ML20155F861

Notification of Time Change for 870804 Meeting W/Util in Bethesda,Md to Discuss Emergency Operating Procedures Program & Direct Torus Vent Mod

ML20155F861
Person / Time
Site:	Pilgrim
Issue date:	07/29/1987
From:	Wessman R Office of Nuclear Reactor Regulation
To:	Nerses V Office of Nuclear Reactor Regulation
Shared Package
ML20151H280	List: ML20151H277 ML20155F838 ML20155F850 ML20155F854 ML20155F861 ML20155F866 ML20155F873 ML20155F878 ML20155F884 ML20155F887 ML20155F893 ML20155F897 ML20155F904 ML20155F911 ML20155F917 ML20155F920
References
FOIA-88-198 NUDOCS 8810130404
Download: ML20155F861 (29)

Text

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.A July 29n 1937 MEMORANDUM FOR: Victor Nerses, Acting Director Project Directorate I-3 '

Division of Reactor Projects 1/11 FROM: Richard Wessman, Project Manager Project Directorate I-3 Division of Reactor Projects I/t!

SUBJECT:

FORTHCOMING MEETING WITH BOSTON E0! SON COMPANY (BEcoi P!LGRIM NUCLEAR POWER STATION DATE & TIME: Tuesday, August 4. 1987 btGAM-3:00PM

\ O '0D M LOCATION: Phillips . 118 Phillips Building Bethesda, Maryland 1 PURPOSE:

f Te discuss Pilgrim Emergency Operating Procedures Program and Direct ToFJs Vent Modification PARTICIPANTS *: NRC BEco D essman D oward

-b Germ 4+y C. S. Brennion A. Thadani J. P. Gerety 1 W. Hodges Seu % g et al.

G. Thomas J. Kudrick

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I V ), U.S. NUCLEAR REGULATORY CO OrFICE OF NUCLEAR REACTOR REGULATION g . .s .,...f 13.5.2 OPERATINGAND(MAINTENANCEPROCEDUREh, REVIEV RESPONSIBILITIES Primary - Procedures and Systems Review Branch (PSRB)

Secondary - kone

1. AREAS OF REVIEV P$RB reviews the applicant's plan for development and implementation of operating and maintenance procedures as described in the applicant's Safety Analysis Report (SAR). This section of the SAR should describe the operating procedures that will be used by the operating organization (plant staff) to assurv that routine operat-ing, off-normal e and emergency activities are conducted in a safe manner. It is not expected that detaileo written procedures will be included in the SAR. The Preliminary Safety Analysis Report (PSAR) should describe preliminary schedules r for the preparation of procedures and the Final Safety Analysis Report (FSAR) should provide descriptions of the content and development process for procedures b as detailed below.

A. The FSAR or other submitted stction should describe the differerit classifi-cations of procedures the operators will use in the control room for plant operations. The group within the operating organization having the respon-siotitty for maintaining the procedure should be identified and the general format and content of the different classifications should be described. It is r.ot necessary that each appitcant's procedures conform precisely to the same classificatica since the objective is to assure that procedures will be available to the plant staff to accotsplish the functions contained in the listing of Regulatory Guide 1.33. For example some 11centees prefer a classification of abnormal operating p*ocedures whereas others may use of f-normal condition procedures. Examples of classifications follow:

Rev. 1 - July 1985 USNRC STANDARD REVIEW PLAN sue seea ees. Heae ce e'ww.* '* su ewWeau d tu o"we H Nwswo mune nowuiien enn ,w,eae; ie eu ,% en4. e esp.sei.... a sean,wu eas eeerce man me.., eisai. Tsue suwmean v. aes. .uusie a iwe >wne e een e tu i

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1. System Procedures. Procedures that provide instructions for energizing, filling, venting, draining, starting up, shutting down, changing modes of operation, returning to service following testing f (if not contained in the applicable testing procedure), and ottier instructions appropriate for operation of system toportant to safety.

2. General Plant Procedures. Procedures that provide instructions for f I

the 1,tegrated operations of the plant, e.g., startup, shutting down, shutdown, power operation and load changing, process monitoring, and l fuel handling. l Off-norsal Condition Procedures. Procedures that specify cperator 3.

actions for restoring an operating variable to its normal controlled I value when it departs from its rormal range or to restore normal operating conditions following a transient. Such actions are invoked fo11owing an operator observ'ation or an annunciator alars indicating a condition which, if not corrected, could degenerate into a condi-tion requiring action under an emergency operating procedure (E0P).

4. Emergency Operating Procedur4s. Procedures that direct actions nee-essary far the operators to mitigate the consequences of transients and accidents that cause plant parameters to exceed reactor protec-tion system or engineered safety features actuation setpoints.

5. Alars Procedures. Procedures that guide operator acticns for responding to plant alarms.

The FSAR should describe how maintenance and other operating procedures B.

are classified, what ;roup or groups within the operating organization Q' have the responsibility for maintaining and performing the duties pre-scribed in each class of procedures, and the general objectives and char-acteristics of each class. If their general objectives and characte*is-tics hre described elsewhere in the FSAR or application, these say be

, approximately referenced.

An acceptable procedures classification system for 18 is contained in Regulatory Guide 1.33.

C.

The F$AA or other submittal should describe the applicant's program for emergency operating procedures (A.4 above) and prevides a description of the required coi. tent of ths applicant's submitta). PSRB will review the appbcant's program for development and implementation of the E0Ps.

A Procedures Generation Package (PGP) for E0Ps should be sutaitted to NRC at least three months prior to the date the applicant plans to begin formal operator training on the E0Ps. The PGP should include:

1. Plant specific Technical Guidelines (P STGs). Guidelines based on analysis of transients and accidents that are specific to the The subeitted appileent's plant design and operating philosophy.

documentation of the P STGs will provide the basis for and include a reference to generic guidelines if used.

13.5.2-2 Rev. 1 - July 1985

For plants not referencing generic guidelines, this section should contain the action steps neLessary to mitigate transients and acci-dents in a format that allows mittgation without first having aiag-nosed the specific event, along 5 (th all supporting analyses, to meet the requirements of TN! Action Plan Item I.C.1. (NUREG-0737 and Supplement 1 to NUREG-0737).

For plants referencing generic guidelines, the submitted documenta-tion should include: 1) a description of the process used to Javelop plant-specific guidelines from the generic guidelines, 2) identift-cation of significant deviations from the generic guidelines includ-ing identification of additional equipment beyond that identified in the generic guidelines, along with all necessary engineering evalua-tion or analyses to support the adequacy of each deviation, and 3) a description of the process used for identifying operator information and control requirements. Er.amples of significant safety deviations are provided in Appendix A to this SRP section, subsection 3.3.2.

2. A plant-specific writers guide (P-SWG) that details the specific 3 methods to be used by the applicant in preparing E0Ps based on P STGs.

3. A description of the program for verification / validation (V/V) of E0Ps.

4. A description of the program for training operators on E0Ps.

PSRB coordtr.ates evaluations by other branches that involve the review of oper-1 ating and emintenance procedures. If an applicant references or provides unreviewed technical guidelines as the basis for the plant-specific E0Ps, PSRB j will conduct an initial review of the guidelines. If the unapproved guidelines incorporete significant technical changes from approved guidelines, then the PSRB may tex,est technical review by R58. R$8 will provide requests for addt-tional information, if necessary, and will provide SER input to P5RR.

4 11. ACCEPTANCE CRITERIA section 13.5.2 of the SAR constitutes additional evidence of the applicant's l technical qualifications, and forms a basis for a key part of the regulatory inspection program. Acceptance is based on meeting the relevant requirements of 10 CFR Part 50.34 as indicated below. Additional guidelines listed in this subsection provide guidance to applicants for meeting basic requirements.

A. Coepletion of operating and maintenance procedures. A generally accept-

! able target date for completion of operating and maintenance procedures is about sia months before fuel loading to allow adequate time for plant staff i familiarization and to allow NRC staff adequate time to develop operator

license examinations. The PGP for E0Ps must be submitted not later than

thret months prior to the date formal operator training on E0Ps is to begin.

I j 13.5.2-3 Rev. 1 - July 1985

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l S. Operating Procedures to be used by licensed operatort in the control room.

The regulations and staff guidelines applicable to this subsection are as y 1 follows:

1. 10 CFR Part 50, 550.34(a)(6) and (10) and $50.34(b)(6)(iv) and (v).

2. NUREG-0737, Clarification of TMI Action Plan, Item I.C.1, Guidance l l

for the Evaluation and Development of Procedures for Transients and Accidents. (Imergency Operating Procedures Only) l 4

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3. Supplement 1 to NUREG-0737, TM! Action Plan Items !.C.1 and I.C.9 Requirements for Emergency Response capability, Item 7, Subsection 7.1 and 7.2, Upgrade of Emergency Operating Procedures. (Emergency Oper-eting Procedures Only) l

4. The guidelines in the Regulatory Position Section of Regulatory Guide 1.33. '

1

5. The guidelines of ANS!/ANS 3.2 - 1982, Section 5.3.

6. Appendix A to Standard Review Plan, Section 13.5.2, Guidelines for the Evaluation of Procedures Generation Packages. (Emergency operat-ing Procedures only)

C. Other Operating and Maintenance Procedures. The regulations and staff guidelines applicable to this section are as follows: ,,

10 CFR Part 50, $50.34(a)(6) and 550.34(b)(6)(iv).

1.

2. The guidelines in the Regulatory Position Section of Regulatory Guide 1.33.

3. The guidelines of ANS!/ANS 3.2 - 1982, Section 5.3.

!!!. REVIEV PROCEDURES Review of the FSAR in accordance with this section consists of a detailed com-parison of the information submitted with the acceptance criteria of subsec-tion !! above. The PSAR review should encompass only the schedules for pruce-dures development and determination that the applicant cosetts to follow the applicable Regulatory Guides and Standards.

To supplement the expertise of the reviewer especially in tne htman factors area and to promote consistency among the PGP reviews, Appendix A identifies

.. the subjects which should be considered by the reviewer in the evaluation.

However, Appendix A is not a "checklist" and each item of Appendix A need not be addressed in the PGP to be acceptable.

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Normally the PGP review should be conducted prior to the date the applicant g,lans to begin formal operator training on the E0Ps.

If this is not possible j Spe- ,

because of a delayed submittal, perform an acceptance review of the' PGP. ,

cifically, audit the four parts of the PGP to detemine if there are any major If deficiencies in the E0P program that warrant postponing operator training.

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13.5.2-4 Rev. 1 - July 1985 l

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major deficienciss are found, identify the additional information necessary to  !

conduct the complete PGP review to the Licensing Project Manager 50 that the applicant can be notified prior to the initiation of training on the E0Ps. ,

I Review the PGPs for operating license applicants to determine if the applicant's program meets the requirements of Generic Letter 82-33. The review consists of the evaluation of the four parts of the PGP: The P-STGs, the P-5WG, the descrip-  !

tion of the program for V&V of the E0Ps, and the description of the training i

program for E0Ps necessary to support the conclusions described in Section IV below. To support this review Appendix A provides additional review guidance.

Review the P-STGs to determine if acceptable analyses of accidents and tran-sients and development of technical guidelines for operator actions applicable to the plant have been completed, and to determine if an acceptable process for identifying operator information and control needs has been described. Instead of being included in the PGP, this process may be described by the applicant in the documentation submitted for staff review in accordance with SRP 28.1, in support of the Detailed Control Room Design Review (DCRDR). The reviewer should coordinate review of this material with the Human Factors Engineering Branch (HFEB). It is expected that most applicants will reference generic technical guidelines.

For an app 1tcant using approved generic technical guidelines as the basis for its P-STG, the major portion of the review of the technical guidelines has been accoeplished generically. Staff SERs approving each of the four owners groups' ,

generic technical guidelines for use have been published and may be supplemented as guidelines are revised. To review this type of P*STG, review the process l described for converting generic technical guidelines into plant-specific pro- i c~ cedures to ensure that the safety significant deviations from the genet l

guidelines are controlled. Evaluate the technical adquacy of the iden. < df plant-specific deviations. Finally, evaluate the process for developmei the plant-specific information and control requirements necessary to use cae E0Ps.

The review of identified safety-significant deviations from generic technical guidelines will be conducted to the same level of detail as the generic techni-cal guidelines. Examples of safety-significant deviations are given in Appen-dix A, Subsection 3.3.2. Assistance from other technical review branches will be obtained as necessary to perfora a thorough review of the safety-significant deviations. Only safety-significant deviations need to be reviewed. However, the reviewer will determine that '.he applicant's program will control this pro-cess so that the work is auditable. It is expected that most applicants will i

J control the rocess by documenting all deviations,

' Since B&W plant ownero elected to use a lead plant concept rathee than generic technical guidelines, each &&W applicant's identified deviations from the lead J

plant's (Oconee) guidelines will be revivwed, l For appiteents not referencing generic technical guidelines, ensure that the l submittal inc19 des analysis of accidents and transients in accordance To do this, with the guidance of NUREG-0660 and HUREG-0737 Items 1.C.1 and I.C.9.

(1) become f amiliar with the integrated perfor.aance of the H555 and balance of plant systems, (2) evaluate the completeness of the accidents and transients analyzed. (3) evaluate the use of appropriate models, calculational methods, 13.5.2-5 Rev. 1 - July 1985

- _ _ . _ ___ _ __ - - - ____ - .-. - _=

and plant data, (4) cons'ider audit calculations of selected accidents and tran-sients, (assistance from other technical review branches required), (5) evaluate the adequacy of the applicant's program to develop guidelines from the analysis f of accidents and transients, (6) test the guidelines against scenarios includ-ing multiple failures, and (7) evaluate the information and control needs of the operators to 4xecute the instructions of the guidelines.

The P-5WG review will consider the adequacy of the methods of presentation of the technical information as E0Ps for the intended users of the E0Ps (e.g. ,

control room operators, shift supervisors, and auxiliary operators). Review the P-5WG by evaluating the applicant's methods for meeting the overall writer's guide objectives stated in NUREG-0899. Appendix A provides guidance to assist I the reviewer in making this evaluation. This guidance is not to be used as strict criteria, but is to be use as an aid in the overall evaluation of the P-5WG, Because strict criteria do not exist for the human factors evaluation, ,

the reviewer must make a professional judgment regarding tha Gequacy of the appiteent's methods as described in the P-5WG.

Review the V/V and training programs by comparing the program descriptions with the objectives of NUREG 0899.

The level of effort for these reviews will vary significantly. For example, the ef fort necessary to review the P-STG will vary depending on the number, complexity and significance of the plant-specific deviations from the approved generic technical guidelines.

If the review of the PGP does not provide suf ficient information to support the , . ,

conclusions of the Evaluation Findings section, the reviewer should obtain at least one E0P for review. As aproduat of the E0P program, the E0P(s) would then be additional information for judging the program's acceptability and will

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provide additional information as to how the applicant's program for develop-ment and implerentation of E0Ps should be modified to ensure that it contains suf ficient inforsation to assure acceptability of the resulting E0Ps.

When the reviewer has determined that each of the criteria of Section !! have been satisfied based upon the statements made by the applicant in the SAR, the review of Section 13.5. 2 is complete.

When the review has determined that each of these criteria has been satisfied based upon the statements made by the applicant in the SAR, the review of this i SRP section is complete.

l IV. EVALUATION FINDINGS The reviewer verifies that the information presented and his review support the following type of conclusion, to be used in the staf f's safety evaluation report:

The applicant's program for operating and maintenance procedures as described in the SAR is in accordance with 10 CFR 50.34, Regulatory Guide 1.33, and AN51/ANS 3.21982 Section 5.3 and is acceptable.< The ]

applicant's program for development of 70Ps has been reviewed and the staff concludes that:

13.5.2 6 Rev. 1 - July 1985 l

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1. In the area of the technical guidelines:

l (a) The E0Ps will be based upon acceptable technical guidelines derived from approved analyses of transients and accidents.

(b) Implementation of the applicant's described methods for conducting an anlysis of the operator's tasks should result in the identification of the instrumentation and cont *ols necessary to perfore the tasks specified in the P-STGs.

2. In the area of writer's guidance:

(a) The writer's guide provides sufficient information to help ensure that E0Ps developed using P-STGs will be useable, accurate, com-plete, readable, convenient to use, and acceptable to control ,

room personnel. I r

I (b) The methods described by the writer's guide appear sufficient to support upgrading of the procedures and to ensure long-ters con-sistency within and among procedures.

3. !aplementation of the described V/V program provides adequate assur-i ance that E0Ps are technically corrent and useable, follow the writer's 1 guide, correspond to the control room / plant hardware, and are com-patible with the minimum number, qualifications, training, and experience of the operating staf f. .

4. Isiplementation of the described training program should result in the w' operator understanding the philosophy behind the approach to the i

E0Ps, understanding the sitigative strategy ant

• technical basis of '

the E0Ps, having a working knowledge of the technical content of the E0Ps, and having the capability to execute the E0Ps under operational conditions.

The evaluation findings for this sattion should also include the following:

1. A statement that the applicant has coanitted to operate the p1Lnt in accordence with written and approved procedures. .

2. A brief description of the categories of procedures to be included.

3. A description of the review conducted to ensure that Supplement I to NUREG-0737 Itee 7. "Upgrade of Emergency Operating Procedures" has been toplemented.

y. IMPLEMENTATION The following is intended to provide guidance to applicants and licensees j

regarding the MAC staff's plans for using this SRP Section.

i i Except in those cases in which the applicant proposes an acceptable alternative

' method for complying with specified portions of the Coenissions' regulations, the method described herein will be used by the staff in its evaluation of con-I formance with Cennission regulations.

13.5.2-7 Rev. 1 - July 1985 l

Implementation schedules for conformance to parts of the methods discussed herein are contained in the referenced regulatory guides. NUREGS and in accor-dance with the following:

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a. This SRP revision is applicable to construction permit applicants.

Only the guidance pertaining to PSAR contents, i.e. , schedules and connitments to follow guidance in appropriate published documents, will be used as review guidance,

b. This SRP revision will be used by the staf f for judging the accept-ability of Operating Reactor licensees and operating license applicant emergency operating procedure program submittals made in accordance with Supplement 1 to HUREG-0737 - Requirements for Emer-gency Response Capability (Generic Letter 82-33). The review guid-ance in this SRP Section replaces the review guidance contained in Generic Letter 82-33.

VI. REFERENCES

1. ANSI /ANS 3.21982, "Standard for Administrative Controls for Nuclear Power Plants," American National Standards Institute.

2. Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)."

3. 10 CFR Part 50, 5 50.34, "Contents of Applications; Technical Inforsation."

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4. Regulatory Guide 1.70, "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants." \ j

5. NUREG-0737, Clarification of TM1 Action Plan Requirements.

6. Supplement 1 to NUREG-0737 Requirements for Emergency Response Capability (Generic Letter 82-33, December, 1982).

I 7. NUREG-0899, Guidelines for Preparation of Emergency Operating Procedures.

8. Generic Letters 83-05, 83 22, 83-23, and 83-31, Staff Safety Evaluation l

i Reports for Generic Technical Guidelines for GE, CE, W, and S&W plants, respectively.

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13.5.2-8 Rev. 1 - July 1985  !

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- - NUREG 0800 1Firmerly NUREG 75/0t?)

/ \, U.S. NUCLEAR REGULATORY COMMISSION i STANDARD REVIEW PLAN (7 OFFICE OF NUCLEAR REACTOR REGULATION g . . . . . ,/

i Appendix A to REVIEW PROCEDURES FOR THR EVALUATION SRP Section 13.5.2 0F PROCEDURES GENERATION PACKAGES Review Responsibilities Primary Procedures and Systems Review Branch (PSRS)

Secondary - None )

1.0 Backaround In August of 1982. NUREG-0899, "Guidelines for the Preparation of Emergency Oper-ating Procedures" was published. This. document is designed to "identify the elements necessary for licensees and applicants to prepare and implement Emergency

< e. Operating Procedures (E0Ps) that will provide the operator with directions to mitigate the consequences of a broad range of accidents and multiple equipment v failures." In addition to identiging these elements, the document also outlines the process by which licensees and applicants should develop, implement, and maintain E0Ps. To ensure that the elements are addressed in the new or upgraded procedures and that acceptable processes of development, ireplementation and main-l tenance are used, the staff identified a method of review that is intended .s p ro- l 1 vide confidence that E0Ps written or upgraded according to a given plant e program I

would be acceptable. The NRC staff believes that it is more important that they ]

ensure that the process used to generate procedures and their technical basis is '

sound and we11 documented, than to perfore a one-time review of E0Ps with no e  !

assurance that future E0P revisions are technically adequate and consistent with 1 i existing E0Ps. With this approach, responsibility for the generation and review

! of the E0Ps, as we11 as future revisions to E0Ps, is retained by th licensee.

In NUREG-0899, four aspects of E0P development and implementation are identified as providing an adequate basis for review. These are (1) plant specific technical guidelines (P-51G); (2) a plant-specific writer's guide; (3) a descrition of the 13.5.2-Al Rev, 0 - July 1985 USNRC STANDARD REVIEW PLAN 1 siended rece= pt a. ce p**pued to t** evideace e,t the o.meo et NueSen meeste.mesvietiea sten eos oppucatione to seasirvei ead epeeste awcies Pe=e pieat Theee doew.neate .. made e,siiente ie the twsw. es peri et the Commission a petcy se poorm the nuclear nadwetry and the eeneret tw6lse et tegwtetory peocedwres and seksies standeed rece= The l'

piene are not eietetitwtee fee tegvletery guides oe the Commission's regulatione and temphence with them is met toewired stendeed tesiew ple9 esto'*As are hoved to the stendeed Format and Coatent et saf ety Amelve r. Reporte to, Nwclose penet Pteau N ot att settsees et the stmassed iorma' have a tetreepeading revew plan.

! Pwbbehed steaderd rev,w plea will be f eceed Perioditelly, on appropriate. to attemmedete commemte sad to rehest een inf e'me tsoa one espe *4 ate Commente Once 04 Nycteer sad meowle. ctee peWetion. set **e Yosehemstem, fee 6mprovement D C 30M4 mits be seasidered and showid be sent to t*4 V s Nweleet Reg

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program for verification / validation of the E0Ps; and (4) a description of the f program for training operators on the E0Ps. Information on each of these items are to be provided as the "Procedures Generation Pachge" (PGP). The PGP for each plant will provide the licensee with a technical and human factors basis for developing its E0Ps and for making futurs revisions to its E0Ps.

The formal requirement for submitting this package is provided in Supplement 1 to NUREG-0737, "Requirements for Emergency Response capability" (Generic Letter No. 82-33). E0Ps at all plants will eventually be audited as a part of routine regaional inspections to ensure consistency with the PGP.  !

The purpose of this document is to provide guidance for reviewers during their evaluation of PGPs. The PGP is expected to contain specific information in each of its four parts. The review guidance below is divided into general ob-jectives and specific review guidelines. The listing of review guidelines represents what the staff believes should be considered by reviewers in deter-mining if the general objectives are inet. Because each of the objectives can be adequately addressed in many ways and may be satisfied without addressing each of the review guidelines, it will of ten be necessary for reviewers to use their expert judgment in determining the acceptability of a particular submit-tal. The general objectives and supporting documents such as NUREG 0899 and NUREG-0799 should be used as guidance in making these judgments. The methods  ;

provided in NUREG 0799 are an acceptable approach for preparing E0Ps. It should be recognized, however, that approaches other than those found in these docu-ments may be acceptable, and reviewers will need to use their judgment in deter- ,

mining the adequacy of the PGP. j ,

As described in the SRP, all PGPs will be reviewed by the staff. The review guidelines presented in Subsections 3 through 6 of this appendix provide addt-tional assistance to the reviewers. All applicants have the option of provid- ,

ing a justification for their approach where tt,sy disagree with a staff posi- I tion. When all issues are resolved or when the schedule dictates, the reviewer will prepare a Safety Evaluation Report (SER).

2.0 General Guidance to Reviewers 1

The guidance that follows is provided to assist the reviewer in using the crt-teria presented in Subsections 3 through 6 of this appendix, a

2.1 Reviewers should be eware that different degrees of objectivity (and thus, subjectivity) may be required in reviewing each of the four parts of the PGP since the parts say differ in detail and approach.

2.2 Reviewers should become very familiar with the General Objectives ,

associated with each section of a PGP. The specific reviou guide- 1 lines can serve as the basis for making the subjective evaluations of the general objectives. '

l 2.3 When an objective is not met or a specific responsi cannot be judged acceptable because of missing information, the reviewer should iden-tify the information that is missing and what is needed in the PGP to j make it acceptable.

2.4 Some items included in a PGP may not be addressed either within the general ebjectives or the specific review guidelines. These items l 13.5.2-A2 Rev 0 - July 1985

= _ _ - . _ _ _ _ - _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _-

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I must be evaluated carefully to ensure that unnecessary or possibly detrimental inclusions do not occur in the E0Ps (e.g. , an "E0P Def t-ciencies" section is not a desirable inclusion in an E0P).

2.5 As stated in the Background, most of the review guidelines are sub-jective in nature. The reviewer will have to jduge whether the dis-cussion of an item is sufficiently clear, complete and technically acceptable to achieve the objectives.

2.G In some instances the languege (i.e. , names, titles, etc.) used in the PGPs may be different from that used in this document, although the same subjects or items are being discussed. For example, format of "decision aids" may be covered under a PGP section entitled "job performance aids." Reviewers should be careful that identified PGP deficiencies are not based on semantics.

2.7 In some instances a particular subject may not appear to be addressed in the PGP, when in fact it is addressed in another part of the PGP.

For example, the determination of the adequacy of control room instru- ,

mentation and controls may not be addressed in the P-STG, but included l as a part of the validation / verification program. Reviewers usut therefore become familiar with the general objectives u d specific  ;

review guidelines as a whole so that these situations can be readily identified. l l

r 3.0 Plant-Specific Technical Guidelines .

j b 3.1 General Discussion i All licensees and applicants are required to subatt P-STGs. These gu Helines '

say be based on (1) generic technical guidelines (prepared by the owner's group),

or (2) a plant-specific reanalysis of transients and accidents as described in f TN! Action Piln Iten I.C.1. In either case, the P-STG should be based on the  ;

identificatio:s of plant systees and functions, and be supported ty an analysis of operator tasks to identify operator information and control needs. Among the four ap'jroved generic technical guidelines, operator task information is provided using different levels of detail. If generic technical guide)ines are referenced, the need for additional task specification will be different depend-ing upon the level of task information provided by the generic technical guide-lines, and the nature of deviations from the guidelines.

The information to be subettted in the PGP as P-STG is dependent on whether or not generic technical guidelines are used, as well as the degree to which plant specific characteristics (e.g., equipment) are consistent with the plant on which the generic technical guidance is based, j Some of the "deviations" that must be addressed as part of the P-STG submittal  !

l are differer.ces between the generic technical guidelines and the P STG. This l includas differences due to plant initiatives and those identified in the ge-neric guidelines as "plant specific" items. Only differences that are st.fety i significant, e.g., related to systees functions, or methods, should be re-viewed. Subsection 3.3.2 provides examples of other deviations that must also be addressed. Where an applicant does reference NRC approved generic to:hnical l

l 13.5.2 A3 Rev. 0 - July 1985 l l

-_____----_______.1

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However, safety signifi-guidelines, they should not submit those guidelines.

cant deviations from the altigative strategy should be described. Furthermore. l cppiteants using generic guidelines need not submit the detailed action steps.

The process for developing the action steps from the generic guidelines should be described. Applicants not using generic guidelines should submit, as a part of the P-STG, the action steps necessary to attigate transients and accidents, and supporting technical analysis and bases. The P-STG should have an orienta-tion that allows mitigation withert event diagnosis. In either case, the appli-cant should submit a description of how operator information and control needs were derived and used to specify instrumentation and control requirements.

This description :ay be in the PGP or in the Section of the FSAR addressed by SRP Section 18.1, Control Room.

The guidance presented below trientifies elements reviewers should consider in l determining acceptability of P-STG.

3.2 General Technical Objectives The purpose of the review of the technical guidelines submittal isA tolisting determine of that the following general objectives are adequately addressed.  ;

l specific evaluation elements are identified in Subsections 3.3 and 3.4  ;

3.2.1 The E0Ps will be based on acceptable technical guidelines derived from approved analyses of transients and accidents as described in NUREG 0660, Iten 1.C.1 and 1.C.9, as clarified by NUREG-0737 and l Supplement 1 to it, Item 1.C.1. The P-STG along with the generic '

guidelines (if referenced) and supporting documentation provide E0P '

writers with all the technical information necess3ry for preparing l l

E0Ps which direct operators' actions to attigate the consequences of '

transients and accidents without a need to first diagnose an event to maintain the plant in a safe c.ondition (function orientation).

Part of the acceptability of the P-STG is that the P-STG are ve11-

)

dated by the appitcant using methods acceptable to the reviewer (see NUREG-0899, Sections 2.6 and 4.2).

l 3.2.2 The PGP describes an adequate method to identify information and con-trol needs to be used as a basis for identifying control room instru-sentation and controls necessery to perfore the tasks specified in l

~

the technical guidelines.

3,3 Specific Review Guidelines - Plants Using NRC Approved Generic Technical J Guidelines i

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To determine that the appilcant's PGP adequately accomplishes the above objec-  ;

! tives, the reviewer should consider the following:

3.3.1 P STG Development

3. 3.1.1 Approved version of generic technical guidelines indicated.

3.3.1.2 A description of the process used to translate the generic l j

technical guidelines into the P-STG, l

Rev. 0 - July 1985 13.5.2-A4

i .

3.3.2 Deviations and Additions 3.3.2.1 Identification of safaty significant deviations from the NRC approved generic technical guidelines. Examples of deviations that should be considered are as follows:

a. any modification to the mitigative strategy of the generic technical guidelines (e.g. , for a Westinghouse plant, initial depressurizing the RCS following a stone generator tube rupture without first having con-ducted a limited cooldown in accordance with the guide-l lines to establish a margin to saturation).

l b, differences in equipment operating criteria (e.g., RCP

trip criteria, $1 injection teretnation criteria).

c. differences in equirment operating characteristics (i.e., between the plant specific equipment and that assumed in the generic analyses, such as 51 that can be throttled vs. only on/off).

d. identification of methods and equipment used to address the technical areas of the generic guidelines that are specified as "plant-specific."

l e, plant-specific setpoints or action levels that are calculated or determined in the manner other than s- specified in the generic technical guidelines, NOTE: Plant-specific setpoints (e.g., setpoints associated with automatic initiation of ECCS) called for by the generic guidelines need not be included in the P STG subatttal.

, f. actions that are taken in addition to those specified i

in the generic guidelines and that affect the attiga-

{ tive strategy.

i l 1. differences that affect the equipment's ability

) to adequately provide the necessary sitigative 4

function.

2. use of differant instruments or control parameters

, than those specified in the generic technical

! guidelines or deteretning instrumentation and control characteristics in a sanner different than, or with a different basis then, thet spect-fled in the generic technical guidelines.

3.3.2.2 Identification of items not covered by the NRC approved 3

generic technical guidelines (e.g., plant specific condi-i tions, equipment, operations, or bracketed ( ) information froe the generic technical guide *.ines that relate to sys-j tess, functions or methods).

13.5.2-A5 Rev. 0 - July 1985 i

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$. 3. 2. 3 Indication that the safety significant deviations and addt-tions have been identified and technically justified.

l The reviewer has the option of either reviewing Yi NOTE: i the complete P-STG with associated technical i justification, or reviewing only the identified i deviations from generic technical guidelines, l including technical justification consistent with '

the Generic Letter 82-33 requiremente. l 3.3.3 Technical Adequacy of Operator Actions (not covered by, or deviations from, the generic technical guidelines) i NOTE: The evaluation of the technical adequacy of operator actions (i.e., that the procedures will work) may be addressed in I the validation / verification sections of the PGP (i.e., at the completion of E0P development rather than during E0P

development). The P-STG portion of the PGP should describe how the licensee will determine if the approach taken is effectise in sitigating transients and accidents. ,

3.3.3.1 Description of the validation / verification of operator actions (to determine instr technical adequacy) l 3.3.4 Applicant's determination of the Need For and the Adequacy of Contrc1 Room Instrumentation and Controls for Emergency Operations 3.3.4.1 Description of the method used to determine information and .O control needs of the operators (function and task analysis) \,,, '

NOTE: The determination of the adequacy c.f control instrumentation and controls may be addressed in the validation / verification sections of t. oGP

. (i.e., at the conclusion of E0P development rathcr i

• than during E0P development). For the P-5TGs, adequacy of control room instrumentation and con-trols means that the available instrumentation and controls have been evaluated against the in-i formation and control needs of the operators and j it has been determined that the paraseters are l correct and that the instrument and control l 4 characteristics (e.g., instrument rangw, units, I

precision, rate and setpoints; control type, func-tion, rate, gain and response) seets the neede l identified. This may be in the PGP or the sec- i tion of the FSAR addressed by $PP 5ection 18.1.

3.3.4,2 Description of the method used to oetermine if the control L; room instrumentation and controls meet the information and l

contro'. needs of the operators. l 4

3.4 Specific Review Guidelines - Plants Not Using Generic Guidelines l i A

The review of the P-STGs for plants not referencing generic guidelines will be l performed using a methodology similar to that used to evaluate the acceptability 13.5.2 A6 Rev. 0 - July 1985 j

of the owner's group guidelines. The reviewer should evaluate analyses sub-sitted to support proposed accident recovery strategies. When necessary, the reviewer should request 051 (or other cognizant division) to evaluate analytta cal esodels. Isorovements in accident recovery techniques should be encouraged; however, in the review of alternate strategies the reviewer should obtain from the applicant sufficient technical bases to demonstrate that the plant remains within its F5AR licensing basis envelope (for licensing basis events).

The reviewer evaluates the effects or and resulting recovery strategies for transients and accidents, using the guidance available in NUREG-0737. The e STG reviewer should consider the following:

3.4.1 Analysis of transients and accidents (consistent with requirements

, ,,, of NUREG-0660 and NUREG-0737).

NOTE: The steps to be taken for this review are contained in the Review Procedures, SRP 5ection 13.5.2.

3.4.2 Validation of Technical Adequacy of Operator Actions NOTE: The evaluation of the technical adequacy of operator actions

. (i.e., that the procedures will work) say be addressed in the validation / verification sections of the PGP (i.e., at the completion of E0P developeint rathat than af ter P STG development). The P-STG portion of the PCP should describe (

I bow the applicant will determine if the approach taken is effective in nitigating transient and accidents, s ,r 3.4.2.1 Description of the validation / verification of operator actions 3.4.3 Determination of the need for and the adequacy of Control Room Instrumentation and Controls for emergency operation 3.4.3.1 Description of the method used to determine information and control needs of the operators NOTE: The deterstnation of the adequacy of control roon j instrumentation and controls may be addressed in '

the validation / verification sections of the PGP (i.e. , at the conclusion of E0P development rather than af ter P 5fG development) or in the part of the FSAR addressed by SRP 5ection 18.1, Control i

Room. For the P-STGs, adquacy of control roos instrumentation and controls means that the avail-able instrumentation and controls have been evaluated against the information and control needs of the operators and it has been determined

' that the parameters are correct and that the in-strument and control characteristics (e.g., in-strument range, units, precision, rate and set-points; control type, function, rate, gain and j

response) poet the needs identified.

13.5.2-A7 Rev. 0 - July 1985

3.4.3.2 Description of the method used to detemine if the control room instrumentation and controls meet the information and control needs of the operators fII 4.0 Writer's Guide (Plant Specific) Review 4.1 General Discussion Applicants are required to submit a writer's guide that details the specific methods to be used in preparing E0Ps which are based on the P-STGs. NUREG-0899 provides objectives and intent for the writer's guide. Because of the variety of available technical writing style guida and other references pertaining to 1 the presentation of information, the specific inforsation found in the writer's guide is upected to vary considerably among plants. To supplement the human factors expertise of the reviewer, review guidelines are provided that address instructions and guidance expected to be found in writer's guides. In addition, ,

the writer's guide should contain general, philosophical standards and informa- l tion which would assist the writers in preparing the E0Ps. l 4.2 General Writer's Guide Objectives The purpose of the evaluation is to determine if acceptable methods are described for accomplishing the following general objectives.

4.2.1 The writer's guide provides sufficient information for developing E0Ps from the P-STG, which are useable, accurate, complete, readable, convenient to use, and acceptable to control room personnel. .

4.2.2 The writer's guide supports upgrading of the procedures and long term consistency within and between procedures.

4.3 Specific Review Guidelines NOTE: Fo11owir.g each element, the number in parentheses casignates the specific section within NUREG-0899 where the element,is addressed.

Asterisked items are those which may appear in a procedure at the discretion of the npplicant. If they are used in the E0Ps, they should be addressed in the l writer's guide and considered in the review. Where a sample procedure is sub-sitted as a part of the writer's guide, the reviewer should verify that any non-required element included in the procedure is addressed in the writer's i guide. 1 I

J - To determine that the applicant's PGP includes methods which appear adequate to accomplish the above objectives, the reviewer should consider the following 1 4.3.1 Organtastion, Content, and Forset of Major Sections of the E0Ps (5.5)

]

4.3.1.1 Cover page (5.4.1) 4.3.1.2 Table of contents" (5.4.2)

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13.5.2 AS Rev. 0 July 1985

-w~v - rn -->- e

4.3.1.3 Scope statement (5.4.3) 4.3.1.4 Entry conditions (5.4.4) 4.3.1.5 Automatic actions * (5.4.5) 4.3.1.6 Content and Format of Operator Action Steps including (a) simple action steps, (b) steps which verify an action.

(c) steps of continuous or perisdic concern / applicability.

(d) steps for which a number of alternative actions are equally a:ceptable, and (e) steps performed concurrently with other steps, and (f) steps which lead the operator to the appropriate subsection of the E0Ps (5.4.6, 5.4.7, 5.7 5.8).

4.3.1.7 Figures and tables * (5.4.8 and 5.5.8) 4.3.1.8 Flowcharts an.1 decision aids" (5.4.8 and 5.5.9) 4.3.1.9 E0P page identifying information including title, procedure number, revision numb 6r and data, number of pages, unis designation (if applicable), fact 11ty designation, and location of identifying information in the E0P (5.5.1) 4.3.1.10 Page Layout including margins, line spacing, and steps complete on page (5.5.2) 4.3.1.11 Warnings (or Cautions) and Notes including placement, deft-nitions, emphasis and format, and warnings (Cautions) and notes complete on one page (5.3, 5.7.9, 5.7.10) 4.3.1.12 Placekeeping aids (5.5.4) 4.3.1.13 Emphasis techniques (5.5.6) 4.3.1.14 Olvisions Headings and Numbering of Pages and Steps (5.5.5) 4.3.2 Writing Style (5.6) 4.3.2.1 A vocabulary list - words to use, their definition, and words to avoid (5.6.1) ,

i

' 3.2.2 A list of abbreviations, acronyms and symbols, and late) consistency between procedures and control room (5.6.2) l 4.3.2.3 Sentence structure and Itait on actions per step (5.6.3) 4.3.2.4 Punctuation (5.6.4)

4. 'a, 2. 5 Capita 11:ation (5.6.5) ,

4.3.2.6 Units of seasure in the action steps and in the tab 1c', and figures should be consistent with presentation of inforea-tion in the cordf s) room (5.6.6) 13.5.2-A9 Rev. 0 - July 1985

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4.3.2.7 Numerals including type, use of decimals and signift- E cant digits (5.6.7) F 4.3.2.8 Tolerances (5.6.8) 4.3.2.9 Formulas and calculations" (5.6.9) 4.3.2.10 Titles / nomenclature of instrumentation and controls (what information to provide in the procedure and in what forsat)

(5.6.2)

)

4.3.3 Conditional and Logic Statements including format, style, emphasis; definition and use of logic terns; and logic terms and sequences to avoid (5.6.10 and Appendix B) 4.3.4 Referencing Other Procedures, Sections of Procedures or Subprocedures and Specific Steps Within a Procedure (5.2.2 and 5.5.7) j 4.3.4.1 Content and format of reference (5.2.2) l 4.3.4.2 The criteria used to determine when steps of a referenced procedure are to be included in an E0P (to minimize cross-referencing) (5.2.2) 4.3.4.3 Method for identifying sections or subsections (e.g., use j of tabbing) (5.5.7 and 6.1.4) '

4.3.5 When and how to present location Information (equipment, controls L..

and displays) (5.7.11) 4.3.6 Control Room Staffing and 831 vision of Responsibilities (5.4)

NOTE: This section addresses the need to consider operating crew staffing and responsibilities during the process of devel-eping E0Ps to help ensure efficient and effective imple-mentation of E0Ps during an emergency. Deficiencies in this regard may be identified by the appittant during vali-dation/ verification of the E0Ps. Subsection items 4.3.6.1 l through 4.3.6.4 say therefore be addressed under validation / 1 verification.

l

! 4.3.6.1 Structuring of E0Ps to ensure that minimum staffing can execute the E0Ps l

, 4.3.6.2 Designating the operators' responsiblittler in implementing ,

E0Ps (i.e., each operator will know wn., they have to do  ;

during an emergency; it is not necessai 'o specify roles. l in PGP or F0Ps) 4.3.6.3 Sequencing action steps to minimize physical interferer.ce between operators 4.3.6.4 Sequencing action steps to avoid their unintentional dupli-cation by operators 13.5.2-A10 Rev. 0 - July 1985

1

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'  ; 4.3.7 Use and Maintenance of E0Ps includin0 accessibility and quality of copies (6.0)

]

4.3.4 5tatesient of comunitment to use Writer's Guide in developing and revising the E0Ps 1

5.0 _ Program for Validation / Verification '

5.1 General Discussion All appitcants must submit a description of their programs for validating and verifying their E0Ps. locause of the lack of a consistent and clearcut dis-tinction between "validation" and "verification" within the nuclear industry, the staff has elected to bypass the semantic ambiguity by leaving their defini-i l

tion up to the individual appiteents; only the desired outcomes are specified  !

(independent of terminology). As a result, it is anticipated that there will l be considerable variation in the nature of the submittals, particularly with '

regard to the geldelines addressed under each item below (if distinguished),

and the amount of detail providea. Furthermore, both technical and human fac-tors aspects of the E0Ps are addressed by validation / verification activities, and submittals may integrate the two aspects under a given evaluation scheme.

For these reasons reviewers will have to exercise considerable judgment in their review of the submittals. The evaluation elements for validation /

vertf tcation were drawn from the six objectives identified in NUREG-0899 (sub-section 3.3.5.1) which are repeated below. These objectives should serve as the

,- aeneral basis for determining the acceptability of the validation / verification l l t 3 grams reviewed, l  %

) 5.2 General objectives The purpose of evaluating the validation / verification program is to ensure that

)

the following general objectives are set. A listing of specific evluation ele-eents is provided in Subsection 5.3.

l j 5.2.1 E0Ps are technically correct, i.e., they eccurately reflect the tech-j nical guidelines j

5.2.2 EOPs are written correctly, i.e. , they accurately reflect the plant-1 specific writer's guide 5.2.3 E0Ps are useable, i.e they can be understood and followed without confusion, delays, errors, etc.

5.2.4 There is a correspondence between the procedures and the control room /

plant hadware, i.e., controls, equipment, anu indications that are I

ref erenced, are available (inside and outside of the control rooa),

use the same destgr,etions, use the same units of measureeent, and operate as specified in the procedures 5.2.5 The language and level of inforsation presentation in the EOPs are compatible with the minimum number, qualifications, training and experience of the operating staf f 13.5.2 A11 Rev. 0 - July 1985 l

l

. l 1

5.2.6 There is a high It. vel of assurance that the procedures will work, i.e., the procedures guide the operator in mitigating transients and fl accidents I I

i 5.3 Specific Validation / Verification Asview Guidelines '

To aid the reviewer in the evaluation of the validation / verification program, l the reviewer should consider the fc11owing review guidelines:  ;

5. 3.1 Indication of the methods that will be used to meet each of the objec- l tives (as specified in subsection 5.2 above) of the validation / '

verification program: the specific combination of methods for poeting each objective thould be identified by the applicant so that the re- l viewer has assurance that thu objectives of the overall validation / '

verification program are met. In the staff's judgment, the fcilowing corbination of sethods should be used to meet each of the objectives:

l 5.3.1.1 Whether the E0Ps are technically correct. (i.e., whether l they accurately reflect the technical guidelines), is ex- 1 pecte1 to be evaluated by a combination of the following

. methods: (a) desk top review, (b) seminars, workshops,

! operating team review, and computer modeling/ analysis, i

5.3.1.2 Whether the E0Ps are written corrtetly (i.e., whether they securately reflect the (approved) plant-specific writer's guide), is expect to be evaluated by a combination of the .

following methods: (a) desk top review, and (b) seminars, workshops, operating team review. /

5. 3.1. 3 Whether there is a correspondence between the procedures and the control room / plant hardware, (i.e., controls, equip-ment, and indications that are referenced are avritable

. (inside and outside the cnntrol rooe), use the same desig-nations, use the same units of measurement, and operate as specified in the procedures) is expected to be evaluated by a combination of the following methods: (a) seetners, j workshops, operating team review. (b) control room walk- j throughs (static), and (c) simulation (if plant specific) l (static).

i 5.3.1.4 Wsther the E0Ps are usable (i.e. , they can be understood and followed without confusion, delays, errors, ett.) for the given level of qualifications, training, and asperience of the control room staff, is expected to be evalueted by a ,

( . combination of the following methods: (a) seminars, work- I shops, operating team review, (b) simulator exercises, and (c) control room walkthroughs (dynamic).

5.3.1.5 whether the language and level of information presentation in tbs E0Ps are compatible with the minimum control room i staffing and the qualifications, training, and experience of the cantrol room staf f 1s exp'ated to be evaluated by a coe.bination of the following methods: (a) desk top review, 13.5.2 A12 Rev. 0 - July 1985

(b) seminars, workshops, cperating team review (c) simula-toe exercises, and (d) control room walkthroughs (dynamic),

l 5.3.1.6 Whether there is a high level of assurance that the proco-  !

dures will work (i.e., the procedures guide the operator <

in mitigating transt6nts and accider,ts) is expected to be evaluated by a combination of the following methods:

(a) desk-top review (b) seminars, workshops, operating t:3m review (c) simulator exercises, and (d) control room I walkthroughs (dynamic).

5.3.2 Indigation that plant operators, subject matter experts, and proce- ,

dures writers are involved 5.3.3 Identification of the roles played by the participants (i.e., how I will operators, subject datter experts, etc., participate in the validation / verification process) (roles should be based on specific validation / verification objective being addressed) 5.3.4 Use of Scenarios Indication that the full complement of E0Ps are exercised, including multiple failures (simultaneous and sequential), and inclusion of criteria for selecting scenarios l l

, NOTE: Where a generic simulator is used, and to some extent, where a plant reference simulator is used, it will not be pos*1ble to fully exercise all parts of the E0Ps. In these insteaces.

the PGP should describe the method that the licensee wil)

! use to ensure that the validation / verification program will l cover areas missed in the simulator exercises. The follow-ing elem3nt is included to address this issue.

5.3.5 Indication that areas not cove'w by simulator exercises will undergo validation / verification 5.3.6 Description of the plan for correcting and revising E0Ps as a result

)

4 of the validatis'/vertf tcation and for feedback from simulator emer- .

I cites, control room walkthrough, desk top reviews, operating team l reviews and operator training to address accuracy, readability, use- -

l' ability, and completeness of tt.e E0Ps f 1

5.3.7 Stat,ennt of coannitsent to validate / verify revisions to E0Ps, when  !

j appropriate, and the conditions under wtitch revisions should be  !

l

' validated /vertfled

1. 5.3.4 Description of the method by which multiple units will be handled in the validation / verification process to account for unit differences NOTE: For multi-unit sites, the part of the validation / verification ,

process involving control room walk-throughs and use of operators should be carried out for each unit of a multi-unit site to the extent that the units differ in teres of

)

instrumentation, controls, equipaent (including availability i

13.5.2 A13 Rev. 0 - July 1985 I

of, design of, labeling of, or location of) or any other y aspect that may tapact p1&nt safety.

i 3.3.9 Indication that the 10Ps will be compatible with minimum control room staffing 5.3.10 Description of the plan by which adequacy (in terms of availability, readability and usability) of control room instrumentation and con-trols will be determined 5.3.11 Description of the plan by which correspondence between t0Ps and control room instrumentation and controls will be determined 5.3.12 Where available instrumentation and controls have not been evaluated

' against the inforsation and control needs of the operators as a part of the P-STG (see Subsection 3.3.4.2 and 3.4.3.2), they should be evaluated as a part of the validation /vertftcation program. The de-l I scription of the validation /vertf tcation program should include the method that will be used to deterstne the adequacy of control room j

instrumentation and controls in meeting the information and control needs of the operators [1.e., it has been deterstned that the param-eters are correct and that the instrument and control characteristics (e.g. , accuracy, scaling, etc.) neat the needs ide.itified).

NOTE: Stace many aspects of validation /vertftcation can be ad-i dressed during operator training, it is anticipated that I 1

appitcants will combine these activities to make more ef ficient use of simulator time. Where validation / Q vertf tcation is tied to the E0P training program it is necessary for appiteents to distinctly address validation /

verification through a formal process ehich documents re-suits and provides for feeding ints inforsation back into the 10P development process. The PGP should describe this process.

l h0TC: Where (0Ps are partially validated /vertfled on a generic 1

simulator, licensees should commit to performing the dynamic portion of the validation / verification of the 10Ps if a plant reference simulator becomes available.

6.0 Proaru for Operator Trainina on 10Ps 1

6.1 General 01scussion Applicants are to subett descriptions of their planned programs .*or training

operators on t0Ps. The intent of reviewing the E0P training program to to ensure that operators wt11 be trained prior to topleme..tation of the E0Ps. and I

that there is a reasonable asserence that the methods to be used in training i are adequate. This determination can be made by vertfying t%t the training progran meets the general training objectives identified in Subsection 6.2. To l! determine that these general objectives art met, the reviewer should consider g I the specific review guidelines of Subsection 6.3.

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13.5.2 A14 Rev. 0 - July 1985

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l 4.2 General E0P Training Program Objectives The purpose of the evaluation is to determine that the following general objec-tives are adequately addressed in the training program described by considering ,

the specific review guidelines provided. These guidelines are not intended to  !

represent all the necessary components of an adequate training program, but l rather to serve as a basis for assuring the staff that the operators have been i l trained prior to E0P implementation and that they will be capable of using the i E0Ps.

6.2.1 Trainees should understand the philosophy behind the approach to the E0Ps, i.e. their structure and approach to transient and accident eitigation, including control of safety functions, accident evalua-tion and diagnosis and the achievement of safe, stable or shutdown conditions.

6.2.2 Trainees should understand the mitigation strategy and technical bases of the E0Ps, i.e. , the function and use of plant systems, subsystems, components. in mit.lgating transients and accide ts.

6.2.3 Trainees should 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.

l 6.2.4 Trainees should be capable of executing the E0Ps )as indivduals and

/ teams) under operational conditions, i.e. , 'they must be able to carry q out an E0P successfully during trenstants and accidents.

6.3 Specific E0P Training Review Guidelines The reviewer should consider the following specific review guidelines in evalu-ating the description of the E0P training program:

6.3.1 Inclusion of training objectives consistent with Subsection 6.2 above i

j 6.3.2 Use of Steulator Exercises 6.3.2.1 Specification of plant-specific or generic simulation j J

1 l 6.3.2.2 Indication that all E0Ps will be exercised by all operators 1 Where a generic staulator is used, and to some WTE:

extent, where a plant reference simulator is used. l j

it will not be possible to fully exeN:tse all t parts of the E0Ps. In these instances, the PGP 1

should describe the method that the applicant will use to ensure that the validation / verification program will cover areas missed in the simulator l

j exercises. The following element is included to address this issue, I 6.3.2.3 A description of the method for training in areas not 1

covered by simulator exercises i

13.5.2-A15 Rev. 0 - July 1985 i

I 6.3.2.4 Indication of planned operator roles and team work 6.3.2.5 Indication of the use of a wide variety of scenarios (i.e.,

incorporating multiple, simultaneous and sequential, failures) 6.3.3 Use of Control Room Walk through j 6.3.3.1 Indication of walk through of all (0Ps by all operators

) 6.3.3.2 Indication of planned operator roles and team work

6. 3. 3. 3 Indication of use of a wide variety of scenarios (i.e.,

incorporating maltiple f ailures, simultaneous and l t sequential)

! 6.3.4 Use of lectures, discussion sessions, and seminars

! 6.4 Indication that operators will be trained crior to implementation of (ops

6.5 Indication that operators will be evaluated as part of the training  !

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11.5.2-A16 Rev. 0 - July 1985 l \

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PTEftNG NOTICE 015TRIBUT104:

• mut1 FILE 3 NRC Participants NRC POR g. vestman Fj Local POR o, Gormley .-

T. Murley/J. 5*.iezek A. ThadeM  !

F. Miraglia W, Hodges  :

OGC Bethesda J. Kudrick l E. Jordan J. Craig  !

ACRS(10) C. Tinkler ,l GPA/PA W. Regan V. Wilson J. Songarra ,

neceptionist Phillips Bldg. g. Boger -l .

BEco i Doward i C. 5. Brennion J. P. Gerety [

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