Issue Date: 06/28/91 - 1 - 42001

NRC INSPECTION MANUAL LHFB

INSPECTION PROCEDURE 42001

EMERGENCY OPERATING PROCEDURES

PROGRAM APPLICABILITY: 2515

42001-01 INSPECTION OBJECTIVES

01.01 To follow up on inspection issues, events, or allegations

concerning the licensee's Emergency Operating Procedure (EOP)

Program.

01.02 To determine whether significant changes to the licensee's

EOPs since the last inspection meet commitments and regulatory

requirements.

01.03 To assess the impact of the changes to the licensee's EOPs

on the licensee's EOP program and overall plant safety.

42001-02 INSPECTION REQUIREMENTS

02.01 Review of EOPs and Supporting Procedures

a. Conduct an in-depth human factors adequacy review of EOPs

where significant human factors changes have been made.

b. Where significant changes have been made, verify that the

procedures are technically correct and accurately incorporate

the most recent owner's group generic technical guidance and

that any deviation(s) warranted by the plant-specific design

are adequately justified and incorporated into the EOPs as

required.

c. Verify that entry and exit points are easily followed, and

that transitions between and within the Normal Operating,

Alarm and Abnormal Operating Procedures and EOPs are appropriate, well defined, and easy to follow.

d. Evaluate the procedures and the licensee writer's guide

relative to significant human factors issues raised by changes

to structure and format.
42001 - 2 - Issue Date: 06/28/91

e. Determine the extent of deviations in the procedures from the

current licensee writer's guide and evaluate the licensee's

justification for the deviations.

f. Evaluate decision points in the procedures to determine if

they can be easily discriminated and understood.
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g. Verify that the use of notes and cautions is consistent and

correct in the procedures.

02.02 Use of EOPs and Supporting Procedures. Where significant

changes have been made, verify that the EOPs and supporting

procedures can be physically and correctly performed both inside and

outside the control rooms including simulator exercises if

appropriate.

02.03 Knowledge and Performance of Duties

a. Verify that the control room staff is aware of and understands

all significant changes to the EOPs.

b. Verify that operators receive training on revised EOPs before

the revised EOPs are implemented.

c. Evaluate operator concerns regarding the EOPs.

02.04 Review of Licensee EOP Programmatic Controls

a. Verify that the licensee's administrative procedures adequately govern the program for controlling changes to the

EOPs, the supporting procedures and associated operator

training.

b. Verify that the licensee's documentation reflects adequate

conduct of activities required by administrative procedures

that control the EOPs, and that EOP changes are incorporated,

as appropriate, into the licensee's operator training program.

c. Verify that the licensee's staff possesses the required

understanding of administrative procedures governing EOPs and

correctly implements them.

d. Verify that the licensee conducts independent audits of the

EOP program, as required, and has provisions for document

control that are commensurate with NRC requirements, including

facility licensing requirements.

02.05 Follow-up of Licensee Corrective Actions Involving EOPs

a. Verify that the licensee's documentation identifies and

prioritizes EOP weaknesses and that timely corrective actions

are implemented.

b. Evaluate the effectiveness of the licensee's corrective

actions by control room and in-plant walkdowns, simulator

scenarios, and plant staff interviews as applicable.

42001-03 INSPECTION GUIDANCE

General Guidance. This procedure is intended primarily for use in

implementing regional discretionary resources for Regional

Initiatives or Reactive Inspection to inspect the significant

changes to the licensee's EOPs and associated programs. These
42001 - 4 - Issue Date: 06/28/91

inspection activities include the examination of licensee programs

to follow up on corrective actions, to review programmatic controls,

and to follow up on identified issues requiring licensee resolution

relative to EOP program deficiencies, weaknesses, or implementation.

This procedure is also intended for use in conjunction with NRC

Manual Chapter 0517, "Management of Allegations," to examine

elements of the licensee's EOP Program as appropriate to follow up

on allegations concerning the program. It is not intended that each

inspection requirement be covered during an inspection. Rather,

inspection requirements should be selected or modified, as

appropriate, to address the issue or event that prompted the

inspection. Preparation for the inspection should include a review

of issues identified during previous inspections or operator

licensing examination reports that would be indicative of weaknesses

in the EOP Program, policy, or implementation. Significant events

with a root cause related to EOPs should also be reviewed in

preparation for inspection. During onsite inspection, all major

changes, including those related to the resolution of identified

issues, the bases for the changes, and the effect of the changes on

program effectiveness, should be discussed by the team leader with

licensee management.

By reference to the appropriate revision of Regulatory Guide 1.33,

"Quality Assurance Program Requirements," Section 6.8 of the

Standard Technical Specifications requires that Emergency Operating

Procedures be established, implemented, and maintained. In

addition, the licensee should review the EOPs to evaluate the safety

review functions and the responsibilities of the onsite safety

review organization. Further, 10 CFR 50 Appendix B, Criterion VI,

requires that quality related documents, and changes thereto, be

reviewed for adequacy and approved for release by authorized

personnel. In general, technical inadequacies or failures to

properly implement and maintain EOPs are violations of these

requirements.

The NRC evaluates the owner's group Generic Technical Guidelines

(GTGs) for safety and approves them. Where licensees elect to

deviate from the NRC-approved GTGs, they need to implement correctly

the 10 CFR 50.59 process to ensure safe plant operation, particularly for design basis events. Insufficient or incorrect use of the

10 CFR 50.59 process to evaluate deviations from the NRC-approved

GTGs may constitute a violation.

Specific Guidance

03.01 Review of EOPs

a. The review for human factors adequacy determines whether the

EOPs are adequate for the intended use and whether the

licensee has accurately incorporated the guidance of the GTGs.

Plant staff interviews should be conducted with cognizant

licensee personnel to assist in determining whether the GTGs

remain appropriately incorporated in the EOPs. Significant

changes to the EOPs and supporting procedures should be

reviewed by inspectors with experience in human factors
Issue Date: 06/28/91 - 5 - 42001

evaluation. See NUREG-0899, NUREG-1358 and NUREG/CR-5228. See

Section 42001-05 of this procedure for full reference.

b. Operator comments on the technical aspects of significant

changes to the EOPs, given during interviews with the plant

staff, procedure walkdowns, and simulator exercises, should

be evaluated and addressed in the inspector's EOP technical

adequacy review. Particular attention should be given to the

following:

1. Comparison of the GTG table of contents to the table of

contents of plant-specific EOPs and evaluation of the

differences.

2. Review of licensee documentation addressing the development of plant EOPs from GTGs.

3. Evaluation of responses to questions about the incorporation of GTGs into the EOPs from interviews with cognizant

licensee personnel.

4. Verification that the licensee has an appropriately

prioritized accident mitigation strategies in the

procedures and that recommended GTG step sequences are

followed.

5. Verification that the licensee has an adequate technical

justification for identified deviations between the

plant-specific EOPs and the generic technical guidelines.

See Generic Letter 82-33. Full reference may be found in

Section 42001-05 of this procedure.

6. Assessment of the safety significance of identified

deviations. A sample of deviations should be examined to

determine if the licensee has reported safety significant

deviations to the NRC. These deviations should be

verified to be in accordance with 10 CFR 50.59.

c. The use of walkthroughs and simulator scenarios provides a

practical means to verify that the procedures are well defined

and easy to follow for entry and exit points and for transitions.

d. For specific program guidance, see NUREG-0899, NUREG-1358, and

NUREG/CR-5228.

e. Significant deviations from the licensee's writer's guide for

the EOPs should be reviewed for adequacy. A significant

number of minor deviations should raise questions about the

consistency of EOP structure.

f. A newly qualified operator should be able to properly

implement the decision points in the EOPs without needing

further guidance. The logic points should have clear

questions that solicit yes or no answers. See NUREG-0899,

NUREG-1358, and NUREG/CR-5228.
42001 - 6 - Issue Date: 06/28/91

g. The caution statements should identify potential hazards, and

the notes and caution statements should not contain action

statements. See NUREG-0899, NUREG-1358 and NUREG/CR-5228.

03.02 Use of EOPs and Supporting Procedures. Where major

changes have been made or concerns have been previously identified,

walkdowns, simulator exercises on EOPs and supporting procedures and

interviews with plant staff should be conducted. Focus on whether:

a. The changes made to the procedures can be physically implemented and whether operators physically interfere with each

other while performing the changed procedures.

b. The changed procedures can be implemented within the time

allotted considering the actual accident, the course of

events, and the availability of the necessary operating

locations involved under those conditions.

c. Environmental conditions (such as temperature, steam,

flooding, and radiological hazards) that would exist during

the event would prevent items 03.02a. and 03.02b. above from

being accomplished.

d. Plant personnel can effectively use the EOPs and supporting

procedures in the control room and other parts of the plant

as necessary. An evaluation of the consistency of instrument

and control designations as compared with installed equipment

labels and procedural descriptions should be included. Also,

the indicators, annunciators, and controls referenced in the

procedures are available to the operators.

e. EOP activities that would occur outside of the control room

can be performed with equipment on hand.

f. The licensee has validated and verified the procedures. A

documented, comprehensive review should have been conducted

by an independent, multidisciplinary team, including a human

factors analysis of the procedural changes and a walkdown of

the procedures in the plant. See NUREG-1358, NUREG/CR 2005,

and NUREG-3632 which are fully referenced in Section 42001-05

of this procedure.

g. The latest revision to the procedures is in the control room,

the Technical Support Center, and the Emergency Operation

Facility.

03.03 Knowledge and Performance of Duties

a. The control room staff should understand how to perform the

current EOPs. To determine whether the operators are aware

of recent changes to the EOPs and understand the changes,

limited plant-specific simulator scenarios should be conducted

on at least one fully staffed shift crew. The simulator

scenario should reflect relevant abnormal operating conditions

that require the use of two or more of the EOPs in which

significant changes have been made. Each procedural step

should be observed to determine that the correct procedures
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are used with proper transitions, and that each step is

correctly implemented. Where concerns are identified, the

sample size should be expanded. Walkdowns should be conducted

to further assess the operator's understanding of the EOPs,

the supporting procedures, and recent changes to the procedures. During the control room and in-plant walkdowns direct

observation should be made of selected operators in the

simulated performance of selected tasks required by the EOPs.

Such tasks include simulated handling of equipment, interpretation of instrument readings, following procedures, proper

sequencing of actions, and an understanding of information

flow patterns related to a specific task. Plant-referenced

simulators, as required by 10 CFR 55.45 should be used for

walkdowns to allow hands-on performance for certain tasks.

See SECY 90-337 which is fully referenced in Section 42001-05

of this procedure.

b. EOP training is covered under Inspection Procedure 41500.

c. Operator concerns regarding the EOPs may be identified by the

review of inspection reports, operator licensing examination

reports, operator responses to licensee training, procedural

review documentation, Licensee Event Reports (LERs), discussions with the Resident Inspectors, and interviews with

operators. Operators' concerns may be evaluated by EOP

desktop reviews, procedure walkdowns, and simulator exercises.

03.04 Review of Licensee EOP Programmatic Controls

a. The licensee's administrative procedures should provide

controls to ensure that all changes such as changes to the

Technical Specifications, setpoints, and those resulting from

instrument and equipment modifications, are reflected in a

timely manner, in the EOPs, the setpoint documents, and the

operator training lesson plans. An active licensee program

should provide for the long-term evaluation of EOPs as

recommended in Section 6.2.3 of NUREG-0899, "Guidelines for

the Preparation of Emergency Operating Procedures." The

licensee's EOP evaluation program should be technically

adequate and the EOPs should be structured to incorporate

operational experience and use, training experience, simulator

exercises, control room and in-plant walkdowns and changes in

plant design, technical specifications, technical guidelines,

Writer's Guide, or other plant procedures. (See Regulatory

Guide 1.33, Rev 2. which is fully referenced in Section

42001-05 of this procedure).

b. No guidance is necessary.

c. Interview the licensee's staff and management involved in the

performance of administrative procedures governing EOPs to

determine if they understand the procedures and if the

procedures are implemented consistently among users.

d. See NUREG-1358.
42001 - 8 - Issue Date: 06/28/91

03.05 Follow-up of Licensee Corrective Actions with Regard to

EOP Concerns. No guidance is necessary.

42001-04 RESOURCE ESTIMATES

For planning purposes, direct inspection effort to accomplish this

procedure should be established by the Regional office, consistent

with the scope of planned regional initiatives or reactive

inspections to be performed. Individuals having experience in

evaluating human factors should accomplish the parts of this

inspection that deal with human factors issues. Direct inspection

effort for reactive inspection or regional initiatives should be

recorded on RITS against Inspection Procedure 42001. If the

procedure is used to follow up allegations in conjunction with NRC

Manual Chapter 517, the actual time expended should be recorded on

RITS against BJ1.

42001-05 REFERENCES

10 CFR Part 50, Appendix B, Criteria V and VI.

10 CFR 50.54(x) and (y).

10 CFR 50.9.

10 CFR Part 2, Appendix C, Criterion VI.

10 CFR 50.34(f)(2)(ii) and (v).

10 CFR 50.36(c)(5).

10 CFR 50.59.

Site-Specific Technical Specifications, Chapter 6.

Generic Letter 82-33, "Supplement 1 to NUREG - 0737, Requirements

for Emergency Response Capability," December 17, 1982. (NUDOCS

Fiche Address 16681/208)

SECY-90-337, "Procedural Adherence Requirements," October 3, 1990.

(NUDOCS Fiche Address 70497/142)

Regulatory Guide 1.33, Rev.2, "Quality Assurance Program Requirements (Operation)," 1978. (NUDOCS Fiche Address 00125/155)

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

Emergency Operating Procedures," April 1989. (NUDOCS Fiche Address

49726/209)

NUREG-1977, "Guidelines for Preparing Emergency Procedures for

Nuclear Power Plants," April, 1981. (NUDOCS Fiche Address

08514/008)
Issue Date: 06/28/91 - 9 - 42001

NUREG/CR-4613, "Evaluation of Nuclear Power Plant Operating

Procedures Classifications and Interfaces," February 29, 1987.

(NUDOCS Fiche Address 39983 /256)

NUREG/CR-3632, "Methods for Implementing Revisions to Emergency

Operating Procedures," May 1984. (NUDOCS Fiche Address 24534/208)

NUREG-0899, "Guidelines for the Preparation of Emergency Operating

Procedures," August 1982. (NUDOCS Fiche Address 15513/286)

NUREG/CR-2005, Rev.1, "Checklist for Evaluation Emergency Operating

Procedures Used in Nuclear Power Plants," April 1983. (NUDOCS Fiche

Address 08790/355)

NUREG/CR-3177, Vols. 1, 2, and 3, "Methods for Review and Evaluation

of Emergency Procedure Guidelines," March 1983. (NUDOCS Fiche

Address 21119/138, 17863/033, and 17862/227)

NUREG/CR-5228, "Techniques for Preparing Flowchart-Format Emergency

Operating Procedures," January 1989. (NUDOCS Fiche Address

49670/141)

"Supplement 3, Safety Evaluation for CEN-152, `Combustion Engineering Emergency Procedure Guidelines,'" November 5, 1986.

"Combustion Engineering Emergency Procedure Guidelines," Submittal

2 of Revision 3, August 6, 1986.

"Supplement Safety Evaluation Report for `Westinghouse Owners Group

Emergency Response Guidelines, Revision 1,'" July 7, 1986.

"Westinghouse Owners Group Emergency Response Guidelines, Revision

1," November 30, 1983.

"Safety Evaluation of `BWR Owners Group Emergency Procedure

Guidelines, Revision 4, March 1987,'" NEDO 31331, August 1, 1988.

"BWR Emergency Procedure Guidelines, Revision 4," March 1987.

END