NRC: Information Notice No. 92-76: Issuance of Supplement 1 to NUREG-1358, "Lessons Learned from the Special Inspection Program for Emergency Operating Procedures (Conducted October 1988 - S...

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Information Notice No. 92-76: Issuance of Supplement 1 to NUREG-1358,

"Lessons Learned from the Special Inspection Program for Emergency

Operating Procedures (Conducted October 1988 – September 1991)"

 UNITED STATES

 NUCLEAR REGULATORY COMMISSION

 OFFICE OF NUCLEAR REACTOR REGULATION

 WASHINGTON, D.C. 20555

 November 13, 1992

NRC INFORMATION NOTICE 92-76: ISSUANCE OF SUPPLEMENT 1 TO NUREG-1358,

 "LESSONS LEARNED FROM THE SPECIAL INSPECTION

 PROGRAM FOR EMERGENCY OPERATING PROCEDURES

 (CONDUCTED OCTOBER 1988 - SEPTEMBER 1991)"

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information

notice to alert addressees to the findings from the third phase of the special

inspection program for emergency operating procedures (EOP-3) and additional

EOP followup inspections conducted from October 1988 through September 1991. 

In conducting these inspections, the staff found continuing deficiencies in

the EOP programs at a number of plants. It is expected that recipients will

review the information for applicability to their facilities and consider

actions, as appropriate, to avoid similar problems. However, suggestions

contained in this information notice are not NRC requirements; therefore, no

specific action or written response is required.

Background

The NRC began its EOP inspection program to determine if licensees were

meeting the requirements of Three Mile Island (TMI) Action Plan, Item I.C.1,

"Guidance for the Evaluation and Development of Procedures for Transients and

Accidents," (NUREG-0737, "Clarification of TMI Action Plan Requirements," and

Supplement 1 to NUREG-0737). During the pilot phase (EOP-1) and second phase

(EOP-2) of the program, the NRC staff found concerns with the industry's

methods for developing and implementing EOPs. In April 1989, the staff issued

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NRC: Information Notice No. 92-76: Issuance of Supplement 1 to NUREG-1358, "Lessons Learned from the Special Inspection Program for Emergency Operating Procedures (Conducted October 1988 - S...

https://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1992/in92076.html[12/29/2016 10:26:57 AM]

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

Operating Procedures, Conducted March - October 1988," to reiterate the

critical elements for preparing effective EOPs described in NUREG-0899,

"Guidelines for the Preparation of Emergency Operating Procedures,"

August 1982. 

Description of Circumstances

In October 1988, the staff began the third phase of the EOP inspection effort

to determine the effectiveness of industry initiatives to improve the EOPs and

address previously found deficiencies. Upon completing EOP-3, the staff noted

9211060196.

 IN 92-76

 November 13, 1992

 Page 2 of 3

continuing areas of deficiency in industry EOPs since NUREG-1358 was issued. 

Some licensees had addressed the concerns raised in NUREG-1358 and had

effectively incorporated the standards for developing EOPs described in

NUREG-0899. However, in conducting most of the EOP-3 inspections, the staff

continued to find technical concerns with licensee methods for developing and

implementing EOPs. Specifically, many licensee EOP programs were found to

have one or more of the following weaknesses: 

 1. inadequate documentation of deviations from the NRC-approved generic

 technical guidelines 

 2. inadequate implementation of the EOP writer's guide or inadequate

 guidance provided in the writer's guide 

 3. inadequate verification and validation of the EOPs and EOP support

 procedures 

 4. inadequate training and evaluation of the operating staff with

 regard to the use of the upgraded EOPs or inadequately defined or

 implemented EOP usage guidance 

 5. failure to adequately control the EOP revision process 

 6. inadequate commitment of resources to develop and maintain the EOPs

These programmatic weaknesses have led to errors and inadequacies in EOPs and

EOP support procedures including: 

 1. lack of appropriate instruments to conduct the actions specified in

 the EOPs and EOP support procedures

 2. incorrect, unnecessary, or incomplete procedural steps

 3. references to actions that cannot be accomplished because of

 environmental conditions or equipment failures during transients

 4. inaccessible or unstaged equipment required to perform EOP actions

 5. overly complex procedural steps or misleading logic

 6. lack of consistent procedural format or terminology

 7. excessive or incorrect transitions between EOPs and additional
NRC: Information Notice No. 92-76: Issuance of Supplement 1 to NUREG-1358, "Lessons Learned from the Special Inspection Program for Emergency Operating Procedures (Conducted October 1988 - S...

https://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1992/in92076.html[12/29/2016 10:26:57 AM]

 support procedures

 8. lack of adequate procedural guidance for certain critical operator

 actions (e.g., bypassing or defeating interlocks of isolations)

.

 IN 92-76

 November 13, 1992

 Page 3 of 3

Discussion

The inability of operators to implement appropriate mitigation strategies

because of weaknesses in the EOPs could directly and adversely affect response

to events at nuclear power plants. Deficiencies in EOPs have also been a

factor in unsatisfactory operator performance during requalification

examinations. The staff published Supplement 1 to NUREG-1358 in September

1992 to inform the industry of the results of the EOP-3 inspections and

continuing EOP followup inspections. In addition to the findings discussed

above, the staff described, in Supplement 1 to NUREG-1358, some good practices

observed in EOP programs and included additional information which may aid in

detection and correction of weaknesses in EOP programs. However, Supplement 1

to NUREG-1358 does not impose any new requirements with respect to EOPs.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

the technical contact listed below or the appropriate Office of Nuclear

Reactor Regulation (NRR) project manager.

 ORIGINAL SIGNED BY

 Brian K. Grimes, Director

 Division of Operating Reactor Support

 Office of Nuclear Reactor Regulation

Technical contact: Greg S. Galletti, NRR

 (301) 504-1831

Attachment:

List of Recently Issued NRC Information Notices

.

Page Last Reviewed/Updated Friday, May 22, 2015

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NRC: Information Notice No. 92-76: Issuance of Supplement 1 to NUREG-1358, "Lessons Learned from the Special Inspection Program for Emergency Operating Procedures (Conducted October 1988 - S...

https://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1992/in92076.html[12/29/2016 10:26:57 AM]

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