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 appropri-
ate, 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.

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

 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.

42001 -2- Issue Date: 06/28/91

 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 ade-
quately 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

Issue Date: 06/28/91 -3- 42001

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, particu-
larly 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

42001 -4- Issue Date: 06/28/91

 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 develop-
ment of plant EOPs from GTGs.
3. Evaluation of responses to questions about the incorpora-
tion 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 transi-
tions.
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.

Issue Date: 06/28/91 -5- 42001

 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 imple-
mented 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

42001 -6- Issue Date: 06/28/91

 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 proce-
dures. 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, interpre-
tation 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), discus-
sions 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.

Issue Date: 06/28/91 -7- 42001

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 Require-
ments (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)

42001 -8- Issue Date: 06/28/91

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 Engineer-
ing 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

Issue Date: 06/28/91 -9- 42001