Number range CHAPTER **NRC INSPECTION MANUAL** COLP

INSPECTION PROCEDURE 42453

PART 52, OPERATING PROCEDURES INSPECTION

PROGRAM APPLICABILITY: 2504

42453-01 INSPECTION OBJECTIVES

01.01 To verify that plant procedures are reviewed and approved in
accordance with technical specifications and regulatory requirements.

01.02 To verify that the technical adequacy of the procedures is
consistent with the desired actions and modes of operation.

01.03 To verify the usability of procedure content and format by
determining the degree to which accepted human factors principles have
been incorporated.

01.04 To verify that temporary procedure changes were made in accordance
with plant administrative procedures and technical specification
requirements.

42453-02 INSPECTION REQUIREMENTS AND GUIDANCE

Licensee plans and procedures guiding the operation and maintenance of
reactor facilities are required by 10 CFR 50.34(b) and (f), as
referenced in 10 CFR 52.79.

02.01 [Sample Selection.]{.underline} Select a sample of at least 15
operating procedures from the following categories of written and
approved guides, steps, or instructions used by a licensee to prescribe
or guide the operation of the facility for review. Typical procedure
content is provided in Appendix A, \"Procedure Content.\"

> a\. Administrative Procedures
>
> b\. General Plant Operating Procedures
>
> c\. Safety Related System Startup, Shutdown, and Operation
>
> d\. Surveillance Test Procedures

02.02 [Procedure Administration.]{.underline} Verify that administrative
controls and responsibilities have been established for the review,
approval, and periodic updating of plant procedures that conform to
license requirements as spelled out in the license, Final Safety
Analysis Report (FSAR), and other facility licensing documents.

02.03 [Procedure Controls.]{.underline} Verify that controls have been
established in writing for the following:

> a\. Procedure preparation in the desired format and content.
>
> b\. Issuing new and revised procedures.
>
> c\. Control and disposition of outdated procedures.
>
> d\. Control of temporary changes to procedures.
>
> e\. Ensuring changes to procedures will be approved by the same
> organization that approved the original unless another qualified
> organization has been designated.
>
> f\. Ensuring that the training organization is informed of procedure
> changes.

02.04 [Procedure Usability.]{.underline} Review the procedures to:

> a\. Determine whether the procedures will accomplish the intended
> purpose within the design characteristics and the safety review
> considerations.
>
> b\. Verify that appropriate technical specification, vendor, or design
> operating limitations, such as heatup/cooldown rates,
> pressure/temperature limits, reactivity limits, safety limits,
> Limiting Conditions of Operation (LCOs), and limiting safety system
> settings, have been incorporated into the procedures.
>
> c\. Determine the degree to which accepted human factors principles
> have been incorporated into each type of procedure to verify that the
> procedures are usable. Determine usability by evaluating the
> procedures against the writing style and format standards established
> in the licensee\'s Writer\'s Guide.
>
> d\. Using the guidance in Appendix B, \"Procedure Usability,\"
> determine the quality of the Writer\'s Guide.
>
> 1\. If a Writer\'s Guide is not available, evaluate the procedures
> directly against the characteristics listed in Appendix B to determine
> the degree to which accepted human factors principles have been
> incorporated to make the information in the procedure clear and
> understandable to users.
>
> 2\. If the procedures were not prepared according to the guidance in
> the Writer\'s Guide, or if several characteristics from Appendix B are
> not evident in the initial sample, select an additional 5 - 10
> procedures for further review to determine the degree to which
> usability may be an issue.

02.05 [Interviews.]{.underline} Interview facility staff to determine
awareness and understanding of the system established for controlling
temporary changes to procedures.

42453-03 RESOURCE ESTIMATE

For planning purposes, 96 hours of on-site inspection effort should be
budgeted. Actual hours required to complete the inspection may vary from
the estimate. The hours expended during an inspection should be modified
for the facility licensee and accurately recorded.

42453-04 REFERENCES

10 CFR Part 50, "Domestic Licensing of Production and Utilization
Facilities."

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

ANSI 3.2, "Administrative Controls and Quality Assurance for the
Operational Phase of Nuclear Power Plants.\"

ANSI N45.2, \"Quality Assurance Program Requirements for Nuclear Power
Plants.\"

Regulatory Guide 1.114, "Guidance to Operators at the Controls and to
Senior Operators in the Control Room of a Nuclear Power Unit."

NUREG-0711, "Human Factors Engineering Program Review Model."

NUREG-0737, \"Clarification of TMI Action Plan Requirements."

NUREG/CR-1368, \"Development of a Checklist for Evaluating Maintenance,
Test and Calibration Procedures Used in Nuclear Power Plants.\"

NUREG/CR-1369, \"Procedures Evaluation Checklist for Maintenance, Test
and Calibration Procedures.\"

10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and
Combined Licenses for Nuclear Power Plants."

42453-05 PROCEDURE COMPLETION

Inspection of the minimum sample size will constitute completion of this
procedure in the Reactor Programs Systems (RPS).

END

Appendices:

A. Procedure Content

B. Procedure Usability

Attachment: Revision History for IP 42453

APPENDIX A

PROCEDURE CONTENT

Administrative Procedures: procedures that provide a clear understanding
of operating philosophy and management policies to ensure safe operation
of the plant within the limits set by the operating license and
Technical Specifications. They ensure that plant activities are
conducted in a manner that will protect the general public, plant
personnel, and equipment.

Administrative procedures should also include, as a minimum, a
definition of proper shift turnover and a description of what is
required for the proper transfer of responsibilities when a reactor or a
senior reactor operator on duty is relieved of control room
responsibilities during a shift or during shift change.

General Plant Operating Procedures: procedures used to guide operations
after reactor startup. General operating procedures include reactivity
control procedures.

Startup Procedures: procedures that direct reactor operation from
shutdown conditions, through startup, and up to power with the generator
synchronized. Startup procedures may also have special provisions for
scram recoveries. The review should focus on whether the procedure
adequately specifies plant conditions and prerequisites for startup and
the limits in effect during the startup.

Shutdown Procedures: procedures that guide system operations during and
following a controlled shutdown. They prescribe the subsequent actions
of operators after a scram has occurred, if the reactor is not to be
returned to power immediately. Conditions for these operations may be
controlled by a mode switch.

> Note: Shutdown operations, as well as startup operations, may be
> guided by a controlling procedure which refers to other procedures for
> equipment operation or these operations may be an integral part of the
> procedures.

System Operating Procedures: procedures that provide detailed steps to
ensure safe operation of the systems which support and control reactor
operation.

Surveillance Test Procedures: procedures written for each surveillance
test listed in the licensee's technical specifications. The procedures
are provided to ensure that tools, gauges, instruments, controls, and
other measuring and testing devices are properly controlled, calibrated,
and adjusted at specified periods to maintain accuracy in performing
surveillance for safety related equipment.

Abnormal Operating Procedures (alarm response procedures): procedures
that specify actions to restore an operating variable to its normal
controlled value when it goes out of normal bounds, or to restore normal
operating conditions following a perturbation. If the condition is not
corrected, it could degenerate into a condition requiring action under
an emergency procedure.

Emergency Operating Procedures: procedures which specify operator
actions to reduce the consequences of an accident or a hazardous
condition which has already occurred or developed. If the condition is
not corrected, or prepared for, a threat to the public health and safety
may occur, and portions or all of the emergency plan may have to be
invoked.

Standing orders: orders used to disseminate to the plant staff
instructions of a general and continuing nature. They may deal with such
items as job turnover and relief, definition of the duties of operators,
transmittal of operating data to management, filing of charts, etc.

Special orders or night orders: orders used to disseminate management
instructions that have short-term applicability. They deal with such
items as special operations, housekeeping, data taking, plotting process
parameters, personnel actions, etc.

Emergency Plan: procedures used to implement the site emergency plan.
Emergency Plan implementing procedures ensure timely and accurate
emergency classification, onsite and offsite notification and reporting
of emergency events, and identification and recommendation of onsite and
offsite protective actions.

Refueling Procedures: procedures used during refueling operations.
Refueling procedures include fuel receipt and inspection; preparations
for refueling including vessel head stud detensioning, vessel head
removal, removal of steam dryers and moisture separators, reactor vessel
cavity seal installation, and flooding of reactor cavity; refueling
bridge operation to include Local Power Range Monitor (LPRM) removal and
replacement; fuel movement from a flooded reactor cavity to a spent fuel
storage pool; control rod unlatching, removal, and installation; and
reactor vessel reassembly, including replacement of reactor vessel
O-Rings.

Technical support procedures: procedures that relate to activities such
as the conduct of preventive and corrective maintenance, measuring and
test equipment, radiation protection, and chemistry control.

APPENDIX B

PROCEDURE USABILITY

Incorporating human factors principles into procedures increases the
likelihood that the procedures will be easier to use and follow.
Standards for format and writing style will usually be found in the
licensee\'s writer\'s guide. Usability should be determined by
evaluating the degree to which procedures follow the guidance outlined
in the writer\'s guide.

When a writer\'s guide is not available or if the writer\'s guide is in
question, procedure usability can be determined by evaluating the
elements of writing style and format and organization. The list that
follows each element below describes characteristics that increase the
likelihood that a procedure will be performed successfully.

**WRITING STYLE** The information in a procedure is presented in a
manner that increases the likelihood that the task will be performed
successfully.

Procedures are more likely to be performed successfully if:

> ● The writing style is consistent among procedures within a department
> and within the same procedure type.
>
> ● The level of detail is appropriate for the complexity of the task
> and the expected ability of the users.
>
> ● Descriptions of actions to be taken are easy to understand and
> unambiguous.
>
> \- Action instructions are written as separate and positive commands.
>
> \- Short, simple sentences are used.
>
> \- Multiple actions are written in order of sequence and clearly
> identify when actions must be completed in order of occurrence.
>
> \- Acronyms and other abbreviations are used consistently and are
> defined explicitly.
>
> \- Quantitative words are used in instructions.
>
> ● References to equipment or documents contain complete identification
> information, including plant unit applicability, and exactly match
> equipment labels.
>
> ● Numerical units used in procedures correspond to the units on the
> related instrumentation.
>
> ● Conditional statements are presented using the appropriate format.
>
> \- IF and WHEN are used to present a condition.
>
> \- THEN is used to present an action.
>
> \- IF NOT is used in combination with THEN to present an alternative.
>
> \- NOT is used to emphasize an opposite condition (NOT running).
>
> \- AND is used to present all conditions that must be met before
> taking action.
>
> \- OR is used to present one or more conditions that must be met
> before taking action.

**FORMAT AND ORGANIZATION** An uncluttered appearance and clear
structure of the information in a procedure increase the likelihood that
the task will be performed successfully.

Procedures are more likely to be performed successfully if:

> ● Organization is hierarchical, logical, consistent, and reveals the
> organization to users through the use of headings.
>
> ● Step numbering and structure is not overly complex.
>
> ● Appendices and attachments provide explicit guidance for their
> allowed use and present relevant information that would be difficult
> to integrate into the procedure.
>
> ● Figures and charts are explicitly and uniquely identified so they
> are easy to find within the procedure.
>
> ● Procedure identification information is adequate to ensure the
> procedure is complete and current.
>
> ● Procedure is legible in the worst expected conditions for use. Type
> is readable (1) at an expected distance within which the procedure is
> used, (2) after copying and (3) under degraded lighting.
>
> ● Job aids are used to help users to track their progress through a
> procedure where applicable.
>
> ● Warnings, cautions and notes (WCNs) are consistent within a
> department and within a procedure type.
>
> \- WCNs are obvious and address a single topic.
>
> \- WCNs are linked to the related procedure step.
>
> \- WCNs contain no actions.
>
> \- Warnings and cautions identify the consequence of wrong action.
>
> \- Notes supply only supplemental information.
>
> ● The final step is clearly indicated.
>
> ● Checklist information reflects the sequence of information in the
> steps of the procedure.

Procedure Evaluation Checklist

Procedure Title/No.

Revision Reviewed by Date

Review the procedure for each of the following items. If the procedure
possesses the attribute described in the item, check Yes; if the
procedure lacks the attribute, check No. Check N/A (Not Applicable) if
the attribute does not apply to the procedure.

An example given in a checklist item is only one way of meeting the
evaluation criterion and should not be interpreted as the only way of
meeting the criterion.

+---+-------------------------------------------------------+---+---+---+
|   | Attribute                                             | Y | N | N |
|   |                                                       | e | o | / |
|   |                                                       | s |   | A |
+===+=======================================================+===+===+===+
| 1 | Is the procedure format consistent for all procedures |   |   |   |
|   | within a group?                                       |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Are page margins adequate?                            |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Is the title short and descriptive of the purpose of  |   |   |   |
|   | the procedure?                                        |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | If the purpose of the procedure is not clear from the |   |   |   |
|   | title, is there a statement of scope or purpose which |   |   |   |
|   | clearly specifies the function the procedure          |   |   |   |
|   | performs? The description should appear in an         |   |   |   |
|   | introductory section preceding the instructions.      |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 5 | If the procedure is scheduled maintenance or tests,   |   |   |   |
|   | does the title state the frequency, e.g., weekly,     |   |   |   |
|   | monthly?                                              |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 6 | Does the procedure cover or first page provide the    |   |   |   |
|   | following identification information?                 |   |   |   |
|   |                                                       |   |   |   |
|   | a\. Title                                             |   |   |   |
|   |                                                       |   |   |   |
|   | b\. Procedure number                                  |   |   |   |
|   |                                                       |   |   |   |
|   | c\. Revision number and date                          |   |   |   |
|   |                                                       |   |   |   |
|   | d\. Unit number (if applicable)                       |   |   |   |
|   |                                                       |   |   |   |
|   | e\. Approval signature and date                       |   |   |   |
|   |                                                       |   |   |   |
|   | f\. Number of pages                                   |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 7 | If this is a multiple unit site, does the procedure   |   |   |   |
|   | refer to one unit only and is it readily identifiable |   |   |   |
|   | to that unit?                                         |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 8 | Does each page provide the following identification   |   |   |   |
|   | information?                                          |   |   |   |
|   |                                                       |   |   |   |
|   | a\. Title or number                                   |   |   |   |
|   |                                                       |   |   |   |
|   | b\. Revision number and date                          |   |   |   |
|   |                                                       |   |   |   |
|   | c\. Unit number (if applicable)                       |   |   |   |
|   |                                                       |   |   |   |
|   | d\. Page \_\_\_ of \_\_\_                             |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 9 | Is the location of page identification information    |   |   |   |
|   | consistent?                                           |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | Is the last page of the procedure clearly identified  |   |   |   |
| 0 | by marking, e.g., Page \_\_\_ of \_\_\_ or Final      |   |   |   |
|   | Page?                                                 |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | If this is a temporary procedure, is it clearly       |   |   |   |
| 1 | marked with the expiration date?                      |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | Does the procedure provide the following job planning |   |   |   |
| 2 | information?                                          |   |   |   |
|   |                                                       |   |   |   |
|   | a\. Other actions or procedures which must be         |   |   |   |
|   | completed prior to use.                               |   |   |   |
|   |                                                       |   |   |   |
|   | b\. Plant, system, or equipment conditions which must |   |   |   |
|   | exist prior to use.                                   |   |   |   |
|   |                                                       |   |   |   |
|   | c\. Precautions which must be observed in the         |   |   |   |
|   | performance of the procedure. For example, are        |   |   |   |
|   | applicable radiological requirements and precautions  |   |   |   |
|   | specified?                                            |   |   |   |
|   |                                                       |   |   |   |
|   | d\. The specific equipment (by part number and/or     |   |   |   |
|   | unique nomenclature) to which the procedure is        |   |   |   |
|   | applicable.                                           |   |   |   |
|   |                                                       |   |   |   |
|   | e\. Special tools and test equipment required to      |   |   |   |
|   | perform the procedure (by part number and/or unique   |   |   |   |
|   | nomenclature).                                        |   |   |   |
|   |                                                       |   |   |   |
|   | e\. Other documents, e.g., procedures, drawings,      |   |   |   |
|   | schematics, required to perform the procedure.        |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | If more than one person is required to perform the    |   |   |   |
| 3 | procedure, is the procedure written to one            |   |   |   |
|   | \'primary\' user? That is, is it clear from the way   |   |   |   |
|   | that instructions are written that one person is      |   |   |   |
|   | responsible for coordinating the activity? For        |   |   |   |
|   | example, is critical communication between persons    |   |   |   |
|   | located remotely from each other specified?           |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | Does the procedure provide adequate quality control   |   |   |   |
| 4 | hold points?                                          |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | Does the procedure provide for verification and       |   |   |   |
| 5 | signoff of actions?                                   |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | If the answer to #15 is Yes, are the verifications    |   |   |   |
| 6 | predominately performed by persons other than those   |   |   |   |
|   | performing the action?                                |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| N |                                                       |   |   |   |
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| . |                                                       |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | Are instructions written in short, concise, numbered  |   |   |   |
| 7 | steps as opposed to multi-step paragraphs?            |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | If explanations/cautions are applicable to the        |   |   |   |
| 8 | performance of specific steps or series of steps, are |   |   |   |
|   | they placed immediately ahead of the step(s) to which |   |   |   |
|   | they apply?                                           |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 1 | Are explanations/cautions separate and easily         |   |   |   |
| 9 | distinguishable in appearance from instructional      |   |   |   |
|   | steps? For example, are they enclosed in boxes, typed |   |   |   |
|   | in bold face letters, headed with the word CAUTION,   |   |   |   |
|   | NOTE, etc.?                                           |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Can the text of a explanation/caution be read without |   |   |   |
| 0 | interruption by intervening steps or page turning?    |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Do explanations/cautions avoid the use of action      |   |   |   |
| 1 | statements? (Statements directing personnel to        |   |   |   |
|   | perform actions must not be imbedded in               |   |   |   |
|   | explanations/cautions. Explanations/cautions should   |   |   |   |
|   | be expressed in the passive voice.)                   |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Do graphs, charts, tables, and figures meet all of    |   |   |   |
| 2 | the following criteria?                               |   |   |   |
|   |                                                       |   |   |   |
|   | a\. They are compatible with the procedure.           |   |   |   |
|   |                                                       |   |   |   |
|   | b\. They are legible and readable under expected      |   |   |   |
|   | conditions of use.                                    |   |   |   |
|   |                                                       |   |   |   |
|   | c\. Values can be extracted or interpolated easily    |   |   |   |
|   | and with required accuracy, e.g., nonlinear scales    |   |   |   |
|   | are not used.                                         |   |   |   |
|   |                                                       |   |   |   |
|   | d\. Units of scale and measurement are readily        |   |   |   |
|   | available and usable to the operator.                 |   |   |   |
|   |                                                       |   |   |   |
|   | e\. Titles are descriptive of contents and use.       |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Do worksheets provide enough space to record data and |   |   |   |
| 3 | perform necessary calculations? For example, in       |   |   |   |
|   | calibration procedures are there provisions for an    |   |   |   |
|   | "as found" column and an "as left" column?            |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Does the procedure (or related data sheets or         |   |   |   |
| 4 | worksheets) provide for independent verification and  |   |   |   |
|   | signoff of computations?                              |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Are acceptance criteria and limits stated in          |   |   |   |
| 5 | quantitative terms?                                   |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Are units expressed as ranges rather than point       |   |   |   |
| 6 | values whenever possible?                             |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | Are acceptance criteria and limits stated compatible  |   |   |   |
| 7 | with limits specified in requirements documents?      |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | If computations are required by the procedure, are    |   |   |   |
| 8 | the computations based on technically accurate,       |   |   |   |
|   | complete, and up-to-date formulas?                    |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 2 | If items (valves, breakers, relays, solenoids,        |   |   |   |
| 9 | jumpers, fuses, switches) require alignment to        |   |   |   |
|   | perform the procedure, do the alignment instructions  |   |   |   |
|   | in the procedure meet all of the following criteria?  |   |   |   |
|   |                                                       |   |   |   |
|   | a\. Each item requiring alignment is individually     |   |   |   |
|   | specified (It is NOT acceptable to refer personnel to |   |   |   |
|   | previous steps.)                                      |   |   |   |
|   |                                                       |   |   |   |
|   | b\. Each item is identified with a unique number or   |   |   |   |
|   | nomenclature.                                         |   |   |   |
|   |                                                       |   |   |   |
|   | c\. The position in which the item is to be placed is |   |   |   |
|   | specified.                                            |   |   |   |
|   |                                                       |   |   |   |
|   | d\. The position in which the item is placed is       |   |   |   |
|   | verified and checked off or signed off.               |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | If any of the alignment instructions in step 29 are   |   |   |   |
| 0 | for system restoration, is the verification performed |   |   |   |
|   | by someone other than the person performing the       |   |   |   |
|   | alignment?                                            |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | If any follow-on action, test, or procedure must be   |   |   |   |
| 1 | performed upon completion of the procedure, does the  |   |   |   |
|   | procedure or related document (e.g., work order)      |   |   |   |
|   | instruct the user regarding what follow-on action is  |   |   |   |
|   | required and whom to notify?                          |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Does the procedure provide instructions for           |   |   |   |
| 2 | reasonable contingencies? For example, if equipment   |   |   |   |
|   | is operating outside the range specified by the       |   |   |   |
|   | procedure, is the person instructed as to what action |   |   |   |
|   | to take?                                              |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Are contingencies written in a consistent style and   |   |   |   |
| 3 | expressed so that the conditional statement precedes  |   |   |   |
|   | the action statement?                                 |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Are contingency instructions easy to understand? For  |   |   |   |
| 4 | example, if three or more conditions are associated   |   |   |   |
|   | with an action, they should be listed separately from |   |   |   |
|   | and ahead of the action statement.                    |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Are the titles and numbers of all referenced          |   |   |   |
| 5 | documents identified correctly and consistently?      |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Does the procedure contain provisions for             |   |   |   |
| 6 | coordinating the activities of others? For example,   |   |   |   |
|   | is there a checklist for a coordinator to record that |   |   |   |
|   | an action has been completed?                         |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Are the instructions printed in both upper and lower  |   |   |   |
| 7 | case letters as conventionally used as opposed to all |   |   |   |
|   | upper case letters? (Capitalization can be used to    |   |   |   |
|   | emphasize individual words in sentence, and must be   |   |   |   |
|   | used when referring to labels on equipment.)          |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Is there consistent use of the following?             |   |   |   |
| 8 |                                                       |   |   |   |
|   | a\. Abbreviations, acronyms, and symbols              |   |   |   |
|   |                                                       |   |   |   |
|   | b\. Methods of emphasis                               |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 3 | Are the steps that must be performed in a fixed       |   |   |   |
| 9 | sequence clearly distinguishable from steps that do   |   |   |   |
|   | not have to be performed in a fixed sequence?         |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | Does each instructional step direct only one action?  |   |   |   |
| 0 |                                                       |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | Does each instructional step meet the following       |   |   |   |
| 1 | criteria?                                             |   |   |   |
|   |                                                       |   |   |   |
|   | a\. The action to be taken is specifically identified |   |   |   |
|   | (open, turn, shut).                                   |   |   |   |
|   |                                                       |   |   |   |
|   | b\. Limitations are expressed quantitatively, e.g., 2 |   |   |   |
|   | turns, 80 (75-85) gpm.                                |   |   |   |
|   |                                                       |   |   |   |
|   | c\. Equipment and parts are identified clearly and    |   |   |   |
|   | unambiguously.                                        |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | If a step contains three or more objects of an        |   |   |   |
| 2 | action, are they listed rather than embedded in the   |   |   |   |
|   | sentence? For example, if an operator is directed to  |   |   |   |
|   | close three or more valves, they should be displayed  |   |   |   |
|   | as a list rather than strung out in a sentence.       |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | Are instrument readings, control values, and other    |   |   |   |
| 3 | limits used to guide operator actions expressed in    |   |   |   |
|   | quantitative terms when possible?                     |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | If the procedure specifies an action that must be     |   |   |   |
| 4 | performed at a later time or repeated at periodic     |   |   |   |
|   | intervals, does it provide a means to assist the      |   |   |   |
|   | operator in performing the step(s) within the         |   |   |   |
|   | required time frame? For example, if an action must   |   |   |   |
|   | be repeated every 15 minutes, are there spaces for    |   |   |   |
|   | the operator to record the times at which the action  |   |   |   |
|   | must be performed?                                    |   |   |   |
+---+-------------------------------------------------------+---+---+---+
|   |                                                       |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| P |                                                       |   |   |   |
| e |                                                       |   |   |   |
| r |                                                       |   |   |   |
| f |                                                       |   |   |   |
| o |                                                       |   |   |   |
| r |                                                       |   |   |   |
| m |                                                       |   |   |   |
| a |                                                       |   |   |   |
| W |                                                       |   |   |   |
| a |                                                       |   |   |   |
| l |                                                       |   |   |   |
| k |                                                       |   |   |   |
| - |                                                       |   |   |   |
| t |                                                       |   |   |   |
| h |                                                       |   |   |   |
| o |                                                       |   |   |   |
| u |                                                       |   |   |   |
| g |                                                       |   |   |   |
| h |                                                       |   |   |   |
| o |                                                       |   |   |   |
| f |                                                       |   |   |   |
| t |                                                       |   |   |   |
| h |                                                       |   |   |   |
| e |                                                       |   |   |   |
| P |                                                       |   |   |   |
| r |                                                       |   |   |   |
| o |                                                       |   |   |   |
| c |                                                       |   |   |   |
| e |                                                       |   |   |   |
| d |                                                       |   |   |   |
| u |                                                       |   |   |   |
| r |                                                       |   |   |   |
| e |                                                       |   |   |   |
| f |                                                       |   |   |   |
| o |                                                       |   |   |   |
| r |                                                       |   |   |   |
| I |                                                       |   |   |   |
| t |                                                       |   |   |   |
| e |                                                       |   |   |   |
| m |                                                       |   |   |   |
| s |                                                       |   |   |   |
| # |                                                       |   |   |   |
| 4 |                                                       |   |   |   |
| 6 |                                                       |   |   |   |
| a |                                                       |   |   |   |
| n |                                                       |   |   |   |
| d |                                                       |   |   |   |
| # |                                                       |   |   |   |
| 4 |                                                       |   |   |   |
| 7 |                                                       |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | Are equipment numbers and/or nomenclature used in the |   |   |   |
| 5 | procedure the same as those which are displayed on    |   |   |   |
|   | the equipment?                                        |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | Are the units of measurement used in the procedure    |   |   |   |
| 6 | the same as those displayed on instruments?           |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| O |                                                       |   |   |   |
| b |                                                       |   |   |   |
| s |                                                       |   |   |   |
| e |                                                       |   |   |   |
| r |                                                       |   |   |   |
| v |                                                       |   |   |   |
| e |                                                       |   |   |   |
| a |                                                       |   |   |   |
| S |                                                       |   |   |   |
| i |                                                       |   |   |   |
| m |                                                       |   |   |   |
| u |                                                       |   |   |   |
| l |                                                       |   |   |   |
| a |                                                       |   |   |   |
| t |                                                       |   |   |   |
| i |                                                       |   |   |   |
| o |                                                       |   |   |   |
| n |                                                       |   |   |   |
| o |                                                       |   |   |   |
| r |                                                       |   |   |   |
| P |                                                       |   |   |   |
| e |                                                       |   |   |   |
| r |                                                       |   |   |   |
| f |                                                       |   |   |   |
| o |                                                       |   |   |   |
| r |                                                       |   |   |   |
| m |                                                       |   |   |   |
| a |                                                       |   |   |   |
| n |                                                       |   |   |   |
| c |                                                       |   |   |   |
| e |                                                       |   |   |   |
| o |                                                       |   |   |   |
| f |                                                       |   |   |   |
| t |                                                       |   |   |   |
| h |                                                       |   |   |   |
| e |                                                       |   |   |   |
| P |                                                       |   |   |   |
| r |                                                       |   |   |   |
| o |                                                       |   |   |   |
| c |                                                       |   |   |   |
| e |                                                       |   |   |   |
| d |                                                       |   |   |   |
| u |                                                       |   |   |   |
| r |                                                       |   |   |   |
| e |                                                       |   |   |   |
| f |                                                       |   |   |   |
| o |                                                       |   |   |   |
| r |                                                       |   |   |   |
| t |                                                       |   |   |   |
| h |                                                       |   |   |   |
| e |                                                       |   |   |   |
| F |                                                       |   |   |   |
| o |                                                       |   |   |   |
| l |                                                       |   |   |   |
| l |                                                       |   |   |   |
| o |                                                       |   |   |   |
| w |                                                       |   |   |   |
| i |                                                       |   |   |   |
| n |                                                       |   |   |   |
| g |                                                       |   |   |   |
| I |                                                       |   |   |   |
| t |                                                       |   |   |   |
| e |                                                       |   |   |   |
| m |                                                       |   |   |   |
| s |                                                       |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | Determine whether the amount and kind of information  |   |   |   |
| 7 | (level of detail) provided by the procedure are       |   |   |   |
|   | adequate for the intended users. Are the following    |   |   |   |
|   | criteria met?                                         |   |   |   |
|   |                                                       |   |   |   |
|   | a\. Can the procedure be performed in the sequence in |   |   |   |
|   | which it is written?                                  |   |   |   |
|   |                                                       |   |   |   |
|   | b\. Can the user locate and identify all equipment    |   |   |   |
|   | referred to in the instructions?                      |   |   |   |
|   |                                                       |   |   |   |
|   | c\. Where general rather than specific instructions   |   |   |   |
|   | are provided, can the user explain in detail how to   |   |   |   |
|   | perform the general instructions?                     |   |   |   |
|   |                                                       |   |   |   |
|   | d\. Can the user perform the procedure without        |   |   |   |
|   | obtaining additional information from persons or      |   |   |   |
|   | documents not specified by the procedure?             |   |   |   |
|   |                                                       |   |   |   |
|   | e\. Can the user perform the procedure without        |   |   |   |
|   | obtaining direct assistance from persons not          |   |   |   |
|   | specified by the procedure?                           |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | If the procedure contains sequence-critical actions,  |   |   |   |
| 8 | is the sequence specified by the procedure correct?   |   |   |   |
|   | (Observe whether the operator performs                |   |   |   |
|   | sequence-critical actions in the sequence specified.) |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 4 | Does the procedure allow enough time to perform       |   |   |   |
| 9 | time-critical actions? (Observe whether the operator  |   |   |   |
|   | can perform time-critical actions in the time         |   |   |   |
|   | allowed, i.e., by equipment response, equipment       |   |   |   |
|   | location, distances involved, etc.)                   |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 5 | Does the procedure identify equipment adequately?     |   |   |   |
| 0 | (Determine whether the operator can readily identify  |   |   |   |
|   | all equipment and items referred to in the            |   |   |   |
|   | procedure.)                                           |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 5 | Are references to equipment in the procedure          |   |   |   |
| 1 | identical to the labels displayed on the equipment?   |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 5 | If the answer to Item #51 is Yes, are references to   |   |   |   |
| 2 | equipment labels typed in upper case letters in the   |   |   |   |
|   | procedure?                                            |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 5 | Does the procedure identify the location of each item |   |   |   |
| 3 | of equipment adequately? (Observe whether the         |   |   |   |
|   | operator can locate switches, gages, etc. in a timely |   |   |   |
|   | manner.)                                              |   |   |   |
+---+-------------------------------------------------------+---+---+---+
| 5 | Is the sensitivity of the test instruments and tools  |   |   |   |
| 4 | being used adequate and are they in proper            |   |   |   |
|   | calibration?                                          |   |   |   |
+---+-------------------------------------------------------+---+---+---+

ATTACHMENT 1

[Revision History for IP 42450]{.underline}

+--------+--------+---------------+----------+----------+--------------+
| Comm   | Issue  | Description   | Training | Training | Comment      |
| itment | Date   | of Change     | Required | Co       | Resolution   |
| Tr     |        |               |          | mpletion | Accession    |
| acking |        |               |          | Date     | Number       |
| Number |        |               |          |          |              |
+--------+--------+---------------+----------+----------+--------------+
| N/A    | 08     | Initial issue | None     | N/A      | ML071090392  |
|        | /19/08 | to support    |          |          |              |
|        |        | inspection of |          |          |              |
|        | CN     | operational   |          |          |              |
|        | 08-024 | programs      |          |          |              |
|        |        | described in  |          |          |              |
|        |        | IMC 2504,     |          |          |              |
|        |        | NON-ITAAC     |          |          |              |
|        |        | INSPECTIONS   |          |          |              |
|        |        |               |          |          |              |
|        |        | Completed 4   |          |          |              |
|        |        | year search   |          |          |              |
|        |        | of Historical |          |          |              |
|        |        | CNs and no    |          |          |              |
|        |        | commitments   |          |          |              |
|        |        | were found.   |          |          |              |
+--------+--------+---------------+----------+----------+--------------+
|        |        |               |          |          |              |
+--------+--------+---------------+----------+----------+--------------+