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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 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 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 .
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