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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August 14, 1986
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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
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