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MAY 3 a 198E
Docket No. 50-267 0 7'v ` f*ftek.'':„
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Mr. 0. R. Lee, Vice President u vat
Electric Production ba
Public Service Company of Colorado F� cL`w
P. O. Box 840
Denver, Colorado 80201
Dear Mr. Lee:
We have reviewed the emergency operating procedure (EOP) upgrade program for
the Fort St. Vrain Nuclear Generating Station (FSV) and find that additional
effort is needed to meet the provisions of NUREG-0737, "Clarification of
the TMI Action Plan ," Item I .C.1 , and Supplement 1 , Item 7. Our review did
not evaluate the technical adequacy of the FSV EOPs ; it focused on the involved
human factors aspects of implementing the EOPs. We have concluded that you
should develop and submit a Procedures Generation Package (PGP) for our review.
The details of our findings are contained in the enclosed Request for Information.
The requested PGP should consist of a writer's guide, a description of the
validation/verification program, and a description of the training program, as
required by Supplement 1 to NUREG-0737. Based on the finding of the referenced
Oak Ridge National Laboratory review, and the fact that technical bases
information is contained in the EOPs , we have determined that the required
plant-specific technical guidelines need not be submitted.
If you have any questions on this subject, please contact the NRC Project Manager,
P. Wagner at (817)860-8127.
Since this request relates solely to FSV, fewer than ten respondents are affected;
therefore , OMB clearance is not required under P.L. 96-511.
Sincerely,
7101, Eric H. Johnson , Chief
Reactor Project Branch 1
Enclosure: Request for Information
cc: see next page
841142
Fort St. Vrain
cc list
C. K. Millen Chairman, Board of County Commissioners
Senior Vice President of Weld County, Colorado
Public Service Company Greeley, Colorado 80631
of Colorado
P. 0. Box 840 Regional Representative
Denver, Colorado 80201 Radiation Programs
Environmental Protection Agency
James B. Graham, Manager 1860 Lincoln Street
Licensing and Regulation Denver, Colorado 80203
East Coast Office
General Atomic Company Don Warembourg
2021 K Street, NW, Suite 709 Nuclear Production Manager
Washington, DC 20006 Public Service Company of Colorado
P. 0. Box 368
J. K. Fuller, Vice President Platteville, Colorado 80651
Public Service Company
of Colorado Albert J. Hazle, Director
P. 0. Box 840 Radiation Control Division
Denver, Colorado 80201 Department of Health
4210 East 11th Avenue
Denver, Colorado 80220
G. L. Plumlee
NRC Senior Resident Inspector Kelly, Stansfield & O' Donnell
P. 0. Box 640 Public Service Company Building
Platteville, Colorado 80651 Room 900
550 15th Street
Denver, Colorado 80202
Darrell G. Eisenhut, Director
Division of Licensing
Office of Nuclear Reactor Regulation
U. S. Nuclear Regulatory Commission
Washington, L C. 20555
REQUEST FOR INFORMATION
EMERGENCY OPERATING PROCEDURE UPGRADE PROGRAM
FORT ST. DRAIN
PUBLIC SERVICE COMPANY OF COLORADO
The NRC staff has conducted a review of the licensee's emergency operating
procedure (EOP) upgrade program. Our review included information obtained
from the following sources:
Letter, dated February 16, 1982, from S. J. Ball (ORNL) to
D. G. Eisenhut
Letter, dated August 24, 1982, from D.- W. Warenbourg to G. Kuzmycz
Letter, dated April 14, 1983, from D. R. Lee to H. R. Denton
Letter, dated March 9, 1984, from H. L. Brey to J. T. Collins
Fort St. Vrain Emergency Procedures A through S, plus EOP INTRO
Conference call between V. DeLiso, B. Clayton, P. Wagner (NRC) and
J. Fills and C. Fuller (PSC)
The review was conducted to determine whether, in the staff's view, a more
formal EOP development program, in the the form of a Procedures Generation
Package (PGP) , is necessary for the licensee to comply with the requirements
of Supplement 1 to NUREG-0737, "Requirements for Emergency Response
Capability (Generic Letter 82-33) ," Section 7. The staff did not attempt to
evaluate the technical adequacy of either the review performed by Oak Ridge
National Laboratory (ORNL) or of the Fort St. Vrain EOPS themselves. The
staff has the following comments on the Fort St. Vrain EOPs and EOP
development program:
1. The staff has the following concerns regarding use of the "SYMPTOM-ACTION
MATRIX" format of the EOPs:
a. Use of identical action identifiers ( i .e. , an "XX" ) for three
different operators within the space provided in each matrix location
could readily lead to errors in operator identification of their
respective assigned tasks. This would be caused by a combination of .
the similarity of the identifiers , their close proximity (especially
where many symptoms are put on a single sheet, as in EP-I) , stress ,
and simple cognitive errors.
b. It is not clear that operators will be able to effectively implement
the EOPs when multiple symptoms occur. The following comments apply
to this concern:
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1) The combination of having related symptoms on more than one page
(e.g. , EP B-1, page 2 of 5, symptoms 1.1 through 1.6, and page 4
of 5, symptoms 1.7 through 1. 12) in conjunction with listing
actions only for the symptoms on that page (e.g. , EP B-1, page 2
of 5 has follow-up actions 3. 1 , 3.2, 3.6, and 3.8, while page 4
of 5 has follow-up actions 3.2, 3.3, 3.4, 3.5, and 3.7) , could
readily lead to errors in execution as the operators go from one
page of symptom-actions to another and back again. The primary
concern is that operators could think an action has been
completed on one page, based on having completed an action in a
similar matrix location on another page.
2) The matrix format does not provide any prioritization for actions
when multiple symptoms occur.
3) During the performance of actions for multiple symptoms, where
more than one operator is specified to take an action, it is not
clear that the matrix format provides for coordination of the
operators ' actions when necessary. Furthermore, it is not clear
how the licensee has determined when, or if, it is necessary for
the operators to perform a given step at the same time, when both
operators are specified to take an action.
These concerns would be addressed by one objective of a validation/
verification program, which is that the EOPs are useable (i .e. , they can
be followed without confusion, delays , or errors) . The other objectives ,
as stated on page 10 of NUREG-0899, "Guidelines for the Preparation of
Emergency Operating Procedures," are not addressed in the documentation
submitted to the NRC.
2. The staff has the following comments on the writing of the action steps
in the EOPs:
a. Conditional action steps are written in an inconsistent manner. This
can lead to errors if the inconsistency causes confusion as to
whether a step is conditional or not, or if the operators miss the
condition because they expect a more clearly formatted conditional
statement. EP-A, steps 3.1 and 3.9, provide good examples of how a
conditional step should be formatted. Other formats used that could
lead to problems are in EP-A, steps 3.2 , 3.5, 3.6, and 4.1 , EP B-1 ,
steps 3.6 and 4.3, and EPD-2, step 2.2. Other inconsistently
formatted conditional steps exist throughout the EOPs.
b. The print size used in the EOPs makes them difficult to use in
reduced lighting conditions.
- 3 -
c. The format of logic statements that use the connectives "and," "or,"
and "and/or" is inconsistent. In addition, the following specific
problems related to the use (i .e. , the definition) of these
connectives exist:
1) The current EOPs use "and" to join multiple actions within one
action step (e.g. , EP-A, steps 2.1, 2.2, and 3.2) . Imbedding
actions in this way has led to operators performing the first
action they read in each step, and not performing the other
actions within a step. There should be only one action per step.
Related actions should be listed as substeps or separate steps.
2) Use of the term "and/or" (e.g. , EP-A, step 3.4) leads to
confusion as to whether the "and" or the "or" applies under
varying conditions. Use of either "and" or "or," but not both
terms , alleviates this confusion.
3) When "or" is used to provide alternative actions (e.g. , EP-A,
step 3.7) , the criteria for when each alternative applies should
be provided.
There should be a consistent treatment of the connectives in logic
statements, in both format and definition.
d. Some terminology appears to be used inconsistently. For example, EP
B-1 , steps 2.3, 2.4 and 2.5, all use the term "Ensure. " Two of the
steps, 2.3 and 2.4, do not include any follow-on actions. By the
nature of these steps , the term "ensure" appears to mean, "check to
see if the action occurred automatically; if the action did not occur
automatically, take manual action to follow through on the action. "
In step 2.5, however, the phrase "Ensure or establish . . ." (emphasis
added) is used, which implies a meaning to the word "ensure" of,
"check, but do not follow through." An additional , related comment
is that some EOPs use "Ensure," while some EOPs use "Insure"
(emphasis added) . There should be a means to ensure consistent use
of terminology throughout the EOPs.
e. Notes and Cautions : There are inconsistencies in how notes are
written. EP-A, page 3 of 5, separates out the note, margin to
margin , while EP-G, page 2 of 2, has the note only under the
"ACTIONS" column. Also, there is no difference in format between
cautions and notes. Because of the different nature of the
information provided, and the different way the information is
regarded by operators , a distinction should be made between cautions
and notes.
- 4 -
f. The orientation of some of the EOP matrixes is horizontal on the
page, while some are oriented vertically on a page. For bound
procedures, or procedures in a loose leaf binder, use of multiple
procedures could cause excessive operator machinations , resulting in
delays in reading and implementation of the actions, as the EOPs are
oriented for reading. A consistent orientation should be used.
3. The lack of detail in the EOPs requires the operators to rely heavily on
their training to properly execute the necessary actions specified in the
EOPs. In addition, the staff has a responsibility to ensure that
appropriate training is conducted on the upgraded EOPs. The staff will ,
therefore, need to review a description of the training programs for the
upgraded EOPs.
As stated earlier, the staff did not undertake an independent review of the
technical adequacy of the Fort St. Vrain EOPs. It appears that the EOPs
which were reviewed by ORNL include the technical basis that should be
provided in the plant-specific technical guidelines required by Supplement 1
to NUREG-0737. Therefore, the licensee is not required to submit
plant-specific technical guidelines. However, based on the problems
identified in the current version of the EOPs, the staff requires that the
licensee develop and submit the remaining portions of the PGP. These are the
EOP writer's guide, a description of the validation/verification program that
has been, or will be, conducted, and a description of the training program
for EOPs. This requirement, specified in Supplement 1 to NUREG-0737, is to
ensure that the current EOPs are acceptably and consistently human-factored
and implemented, and to ensure that all future EOP revisions are of the same
aceptable quality. The staff does not require responses to the individual
concerns stated above.
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