Issue Date: 09/09/13 1 42454

NRC INSPECTION MANUAL COLP

INSPECTION PROCEDURE 42454

PART 52, EMERGENCY OPERATING PROCEDURES

PROGRAM APPLICABILITY: 2504

42454-01 INSPECTION OBJECTIVES

To verify that plant emergency operating procedures are prepared to adequately control safety 

related functions in the event of indications of a system or component malfunction.

To determine the adequacy of management controls in implementing and maintaining a viable 

procedure system.

To verify that the technical adequacy of procedures is consistent with desired actions and 

modes of operation.

To verify the usability of procedure content and format by determining the degree to which 

accepted human factors principles have been incorporated.

42454-02 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. Select a sample of at least 15 plant emergency operating 

procedures used by the licensee to correct and to mitigate emergencies and other significant 

plant events. Verify that each procedure is in the format specified in the administrative controls 

procedure. Verify that each procedure has been reviewed by a competent technical authority 

and found to be technically adequate to accomplish its stated purpose. 

02.02 Procedure Administration. Verify that administrative controls and responsibilities have 

been established for the review, approval, and periodic updating of emergency operating 

procedures that conforms to license requirements.

02.03 Procedure Controls. Verify that controls exist 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c. Control and disposition of outdated procedures. 
Issue Date: 09/09/13 2 42454

d. Control of temporary changes to procedures.

e. Ensuring changes to procedures are 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. Review the procedures to:

a. Verify that the procedures have been determined to accomplish their intended purpose, 

within the design characteristics and the safety review considerations.

b. Verify that appropriate technical specification, vendor, or design operating limitations, 

such as heat up/cool down rates, pressure/temperature limits, reactivity limits, safety 

limits, Limiting Conditions of Operations (LCOs), and limiting safety system settings, are 

incorporated in the procedures.

c. Verify that human factors principles (Appendix B, Procedure Usability) are incorporated 

into the procedures. Verify that the procedures are usable by the personnel intended. 

Evaluate the procedures against the writing style and format standards established in 

the licensee's Writer's Guide.

d. Using the guidance in Attachment A, "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 Attachment A to determine that human factors principles 

were used to make 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 Attachment A are not evident in the initial 

sample, select additional 5 - 10 procedures for review. Document the results of 

the review.

02.05 Interviews. Interview facility staff to determine awareness and understanding of the 

established controls for temporary changes to procedures.

42454-03 RESOURCE ESTIMATE

For planning purposes, the direct inspection estimate is 96 hours of on-site inspection, 

consistent with the scope of the planned regional initiative(s) to be performed. 

The inspection hour’s estimate is for budgeting purposes. The hours expended during an 

inspection should be tailored to the facility and accurately recorded.
Issue Date: 09/09/13 3 42454

42454-04 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 and NUREG-0737, Supplement, "Clarification of TMI Action Plan Requirements.”

NUREG-0737, Supplement 1, “Clarification of TMI Action Plan Requirements”

NUREG-0899, “Guidelines for the Preparation of Emergency Operating Procedures”

NUREG/CR-2005, "Checklist for Evaluating Emergency Operating Procedures Used in Nuclear 

Power Plants"

NRC Information Notice 92-76, “Issuance of Supplement 1 to NUREG-1358, Lessons learned 

from the Special Inspection Program for Emergency Operating Procedures”

10 CFR Part 52, “Early Site Permits; Standard Design Certifications; and Combined Licenses 

for Nuclear Power Plants”

42454-05 COMPLETION STATUS

For completion the following must be present: 

a. Inspection of the minimum sample size required to make an assessment in accordance 

with the Reactor Oversight Process (ROP),

b. the assessment results of the program are acceptable to the geographic Region, and

c. transition to inspection under the ROP will constitute completion of this procedure in the 

Construction Inspection Program.

END
Issue Date: 09/09/13 4 42454

Appendices:

A. Procedure Content

B. Procedure Usability

Attachment 1: Revision History for IP 42454
Issue Date: 09/09/13 1 42454 App A

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 operator 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. 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 operations during and following a controlled 

shutdown and 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 are 

controlled by a mode switch.

Note: Both shutdown operations and 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 of the correct operation 

of systems which control or support 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 operating 

procedure.
Issue Date: 09/09/13 2 42454 App A

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. 
Issue Date: 09/09/13 1 42454 App B

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, format and organization. 

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.
Issue Date: 09/09/13 2 42454 App B

- 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.
Issue Date: 09/09/13 3 42454 App B

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 Yes No N/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 it 

performs?

5 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

6 If this is a multiple unit site, does the procedure refer to one unit only 

and is it readily identifiable to that unit?
Issue Date: 09/09/13 4 42454 App B

Attribute Yes No N/A

7 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 ___

8 Is the location of page identification information consistent?

9 Is the last page of the procedure clearly identified by marking, e.g., 

Page ___ of ___ or Final Page?

10 If this is a temporary procedure, is it clearly marked with the 

expiration date?

11 Do the immediate operator actions avoid referencing operators to 

other procedures for instructions?

12 Are the titles and numbers of all referenced documents identified 

correctly and consistently?

14 Does the procedure contain provisions for coordinating the activities 

of others? For example, is there a checklist for a coordinator to 

record that an action has been completed?

15 Does the procedure provide a means to check off that the following 

were observed or performed?

a. Symptoms

b. Automatic actions

c. Immediate operator actions

17 Are the instructions printed in both upper and lower 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.)

18 Is there consistent use of the following?

a. Abbreviations, acronyms, and symbols

b. Methods of emphasis
Issue Date: 09/09/13 5 42454 App B

Attribute Yes No N/A

19 Are the steps that must be performed in a fixed sequence clearly 

distinguishable from steps that do not have to be performed in a fixed 

sequence?

20 Does each instructional step direct only one action?

21 Does each instructional step meet the following 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.

22 If a step contains three or more objects of an action, are they listed 

rather than imbedded in the sentence? For example, if an operator is 

directed to close three or more valves, they should be listed rather 

than strung out in a sentence.

23 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.

24 If explanations/cautions are applicable to the performance of specific 

steps or series of steps, are they placed immediately ahead of the 

step(s) to which they apply?

25 Are explanations/cautions separate and easily 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.?

26 Can the text of an explanation/caution be read without interruption by 

intervening steps or page turning?

27 Do explanations/cautions avoid the use of action statements? 

(Statements directing personnel to perform actions must not be 

imbedded in explanations/cautions. Explanations/cautions should be 

expressed in the passive voice.)
Issue Date: 09/09/13 6 42454 App B

Attribute Yes No N/A

28 Are explanations/cautions provided to inform personnel when 

displays are based on secondary sensing modes? For example, is a 

caution provided when a light indicates only that a circuit is energized 

rather than the position of the valve?

29 Are instrument readings, control values, and other limits used to 

guide operator actions expressed in quantitative terms when 

possible?

30 Are quantitative limits expressed as ranges rather than single 

values?

31 Are limits compatible with those stated in the emergency operating 

procedure technical guidelines?

32 Are the contingencies provided for in the procedure consistent with 

those specified in the emergency operating procedure technical 

guidelines?

33 Are contingencies written in a consistent style and expressed so that 

the conditional statement precedes the action statement?

34 Are contingency instructions easy to understand? For example, if 

three or more conditions are associated with an action, they should 

be listed separately from and ahead of the action statement.

35 If calculations are required, is space provided in the procedure to 

perform the computations and to record the results?

36 Do required calculations use formulas and values that are compatible 

with the emergency operating procedure technical guidelines?

37 Do graphs, charts, tables, and figures meet all of 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.
Issue Date: 09/09/13 7 42454 App B

Attribute Yes No N/A

38 If the procedure specifies an action that must be 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?

Perform a Walk-though of the Procedure for Items #39 and #40

39 Are equipment numbers and/or nomenclature used in the procedure 

the same as those which are displayed on the equipment?

40 Are the units of measurement used in the procedure the same as 

those displayed on instruments?

Observe a Simulation or Performance of the Procedure for the Following Items

41 Are the emergency operating procedures readily identifiable and 

easily accessible?

42 Does the procedure identify all major symptoms or combinations of 

symptoms associated with the emergency? (Determine whether the 

operator can describe major symptoms or combinations not identified 

by the procedure.

43 Does the procedure specify automatic actions associated with the 

emergency adequately? (Determine whether the operator can 

describe automatic actions not identified by the procedure.)

44 Does the procedure specify all critical actions required to respond to 

the emergency? (Observe whether the operator performs critical 

actions not specified by the procedure.)

45 If the procedure contains sequence-critical actions, is the sequence 

specified by the procedure correct? Observe whether the operator 

performs sequence-critical actions in the sequence specified.)

46 Does the procedure allow enough time to perform time-critical 

actions? (Observe whether the operator can perform time-critical 

actions in the time allowed, i.e., by equipment response, distances 

involved, etc.)

47 Does the procedure identify equipment adequately? (Determine 

whether the operator can readily identify all equipment and items 

referred to in the procedure.)

48 Are references to equipment in the procedure identical to the labels 

displayed on the equipment
Issue Date: 09/09/13 8 42454 App B

Attribute Yes No N/A

49 If the answer to Item #48 is Yes, are references to equipment labels 

typed in upper case letters in the procedure?

50 Are the units of measurement used in the procedure the same as 

those displayed on instruments?

51 Does the procedure identify the location of each item of equipment 

adequately? (Observe whether the operator can locate switches, 

gages, etc. in a timely manner.)
Issue Date: 09/09/13 Att1-1 42454

ATTACHMENT 1

Revision History for IP 42454

Commitment 

Tracking 

Number

Accession Number 

Issue Date

Change Notice

Description of Change Description of

Training Required

and Completion Date

Comment and 

Feedback Resolution 

Accession Number

NA 07/29/08

CN 08-021

Initial issue to support inspections of 

operational programs described in 

IMC 2504, NON-ITAAC INSPECTIONS

Completed review of CNs for previous 

4 years and found no commitments.

None ML071090407

NA ML13232A368

09/09/13

CN 13-020

Researched commitments for 4 years and 

found none. 

Revision based on periodic review and 

update. Change title to more accurately 

reflect the procedures being inspected. 

Added Program Applicability, removed one 

reference, and made formatting changes.

None N/A