Information Notice No. 86-64: Deficiencies in Upgrade Programs for Plant Emergency Operating Procedures

                                                            SSINS No.: 6835 
                                                            IN 86-64       

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                            WASHINGTON, DC 20555

                               August 14, 1986

Information Notice No. 86-64:   DEFICIENCIES IN UPGRADE PROGRAMS FOR 
                                   PLANT EMERGENCY OPERATING PROCEDURES 

Addressees: 

All nuclear power reactor facilities holding an operating license or a 
construction permit. 

Purpose: 

This notice is to alert recipients to problems found in reviews and audits 
of Procedures Generation Packages (PGPs) and emergency procedures for 
operating reactors and license applicants. Indications are that many 
utilities have not appropriately developed or implemented upgraded emergency
operating procedures (EOPs). Deficiencies have been identified in the 
development and implementation of each of the four major aspects of the 
upgrade programs for utility procedures. 

It is expected that recipients will review the information for applicability
to their facilities and consider actions, if appropriate, to preclude 
similar problems occurring at their facilities. However, suggestions 
contained in this notice do not constitute NRC requirements; therefore, no 
specific action or, written response is required. 

Background: 

As required by the TMI Action Plan, NUREG-0737, the industry developed 
technical guidelines based on re-analysis of transients and accidents to 
support upgrading EOPs. In addition, the staff developed a long range 
program for upgrading EOPs in the industry. Development and implementation 
of upgraded EOPs were requested by the NRC staff in Generic Letter 82-33, 
(NUREG-0737, Supplement 1, Requirements for Emergency Response Capability), 
pursuant to 10 CFR 50.54f. "Guidelines for the Preparation of Emergency 
Operating Procedures" (NUREG-0899), was identified as the reference guidance
document for the EOP upgrade effort. 

NUREG-0737, Supplement 1, specifies submittal of a PGP that describes a 
licensee s program for upgrading and implementing EOPs by addressing four 
major areas: the technical bases of the procedures, the procedures writer's 
guide, the program for validation of the procedures, and the operator 
training program for the upgraded procedures. The NRC staff had planned to 
review and approve generic technical guidelines and plant-specific PGPs and 
had not planned to routinely review, the EOPs. The PGP review may be 
performed after 


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an operating reactor has implemented its upgraded EOPs so as not to delay 
their implementation. PGPs for applicants are reviewed as part of their FSAR
submittal before licensing. The PGP review for operating reactors and 
applicants is conducted in accordance with NUREG-0800, Standard Review Plan,
Section 13.5.2, revised July 1985. PGPs for 89 plants have been received by 
the staff, 79 have been implemented by plants, and reviews of PGPs for 48 
plants have been conducted. 

Description of Circumstances: 

The NRC staff has collected information on the quality of the upgraded EOPs 
throughout the industry. This information has come from several sources 
including: (1) in depth audits of EOP upgrade programs at four plants, (2) 
reviews of PGPs, (3) the review of procedures as a part of operating event 
analyses, (4) reviews of detailed control room design review program plans 
and summary reports, (5) examiners' experiences during operator license 
examinations, (6) industry comments on procedure-related research efforts, 
and (7) other interactions with licensees. The assessment of this 
information indicates that significant deficiencies in implementing the EOP 
upgrade programs exist. Specifically: 

1.   Licensees have not followed commitments they made in their PGPs. That 
     is, the emergency operating procedures, the verification and validation
     program, and/or the operator training program was not found to 
     adequately adhere to the PGP at any of the four plants audited. 

2.   Undocumented deviations from the Owners Groups' generic technical 
     guidelines have been found at all four plants audited. Deviations are 
     expected, but Generic Letter 82-33 requests that they be identified, 
     and a technical justification provided in the PGP. In addition, 
     programs have been found deficient where deviations were identified 
     after the PGP had been submitted, reviewed and approved by the NRC. 
     NUREG-0899 provides guidance in processing such deviations. 

3.   Failures to appropriately adapt the Owners Groups' generic technical 
     guidelines have been found at some of the plants audited, There are 
     also instances in which the generic technical guidelines are 
     technically inappropriate to the particulars of individual plants so 
     that deviations are necessary but have not been made in the emergency 
     operating procedures and/or documented in the PGP or plant records. In 
     addition, some licensees have neither adopted nor deviated from the 
     generic technical guidelines, but have used them verbatim as emergency 
     operating procedures. The NRC review and approval of the generic 
     technical guidelines has been limited to assessing their suitability as 
     technical guidelines; not as procedures for typical plants. 

4.   Failures to adhere to the PGP writer's guide have been found at all 
     four plants audited. The purpose of following an approved writer's 
     guide is to assure that potentially confusing or error-prone writing 
     styles, nomenclature, formats, conventions, or inconsistencies are 
     avoided.  Failure to adhere to the approved writer's guide in the PGP 
     has resulted in instances of safety significant problems in the EOPs at 
     some of the plants audited. 
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5.   Failures to adhere to PGP commitments on the verification and 
     validation (V&V) of emergency operating procedures have been found at 
     all plants audited. The implementation of V&V programs has not been 
     successful in identifying and correcting the types of deficiencies 
     cited in this notice at any of the plants audited. Approved PGPs 
     generally include commitments to use multidisciplinary teams in 
     conducting the V&V programs. Single individuals rather than 
     multidisciplinary teams performed the V&V function at most plants 
     audited. 

6.   Training programs at some plants audited have been found deficient in 
     areas such as (a) providing adequate instruction in the philosophy 
     behind the function orientation of upgraded EOPs, (b) training all 
     operators on all EOPs before they are implemented, and (c) evaluating 
     operator knowledge and performance after they have received training on
     the upgraded EOPs. 

Discussion: 

While the above findings do not necessarily represent the situation at any 
single plant, their occurrence across the plants contacted suggests that the
overall quality of EOPs may not meet the requirements of NUREG-0737, 
Supplement 1, and may need to be improved. To address these potentially 
safety significant deficiencies, the NRC staff is (1) issuing this 
information notice to alert licensees to the deficiencies, (2) continuing 
the audit program on a priority basis to determine the scope and safety 
significance of these deficiencies, and (3) planning inspections at all 
plants to evaluate the implementation of the licensees' commitments to 
develop and implement upgraded EOPs. 

No specific action or written response is required by this information 
notice. If you have any questions.about this matter, please contact the 
Regional Administrator of the appropriate NRC regional office or this 
office. 


                                   Edward L. Jordan Director 
                                   Division of Emergency Preparedness 
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contact:  J. Bongarra, NRR
                    (301) 492-4882

                    W. G. Kennedy, NRR
                    (301) 492-4578

                    H. Bailey, IE
                    (301) 492-9006

Attachment: List Of Recently Issued IE Information Notices