(FormeryNUE-75/87)

U.S. NUCLEAR REGULATORY COMMISSION

i STANDARD REVIEW PLAN

OFFICE OF NUCLEAR REACTOR REGULATION

13.5.2.1 OPERATING AND EMERGENCY OPERATING PROCEDURES

REVIEW RESPONSIBILITIES

Primary review branch - The branch responsible for human performance

Secondary - None

I. AREAS OF REVIEW

The staff reviews the applicant's plan for development and implementation of operating

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 ensure that routine operating, off-normal, and emergency activities are

conducted in a safe manner. It is not expected that detailed written procedures will be included

in the SAR. It is recognized that development of detailed procedures and associated training

materials may be beyond the scope of the application (e.g., for design certification) and are the

responsibility of a combined license (COL) applicant referencing the certified design. The SAR

should provide descriptions of the content and development process for procedures as detailed

below, including preliminary schedules for preparation of procedures.

A. Procedure Classification

The SAR or other submittal should describe the different classifications of procedures the

operators will use in the control room and locally in the plant for plant operations. The

group within the operating organization responsible for maintaining the procedures should

be identified and the general format and content of the different classifications should be

described. It is not necessary that each, applicant's procedures conform precisely to the

same classification since the objective is to ensure that procedures will be available to the

Rev. 1 - November 2005

USNRC STANDARD REVIEW PLAN

Standard review plans are prepared for the guidance of the Office of Nuclear Reactor Regulation staff responsible for the

review of applications to construct and operate nuclear power plants. These documents are made available to the public as part of the Commission s policy to Inform the nuclear indus ry and the general pubic of regulatory procedures and polices. Standard review plans are not substitutes for regulatory guides or the Commission's regulations and compliance with them Is not required. The standard review plan sections are keyed to the Standard Format and Content

of Safety Analysis Reports for Nuclear Power Plants. Not all sections of the Standard Format have a corresponding review plan.

Published standard review plans will be revised periodically, as appropriate, to accommodate comments and to reflect

new Information and experfence.

Comments and suggestions for Improvement will be considered and should be sent to the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Washington, D.C. 20555.
plant staff to accomplish the functions contained in the listing of Regulatory Guide 1.33.

For example, some licensees prefer a classification of abnormal operating procedures,

whereas others may use off-normal condition procedures. Examples of classifications

follow:

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 (if not given in the applicable testing

procedure), and other instructions appropriate for operation of systems important to

safety.

2. General Plant Procedures. Procedures that provide instructions for the integrated

operations of the plant, e.g., startup, shutting down, shutdown, power operation

and load changing, process monitoring, and fuel handling.

3. Off-Normal Condition Procedures. Procedures that specify operator actions for

restoring an operating variable to its normal controlled value when it departs from

its normal range or to restore normal operating conditions following a transient.

Such actions are invoked following an operator observation or an annunciator

alarm indicating a condition which, if not corrected, could degenerate into a

condition requiring action under an emergency operating procedure (EOP).

4. Emergency Operating Procedures. Procedures that direct actions necessary for

the operators to mitigate the consequences of transients and accidents that cause

plant parameters to exceed reactor protection system or engineered safety

features actuation setpoints.

5. Alarm Procedures. Procedures that guide operator actions for responding to plant

alarms.

B. Operating Procedure Program

The SAR or other submittal should describe the applicant's program for developing the

operating procedures (A.1 -5 above). The staff will review the applicant's program for

development and implementation of the operating procedures.

C. Emergency Operating Procedure Program

The SAR or other submittal (e.g., the procedures generation package [PGP]) should

describe the applicant's program for developing EOPs (A.4 above) as well as the required

content of the EOPs. The staff will review the applicant's program for development and

implementation of the EOPs.

The procedure development program, as described in the PGP for EOPs, should be

submitted to the NRC at least 3 months prior to the date the applicant plans to begin

formal operator training on the EOPs. The PGP should include:

1. Plant-specific technical guidelines (P-STGs), which are guidelines based on

analysis of transients and accidents that are specific to the applicant's plant design

.and operating philosophy. The submitted documentation of the P-STGs will

provide the basis for, and include a reference to, generic guidelines if used.

Rev. 1 - November 2005 1 3.5.2.1 -2
For plants not referencing generic guidelines, this section of the submittal should

contain the action steps necessary to mitigate transients and accidents in a

sequence that allows mitigation without first having diagnosed the specific event,

along with all supporting analyses, to meet the requirements of TMI Action Plan

item l.C.1 (NUREG-0737 and Supplement 1 to NUREG-0737).

For plants referencing generic guidelines, the submitted documentation should

include (1) a description of the process used to develop plant-specific guidelines

from the generic guidelines, (2) identification of significant deviations from the

generic guidelines (including identification of additional equipment beyond that

identified in the generic guidelines), along with all necessary engineering

evaluations or analyses to support the adequacy of each deviation, and (3) a

description of the process used for identifying operator information and control

requirements. Examples of significant safety deviations are provided in Subsection

3.3.2 to Appendix A to this Standard Review Plan (SRP) section.

2. A plant-specific writer's guide (P-SWG) that details the specific methods to be used

by the applicant in preparing EOPs based on P-STGs.

3. A description of the program for verification and validation (V&V) of EOPs.

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

D. Review Interfaces

Assistance from other technical review branches will be obtained as necessary to perform

a thorough review of operating procedures as defined in A above.

II. ACCEPTANCE CRITERIA

Section 13.5.2.1 of the SAR provides additional evidence of the applicant's 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 50.34 as indicated

below. Additional guidelines listed in this subsection provide guidance to applicants for meeting

basic requirements.

A. iOperating Procedure Schedule

A generally acceptable target date for completion of operating procedures is about

6 months before fuel loading to allow adequate time for plant staff familiarization and to

allow NRC staff adequate time to develop operator license examinations. The PGP for

EOPs must be submitted not later than 3 months before the date formal operator training

on EOPs is to begin.

B. Control Room and Plant Procedures

The following regulations and staff guidelines applicable to operating procedures are to

be used in the control room and locally in the plant:

1. I10 CFR 50.34(a)(6) and (10) and 10 CFR 50.34(b)(6)(iv) and (v).

13.5.2.1 -3 Rev. 1 - November 2005
2. 10 CFR Part 50, Appendix B, Criteria V and VI, establish criteria for development,

approval, and control of procedures for all activities affecting quality.

3. The review criteria for procedures in NUREG-071 1, Chapter 9, "Element 8 -

Procedure Development.'

4. NUREG-0737, "Clarification of TMI Action Plan," item l.C.1, "Guidance for the

Evaluation and Development of Procedures for Transients and Accidents."

(emergency operating procedures only)

5. Supplement 1 to NUREG-0737, TMI Action Plan items l.C.1 and I.C.9,

"Requirements for Emergency Response Capability," Item 7, Subsections 7.1 and

7.2, "Upgrade of Emergency Operating Procedures." (emergency operating

procedures only)

6. The guidelines in the Regulatory Position section of Regulatory Guide 1.33.

7. The guidelines of ANSI/ANS 3.2-1982, Section 5.3.

8. Appendix A to SRP, Section 13.5.2.1, uGuidelines for the Evaluation of Procedures

Generation Packages" (emergency operating procedures only)

9. Supplement 1 to NUREG-1358, "Lessons Learned from the Special Inspection

Program for Emergency Operating Procedures," 1992.

C. Technical Rationale

The technical rationale for application of these acceptance criteria to operating

procedures is discussed in the following paragraphs:

1. Compliance with the requirements of 10 CFR 50.34(a)(6) and (10) and 10 CFR

50.34(b)(6)(iv) and (v) requires that the applicant include in the SAR preliminary

plans for emergency organization, training, conduct of operations, and coping.

Sections 50.34(a)(6) and (10) and 50.34(b)(6)(iv) and (v) of 10 CFR are applicable

to this SRP section because they specify in general terms the information to be

submitted in the SAR regarding the operating procedure program, an important

part of the safe conduct of operations for emergency and nonemergency activities.

Meeting these requirements provides assurance that the conduct of operations at

the plant will be formalized with procedures covering normal and emergency

activities. The planning and implementation of the procedure program will provide

means for correct and standardized performance of activities important to safety.

2. Compliance with the requirements of 10 CFR Part 50, Appendix B, Criteria V and

VI, requires that activities affecting quality be prescribed by documented

instructions, procedures, and drawings and that measures be established to control

issuance of and changes to these documents.

Criteria V and VI are applicable to this section because they require an applicant to

ensure that quality assurance considerations are an integral part of the operating

Rev. 1 - November 2005 13.5.2.1 -4
procedure program for developing technical procedures, V&V, implementation, and

document control relative to the safe operation of the facility under routine, offnormal, and emergency operating conditions.

Meeting these requirements provides assurance that activities affecting quality will

be satisfactorily controlled.

Ill. REVIEW PROCEDURES

Review of the SAR or other submittal in accordance with this section consists of a detailed

comparison of the information submitted with the acceptance criteria of Subsection II above.

The SAR review should encompass only the schedules for procedure development and the

applicant's commitment to follow the applicable regulatory guides and standards.

The following paragraph is applicable to all operating procedures as described in Section l.A

above:

Review the applicant's program for the development of operating procedures to ensure the

application of accepted human factors principles and practices for the design of the operating

procedures. Element 8 of NUREG-071 1, "Procedure Development," describes an acceptable

method for developing operating procedures. The method is an integral part of the human

factors engineering (HFE) program. The HFE program is described more fully in Chapter 18 of

the SRP.

The following paragraph is applicable to EOPs only:

To supplement the expertise of the reviewer, especially in the human factors area, and to

promote consistency among the PGP reviews, Appendix A identifies the subjects that should be

considered by the reviewer in the evaluation. However, Appendix A is not a "checklist" and an

acceptable PGP need not address each item of Appendix A.

Normally the PGP review should be conducted prior to the date the applicant plans to begin

formal operator training on the EOPs. If this is not possible because of a delayed submittal,

perform an acceptance review of the PGP. Specifically, audit the four parts of the PGP to

determine if there are any major deficiencies in the EOP program that warrant postponing

operator training. If major deficiencies are found, identify the additional information necessary

to conduct the complete PGP review so the applicant can be notified prior to the initiation of

training.

Review the PGPs 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-SWG, the description of the program for V&V, and the description of the training program

necessary to support the conclusions described in Subsection IV below. To support this review,

Appendix A provides additional review guidance.

Review the P-STGs to determine whether acceptable analyses of accidents and transients and

development of technical guidelines for operator actions applicable to the plant have been

completed, and whether an acceptable process for identifying operator information and control

needs has been described. The Human Factors Engineering Program Review Model (HFE

1 3.5.2.1 -5 Rev. 1 - November 2005
PRM), as described in NUREG-071 1, provides additional guidance on reviewing applicant

procedure development programs. It is expected that most applicants will reference generic

technical guidelines.

For an applicant using approved generic technical guidelines as the basis for its P-STGs, the

major portion of the review of the technical guidelines has been accomplished generically. Staff

SERs approving the use of each of the four owners groups' generic technical guidelines have

been published (and may be supplemented as guidelines are revised). The review of this type

of P-STGs should focus on the process described for converting generic technical guidelines to

plant-specific procedures to ensure that the safety-significant deviations from the generic

guidelines are controlled. The evaluation should include the technical adequacy of the

identified plant-specific deviations. Finally, the process should be evaluated for development of

the plant-specific information and control requirements necessary to use the EOPs.

The review of identified safety-significant deviations from generic technical guidelines will be

conducted to the same level of detail as the generic technical guidelines. Examples of

safety-significant deviations are given in Appendix A, Subsection 3.3.2. Assistance from other

technical review branches will be obtained as necessary to perform -a thorough review of the

safety-significant deviations. Only safety-significant deviations need to be reviewed. However,

the reviewer should determine that the applicant's program will control this process so that the

work is auditable.

Each B&W applicant's identified deviations from the Emergency Operating Procedure Technical

Bases Document guidelines will be reviewed.

For applicants not referencing generic technical guidelines, ensure that the submittal includes

analysis of accidents and transients in accordance with the guidance of NUREG-0660, 10 CFR

50.34(f)(2)(ii), and NUREG-0737, items I.C.1 and I.C.9. To do so, the reviewer should (1)

become familiar with the integrated performance of the NSSS and balance-of-plant systems, (2)

evaluate the completeness of the accident and transient analyses, (3) evaluate the use of

appropriate models, calculational methods, and plant data, (4) consider audit calculations of

selected accidents and transients (assistance from other technical review branches required),

(5) evaluate the adequacy of the applicant's program to develop guidelines from the analysis of

accidents and transients, (6) test the guidelines against scenarios, including multiple failures,

and (7) evaluate the information and control needs of the operators to execute the instructions

of the guidelines. NUREG-0711 provides guidance on analyses appropriate for human-system

interaction requirements. (Refer to Chapter 18 for additional information.)

The P-SWG review will consider the adequacy of the methods of presentation of the technical

information in the EOPs to ensure that the EOPs are complete, accurate, consistent, and easy

to understand and follow for the intended users (e.g., control room operators, shift supervisors,

and auxiliary operators). Review the P-SWGs by evaluating the applicant's methods for

meeting the overall writer's guide objectives stated in NUREG-0899 and the objectives of

NUREG-071 1, Chapter 9, "Procedure Development,' and the criteria described in Appendix B

of NUREG-1358, Supplement 1. Appendix A provides guidance to assist the reviewer in

making this evaluation. This guidance is to be used not as a set of strict criteria but as an aid in

the overall evaluation of the P-SWG. Because strict criteria do not exist for the human factors

evaluation, the reviewer must make a professional judgment regarding the adequacy of the

applicant's methods as described in the P-SWGs.

Rev. 1 - November 2005 1 3.5.2.1 -6
Review the V&V and training programs by comparing the program descriptions with the

objectives of NUREG-0899 and NUREG-071 1.

The level of effort for these PGP reviews will vary significantly. For example, the effort

necessary to review the P-STGs 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 yield sufficient information to support the conclusions of the

Evaluation Findings section, the reviewer should obtain at least one EOP for review. As a

product of the PGP program, the EOP or EOPs will then be additional information for judging

the program's acceptability and will provide additional information how the applicant's EOP

development and implementation program should be modified to ensure that it contains

sufficient information to assure acceptability of the resulting EOPs.

When the reviewer has determined that each of the criteria of Subsection II has been satisfied

based upon the statements made by the applicant in the SAR, the review of Section 13.5.2.1 is

complete.

For design certification reviews under 10 CFR Part 52, the subject review will be identified as a

review to be performed during COL application review.

IV. EVALUATION FINDINGS

The reviewer verifies that the information presented and the review support the following type of

conclusion in the staff's safety evaluation report:

The applicant's program for operating procedures as described in the SAR is

in accordance with 10 CFR 50.34, Regulatoty Guide 1.33, and ANSI/ANS

3.2-1982, Section 5.3, and is acceptable. The staff reviewed the applicant's

program for development of operating procedures and reached the following

conclusions:

1. With respect to technical guidelines:

(a) The operating procedures will be based upon acceptable technicalguidance-derived plant design bases, system-based technical

requirements and specifications, task analysis results, and critical

human actions identified in the HRAIPRA.

(b) The EOPs will be based upon acceptable technical guidelines derived

from approved analyses of transients and accidents.

(c) Implementation of the applicant's described methods for conducting an

analysis of the operator's tasks should result in the identification of the

instrumentation and controls necessary to perform the tasks specified

in the technical guidelines.

2. With respect to the writer's guide:

(a) The writer's guide or guides provides sufficient information to help

ensure that operating procedures, including EOPs, developed using

13.5.2.1-7 Rev. 1 - November 2005
technical guidelines will be complete, accurate, consistent, and easy to

understand and follow.

(b) The methods described by the writer's guide appear sufficient to

support upgrading of the operating procedures, including EOPs, and to

ensure long-term consistency within and among these procedures.

3. Implementation of the described V& V program provides adequate assurance

that the operating procedures, including EOPs, are technically correct and

useable, follow the applicable writer's guide, correspond to the control room

and plant hardware, and are compatible with the minimum number,

qualifications, training, and experience of the operating staff.

4. After the implementation of the described training program, the operator

should understand the philosophy of the operating procedures, including

EOPs, understand the mitigative strategy of the EOPs and the technical

basis of the operating procedures, have a working knowledge of the technical

content of the operating procedures, including EOPs, and have the capability

to execute the operating procedures, including EOPs, under operational

conditions.

The evaluation findings for this section should also include the following:.

1. A statement that the applicant has committed to operate the plant in accordance 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 NUREG-0737, Supplement 1,

item 7, *Upgrade of Emergency Operating Procedures,' has been implemented.

For design certification reviews, the development of operating and emergency operating

procedures is identified as a COL action item.

V. IMPLEMENTATION

The following is intended to provide guidance to applicants and licensees regarding the NRC

staff's plans for using this SRP section.

This SRP section will be used by the staff when performing safety evaluations of license

applications submitted pursuant to 10 CFR Part 50 or 10 CFR Part 52 and applications for

modifications to systems or functions pursuant to 10 CFR 50.59. Except when the applicant

proposes an acceptable alternative method for complying with specified portions of the

Commissions' regulations, the method described herein will be used by the staff in its

evaluation of conformance with the Commission regulations.

The provisions of this SRP section apply to reviews of applications docketed 6 months or more

after the date of issuance of this SRP section.

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Implementation schedules for conformance to parts of the methods discussed herein are

contained in'the referenced regulatory guides and NUREGs.

The staff will use this SRP for judging the acceptability of an applicant's operating procedure

program, including the EOP (PGP) program, as described in submittals made in accordance

with Supplement 1, NUREG-0737, "Requirements for Emergency Response Capability"

(Generic Letter 82-33). The review guidance in this SRP section replaces the review guidance

in Generic Letter 82-33.

It is recognized that development of detailed procedures and associated training materials may

be beyond the scope of design certification and therefore will be the responsibility of an

applicant referencing the certified design.

VI. REFERENCES

1. 10 CFR 50.34, "Contents of Applications; Technical Information."

2. 10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and Combined

Licenses for Nuclear Power Plants."

3. NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," 1980.

4. NUREG-071 1, "Human Factors Engineering Program Review Model," 2002.

5. NUREG-0737, -Clarification of TMI Action Plan Requirements," 1980.

6. NUREG-0737, Supplement 1, "Requirements for Emergency Response Capability," 1983

(Generic Letter 82-33, December, 1982).

7. NUREG-0899, "Guidelines for Preparation of Emergency Operating Procedures," 1982.

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

Generic Technical Guidelines for GE, CE, W, and B&W plants, respectively.

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

10. Regulatory Guide 1.70, "Standard Format and Content of Safety Analysis Reports for

Nuclear Power Plants."

11. ANSI/ANS 3.2 1982, "Standard for Administrative Controls for Nuclear Power Plants,"

American National Standards Institute.

12. NUREG-1358, "Lessons Learned From the Special Inspection Program for Emergency

Operating Procedures," 1989.

13. NUREG-1358, Supplement 1, "Lessons Learned From the Special Inspection Program

for Emergency Operating Procedures," 1992.

13.5.2.1 -9 Rev. 1 - November 2005
Appendix A to SRP Section 13.5.2.1

REVIEW PROCEDURES FOR THE EVALUATION

OF PROCEDURES GENERATION PACKAGES

1.0 Background

In August of 1982, NUREG-0899, Guidelines for the Preparation of Emergency Operating

Procedures,- was published. This docurrient. is designed to identify the elements necessary for

licensees and applicants to prepare and implement Emergency Operating Procedures (EOPs)

that will provide the operator with directions to mitigate the consequences of a broad range of

accidents and multiple equipment failures.' In addition to identifying these elements,

the document also outlines the process by which licensees and applicants should develop,

implement, and maintain EOPs. To ensure that the elements are addressed in the new or

upgraded procedures and that acceptable processes of development, implementation, and

maintenance are used, the staff identified a method of review that is intended to provide

confidence that EOPs written or upgraded according to a given plant's program would be

acceptable. The NRC staff believes that it is more important that licensees and applicants

ensure that the process used to generate procedures and the technical basis for the

procedures are sound and well documented, than to perform a one-time review of EOPs, with

no assurance that future EOP revisions will be technically adequate and consistent with existing

EOPs. In this approach the licensee is responsible for the generation and review of the EOPs

and for future revisions to EOPs.

In NUREG-0899, four aspects of EOP development and implementation are identified as

providing an adequate basis for review: (1) plant-specific technical guidelines (P-STGs), (2) a

plant-specific writer's guide, (3) a description of the program for verification and validation of the

EOPs, and (4) a description of the program for training operators on the EOPs. Information on

each of these items is to be provided in the procedures generation package (PGP). The PGP

for each plant will give the licensee a technical and human factors basis for developing its

EOPs and for making future revisions to its EOPs.

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).

In 1994, NUREG-071 1, 'Human Factors Engineering Program Review Model" (HFE PRM), was

published. The HFE PRM, described more fully in SRP Chapter 18, contains guidance on

reviewing human factors engineering program elements, including procedure development

(Chapter 9). The HFE PRM addresses technical procedures, including abnormal

and emergency procedures, and seeks to ensure that an "applicant's procedure program will

result in procedures that support and guide human interaction with plant systems and control

plant-related events and activities." Therefore it is important that human-system interaction

issues be considered in the development of all procedures, including all operating procedures

(described in l.A of SRP Section 13.5.2.1) to be used within the control room and locally in the

plant, including emergency operating procedures (EOPs).

The guidance in SRP Section 13.5.2.1, Appendix A, specifically addresses EOPs. Emergency

operating procedures are particularly important for safety in nuclear power plant operation.

However, it should be recognized that all technical procedures are developed to assist

personnel in performing tasks. Elements to consider more broadly can be found in

Rev. 1 - November 2005 13.5.2.1 -10
NUREG-071 1. Other documents that may be used as guidance in the review of procedures

include the documents referenced in the Reference section of this appendix.

The purpose of this document is to give reviewers guidance on evaluating PGPs. The PGP is

expected to contain specific information in each of its four parts. The review guidance below is

divided into general objectives and specific review guidelines. The review guidelines represent

what the staff believes should be considered by reviewers in determining if the general

objectives are met. 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 often be

necessary for reviewers to use their expert judgment in determining the acceptability of a

particular submittal. The general objectives-and supporting documents such as NUREG-0899

and NUREG-1 358, Supplement 1, should be used as guidance in making these judgments.

The methods provided in NUREG-0899 and in Appendix B to NUREG-1358, Supplement 1, are

an acceptable approach for preparing EOPs. It should be recognized, however, that

approaches other than those found in these documents may be acceptable, and reviewers will

need to use their judgment in determining the adequacy of the PGP.

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 additional assistance to the

reviewers. All applicants have the option of providing a justification for their approach if they

disagree with a staff position. 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

The guidance that follows is provided to assist the reviewer in using the criteria presented in

Subsections 3 through 6 of this appendix.

2.1 Reviewers should be aware that different degrees of objectivity or subjectivity may be

required in reviewing each of the four parts of the PGP since the parts may differ in

detail and approach.

2.2 Reviewers should become very familiar with the general objectives of each section of a

PGP. The specific review guidelines can serve as the basis for making the subjective

evaluations of the general objectives.

2.3 When an objective is not met or a specific response cannot be judged acceptable

because of missing information, the reviewer should identify the information that is

missing and what is needed to make the PGP acceptable.-

2.4 Some items included in a PGP may not be addressed within either the general

objectives or the specific review guidelines. These items must be evaluated carefully to

ensure that unnecessary or possibly detrimental inclusions do not occur in the EOPs

(e.g., an EOP Deficiencies section is not a desirable inclusion in an EOP).

2.5 As stated in the Background section, most of the review guidelines are subjective. The

reviewer will have to judge whether the discussion of an item is sufficiently clear,

complete, and technically acceptable to achieve the objectives.

13.5.2.1-1 1 Rev. 1 - November 2005
2.6 In some cases the names, titles, etc., used in the PGPs may be different from those

used in this document, although the same topics are being discussed. For example, the

format of "decision aids" may be covered under a PGP section with the heading 'Job

Performance Aids." Reviewers should be careful that identified PGP deficiencies are

not based on semantics.

2.7 In some cases a particular subject may appear not 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 instrumentation and controls may be addressed not in the

P-STGs but in the validation and verification program. Reviewers must therefore

become familiar with the general objectives and specific review guidelines as a whole so

that these situations can be readily identified.

3.0 Plant-Specific Technical Guidelines

3.1 General Discussion

All licensees and applicants are required to submit P-STGs. These guidelines may be based

on (1) generic technical guidelines (prepared by the owners group), or (2) a plant-specific

reanalysis of transients and accidents as described in TMI Action Plan item l.C.1. In either

case, the P-STGs should be based on the identification of plant systems and functions and be

supported by an analysis of operator tasks to identify operator information and control needs.

The four approved generic technical guidelines use different levels of detail to provide operator

task information. If generic technical guidelines are referenced, the need for additional task

specification will vary depending upon the level of task information provided by the generic

technical guidelines and the nature of the deviations from the guidelines.

The information to be submitted in the PGP as P-STGs depends on whether or not generic

technical guidelines and on the degree to which plant-specific characteristics (e.g., equipment)

are consistent with the plant on which the generic technical guidance is based.

Some of the "deviations" that must be addressed as part of the P-STG submittal are differences

between the generic technical guidelines and the P-STGs. The deviations include differences

due to plant initiatives and differences identified in the generic guidelines as "plant-specific"

items. Only differences that are safety significant, e.g., related to systems functions, or

methods, should be reviewed. Subsection 3.3.2 provides examples of other deviations that

must be addressed. If an applicant does reference NRC-approved generic technical guidelines,

the applicant should not submit the guidelines. However, safety-significant deviations from the

mitigative strategy should be described. Furthermore, applicants 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-STGs, the action steps necessary to mitigate transients and accidents, as

well as supporting technical analysis and bases. The P-STGs should have an orientation that

allows mitigation without event diagnosis. In either case, the applicant should submit a'

description of how operator information and control needs were derived and used to specify

instrumentation and control requirements.

The guidance presented below identifies elements reviewers should consider in determining the

acceptability of P-STGs.

Rev. 1 - November 2005 13.5.2.1 -1 2
3.2 General Technical Objectives

The purpose of the review of the technical guidelines submittal is to determine that the following

general objectives are adequately addressed. Specific evaluation elements are identified in

Subsections 3.3 and 3.4.

3.2.1 The EOPs will be based on acceptable technical guidelines derived from approved

analyses of transients and accidents as described in NUREG-0660, items 1.C.1 and I.C.9,

as clarified by item I.C.1 in NUREG-0737 and Supplement 1 to NUREG-0737. The

P-STGs, the generic guidelines (if referenced), and supporting documentation provide

EOP writers with all the technical information necessary for preparing EOPs which direct

operators' actions to mitigate the consequences of transients and accidents without a

need to first diagnose an event to maintain the plant in a safe condition (function

orientation).

Part of the acceptability of the P-STGs is that the P-STGs are validated by the applicant

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

3.2.2 The PGP describes an adequate method to identify information and control needs and to

provide a basis for identifying control room instrumentation and controls necessary to

perform the tasks specified in the technical guidelines.

3.3 Specific Review Guidelines - Plants Using NRC-Approved Generic Technical Guidelines

To determine that the applicant's PGP adequately accomplishes the above objectives, 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 technical guidelines

into the P-STGs

3.3.2 Deviations and additions

3.3.2.1 Identification of safety-significant deviations from the NRC-approved generic

technical guidelines. The following are examples of deviations that should be

considered:

a. any modification to the mitigative strategy of the generic technical guidelines

(e.g., for a Westinghouse plant,- depressurizing-the RCS following a steam

generator tube rupture without first having conducted a limited cooldown in

-accordance with the guidelines -to establish a margin to saturation)

b. differences in equipment operating criteria (e.g., RCP trip criteria, SI injection

termination criteria)

13.5.2.1-13 Rev. 1 - November 2005
c. differences in equipment operating characteristics (i.e., between the

plant-specific equipment and the equipment assumed in the generic

analyses, such as SI 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-specifich

e. plant-specific setpoints or action levels that are calculated or determined in a

manner other than 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 submittal.

f. actions that are taken in addition to those specified in the generic guidelines

and that affect the mitigative strategy:

1. differences that affect the equipment's ability to adequately provide

the necessary mitigative function

2. use of different instruments or control parameters than specified in

the generic technical guidelines or determination of instrumentation

and control characteristics in a manner different or with a different

basis than specified in the generic technical guidelines

3.3.2.2 Identification of items not covered by the NRC-approved generic technical

guidelines (e.g., plant-specific conditions, equipment, operations, or (bracketed]

information from the generic technical guidelines on systems, functions, or

methods)

3.3.2.3 Indication that the safety-significant deviations and additions have

been identified and technically justified

NOTE: The reviewer has the option of reviewing the complete P-STGs with the

associated technical justification or reviewing only the identified deviations from

generic technical guidelines, including technical justification consistent with the

Generic Letter 82-33 requirements.

3.3.3 Technical adequacy of operator actions (not covered by, or deviations from, the generic

technical guidelines)

NOTE: The evaluation of the technical adequacy of operator actions (i.e.,whether the

procedures will work) may be addressed in the validation and verification sections of the

PGP (i.e., at the completion of EOP development rather than during EOP development).

The P-STG portion of the PGP should describe how the licensee will determine if the

approach taken is effective in mitigating transients and accidents.

3.3.3.1 Description of the verification and validation of operator actions (to determine

their technical adequacy)

Rev. 1 - November 2005 13.5.2.1 -14
3.3.4 Applicant's determination of the need for and the adequacy of control room

instrumentation and controls for emergency operations

3.3.4.1 Description of the method used to determine information and control needs of

the operators (function and task analysis)

NOTE: The determination of the adequacy of control instrumentation and

controls may be addressed in the validation and verification sections of the PGP

(i.e., at the conclusion of EOP development rather than during EOP

development). For the P-STGs, adequacy of control room instrumentation and

controls means that the available 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 instrument and

control characteristics (e.g., instrument range, units, precision, rate, and

setpoints; control type, function, rate, gain, and response) meet the needs

identified.

3.3.4.2 Description of the method used to determine if the control room instrumentation

and controls meet the information and control needs of the operators

3.4 Specific Review Guidelines - Plants Not Using Generic Guidelines

The review of the P-STGs for plants not referencing generic guidelines will be performed using

a methodology similar to that used to evaluate the acceptability of the owners group guidelines.

The reviewer should evaluate analyses submitted to support proposed accident recovery

strategies, including any analytical models. Improvements 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 SAR licensing basis envelope (for licensing basis events).

The reviewer evaluates the effects of, and resulting recovery strategies for, transients and

accidents, using the guidance in NUREG-0737. The P-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 given in the review procedures,

SRP Section 13.5.2.1.

3.4.2 Validation of technical adequacy of operator actions

NOTE: The evaluation of the technical adequacy of operator actions

(i.e.,whether the procedures will work) may be addressed in the validation and

verification sections of the PGP (i.e., at the completion of EOP development

rather than after P-STG development). The P-STG portion of the PCP should

describe how the applicant will determine if the approach taken is effective in

mitigating transients and accidents.

3.4.2.1 Description of the validation or verification of operator actions

13.5.2.1-15 Rev. 1 - November 2005
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 determination of the adequacy of control room

instrumentation and controls may be addressed in the validation and

verification sections of the PGP (i.e., at the conclusion of EOP

development rather than after P-STG development) or in the part of

the SAR addressing the human factors engineering of plant systems

(SRP Chapter 18). For the P-STGs, adequacy of control room

instrumentation and controls means that the available

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 instrument

and control characteristics (e.g., instrument range, units, precision,

rate, and setpoints; control type, function, rate, gain, and response)

- meet the needs identified.

3.4.3.2 Description of the method used to determine if the control room

instrumentation and controls meet the information and control needs

of the operators.

4.0 Review of the Plant-S~ecific Writer's Guide

4.1 General Discussion

Applicants are required to submit a writer's guide that details the specific methods to be used in

preparing EOPs which are based on the P-STGs. NUREG-0899 provides the objectives and

purpose of the writer's guide. Appendix B of NUREG-1358, Supplement 1, provides additional

criteria useful in developing a writer's guide. Because of the variety of available technical

writing style guides and other references pertaining to the presentation of information, the

specific information found in the writer's guide is expected 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 standards and information which will assist the writers in

preparing the EOPs.

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 using the P-STGs to

develop EOPs which are useable, accurate, complete, readable, convenient to

use, and acceptable to control room personnel.

Rev. 1 - November 2005 13.5.2.1 -1 6
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

The number in parentheses following each element designates the specific section of

NUREG-0899 where the element is addressed. The items with asterisks may appear in a

procedure at the discretion of the applicant. If they are used in the EOPs, they should be

addressed in the writer's guide and considered in the review. If a sample procedure is

submitted as a part of the writer's guide, the reviewer should verify that any nonrequired

element included in the procedure is addressed in the writer's guide.

To determine that the applicant's PGP includes methods which appear adequate to accomplish

the above objectives, the reviewer should consider the following:

4.3.1 Organization, content, and format of major sections of the EOPs (5.5)

4.3.1.1 Cover page (5.4.1)

4.3.1.2 Table of contents* (5.4.2)

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 periodic concern or applicability, (d) steps for which a number of

alternative actions are equally acceptable, (e) steps performed

concurrently with other steps, and (f) steps which lead the operator

to the appropriate subsection of the EOPs (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 and decision aids* (5.4.8 and 5.5.9)

4.3.1.9 EOP page identifying information, Including title, procedure number,

revision number and date, number of pages, unit designation (if

applicable), facility designation, and location of identifying

information in the EOP (5.5.1)

4.3.1.10 Page layout, including margins, line spacing, and the requirement

that the other steps be given on one page (5.5.2)

4.3.1.11 Warnings (or cautions) and notes, including placement, definitions,

emphasis and format, and the complete step-on-one-page

requirement (5.3, 5.7.9, 5.7.10)

13.5.2.1 -17 Rev. 1 - November 2005
4.3.1.12 Placekeeping aids (5.5.4)

4.3.1.13 Emphasis techniques (5.5.6) K.

4.3.1.14 Divisions, 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 (with definitions) and words to avoid

(5.6.1)

4.3.2.2 A list of abbreviations, acronyms, and symbols, that should be

consistently used in the procedures and in the control room (5.6.2)

4.3.2.3 Sentence structure and limit on actions per step (5.6.3)

4.3.2.4 Punctuation (5.6.4)

4.3.2.5 Capitalization (5.6.5)

4.3.2.6 Units of measure in the action steps and in the tables and figures

should be consistent with presentation of information in the control

room (5.6.6).

4.3.2.7 Numerals, including type, use of decimals, and significant digits

(5.6.7)

4.3.2.8 Tolerances (5.6.8)

4.3.2.9 Formulas and calculations* (5.6.9)

4.3.2.10 Nomenclature for instrumentation and controls (what information to

provide in the procedure and in what format) (5.6.2)

4.3.3 Conditional and logic statements, including format, style, emphasis; definition

and use of logic terms; and logic terms and sequences to avoid (5.6.10 and

Appendix B)

4.3.4 How to reference other procedures, sections of procedures or subprocedures,

and specific steps of procedures (5.2.2 and 5.5.7)

4.3.4.1 Content and format of reference (5.2.2)

4.3.4.2 The criteria used to determine when steps of a referenced

procedure are to be included in an EOP (to minimize crossreferencing) (5.2.2).

4.3.4.3 Method for identifying sections or subsections (e.g., use of tabbing)

(5.5.7 and 6.1.4)

Rev. 1 - November 20051 13.5.2.1 -1 8
4.3.5 When and how to present location information (equipment, controls and

displays) (5.7.11)

4.3.6 Control Room Staffing and Division of Responsibilities (5.8)

NOTE: This section addresses the need to consider operating crew staffing and

responsibilities during the process of developing EOPs to help ensure efficient

and effective implementation of EOPs during an emergency. Deficiencies in this

regard may be identified by the applicant during validation or verification of the

EOPs. Subsection items 4.3.6.1 through 4.3.6.4 may therefore be addressed

under validation and verification.

4.3.6.1 Structuring of EOPs to ensure that minimum staffing can execute

the EOPs

4.3.6.2 Designating the operators' responsibilities in implementing EOPs

(i.e., each operator will know what he or she has to do during an

emergency so that it is not necessary to specify roles in the PGP or

EOPs)

4.3.6.3 Sequencing action steps to minimize physical interference between

operators

4.3.6.4 Sequencing action steps to avoid their unintentional duplication by

operators

4.3.7 Use and maintenance of EOPs, including accessibility and quality of copies (6.0)

4.3.8 Statement of commitment to use writer's guide in developing and revising the

EOPs

5.0 Program for Validation and Verification

5.1 General Discussion

All applicants must submit a description of their programs for validating and verifying their

EOPs. NUREG-071 1, Element 10, Human Factors Verification and Validation, provides

additional guidance on the development of a verification and validation program. Both technical

and human factors aspects of the EOPs are addressed by validation and verification activities,

and submittals may integrate the two aspects under a given evaluation scheme. For these

reasons reviewers must exercise considerable judgment in their review of the submittals.

The evaluation elements for validation and verification were drawn from the six objectives

identified in NUREG-0899 (Subsection 3.3.5.1). These objectives, which are repeated below,

are the general basis for determining the acceptability of the validation and verification

programs reviewed.

13.5.2.1-1 9 Rev. 1 - November 2005
5.2 General Objectives

The purpose of evaluating the validation and verification program is to ensure that the following

general objectives are met. Specific evaluation elements are listed in Subsection 5.3.

5.2.1 EOPs are technically correct (i.e., they.accurately reflect the technical

guidelines).

5.2.2 EOPs are written correctly (i.e., they accurately reflect the plant-specific writer's

guide).

5.2.3 EOPs are useable (i.e, they can be understood and followed without confusion,

delays, errors, etc.)

5.2.4 The controls, equipment, and indications that are referenced are available (inside

and outside of the control room), use the same designations, use the same units

of measurement, and operate as specified in the procedures.

5.2.5 The language and level of information in the EOPs are compatible with the

minimum number, qualifications, training, and experience of the operating staff.

5.2.6 There is a high level of assurance that the procedures will work (i.e., the

procedures guide the operator in mitigating transients and accidents).

5.3 Specific Validation and Verification Review Guidelines

To aid the reviewer in the evaluation of the validation and verification program, the reviewer

should consider the following review guidelines:

5.3.1 The applicant should indicate the methods that will be used to meet each of the

objectives (as specified in Subsection 5.2 above) of the validation and

verification program; the specific combination of methods for meeting each

objective should be identified by the applicant so that the reviewer has

assurance that the objectives of the overall validation and verification program

are met. In the staff's judgment, the following combination of methods should be

used to meet each of the objectives:

5.3.1.1 Whether the EOPs are technically correct (i.e., whether they

accurately reflect the technical guidelines) should be evaluated by a

combination of the following methods: (a) desktop review and (b)

seminars, workshops, operating team review, and computer

modeling/analysis.

5.3.1.2 Whether the EOPs are written correctly (i.e., whether they

accurately reflect the approved plant-specific writer's guide) should

be evaluated by a combination of the following methods: (a)

desktop review and (b) seminars, workshops, and operating team

review.

Rev. 1 - November 2005 13.5.2.1 -20
5.3.1.3 Whether controls, equipment, and indications that are referenced

are available inside and outside the control room, use the same

designations and the same units of measurement, and operate as

specified in the procedures should be evaluated by a combination of

the following methods: (a) seminars, workshops, and operating

team review, (b) control room walkthroughs (static), and (c)

simulation (if plant-specific) (static).

5.3.1.4 Whether the EOPs are usable (i.e., whether they can be understood

and followed without confusion, delays, errors, etc.) for the given

level of qualifications, training, and experience of the control room

staff should be evaluated by a combination of the following methods:

(a) seminars, workshops, and operating team review, (b) simulator

exercises, and (c) control room walkthroughs (dynamic).

5.3.1.5 Whether the language and level of information presented in the

EOPs are compatible with the minimum control room staffing and

the qualifications, training, and experience of the control room staff

should be evaluated by a combination of the following methods: (a)

desktop review, (b) seminars, workshops, and operating team

review, (c) simulator exercises, and (d) control room walkthroughs

(dynamic).

5.3.1.6 Whether there is a high level of assurance that the procedures will

work (i.e., whether the procedures will guide the operator in

mitigating transients and accidents) should be evaluated by a

combination of the following methods: (a) desktop review, (b)

seminars, workshops, and operating team review, (c) simulator

exercises, and (d) control room walkthroughs (dynamic).

5.3.2 Indication that plant operators, subject matter experts, and procedure writers are

involved

5.3.3 Identification of the roles played by the participants (i.e., how operators, subject

matter experts, etc., will participate in the validation or verification process) (roles

should be based on the specific validation or verification objective being

addressed)

5.3.4 Use of scenarios

Indication that the full complement of EOPs Is exercised, including multiple

failures (simultaneous and sequential), and inclusion of criteria for selecting

scenarios

NOTE: Where a generic simulator is used, and to some extent where a plant

reference simulator is used, it will not be possible to fully exercise all parts of the

EOPs. In these cases, the PGP should describe the method that the licensee

will use to ensure that the validation and verification program will cover areas

missed in the simulator exercises. The following elements are included to

address this issue.

13.5.2.1-21 Rev. 1 - November 2005
5.3.5 Indication that areas not covered by simulator exercises will undergo validation

or verification

5.3.6 Description of the plan for correcting and revising EOPs as a result of the

validation or verification and feedback from simulator exercises, control room

walkthrough, desktop reviews, operating team reviews, and operator training to

address accuracy, readability, usability, and completeness of the EOPs

5.3.7 Statement of commitment to validate and verify revisions to EOPs,

when appropriate, and the conditions under which revisions should be validated

and verified

5.3.8 Description of the method by which multiple units will be handled in the validation

and verification process to account for unit differences

-NOTE: For multiunit sites, the part of the validation and verification process

involving control room walkthroughs and use of operators should be carried out

for each unit of a multiunit site to the extent that the units differ in terms of

instrumentation, controls, equipment (including the availability, design, labeling,

or location of equipment), or any other aspect that may impact plant safety.

5.3.9 Indication that the EOPs will be compatible with minimum control room staffing

5.3.10 Description of the plan for determining adequacy (availability, readability and

usability) of control room instrumentation and controls

5.3.11 Description of the plan for determining correspondence between EOPs and

control room instrumentation and controls

5.3.12 Where available instrumentation and controls have not been evaluated against

the information and control needs of the operators as a part of the P-STGs (see

Subsections 3.3.4.2 and 3.4.3.2), they should be evaluated as a part of the

validation and verification program. The description of the validation and

verification program should include the method that will be used to determine the

adequacy of control room instrumentation and controls in meeting the

information and control needs of the operators (i.e., it has been determined that

the parameters are correct and that the instrument and control characteristics

[e.g., accuracy, scaling, etc.] meet the needs identified).

NOTE: Since many aspects of validation and verification can be addressed

during operator training, it is anticipated that applicants will combine these

activities to make more efficient use of simulator time. Where validation or

verification is tied to the EOP training program, applicants must address

validation or verification through a formal process which documents results and

provides for feeding this information back into the EOP development process.

The PGP should describe this process.

Rev. 1 - November 2005 1 3.5.2.1 -22
NOTE: Where EOPs are partially validated or verified on a generic simulator,

licensees should commit to performing the dynamic portion of the validation and

verification of the EOPs if a plant reference simulator becomes available.

6.0 Program for Operator Training on EOPs

6.1 General Discussion

Applicants are to submit descriptions of their planned programs for training operators on EOPs.

The purpose of reviewing the EOP training program is to ensure that operators will be trained

prior to implementation of the EOPs, and that there is a reasonable assurance that the methods

to be used in training are adequate. This determination can be made by verifying that the

training program meets the general training objectives identified in Subsection 6.2. To

determine that these general objectives are met, the reviewer should consider the specific

review guidelines of Subsection 6.3 and of NUREG-071 1, Element 9, Training Program

Development.

6.2 General EOP Training Program Objectives

The purpose of the evaluation is to determine that the following general objectives are

adequately addressed in the training program described by considering the following review

guidelines. These guidelines are not intended to identify all the necessary components of an

adequate training program but to serve as a basis for assuring the staff that the operators have

been trained prior to EOP implementation and that they will be capable of using the EOPs.

6.2.1 Trainees should understand the philosophy behind the approach to the EOPs

(i.e., their structure and approach to transient and accident mitigation, including

control of safety functions, accident evaluation and diagnosis, and the

achievement of safe, stable, or shutdown conditions)

6.2.2 Trainees should understand the mitigation strategy and technical bases of the

EOPs (i.e., the function and use of plant systems, subsystems, and components

in mitigating transients and accidents)

6.2.3 Trainees should have a working knowledge of the technical content of the EOPs,

i.e., they must understand and know how to perform each step in all EOPs to

achieve EOP objectives.

6.2.4 Trainees should be capable of executing the EOPs as individuals and teams

under operational conditions (i.e., they must be able to carry out an EOP

successfully during transients and accidents)

6.3 Specific EOP Training Review Guidelines

The reviewer should consider the following specific review guidelines in evaluating the

description of the EOP training program:

6.3.1 Inclusion of training objectives consistent with Subsection 6.2 above

6.3.2 Use of simulator exercises

13.5.2.1 -23 Rev. 1 - November 2005
6.3.2.1 Specification of plant-specific or generic simulation

6.3.2.2 Indication that all EOPs will be exercised by all operators

NOTE: Where a generic simulator is used, and to some extent where a plant

reference simulator is used, it will not be possible to fully exercise all parts of the

EOPs. In these cases, the PGP should describe the method that the applicant

will use to ensure that the validation and verification program will cover areas

missed in the simulator exercises. The following elements are included to

address this issue.

6.3.2.3 A description of the method for training in areas not covered by

simulator exercises

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 Walkthroughs

6.3.3.1 Indication of walkthrough of all EOPs 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 multiple

failures, simultaneous and sequential) a_

6.3.4 Use of lectures, discussion sessions, and seminars

6.4 Indication that operators will be trained prior to implementation of EOPs

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

7.0 References

NUREG-071 1, 'Human Factors Engineering Program Review Model," 1994.

NUREG-0737, "Clarification of TMI Action Plan Requirements," 1980.

NUREG-0737, Supplement 1, "Requirements for Emergency Response Capability," 1983.

NUREG-0899, 'Guidelines for Preparation of Emergency Operating Procedures," 1982.

NUREG-1358, "Lessons Learned From the Special Inspection Program for Emergency

Operating Procedures," 1989.

NUREG-1 358, Supplement 1, "Lessons Learned From the Special Inspection Program for

Emergency Operating Procedures," 1989.

Rev. 1 - November 2005 13.5.2.1 -24
Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)."

ANSI/ANS 3.2-1982, "Standard for Administrative Controls for Nuclear Power Plants," American

National Standards Institute.

13.5.2.1 -25 Rev. 1 - November 2005
[NRC FORM 335

NC FORM 335 V9-2004)

NRCMOD 2.

US. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(Assigned by NRC, Add Vol., Supp, Rev.,

and Addendum Numbers. I any.)

BIBLIOGRAPHIC DATA SHEET

(See kstn&1tins on the reverse) NUREG-0800

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

NUREG-0800, Standard Review Plan MONTH YER

Chapter 13, Conduct of Operations

Section 13.5.2.1, Operating and Emergency Operating Procedures December 2005

Revision 1 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

R. M. Pelton, J. P. Bongarra

7. PERIOD COVERED (bInusive Dams)

B. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC. provide Dwslon, OftX or Region, US Nudeur Regulatory Comnmssion, and maiing address, contracor,

plovida name and maing address.)

Division of Inspection and Regional Support

Office of Nuclear Reactor Regulation

U. S. Nuclear Regulatory Commission

Washington, DC 20555-0001

9. SPONSORING ORGANIZATION- NAME AND ADDRESS flNRC. ape 'Same as abovale; cotractor. provide NACDAsWon, OfteoReghan, US. NudcearReguimmtiyzombsin,

and maing addre-s)

(Same as above)  r... .. 1. CO

3

10 SUPPLEMENTARY NOTES

. . I

I1. ABSTRACT 12W words or Oes) t

This document provides review guidance for NRC staff to evaluate licensee's or applicant s operating and emergency operating

procedures. The staff will review the applicants plan for the development and Implementation of operating procedures as

described In the safety analysis report. The staff review will Include the procedure content and development process Including

scheduling for preparation of procedures. The classes of procedures in this review are system procedures, general plant

procedures, abnormal or off-normal procedures, emergency operating procedures, and alarm response procedures. The

review is meant to ensure that routine operating, off-normal, and emergency activities are conducted in a safe manner. It is

recognized that development of detailed procedures will be the responsibility of the combined license applicant referencing the

certified design.

12. KEY WORDSIDESCRIPTORS st wordsorph seasmti fssstresearhes hbatk Mte rport) 13. AVAILAILY STATEMENT

Operating Procedures, Emergency Operating Procedures, Abnormal Procedures, Off-normal unlimited

Procedures, Alarm Response Procedures, Plant Procedures, Procedure Generation Package, Writer's 14. SECURITY CLASSIFICATION

Guide, Plant-specific Technical Guidelines, System Procedures, Plant-specific Writer's Guide MPagoe)

unclassified

:ThisRpodJ ( 

unclassified

IS. NUMBER OF PAGES

16. PRICE

NRC., ,OR _31-04 PRNE NRCCE AE

NRC FORM 335 19-20M) PRINTED ON RECYCLED PAPER
o9 UNITED STATES 3 

3

NUCLEAR REGULATORY COMMISSION

v: WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS