United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 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)"

                                 UNITED STATES
                         NUCLEAR REGULATORY COMMISSION
                            WASHINGTON, D.C.  20555

                               November 13, 1992

                               (CONDUCTED OCTOBER 1988 - SEPTEMBER 1991)"


All holders of operating licenses or construction permits for nuclear power


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.


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


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                                                            November 13, 1992
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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

     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)


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                                                            November 13, 1992
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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

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