heat transfer transients, as specified in the TBD?.-

Yes -No N/A

c. Could the revision reduce operator ability to identify and-control inadequate primary to secondary heat transfer, as specified in the TBD?

Yes No N/A

d. Could the revision reduce operator ability to identify natural ,

circulation or loss of natural circulation, as specified in the TBD?

Yes. No 'N/A

e. Could the revision reduce operator ability to identify and control the five functions which influence heat transfer:

Reactivity Yes No- -N/AL RCS Inventory Yes No N/A RCS Pressure Yes No N/A SG Pressure Yes No N/A-SG Inventory Yes No .N/A-l Attachment 1

Page'2 of 6 a

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- 4 ~&o- 6 4 - i 4 4 724 Rzv. 0 ATTACHMENT 1: TECHNICAL VERIFICATION CHECKLIST-

f. Could the revision reduce operator: ability to identify lossaof and restore power sources ito busses ~, MCCs, and instrumentation:

and control systems, as required by the TBD?

Yes - No N/A

g. If the revision alters the intent of TBD. Figure III.A-1,-Vital System Status Verification Flow Chart, is there a need for further' justification?.

-Yes. No N/A

h. Does the revision delete or alter the TBD actions associated-with a loss of SCM?

I 4 Yes No N/A

i. Does the revision alter the TBD criteria for maintaining' proper-

< SG levels during natural circulation, boiler condenser cooling-or loss of SCM?

~Yes No N/A j . If the revision alters the intent of TBD Figure III.B-1, Lack of Adequate Subcooling Margin Flow Chart, is there a need'for further justification?

Yes No N/A

k. Does the revision alter the TBD criteria for establishment of HPI/MU cooling?

Yes No N/A

1. Does the revision alter the TBD criteria for establishment of MU?

l Yes No N/A

m. Does the revision alter the TBD criteria for RCP operation i during loss of SCM, lack of heat transfer or ICC conditions?-

Yes No N/A

n. If the revision alters the intent of the TBD Figure III.C-1, Lack of Adequate Primary to Secondary Heat Transfer Flow Chart, is there a need for further justification?  ;

~Yes No N/A t'

l Attachment 1 i Page 3 of 6- l

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25 R;v. O .

ATTACHMENT 1: TECHNICAL VERIFICATION CHECKLIST

o. Does the revision alter the TBD criteria for isolating SGs during an overcooling transient?

Yes No N/A'

p. If the revision. alters the intent'of the'TBD Figure III.D-1, Excessive Primary.to Secondary Heat Transfer Flow Chart, is there a need for further justification?

Yes- No N/A

q. Does the revision alter the TBD method or criteria for handling SGTRs?

Yes No. N/A

r. If.the revision alters the intent of the TBD Figure III.E-1, SGTR Functional Flow Diagram, is there a need for further justification?

Yes No N/A-

s. Does the revision alter the TBD methods or criteria for handling  ;

ICC?.

Yes No N/A

t. If the revision alters the intent of the TBD Figure III.F-2, Inadequate Core Cooling Flow Chart, is there a need for further justification?

Yes No N/A

u. Does the revision alter the TBD criteria and limits associated with the following RCS cooldowns methods?

Natural Circulation Cooldowns Yes No N/A Single Loop Cooldowns (Forced

& Natural) Yes No N/A hPI Cooldowns Yes No N/A DHR Cooldowns Yes No N/A Attachment 1 Page 4 of 6

w s

- 26 R;vD 0' ATTACHMENT 1: TECHNICAL VERIFICATION' CHECKLIST

v. Does the revision alter'the TBD criteria for operation of the following systems:

HPI< Yes~ No- N/A LPI Yes No, N/A DHR Yes- - No: N/A CF Yes No N'/A AFW -Yes No N/A .

- W. 'DoestherevisionalterthemethodsofmonitoringRCSl tempera-ture-during all types of transients-(i.e.'incores vs. Tc and Th)?

Yes No . N/A-X. Does the revision alter the TBD criteria for controlling Con-tainment atmosphere?

Yes No- ~N/A' Y. Does the revision alter the TBD Specific Rules associated with-HPI/LPI, MFW/AFW, or RCPs?

Yes' No N/A-SECTION 2.0 2.0 Compare each revised section/ step of the EP to the corresponding a section/ step of the EP Basis Document, DB ATOG or other EP Source Documents while answering the following questions. If'any signifi-cant technical difference is found, appropriate justification for i

these differences shall be provided in the EP Basis Document.

E a. Will the revision alter the sequence of actions operators must

take to mitigate the transient? (Review all revised procedural' routing.)

j Yes No N/A k- b. Will the routing revision cause operators to bypass important

! information such as CAUTIONS or verification steps?

Yes No N/A 4

3 4

-Attachment 1 Page 5 of 6 i.

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. 4 27 R;v. 0

. ATTACHMENT 1: TECHNICAL VERIFICATION CHECKLIST

c. Will the revision violate a_ previous identified license commitment?

Yes No~ N/A

d. Will the revision require further engineering justification to ensure plant specific.information is correct such as:

Conditions for starting /stoppiag actions Yes No-- N/A Setpoint changes Yes No N/A Qualitative values and tolcrance band i

Yes No N/A Specific rule, attachment, figure, and table changes Yes No N/A 1

e. Has the underlying intent of the step been revised without proper justification?

Yes No N/A

f. Will the revision require revisions to branch procedures? (Exit conditions of the EP should be compatible with entry conditions of branch procedures.)

Yes No N/A

g. Does step numbering revision inadvertently alter _ routing strate-gy or logic?

Yes- No N/A

h. Will the revision alter the criteria for making entry into the EP (or EP sections) and cause operator confusion?

Yes No N/A Attachment 1 Page 6 of 6 P

-~ -

t 28 . Rav. O ATTACHMENT-2: -EDITORIAL VERIFICATION CHECKLIST' EP 1202.01 Rev.

~

' INSTRUCTIONS Refer to Volume IV of the Writer's Guide when performing this Editorial Verification Checklist.

- All' checklist items call for a "yes" "no" or "N/A" answer. "No" indicates- >

a discrepancy from the Writer's Guide. In such cases, use a document review sheet-to identify the' discrepancy (e.g., record the step number) and describe'the deviation in detail.

Editorial Verification Team:

1

~

Editorial Evaluator Date Editorial Evaluator- Date 4 .

V&V Coordinator Date t

4 l

t I

Attachment 2 Page 1 of 4

4 12 9 R v. 0

' ATTACHMENT 2: EDITORIAL VERIFICATION CHECKLIST

- 1. Is all of the information contained .

in the procedure legible.(including text, figures,-tables, attach--

ments/ enclosure)? Yes .No N/A.

2. Are all. required sections and other elements present,-in the standard' order? Yes No N/A

' 3. Does the required identifying information appear on each page?- Yes No N/A

- 4. Are the correct formats used for 4

the Title Page, List of Effective Pages, and Table of Contents? Yes No N/A

5. :Does pagination meet Writer's Guide requirements? Yes No. N/A

6. Are sections, subsections and steps numbered correctly? Yes No N/A

7. Are figures and tables in the body of the procedure, and attach-ments/ enclosures to the procedure, numbered correctly in the order in which they are.first referenced? Yes No N/A

8. Are steps written according to the guidance given the Writer's Guide (short, simple, imperative sentences, etc.)? Yes No N/A t

9. Are punctuation, grammar, and spelling correct? Yes No N/A

10. Does the use of capitalization follow the guidance in the

Writer's Guide? Yes No N/A i

11. Are logic statements correctly used and formatted? Yes No- N/A

12. Are Warnings, Cautions and Notes used according to the definitions of those terms? ' Are they formatted and numbered'according to the guidance in the Writer's Guide? Yes No N/A f

Attachment 2 Page 2 of 4 l

30 R:v. O' 1

ATTACHMENT 2: EDITORIAL VERIFICATION CHECKLIST

13. Are . figures, tables, forms, and other . aids formatted according to the guidance in the Writer's Guide?

Can they be interpreted easily? Yes- No 'N/A

14. Are charts / graphs / formulas provided,

~

as 'necessary, for calculations? Yes No -N/A

15. Are adequate provisions made for

'the user to record necessary data and perform required calculations? Yes No 'N/A

16. Do acronyms and abbreviations conform to the abbreviation list provided in the Writer's Guide? Yes No N/A

17. Do Caution and Note statements avoid the use of the action statements? Yes No N/A

18. Do decision boxes on the flow chart require a choice between one of two opposite possibilities (i.e., YES/NO HIGH/ LOW, etc.)? Is.the direction proper? Yes No N/A

19. Does the spacing of paths on flow charts allow the operator easy and accurate movement through the different flow chart branches? Yes No N/A

20. Is the direction of flow chart paths indicated by arrows? Yes No N/A

21. Do flow chart symbols contain the corresponding step number? Yes No N/A

22. Do graphs provide:

• Readable information

• Information that can be extracted to the necessary level of. detail

• Values that correspond to i plant instrumentation? Yes No N/A 1

Attachment 2 Page 3 of 4 l

-31 R:v. O ATTACHMENT 2: EDITORIAL VERIFICATION CHECKLIST

23. Are values specified in a way that mathematical operations are not required of the operator? Yes No. N/A

24. Are units of measurement in the EP the same as those used on instrumentation or displays? Yes No N/A

25. Do procedures or procedure sections referenced in the EP contain the required information needed by operators? Yes No N/A

26. Do revised flowchart step numbers agree with the step numbers in the body of the EP? Yes No N/A

27. Do the revised steps reference tLa correct Section, Specific Rules, Attachments, Figures, and Tables? Yes No N/A

28. Are LCTS items italicized? Yes No N/A Attachment 2 Page 4 of 4

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32 Rsv. 0 ATTACHMENT'3': GUIDELINES FOR EP VALIDATION OBSERVATIONS

'These guidelines are for use in validating the operational usability of

~

the EP. They apply to Simulator.and Walk-Through Validation activities.

Any problem or question about the operational usability of the EP should be recorded on the Validation Comment Form (Attachment 5). Key-items that should be considered are described below:

c 1. . SUFFICIENT INFORMATION j Does each instructional: step provide sufficient information to allow the operator to perform the action correctly?-

2. CLEAR INSTRUCTIONS.

Is each instruction stated clearly,'with correct use of abbrevia-

'tions, equipment nomenclature, and location information so that personnel can quickly understand what is to be done and where it is to be done?

s

3. CORRECT SEQUENCE Is each instruction presented at the correct time? Does it interfere i with any previous actions or any actions being executed concurrently by other personnel?

4. CLEAR FLOW IOGIC

' Can personnel easily follow the path of action indicated by the flowchart, including branching?

5. TIMING

, Do instructions clearly identify any time limits or frequency re-l quirements for performance of an action or any related actions, and j can the actions be completed within these limits or frequency requirements?

^

6. COMMUNICATIONS i -

Is there a communication need associated with performance of the step? Are necessary communic'ations made in a timely mann r? Are competing communications a potential problem area? Do communications interfere with the performance of other personnel?

]

I i

i Attachment 3 Page 1 of 2 1

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. 1 33 -RIv. 0

-s ATTACHMENT 3: -GUIDELINES FOR EP VALIDATION OBSERVATIONS

-7. . COORDINATION Can the performance of steps by different personnel be directed and coordinated without confusion?

8. ' PLACE-KEEPING I

Can the supervisor (Shift Supervisor or Assist. Shift Supervisor).

easily keep ~ track of where personnel are in executing procedural steps, particularly when operating in more than one branch of the EP and/or in more than one procedure concurrently?

1.

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, Attachment 3 Page 2 of'2 i

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'34 -R;v. O ATTACHMENT 4':' VALIDATION CHECKLIST Each participant in the validation performance activity should complete a Validation Checklist. If a problem or question related to any item is identified, the reviewer should explain it'on a Validation Comment Form. The Validation Checklists and Comment forms-completed by all reviewers should be assembled in one package and~

given to the V&V Coordinator.

EP 1202.01 Rev:

. Validation Method (check on) Simulator Walk-Through Reviewer Name:

Job

Title:

License Experience: R0 SRO Role in validation performance exercise:

1. Is sufficient information provided in the revised EP 'for qualified operators to perform each action?

Yes No N/A

2. Is sufficient information available for the operator to make. a correct choice at each decision point?

Yes No N/A

3. Does the revised EP adequately handle needs for recurrent verifica -

tions or actions?

Yes No N/A

4. Is appropriate system response information (i.e., indications) provided in the EP?

Yes No N/A

5. Were all required actions performed as specified in the EP?

Yes No N/A

6. Is any terminology, nomenclature, abbreviation, acronym, or symbol used in the EP that is not familiar to the operators?

Yes No N/A Attachment 4 Page 1 of 3

35 R;v. O ATTACIDfENT 4: VALIDATION CHECKLIST

7. Are locations of equipment, controls, or displays'that are infre-quently used, are in out-of-the-way places, or are at local panels adequately described?

Yes No N/A

8. Did equipment responses correspond to what is in the EP?

Yes No N/A

9. Did the EP accurately predict what actually happened?-

Yes No N/A

10. Did the EP achieve the expected objective?

Yes No N/A

12. Is the EP consistent with the manning philosophy? (Can it be execut-ed by the minimum staff required by Technical Specifications?)

Yes No N/A

13. When the EP was performed by more than one person, did the Shift Supervisor or Assistant Shift Supervisor define their individual responsibilities clearly?

Yes No N/A

14. Did the operators have enough time to accomplish what was required?

Yes No N/A

15. Where setpoints (or other limiting values) apply, was enough guidance presented to ensure timely operator action?

Yes No N/A

16. Was sufficient information given to allow the operators to find the appropriate controls and displays?

Yes No N/A

17. Were prerequisites for starting equipment clearly identified?

Yes No N/A Attachment 4 Page 2 of 3

36 R v. O ATTACIDfENT 4: VALIDATION CHECKLIST

18. Did the EP instruct the operators to start equipment at the appropri-ate time?

Yes No N/A

19. Did communications occur at the appropriate points?

Yes No N/A

20. Was any interference in communications observed?

Yes No N/A

21. Is the information provided in the EP in a form that is easily used?

Yes No N/A

22. Was the coordination of multiple flow paths or multiple steps handled in a manner that resulted in each operator being aware of his respon-sibilities and of current plant conditions?

Yes No N/A

23. Were instructions concerning actions to be taken presented clearly?

Yes No N/A

24. Is the structure of the EP consistent with the roles and responsibil-ities of the operators?

Yes No N/A

25. Are action steps structured to minimize the physical conflicts of personnel moving around the Control Room while carrying out procedur-al steps?

Yes No N/A

26. Are action steps structured to avoid their unintentional duplication by different operators?

Yes No N/A

27. Did EP nomenclature agree with Control Room panel nomenclature?

Yes No N/A Attachment 4 Page 3 of 3

- _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _/

37 Rsv. O ATTACHMENT 5: VALIDATION COMMENT FORM COVER SHEET-The Validation Comment Form should be used to record any problems or questions identified during each validation activity. Make sure this cover sheet is completed and attached to the complete package of Valida-tion Comment Forms.

EP-1202.01 Rev:

Validation Method (check one) Simulator Walk-Through Date of Validation Participants (please record name, job title, license if applicable, and role in the validation activity, for each participant):

Attachment 5 Page 1 of 2

1 2

38 .Rev. 0

' ATTACIDENT 5: : VALIDATION COMMENT FORM Pega of r

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39 R:v.-0 ATTACIDfENT 6: SCENARIO DEVELOPMENT SHEET

,EP 1202.01 Rev.:

Date: Developed by:

Purpose:

Initial Plant Conditions:

Scenario

Description:

(Includes initiating event, subsequent events, and final conditions)

Scenario Sequence and Timing: (Attach additional pages if required)

Attachment 6 Page 1 of 1