ML20209A858

Informs That Procedures Generation Package (PGP) Unacceptable in Present Form.Pgp Needs to Incorporate Listed Addl Info,Including plant-specific Technical Guidelines. Request for Addl Info,In Form of Draft Ser,Encl

ML20209A858
Person / Time
Site:	South Texas
Issue date:	01/16/1987
From:	Kadambi N Office of Nuclear Reactor Regulation
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8702030462
Download: ML20209A858 (27)

Text

o. 6 Mr. J. P. Goldbero Group Vice President, Nuclear UAN 10. 1997 Pouston I.ightina f Power Company P.O. Box 1700 Houston, Texas 77001

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SUBJECT:

RE0 VEST FOR ADDITIONAL. INFORMATION ON THE SOUTP TEXAS PROJECT PROCEDURES GENERATION PACKAGES (PGP)

The staff has reviewed the PGP and determined that it is not acceptable in the current form. The PGP needs to incorporate additional information on plant specific technical guidelines, the writer's guides, the verification and validation proaram and the training program, Most of the requested information was communicated to your staff in a conference call on November 26, 1986. The Enclosure provides the formal transmittal of the reauest in the form of a Draft Safety Evaluation Report, Please provide the requested information within 30 days to enable an expeditious resolution of this item. Please call me at (301) 492-7?72 if you have any questions.

Sincerely,

-} -

N. P. Kadambi, Project Manager Pro.iect Directorate No. 5 Division of PWR l.icensino-A

Enclosure:

As stateJ See next page Distribution

. Docket File:

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8. Grimes J. Partlow N. Thompson N. Kadambi M, Rushbrook ACRS 10)

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h 16 Mi Mr. J. H. Goldberg Group Vice President, Nuclear Houston 1.ighting & Power Company P.O. Box 1700 Pouston, Texas 77001

SUBJECT:

REQUEST FOR ADDITIONAL. INFORMATION ON THE SOUTP TEXAS PROJECT PROCEDURES GENERATION PACKAGES (PGP)

The staff has reviewed the PGP and determined that it is not acceptable in the current form. The PGP needs to incorporate additional information on plant specific technical guidelines, the writer's cuides, the verification and validation procram and the training prooram. Most of the requested information was communicated to vour staff in a conference call on November 76, 19P6. The Enclosure provides the formal transmittal of the reauest in the form of a Draft Safety Evaluation Report.

Please provide the reouested information within 30 days to enable an expeditious resolution of this iter. Please call me at (301) 49?-7272 if you have any questions.

Sincerelv,

- Ao- k u:> {.

N. P. Kadambi, Pro. ject Manacer Pro.iect Directorate No. 5 Division of PWR I.icensing-A

Enclosure:

As stated See next pace 1

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• Mr. J. P. Goldbero Houston lighting and Power Company South Texas Project CC:

• Brian Berwick, Esq. Resident Inspector / South Texas Assistant Attorney General Project Environr. ental Protection Division c/o U.S. Nuclear Regulatory Commission P. O. Box 19548 P. O. Box 910 Capitol Station Bay City, Texas 77414 Austin, Texas 78711 Mr. Jonathan Davis Mr. J. T. Westermeir Assistant City Attorney Manager, South Texas Project City of Austin Houston t.ighting and Power Company P. O. Box 1088 P. O. Box 1700 Austin, Texas 78767 Houston, Texas 77001 Ms. Pat Coy Mr. H. L. Peterson Citizens Concerned About Nuclear Mr. G. Pokorny Power City of Austin 5106 Casa Oro P. O. Box 1088 San Antonio, Texas 78233 Austin, Texas 78767 Mr. Mark R. Wisenberg Mr. J. B. Poston Manager, Nuclear I.icensing Mr. A. Von Rosenberg Houston lighting and Power Company City Public Service Boad P. O. Box 1700 P. O. Box 1771 Houston, Texas 77001 San Antonio, Texas 78296 Mr. Charles Falligan Jack R. Newman, Esq. Mr. Burton t.. I.ex Newman & Poltzinger, P.C. Bechtel Corporation 1615 l Street, NW P. O. Box 2166 Washington, D.C. 20036 Fouston, Texas 77001 Melbert Schwartz, Jr., Esq. Mr. E. R. Brooks Baker & Botts Mr. R. l.. Range One Shell Plaza Central Power and light Company Houston, Texas 77002 P. O. Box 2122 Corpus Christi, Texas 78403 Mrs. Peggy Buchorn Executive Oirector e Citizens for Equitable Utilities, inc'.

Route 1, Box 1684 Brazoria, Texas 77422 l

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O Pouston I.ighting & Power Company South Texas Project CC:

Reaional Administrator, Region IV U.S. Nuclear Regulatory Commission Office of Executive Director

.for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. lanny Sinkin, Counsel fnr Intervenor Citizens Concerned about Nuclear Power, Inc.

Christic Institute 1324 North Capitol Street Washington, D.C. 20002 1.icensing Representative Houston lighting and Power Company Suite 1309 7910 Woodmont Avenue Bethesda, Maryland 20814 I

Enclosure 1 Draft Safety Evaluation Report

. Procedures Generation Package South Texas Project Electric Generating Station Units 1 & 2

1. Introduction Following the Three Mile Island (TMI) accident, the Office of Nuclear Reactor Regulation developed the "TMI Action Plan" (NUREG-0660 and MIPEG-0737), which required licensees of operating reactors to reanalyze transients and accidents and upgrade emergency operating procedures (EOPs) (Iten I.C.1).

The plan also required the NRC staff to develop a long-tem plan that integrated and expanded efforts in the writing, reviewing, and monitoring of plant procedures (Item I.C.9). NUREG-0899, " Guidelines for Preparation of Emergency Operating Procedures," represents the staff's long-term program for upgrading E0Ps, and describes the use of a " Procedures Generation Package (PGP) to prepare E0Ps. Submittal of the PGP was made a requirement by " Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability (Generic Letter 82-33)." The Generic Letter requires each licensee to submit to the NRC a PGP, which includes:

(i) Plant-Specific Technical Guidelines (ii) A Writer's Guide (iii) A description of the programs to be used for the validation and verification of E0Ps.

l (iv) A description of the training program for the upgraded E0Ps.

This report describes the review of Houston Lightino and Power Company's (PL8Pi response to the Generic Letter related to development and implementation of E0Ps for South Texas Project, Units 1 and 2 (STP) (Section 7 of Generic Letter

82-33). ,

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Our review was conducted to determine the adequacy nf the HL&P program for preparing and implementing upgraded E0Ps for STP. This review was based on NUREG-0800, Section 13.5.2 of the Standard Review Plan.

2. Evaluation By letter dated June 14, 1985, the applicant submitted its PGP for STP.

By letter dated September 15, 1986, the applicant provided additional information. The PGP contained an introduction and the following sections:

Plant-Specific Technical Guidelines E0P Writer's Guide E0P Verification and Validation E0P Training Program A. Plant-Specific Technical Guidelines (P-STG)

The P-STG program description was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899.

The applicant will use the Westinghouse Owners' Group (WOG) Emergency Response Guidelines (ERGS), Revision 1, as the basis for STP E0Ps. The applicant identified the following sources of information for use in generating E0Ps for STP.

Writer's Guide for E0Ps STP Final Safety Analysis Report Vendor Manuals and System Descriptions Plant Technical Support Division l

Writer's Guide Plant Electrical Drawings Plant Instrument List Plant Piping and Instrument Drawings Vendor Bulletins and Memos Administrative Memos, Orders, and Procedures Our review of the STP P-STG identified the following concerns:

1. All deviations from and additions to (including plant-specific bracketed information) the ERGS should be documented, and an analysis or other technical .iustification supporting the deviations and additions should be included with the E0P Step Justification /

Verification Form. Those deviations or additions to the ERGS and their justification that are of safety significance should also be included in the PGP.

2. Section 1 of the Emergency Procedures Writer's Guide and Verification document states that additional E0Ps, not previously identified by the WOG, should be prepared as per this procedure. Since these procedures will be an addition to the ERGS, all procedure steps contained therein should be treated as additions to the ERGS and handled accordingly. ,

3. Section 2.2.2.2 of the Emergency Procedures Writer's Guide and Verification document states that each step should be reviewed for preferential order. If the resultant step order is not in accordance with the step sequence reouirements of the respective ERG, the respective steps deviate from the ERGS and should be handled accordingly.

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B. Writer's Guide The writer's guide was reviewed to determine if it provided acceptable methods for accomplishing the ob,iectives stated in NllREG-0899. The writer's guide provides a means for ensuring that all E0Ps are prepared in a consistent manner and provides the writer with good human factors prin-ciples and direction for converting the WOG ERGS into plant specific E0Ps. Our review of the STP writer's guide identified the following concerns: l l

1. Sections 3.1.1 and 3.1.2 discuss the format of the operator section of procedures. This discussion should be revised with regard to the following: 1

a. Section 3.1.2 states that the operator's written procedure section "shall be in the dual-page, four-column style using Addendum 1". l Addendum 1 (p. 28) shows a single page with a dual-column format; thus Addendum 1 does not present the format described in Section 3.1.2. The writer's guide should be revised so that examples and text are consistent.

b. Sections 3.1.2.1.1 and 3.1.2.1.2 state that operator copies of written procedures shall, when opened, present " user information

{ and steps" on the left and "non-user information and steps" l on the right. Because " user information" and "non-user infor-l mation" are not defined, these instructions are not clear.

l The writer's cuide should be revised to define and give formatting instructions for these types of information, and to explain how these types of information will be presented in the four-column l

format discussed in Section 3.1.2.

c. It appears that user information will contain operator instructions.

Because of the importance of operator instructions, such infor-I mation would be better presented in a prominent position. Since

when presented with a set of facing pages the eye is naturally drawn to the right-hand page, operator instructions should be presented on the right-hand page, rather than the left-hand page as specified in Section 3.1.2.1.1. Thus, we suggest that all user information be included on the right-hand page,

d. Section 3.1.2.1.3 states that each operator copy of the written procedure "shall be identified on the front page as which operator section when closed as per Addendum 1". The writer's guide should be revised to clarify these instructions.

2. Procedure writers should be given sufficient informatinn in the writer's guide to produce procedures that are consistently formatted.

In order to assure consistency throuahout the FOPS, instructions and examples in the writer's guide should be revised as follows:

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

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

i l c. Section 3.1.4.4 indicates that user identification will be included j in the upper right-hand corner of each E0P page. User identiff-cation is not included in the sample page in Addendum 1 (p. 28).

The writer's guide should be revised so that user identification is included in Addendum 1.

d. Section 3.1.4.5 specifies that the page number shall be included l on each E0P page. Although the sample page in Addendun 1 (p. 281 presents the page number as "Page of , " Section 3.1.a.5 should be revised to specifically state that the total number of pages will be included in the pagination.

e. Cover sheets are an important source of information for operators. Section 3.2.1, which discusses cover sheets, should be expanded to specify that cover sheets will also include the revision number and the unit and facility designations.

f. Section 3.2.2 states that items on the cover sheet should be separated by a " minimum" of two lines. The writer's guide should be revised to provide exact line spacing requirements.

g. Although Addendum 1, a sample E0P page, includes the facility designation, the text of the writer's guide does not contain instructions to include the facility designation on E0P pages.

The text of the writer's guide should be revised to specify that the facility designation will be included on'each E0P page.

3. Critical Safety Function Status Trees provide important safety information to operators. The discussion of the status trees in the writer's guide should be revised with regard to the following:

a. Section 3.3.5 states that each status tree should " provide information and identify the starting point similar to the WOG status trees". The writer's guide should be revised to provide specific formatting information for this information and starting point. An example should be provided,

b. Sections 6.1.1 and 6.1.3 indicate that different symbols are to be used in the status trees and, flow charts. The presentation of status trees and flow charts in varying formats could lead to operator confusion. Therefore, we recomend that status trees and flow charts be presented using connon symbols. Section 6.1 should define these symbols and an example of a properly formatted status tree should be provided, t

c. Operators must be able to easily locate the status trees.

The writer's guide does not discuss the location of status trees within the procedure set. The writer's guide should be expanded to provide this information.

4. Sections 3.3 and 6 discuss flow charts. Flow charts can be a valuable means of presenting information. So that procedure writers are given sufficient information to produce properly formatted flow charts, the writer's guide should be revised with regard to the following:

a. Section 3.3.3 states that flow charts "may be enlarged and the pages connected together". It is not clear how such enlarged flow charts will be included in the E0Ps. It appears that oversize pages will be used. Because oversize pages are cumbersome and subject to wear, we recommend they not be used in E0Ps. The writer's guide should be revised with regard to this point.

b. Section 3.3.3 states that all flow charts will have " color-coded borders corresponding to unit assignment". The writer's guide should be expanded to specify which colors will correspond to which units.

c. Section 6.2 states that " complete sentences are not required" in flow charts. Incomplete sentences can be difficult for operators to understand. For this reason, this section should be revised to indicate that complete sentences are required in flow charts.

l d. Flow charts cannot present as much detail as can be efficiently presented in written procedures. Section 6.3 should be expanded to specifically address the level of detail to be included in flow charts. This level of detail should be adeouate so that a newly trained operator can use the flow charts, but not so great that the flow charts become cluttered and unusable.

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e. Section 6.5 states that notes and cautions may be placed "directly above or below the flow chart symbol as appropriate". Cautions and notes should always precede the steps to which they apply. The writer's guide should be revised to indicate that cautions and notes will be placed on the flowpath directly before the steps to which they apply.

f. The writer's guide does not discuss line-spacing for flow charts. The writer's guide should be revised to provide line-spacing requirements. Because flow charts can be read more easily if double-spaced, we suggest that the text in flow charts be double-spaced.

g. The entry point into a flow chart should be clearly identified so that operators enter the flowpath at the correct point.

The writer's guide should be revised to specify a means of j

indicating the entry point into a flow chart.

h. The writer's guide does not specify the location of flow l charts within E0Ps or within the control room. The writer's guide should be revised to give this information.

1. Because of the complexity of flow charts, we suggest that an example of a properly formatted flow chart be included in the writer's guide.

5. Sections 3.4 and 4.2 discuss conditional infomation pages. These sections should be revised with regard to the following:

a. Section 3.4.1 states that " conditional infomation pages may be used for various types of infomation and as such may be in several formats". It is not clear how conditional information

pages are to be used in E0Ps, or what types of information should be presented in conditional information pages. The writer's guide should be revised to specifically discuss the types of information to be included in conditional infomation pages and the format that should be used to present each type of information.

b. Section 4.2 states that conditional information pages will be printed on the left pages of procedure text in the Supervisor's procedure section. The writer's guide does not discuss the location of conditional information pages in the operator's section. The writer's guide should be revised to specify the location of conditional infomation pages in the operator's section of procedures.

6. Tables and other printed operator aids can assist operators in making decisions and locating information. Section 3.4.1.1, which discusses tables, should be revised to provide specific formatting instructions for tables.

7. Placekeeping aids can assist operators in keeping track of their position within a procedure. Section 3.5.3 states that checklists I

will be attached as addendums to procedures. Because it would be inconvenient for operators to flip between a procedure and a j checklist, we recommend that, instead of including a separate checklist, spaces for check marks be provided on procedure pages.

8. It is important that a consistent method of step numberina be used throughout E0Ps. The writer' guide should be revised with regard to the followino:

l t l, a. Aside from the example in Addendum 1, the writer's guide provides j no information on the numbering of steps. The text of the writer's guide should be revised to specifically describe a system of step numbering which will assign a unique number to each step.

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b. Step numbers do not precede the examples of steps in various sections (e.g., 7.6.1, 7.10.1, 8.4, and 13.1.3) . The writer's guide examples should be revised so that all steps are properly numbered.

. c. The text of the writer's guide gives no guidance on the numbering of substeps. Furthermore, the following examples do not number substeps in a cons: stent manner: Addendum 1 uses arabic numerals separated by periods (i.e.,1.1,1.1.1); Section 8.4 and 13.2.3 sequentially number substeps (i.e., 1., 2.); Sections 9.4 and 13.1.3 use bullets; Section 3.4.1.2, the example of a conditional statement, uses bullets at one level and lower case letters at a lower level; and Section 7.10.1 does not number substeps at all.

These examples are confusing and contradictory. All examples should be revised to conform to the method cf step numbering to

be described in the text of the writer's guide.

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9. It is important that E0Ps be presenttd in a format that is easy to read. Section 5.4 states that "the use of dashed lines across the page may be considered to keep the horizontal relationship" between

, .i the columns on the page. Because'such lines would clutter the page, we recommend this horizontal relationship be maintained in some other p '

, manner, e.g., sufficient vertical space between steps.

10.!;To ensure that the' flow of information from procedures to operators

, I 'is uninterrupted, f t is important that action steps be presented

' entirely on one page. Section 5.4 states that "if steps from either colomn continue to the next page, print ' Continued Next Page' at the bottom of the affected column. The writer's guide should be revised h

tol ndicate i that steps may not be split between pages, and the

( referenced portion of Section 5.4 should be eliminated.

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11. Instructions should be written for various types of action steps that an operator may take to cope with different plant situations.

The guidance provided in the writer's guide for writing instructional steps should be revised as follows:

a. Instructions should be written as complete sentences. Sections 7.2.2, 7.6.1, 9.4, and 13.1.3 contain examples where instructions are not written as sentences. Sentences should be written using a word order common to standard American English usage. These examples should be rewritten as standard sentences,

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

c. The writer's guide should address the formats and definitions of the following types of action steps: (1) steps that verify an action; (2) steps of continuous or periodic concern /

applicability; (3) steps for which a number of alternative actions are equally acceptable; and (4) steps performed concurrently with other steps.

d. Section 7.1 states that procedure steps "should contain one, but not more than two, actions". Instruction steps which run actions together could be confusing to operators. This section should be revised to clearly state that procedure steps will contain only one action.

e. Section 7.10 states, " Procedures are developed to prescribe a specific series of tasks to be accomplished. These tasks will be identified as the key steps and be performed by the sub-steps listed below". Section 13.1.2, which states "each key step should_ begin with an appropriate action verb or verb with modifier", also indicates that key steps will contain operator actions. We recommend that upper-level (key) steps not include

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operator actions; instead, upper-level steps should be used as headings to introduce lower-level steps, which would  ;

contain specific operator actions. For example, an example l in Section 8.4 has a high-level step " Start a Reactor Coolant Pump". This is not an instruction to start the pump per se, but a heading for the substeps that follow. These substeps provide actions that are to be followed before the pump is to be started. Wording the high-level step ir, this manner can mislead the operator. Thus, the writer's guide should be revised to state that upper-level steps will not contain operator actions.

f. Section 3.1.8 states that a procedure key step should include (1) the action to be taken (2) the information source, and (3) the location. Because upper-level (key) steps should not contain operator actions for the reasons discussed above, this section should be revised to apply to lower-level steps.

9 The examples of procedure key steps in Sections 7.10.1 and 13.1.3 contain neither the inforr+ fon source nor the location.

When Section 3.1.8 is revised in the nenner discussed above, the examples in Sections 7.10.1 and 13.1.3 (as well as all other examples) should be revised to be in conformance with the revised format instructions.

12. It is important that the operators know where to find all of the instrumentation and controls that are referenced in the E0Ps. The writer's guide should be revised with regard to the following points:

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a. Section 7.2.1 presents location inform 6 tion in a different manner than is specified in Section 8. This example should be revised so that location information is presented consistently at all times.

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b. Section 7.5 states that the location of an operator action  :

should be included "when possible". The writer's guide should  !

specifically discuss the situations when location information should and should not be included.

c. Section 8.4 states that location information should be given the first time a piece of equipment is cited in the procedure.

Because of the diverse nature of E0Ps and the cross-referencing between E0Ps, an operator might enter a procedure after the location information had initially been given. For this reason, if location information is necessary, it should be given every time the piece of equipment appears in the procedure.

13. Conditional statements and logic statements should be used in the E0Ps to describe a set of conditions or a sequence of actions. These statements can be confusing, so it is important that the writer's guide provide explicit guidance for their use. Section 10 should be revised to address the following concerns:

a. Section 10.4.3 states that when more than two conditions are combined, "a list format is preferred". Rather that stating what is preferred, this section should be revised to specifically instruct procedures writers to use a list format when combining more than two conditions.

b. The writer's guide does not discuss the difference between the conjunction "and" and the logic term AND. If this difference is not clear, operators could mistake a list for a logical sequence. The writer's ouide should specify the fematting of l conjunctions so they will not be confused with logic terms.

j c. The logic terms AND and OR can be confusing when used in the l same step. Although such uses of AND and OR should be avoided, there are occasions when it becomes necessary to combine these terms. The writer's guide should provide guidance and examples of acceptable usace for these situations.

d. Section 10.4.4 states that OR may be used in both the inclusive and the exclusive sense. So that operators are at all times certain of the meaning of OR, the exclusive OR should be formatted in a different manner than the inclusive OR. This section should be revised to provide instructions for formatting each use,

e. IF is used without THEN once in the example in Section 3.4.1.1, twice in the example in Section 3.4.1.2, and once in the example in Section 13.2.3. These examples should be revised to conform to the rules established in Section 10.3.

f. Recause of the confusion that can result when using logic terms in E0Ps, we suggest that examples of the correct use of each logic term be included in Section 10.

See NUREG-0899, Appendix B for additional information.

14. Notes and cautions provide operators with important supplemental information concerning specific steps or sequence of steps in the E0Ps. The information on notes and cautions in Sections 11 and 12 should to be expanded and revised with regard to the following points:

a. Operators should be aware of all information in a note before they perform the step to which the note applies. Section 12.1 should be revised to indicate that notes will be piaced directly before the step or procedure to which they apply, even when the note " pertains to the results of the step".

b. To ensure that the flow of information to operators is'uninter-rupted, it is important that cautions and notes be presented entirely on one page. The writer's guide should be revised to indicate that each note and caution will appear entirely on a single page.

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15. To minimize confusion, delays, and errors in the execution of E0P steps, the following concerns should be addressed in the writer's guide:

a. Action steps should be structured to minimize the physical interference of personnel in the control room while carrying out procedural steps,

b. Action steps should be structured to avoid unintentional duplication of tasks.

16. Referencing of and branching to other procedures or sections of procedures can be disruptive and cause unnecessary delays. Section 14 should be revised as follows:

a. Section 14.1 states that the term referencing " implies that the procedure will be used as a supplement to the procedure presently being used". This definition of referencing is not clear and could lead to operator confusion during the execution of E0Ps.

For this reason, the definition of referencing should be revised to clarify the distihetion between referencing and branching.

b. Section 14 should be revised to provide the specific fonnatting of a branch and of a reference, and examples should be provided.

We recommend that GO T0 be used to indicate a branch and REFER T0 be used to indicate a reference. We further recomend that the step title and the entire step number be included in the reference, e.g., GO TO POP 05-EO-1, " Loss of Reactor Coolant",

Step 20. Partial step titles could be confusing in an emeroency.

c. Transitions to other procedures or sections of procedures can be disruptive and cause unnecessary delays. In order to facilitate rapid movement from one part of the E0Ps to another, some method for easily identifying sections or subsections in the E0P, such as tabbing, should be specified.

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17. The correct use of punctuation can significantly increase the understandability of procedures. The writer's guide should be revised to address the following problems:

a. The uses of hyphenation described in Sections 15.P.4,15.2.5, and 15.2.6 do not reflect standard English usage, do not appear to make these words less confusing, and should be avoided,

b. Section 15.3.2 instructs procedure writers to "use a colon to indicate that a list of items is to follow'. The lists in the examples in 7.6.1, 7.10.1, and 13.1.3 are not introduced by colons. The writer's guide should be revised so that examples are consistent with instructions in the text.

c. Section 15.3.4 should be revised to allow the use of parentheses for adverse containment conditions as discussed in Section 7.14

18. The proper use of emphasis techniques can contribute to the under-standability of procedures. The emphasis techniques discussed in the writer's guide should be revised with regard to the following:

a. In Sections 3.4.1.1 and 3.4.1.2, the headings " Symptoms of Inadeouate Core Cooling" and " Reactor Coolant Pump Trip Criteria" l are underlined. The text of the writer's guide does not contain instructions to underline such headings. If such headings are to be underlined, the text of the writer's guide should contain instructions to do so,

b. Section 8.5 indicates that the engraved terms on panels should be fully capitalized and underlined in E0Ps. This combination of emphasis techniques is similar to that used for logic terms and would detract from the emphasis of logic terms. For this ,

reason, we reconnend that engraved terms not be underlined.

c. In the example in Section 13.2.3, the word "use" is capitalized. The writer's guide requires that action verbs be capitalized, but "use" is not included in Addendum 6, the list of action verbs. The writer's guide should be revised to eliminate this inconsistency.

19. Vocabulary and syntax used in E0Ps should be readily understood by both procedure preparers and operators. Section 15.4.4 instructs procedure writers to " define key words that may be used in more than one sense". The use of word with more than one meaning could lead to operator confusion. This section should be revised to state that ambiguous terms will be avoided in E0Ps, and that all terms requiring definition will be defined in the list of acceptable tems.

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

a. Section 16.2 states that "the full meaning of the abbreviation, other than abbreviations listed in Addendum 4, should be written out before the first use and whenever in doubt". Because of the diverse nature of E0Ps, and the cross-referencing and branching between E0Ps, an operator might be directed into an E0P after the acronym had been initially defined. For this reason, definitions should be given in the list of acronyms rather than in the text of procedures, and only acronyms from Addendum 4, the List of Abbreviations, should be used.

b. Section 16.5 states that " acronyms may be used if they are defined or coimnonly used". Only acronyms that have been specifically defined in the list of approved acronyms should be used in E0Ps.

Section 16.5 should be revised to state that only acronyms from Addendum 4, the List of Abbreviations, should be used in E0Ps.

c. Many of the abbreviations in Addendum 4 stand for simple expressions, e.g., CLD for cold, DN for down, INL for inlet, LO for low, RM for room, and STRT for start. Such abbreviations could be eliminated without increasing the complexity of procedures; furthermore, these abbreviations would be more easily understood by operators if written out. We suggest that such abbreviations be used only if they are part of an engraved name and Addendum 4 be revised to include only abbreviations and acronyms that simplify complicated expressions.

d. Addendum 4 contains several abbreviations which stand for more than one expression, i.e., DPM for Decades Per Minute or Disintegrations Per Minute; POL for Polish, Polishing, or Polisher; REV for Reverse or Revision; and SYNCH for Synchronize or Synchroscope. The use of such ambiguous abbreviations in procedures could lead to operator confusion. The writer's guide should be revised so that each abbreviation and acronym stands for a single expression.

e. Addendum 4 contains several abbreviations that are similar to each other, e.g., CORT for Control and CONTR for Controller; j EXCS for Excess, EXCT for Excitation, EXH for Exhaust, EXP for

! Expansion, and EXTR for Extraction; H.P. for Health Physics and HP for High Pressure; IMP for Impulse ard IMPL for Impeller; POS for Positive and POSIT for Position; T/C for Thermocouple and Tc/TC for cold leg reactor coolant; and XFER for Transfer, XFMR for Transformer, and XMTR for Transmitter. Such abbrevi-ations could be easily confused by operators. Because such abbreviations would complicate rather than simplify procedures, we recommend that use of these abbreviations be minimized.

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f. Addendum 4 contains many abbreviations which are words themselves, i.e., ADD for Additive, BOOST for Booster, MINI for Minimum, MOIST for Moisture, PRESS for Pressure, TERM for Terminal, and VENT for Ventilation. Because operators could easily mistake these abbreviations for capitalized words, we recommend they be eliminated,

g. Addendum 4 includes the abbreviation Tc/TC for Cold Leg Reactor Coolant Temperature and Th/TH for Pot Leg Reactor Coolant Temper-ature. It appears that two alternative abbreviations are being oiven for each expression. Such redundant terminology needlessly complicates E0Ps and should be avoided. The writer's guide should be revised to address this concern.

21. E0Ps must be current to be usable. The writer's guide should describe a system for ensuring that the E0Ps are updated in a timely fashion when there are changes in the plant design, Technical Specifications, in the control room, or in other plant procedures that interface with the E0Ps.

P2. Because they will be used in stressful conditions and under time constraints, E0Ps must be easily accessible to operators and should be easily identifiable. The writer's guide should be expanded to address the availability of the E0Ps to control room staff and to indicate the manner in which E0Ps will be distinguished from other plant procedures. See NUREG-0899, Section 6.1, for additional guidance.

23. To preclude operator difficulty in reading E0Ps, it is important that the quality of E0P copies (e.g., legibility, completeness, color) approxinates the quality of the orioinal procedure. The writer's guide should be expanded to address this point. See NUREG-0899, Section 6.2.2, for further information.

C. Verification and Validation Program The description of the verification and validation program was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899. The objectives for the verification and validation process are as follows:

Are the E0Ps technically correct, i.e., do they accurately reflect the technical guidelines and other E0P source documents?

Are the E0Ps written correctly, i.e., do they accurately reflect the plant E0P writer's guide?

Are the E0Ps usable, i.e., can they be understood and followed without confusion, delays and errors?

Is there a parallel between the procedures and the control room / plant hardware?

Are the language and level of information presented in the E0Ps compatible with the minimum number, qualifications, training and experience of the operating staff?

Is there a high level of assurance that the procedures will work, i.e., do the procedures guide operators in mitigating transients and accidents?

Our review of the STP verification and validation program description identified the following concerns:

1. The PGP should specify that plant operators, subject matter experts, l procedure writers, and human factors experts should be involved in all phases of the verification and validation processes.

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

3. The validation program description states that either of the two validation test methods, E0P usage on the plant simulator or E0P walk-through validation, may be used, but does not adequately discuss the conditions under which each will be used. The validation program should be revised to address the following:

a. Section 6.2.2 of the E0P Preparation, Approval, and Implementation document should be expanded to include a description of the criteria that will be used to select the scenarios to be run during the validation process. The criteria should be developed on the basis of what is needed to validate the procedures and should ensure that single, sequential, and concurrent failures are included. A review of the capabilities and the limitations of the simulator will then identify what can be validated on the simulator.

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

4. The E0Ps will require a certain number of operators to carry out the various activities and steps as specified. The verification /

validation program should state that the E0Ps will be exercised during simulator exercises or control room walk-throughs with the minimum control room staff required by the facility Technical Specifications.

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5. The PGP should be expanded to discuss how the verification and validation program will account for the diMerences between units.

D. Training Program The description of the operator training program on the STP upgraded E0Ps was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899. All ifcensee operator candidates at STP will receive training prior to the implementation of E0Ps. Our review of the STP training program description for E0Ps I identified the following concerns:

1. The training program description does nnt include training objectives.

These E0P should be expanded to indicate that, after conclusion of training, trainees will:

a. Understand the philosophy behind the approach to the E0Ps, i.e.,

their structure and approach to transient and accident mitigation, including control of safety functions, accident evaluation and diagnosis and the achievement of safe, stable or shutdown conditions,

b. Understand the mitigation strategy and technical bases of the E0Ps, i.e., the function and use of plant systems, subsystems, components, in mitigation transients and accidents.

c. Have a working knowledge of the technical content of the E0Ps, i.e., they must understand and know how to perform each step in all E0Ps to achieve E0P objectives.

d. Be capable of executing the E0Ps (as individuals, and teams) under operational conditions, i.e., they must be able to carry out an E0P successfully during transients and accidents.

2. The training program description should be expanded to indicate all E0Ps will be exercised by all operators on the simulator or, for those areas not conducive to simulator training, in control room walk-throughs,

3. The training program should be expanded to indicate the use of a wide variety of scenarios, including simultaneous and sequential failures, to fully exercise the E0Ps on the simulator or in control room walk-throughs, thus exposing the operators to a wide variety of E0P uses,

d. The PGP should include that operators will be evaluated after training and that all operators will be evaluated.

This evaluation was performed with the assistance of Battelle Pacific Northwest Laboratories' personnel.

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