1. INTRODUCTION

UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

BY THE OFFICE OF NUCLEAR REACTOR REGULATION SAFETY EVALUATION

RELATED TO PROCEDURES GENERATION PACKAGE PUBLIC SERVICE ELECTRIC & GAS COMPANY

DELMARVA POWER AND LIGHT COMPANY ATLANTIC cffy ELECTRIC cdMP&NV

SALEM GENERATING STATION~ UNIT NOS. 1 AND 2 bocKET Nos. 5o-27 AND 50-311

Following the Three Mile Island (TMT) accident, the Office of Nuclear Reactor Regulation developed the "TMI Action Plan•• (NUREG-0660 and NUREG-0737) which required licensees of operating reactors to reanalyze transients and accidents and to upgrade emergency operating procedures (EOPs) (Item I.C.l). The plan also required the NRC staff to develop a long-term plan that integrated and expanded efforts in the writing, reviewing, and monitoring of plant procedures (Item I.C.9). NUREG-0899, "Guidelines for the Preparation of Emergency Operating Procedures," represents the NRC staff's long-term program for upgrading EOPs, and describes the use of a "Procedures Generation Package" {PGP) to prepare EOPs. Submittal of the PGP was made a requirement by Generic Letter 82-33, "Supplemen~ 1 to NUREG-0737 - Requirements for Emergency Response Caoability." The generic letter requires each licensee to submit to the NRC a PGP which includes:

(i) Plant-specific technical guidelines

(ii) A writer's guide

(iii) A description of the program to be used for the validation of EOPs

(iv) A description of the training program for the upgraded EOPs.

This report describes the review of the Public Service Electric and Gas Company (PSE&G) response to the generic letter related to development and implementation of EOPs (Section 7 of Generic Letter 82-33) for Salem Generatt~g Station (Salem).

Our review was conducted to determine the adequacy of the PSE&G proqram for preparing and implementing upgraded EOPs for Salem. This review was based on NUREG-0800 (formerly NUREG-75/087), Subsection 13.5;2, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants. Section 2 of this report briefly discusses the PSE&G submittal, the NRC staff review, and the acceptability of the submittal. Section 3 contains the conclusions of this review.

8911290095 891117 PDR ADOCK 05000272 p . PNU

- 2 -

As indicated in the following sections, our review determined that the procedures generation program for Salem has several items that must be satisfactorily addressed before the PGP is acceptable. PSE&G should address these items in a revision to the PGP, or provide justification for why such revisions are not necessary. This revision and/or.justification need not be submitted, but should be retained for subsequent review by the NRC staff. The revision of the PGP~ and subsequently of the EOPs, should not impact the schedule for the use of the EOPs. The revision should be made in accordance with the Salem administrative procedures and 10 CFR 50.59.

2. EVALUATION AND FINDINGS

In a letter dated May 20, 1983 from E. A. Liden (PSE&G) to S. A. Varga (NRC), PSE&G submitted its PGP for Salem. The PGP contained an introduction and the following sections:

0

0

0

0

0

Technical and Administrative Guidelines, and Procedures Preparation

Author's Guide

Verification Program

Validation Program

Training Program

An audit was conducted by NRC staff on September 23 through 26, 1985 to assess the extent to which PSE&G staff had implemented the PGP during preparation of the Salem EOPs. A list of general comments were prepared by the audit team to document their concerns.

In a letter dated December 30, 1986, PSE&G submitted a revised writer's guide. The NRC staff review of the revised writer's guide is documented in the following subsection.

A. Writer's Guide

·.

The writer's guide was reviewed to determine if it (1) described acceptable methods for accomplishing the objectives stated in NUREG-0899 and (2} addressed the concerns identified in the audit general comments. The writer's guide, 11 Jldministrative Directive - 2, Authors Guide for Operations Department Documents, 11 is intended to provide guidelines on how to format and prepare documents and procedures so that they are complete, accurate, convenient, readable, and acceptable to their users. Our review of the Salem Writer's guide identified the following concerns:

l. Cautions, notes, and precau~ions provide operators with critical or useful information concerning specific steps or sequences of steps in EOPs.

·.

- 3 -

a. Section 4.3.1.b, page 28; 5.3.4.c(7)(c), page 50; and 5.3.5.d{6)(c}, page 57, allow action statements in cautions. Cautions attract attention to essential or critical information in the procedures, and should not include any instructions, directions, or operator actions. Audit General Comment 11.b also stated that action steps should not be presented in caution statements. The noted sections and associated examples should be changed accordingly.

b. Section 2.4.3, page 3, states that "for EOPs only, Cautions and Notes shall be numbered as steps within the step sequence. 11 Cautions and notes are not action steps and they should not be numbered as steps. Audit General Comment 11.a noted that the existing instructions for formatting cautions and notes were acceptable but were not being followed. Section 2.4.3 should be changed to indicate that cautions and notes will not be numbered as steps.

c. Section 4.3 should be revised to state that each caution, note, and precaution will contain only one topic as the importance of any one topic is obscured when a caution, note, or precaution contains more than one topic.

d. Section 4.3.1.d, page 28, and Section 4.3.3.b, page ~9, state that cautions or notes can in some instances be placed after the step to which they apply. Operators should be aware of all information in a caution or note before they perform the step to which the caution or note applies. These sections should be revised to indicate that cautions and notes will be placed directly before the step to which they apply, even when the caution or note pertains to the results of the step.

e. Section 4.3 should state that each note and precaution will be wholly contained on a single page to ensure that the flow of information from procedure to operator is uninterrupted.

f. Section 4.3.2 states that precautionary information should be grouped together in a precautions section, but the writer's guide provides no information about how precautions or the precautions section should be formatted. Section 4.3.2 should be expanded to address formatting of precautions and should provide appropriate examples.

g. Section 4.3.2 discusses precautions, which must be remembered throughout a procedure, and Section 5.3.4.c(7)(c){3), page 50, discusses cautions that must be remembered throughout the use of a flowchart. Operators will be required to

.. ' ..

- 4 -

execute EOPs during stressful conditions and under time restraints. Therefore, EOPs should be designed in such a way that they place a minimal burden on the operators• short term memory. Section 4.3.2 and 5.3.4.c(7)(c)(4) should be expanded to indicate that the use of precautions and cautions of continuous applicability should be minimized. An alternative to using these devices would be to structure the information as rules that operators are required to memorize.

h. Section 4.3 should be expanded to provide examples of properly formatted cautions and notes.

2. Logic statements are used in EOPs to describe a set of conditions or a seauence of actions. Because of their importance and complexity it is important to provide explicit guidance for their use.

a. The logic term IF NOT should be added to the list of logic terms in Section 3.8.3.c, page 14, since its use is described within the section.

b. Section 3.8.3.f(3)(b), page 15, states that decision symbols are used instead of IF ••• THEN in flowcharts, but that IF ••• THEN may be used "during subsequent levels of the decision process if the process must be continued in ••• the 1 No 1 path of a flowchart." Also, the definition of the action step symbol in Figure 2 states that the action step symbol is used to define "contingency action steps (IF ••• THEN)." Because it is important to present decision criteria in a consistent format, decision symbols should be used instead of IF ••• THEN statements throughout flowcharts. Section 3.8.3.f(3)(b), Section 5.3.5.d(2), page 57 and Figure 2 should be revised to indicate that IF • • • THEN statements will not be used instead of decision symbols in flowcharts. This is a form of an embedded logic statement, the use of which should be minimized as stated in Audit General Comment 4.

c. Section 5.3.5.d, pages 56-59, discusses the use of other types of logic terms, in addition to IF ••• THEN, in flowcharts. In flowcharts, sets of conditions and sequences of actions are defined by flowchart symbols. Having to interpret logic statements and flowchart symbols simultaneously can be confusing. Therefore, the writer's guide should express a commitment to minimize logic statements within flowcharts and provide guidance for achieving this objective. Further, Section 5.3.5.d should include sequences to be avoided and examples of the correct use of each logic term--inclusive OR, exclusive OR, a.nd AND and OR toqether--for those occasions in which it is necessary to use them.

. .

. . I

L

- 5 -

d. Because of the confusion that can result when using logic tenns in the written text of EOPs, Section 3.8.3, pages 14-18, should include sequences to avoid and examples of the correct use of each logic term; e.g., IF NOT and IF •• • THEN with more then one contingency action.

e. Section 3.8.3.f(l), page 15, states that "AND is used to join two or more conditions in a list" and that the conditions should be on separate lines. An exception to this practice is given: "AND may be placed within a condition when joining components that are part of the condition." These instructions do not make it clear exactly when each formatting technique should be. used. The instructions should be clarified and examples should be provided.

f. Section 3.8.3.f(2), page 15, and 5.3.5.d, pages 56-59, discuss the logic term OR but do not discuss the two different meanings of OR. So that operators are at all times certain of the intended meaning when OR i~ used, Sections 3.8.3.f(2) and 5.3.5.d should be expanded to provide instructions for formatting logic statements that use the exclusive OR and logic statements that use the inclusive OR. Appropriate examples should be included. See NUREG-0899, Appendix B for additional information.

g. Section 3.8.3.d, page 14, states that when AND and OR are used within the same steo, "the step should be organized to minimize ambiguity." Since the use of AND and OR in the same step can be difficult to interpret, Section 3.8.3.d should provide guidance for an examples of acceptable usage of AND and OR together.

h. In Example 2 in Section 3.12.3, page 17, IF and THEN are not underlined as specified in Section 3.8.3.b, page 14. Additionally, "cannot" has been underlined. The writer's guide does not contain instructions to underline "cannot." The text and examples should be changed so that they are consistent.

3. So that procedure writers can produce procedur~s that are consistently and correctly formatted, the writer's guide should provide complete information about each section of the EOPs. Section 5.3.2 states that EOPs shall consist of both text (8-1/2 x 11") pages and flowchart (29" x 44") sheets.

a. The writer's guide does not adequately describe the relationship between the smaller text pages and the larger flowchart sheets. The writer's guide should be expanded to

·.

- 6 -

discuss how the text pages and the flowchart sheets are combined, both logically and physically, to form a coherent, workable document.

b. Section 5.3.3 discusses three different EOP sections that seem to provide entry conditions: an "Entry Condition" section in the text pages; an "Operator Actions" section in the text pages, which "shall direct the operator to the f1owchart{s); 11 and the entry conditions in the flowcharts themselves. It is not clear why multiple sets of entry conditions are used, how the information in the different secitons differs, or how operators should resolve conflicts if the different sets of conditions contradict each other.

c. Section 5.3.3.a(2) discusses the "Operator Actions" section of EOPs. Other than statina that this section "shall direct the operator to the ffowchart{s) , 11 the writer's guide provides no guidance about how that information will be formatted. It is unclear how Section 4.0, which provides instruction for writing 11 text 11 EOPs, will be used as all EOPs are to be in flowchart format. Section 5.3.3.a{2) should be expanded to discuss what information will be included in the Operator Actions section, and how this section will be formatted.

4. Section 5.3.2, page 39, states that the action steps of EOPs will be presented in flowcharts. Because flowcharts are such an important part of EOPs, writers should be given sufficient information to produce clear and consistently formatted flowcharts.

a. It is not clear whether the information in the writer's guide pertaining to flowcharts is intended to supplement or replace other sections of the writer's guide. For example, it is not clear whether Section 4.3.5, pages 55-61, is intended to supplement or replace Sections 3.7 through 3.8.2, pages 13-14. The writer's guide should describe what guidance outside of Section 5.3 applies to EOP flowchart preparation {e.g., it could contain a statement indicating that all general guidance provided in the writer's guide applies to flowcharts, except Tor information identified as not applicable to flowcharts which could be indicated by notes that immediately precede that information).

b. Text in flowcharts is single-spaced in the examples in the writer's guide. The text in flowcharts can be read more easily if it is double-spaced. The writer's guide should be expanded to state that text in flowcharts will be double-spaced and the examples should be changed accordingly.

. . . .

- 7 -

c. Section 5.3.4, pages 52-55, refers to NUREG-0700, rather than discussing flowchart typeface and flowchart symbol sizes in detail. To ensure consistency in flowcharts, the writer's guide should discuss the legibility and readability requirements for flowcharts. Section 5.3.4 should be revised to include a description of symbol size and a soecific type size.

d. Using all capital letters in flowcharts is prescribed in the writer's guide in the following places: Sections 3.4. 4.7.2.h(2), 5.3.4.h(l), 5.3.4.i(4)(a), 5.3.4.j(7) and 5.3.Sg. Examples are given of flowcharts, or parts of flowcharts, using full capitalization throuqhout the writer's guide. If all words are capitalized, then capitalization cannot be used for emphasis. Furthermore, text written in all capitals is more difficult to read than mixed case. The writer's guide should be revised to state that capitalization in flowcharts shall conform to the rules established for other procedures. and examples should be revised to agree with the text. -

e. The use of bold type in flowcharts is prescribed in the writer's guide in the following places: Section 4.7.2.h(2), 5.3.4.h(l), 52; 5.3.4.1(4)(a), and 5.3.4.j(7). If all type is printed in a bold style then it cannot be used for emphasis. Bold t_ype style should be used in flowcharts in the same manner that it is used in text procedures. Section 5.3.4 should be revised to reflect this concern.

f. Section 4.7.2h(4), page 34, refers to different line patterns that may be used in flowcharts, but the writer's guide does not describe the type of flow path denoted by each type of line. Section 4.7.2.h(4) should be expanded to describe exactly what types of lines may be used in flowcharts, what is denoted by each type of line, and when each type of line should be used. Additionally, Section 5.3.4.c(6), pages 47-48, states that when a series of actions are required to accomplish a goal the individual actions should be bracketed in a flowchart with dashed lines. The writer's guide should discuss formatting techniques that will prevent these dashed bracketing lines from being confused with dashed flowpath lines. Examples that are consistent with the text should be provided for all types of lines used in flowcharts.

g. Section 5.3.4.c(6), page 47, states that "the following example illustrates the position of the noun phrase and the dashed line." The example has not been included. Section 5.3.4.c(6) should be expanded to include the referenced example.

.. . .

-~ -------

- 8 -

h. Section 5.3.4.b, page 42, refers to the dividing of a flowchart onto more than one flowchart sheet. If a flowchart is presented on more than one sheet, the flowchart is harder to use and an operator may enter the wrong flow path when going from one sheet to the next. Section 5.3.4.b should be expanded to describe methods for overcoming these problems.

i. Section 5.3.4.h(4), page 52, refers to Cartesian Coordinates placed on the border of flowcharts, but does not discuss why these coordinates are included or how they are used. Additionally, the sample flowchart in FIG 1-1 does not contain Cartesian Coordinates. The writers' guide should be expanded to discuss how Cartesian Coordinates are used in flowcharts, and FIG 1 should be revised to include Cartesian Coordinates. If the coordinates are to be used in referencing, they should be discussed in Section 5.3.4.c(7)(b), page 49, as well.

j. Sections 4.2.14.d, page 27, and 5.3.4.c(2)(c), page 44, discuss lists i~ flowcharts. If a list of objects is used to reduce the number of individual steps in a flowchart, it becomes more difficult to verify that each action in the list has been perfonned. Sections 4.2.14.d and 5.3.4.c{2)(c) should be expanded to supply detailed guidance for deciding when to use lists instead of multiple steps in flowcharts, and should discuss how these placekeeping difficulties will be overcome.

k. Section 5.3.4.c(2)(c), paqe 44, states that actions can either be joined with "and" or listed vertically with bullets. So that flowcharts are consistently formatted, Section 5.3.4.c(2)(c) should be expanded to state precisely when the actions should be joined by "and" and when they should be listed vertically with bullets (e.g.s, two or three actions should be joined with "and" and four or more actions could be listed with bullets).

1. Section 4.2.14.d, page 27, discusses listing items in two columns. This section should be expanded to describe how a two-column list will be placed into flowchart symbols and to provide examples.

m. Section 4.1.2, page 20, discusses the level of detail to be included in documents. Flowcharts cannot present as much detail as written procedures can efficiently present. A flowchart should provide enough detail for a newly trained operator to use the flowchart, but not so much detail that the ~lowchart. becomes cluttered and unusable. Section 4.1.2 should be expanded to specifically address the level of detail to be included in flowcharts.

... ·.

·.

• - 9 -

n. Section 5.3.4, page 42, discusses title blocks to be included in flowcharts. These blocks have not been included in the sample flowchart, Figure 1, page FIG 1-1. The sample should be changed to be consistent with the text.

o. The list of flowchart symbols in Figure 2, page FIG 2-2, includes the connector symbol, but this symbol is not discussed in the text of the writer's guide. The writer's guide should be expanded to discuss the connector symbol and provide examples of its use.

p. Section 5.3.4.c(l), page 43, describes the format for entry conditions in flowcharts. This format allows for entry conditions to be met when at least one entry condition from a list has been met. It may be possible that a flowchart should only be entered if several conditions are met. If tbis is the case, Section 5.3.4.c(l) should be. expanded to describe how entry conditions will be formatted when the flowchart should be used only after all the entry conditions in a list of conditions have been met.

q. Section 5.3.3.b(3), page 41, states that "the flowchart shall designate exit criteria such as branching to another EDP." This section should be expanded to discuss the other exit criteria that can be designated in a flowchart and how exit criteria shall be designated. Examples should also be provided.

r. Sections 5.3.4 and 5.3.5, pages 42-61, describe elements that could make flowcharts complex and difficult to use. Some flowchart elements of particular concern are (1) retainment steps and continuous cautions which place a burden on short term memory; (2) concurrent steps, which can be disruptive, cause delays, and create placekeeping difficulties; and (3) logic terms, which can increase the complexity of flowcharts by presenting decision criteria in different formats. All of these items, when combined, place a heavy mental load on operators and make flowcharts difficult to use, especially if operators are working in a stressful situation or under time constraints. The writer's guide should be expanded to describe ways in which these elements can be incorporated in complex flowcharts so that operators can easily use the flowcharts.

s. Because the sample flowchart in FIG 1-l has been substantially reduced, it is not legible. The writer's guide should be changed to include a complete, legible, full-size flowchart.

'.

:

·.

- 10 -

t. The large flowchart sheets can be awkward and create usability problems. Sufficient space should be available in the control room for efficient use of the large flowchart sheets. The PGP should be expanded to include a'description of how flowcharts will be mounted or bound, where the flowcharts will be located in the control room, and how they will be located and used by operators. See NUREG-0899, Sections 6.1.2 and 6.1.4 for additional information.

5_. Section 5.3.I.b(l), page 38, discusses Critical Safety Function Status Trees. So that procedure writers are given sufficient information to produce properly formatted status trees, the writer's guide should be significantly expanded to include instructions for formatting status trees. An example should also be provided.

6. During the execution of EOPs it is often necessary to refer operators to other procedures or sections of procedures. Such referencing and branching can be disruptive and cause unnecessary delays.

a. Section 4.5.2.a, page 30, states that referencing should he minimized. Section 4.5.2.a should be expanded to state that branching should also be minimized~

b. Section 4.5, pages 30-31, should discuss the criteria to be used when deciding if the necessary steps should be included in the text of the procedure or if cross-referencing should be used. See NUREG-0899, Section 5.2.2 for additional information.-

c. Section 5.3.4.c(5), page 46, should discuss the criteria to be used when deciding if the necessary steps should be included in a flow path of a flowchart procedure of if the concurrent step symbol should be used.

d. Audit General Comment 6.c stated that the specific steps or sections within a referenced procedure should be noted. Section 4.5.2.b(l), page 30, states that when it is necessary to refer to another procedure, operators should be told "exactly where to go (i.e., what procedure and/or step)," but does not supply specific guidance. This section should be revised to specify that step numbers, procedure numbers,

.and procedure titles are always required when referencing or branching to another procedure. If the citation of an entire procedure is intended to indicate that the operator is to begin at the beginning of the referenced procedure, then the writer's guide should so state.

·.

·.

- 11 -

e. Because of the complexity of flowcharts, it is especially important that operators be provided with all the information necessary to easily locate a flowchart step indicated by a reference, branch, or concurrent step symbol. The writer's guide should be expanded to state how flowchart step location information (e.g., page numbers or a coordinate system that differs by page) will be provided.

f. Section 5.3.4.c(5), page 46, discusses references in flowcharts to "concurrent steps." Section 5.3.4.c(5) states that "the previous action step should refer the operator to the concurrent procedure," and that the reference is also included in the concurrent step symbol. Presenting the reference twice in different symbols is confusing and unnecessary. Section 5.3.4.c(5) should be revised to indicate that references to concurrent steps will be presented only in the concurrent step symbol.

g. Section 5.3.4.c(5), page 46, states that the concurrent step symbol does not contain step numbers. Step numbers of referenced steps should be included in the concurrent step symbol to ensure that operators know where to start in the procedure to be used concurrently. Section 5.3.4.cf 5) should be ~hanged to state that step numbers will be included in the concurrent step .symbol.

h. Section 4.5.3.a, page 30, states that when two procedures are to be used concurrently, "words such as 'concurrently' or 'simultaneously' should be used." Because the use of different words with identical meanings can lead to operator confusion and unnecessary delays, this section should be changed to direct writers to use only one of these terms.

i. Section 5.3.4.f(2), page 52, discusses the cross-referencing of a "series of substeps." It is not clear when it would be preferred to reference a series of substeps rather than the higher level step to which they apply. Section 5.3.4.f(2) should be expanded to provide criteria for determining when a reference should be made to substeps rather than to the pertinent higher level step.

j. Section 4.5.4.c, page 31, defines the term GO TO with v regard to branching. So that it is clear to operators

that GO TO signals them to branch to a different procedure, this term should only be used for branching. Table 1, page TAB 1-4, includes an additional definition to GO TO, "to transport oneself to a given location." This alternate meaning of GO TO should be eliminated from Table 1.

..

- 12 -

k. When referencing or branching to another procedure, it is important that operator be aware of cautions or notes that precede the referenced step. Additionally, when entering a flowchart operators should also be aware of all retainment steps and continuous cautions that precede the entry point. Therefore, the writer's guide should describe a method of ensuring that appropriate cautions and notes are observed when referencing or branching is used in flowcharts.

1. Examples of referencing and branching format, for both text and flowchart procedures, that are consistent with the text should be provided as stated in Audit General Comments 3.c and 6.c.

m. Section 3.8.3.g, page 16, includes examples of action steps that use the term 11 per 11 to allude to actions completed in previous steps. This type of reference is not discussed in the writer's guide and requires the operator to remember how and when an action was taken. The use of 11 per11 in this way should be carefully evaluated and, if retained, should be specified in the text. Otherwise, the writer's guide should be changed so that text and examples are consistent.

n. To help operators move rapidly from one part of the EOPs to another, the writer's guide should specify some method, such as tabbing, for easily identifying sections in the EOP.

7. The-proper use of emphasis techniques makes procedures easier to understand. The instructions on the use of underlining in Section 3.6, page 12, are vague. Section 3.6 should be expanded to state exactly when underlining should be used. Additionally, all underlining used in examples, such as the underlining of step numbers in the examples in Section 3.8.3.g, pages 16-17, should be consistent with Section 3.6.

8. The proper use of vocabulary and syntax is important so that EOPs can be readily understood by both procedure preparers and operators.

a. The writer's guide should be expanded to include a list of words which writers should avoid using. See NUREG-0899, Section 5.6.l for additional information.

b. The list of acceptable action verbs in Table 1, pages TAB 1-TA89, includes two words with the same meaning: "press" and 11 depress. 11 Because the use of different ~ords with identical meanings can lead to operator confusion and unnecessary delays, the list of acceptable verbs should be changed to include only one of these words.

...

- 13 -

c. Section 3.7.1.a, page 13, refers to "sentences, clauses, and phrases." Sentence structure is an important factor in the presentation of information. Complete sentences are more precise and are more easily understood than sentence fragments. Section 3.7.1.a should be expanded to required complete sentences. Additionally, examples such as Example 2 in Section 3.4.2.a(2), page 11, "VERIFY OPEN ISJl and ISJ2," should be changed to be complete sentences.

d. Section 3.76.2, page 13, states that EOPs should be written using the simplest and most definitive word for clarity. For this reason, "initiate" should be replaced with "begin" in the list of acceptable verbs, page TAB 1-4.

9. The writer's guide should include instructions for writing the various types of action steps that an operator may take to cope with different plant situations.

a. Section 4.2~4 through 4.2.10, pages 23-25, define several types of action steps and address special concerns inherent in each type of step. While the writer's guide does describe the objectives of each type of step, it does not provide guidance on how to write these steps to meet the described objectives. The writer's guide should be expanded to describe the format and provide examples of (1) verification steps, (2) nonsequential steps, (3) equally acceptable steps, (4) recurrent steps, and (5) time-dependent steps in both text procedures and in flowcharts. Additionally, Sections 4.2.9 and 4.2.10 should be expanded to describe the format and provide examples of (1) concurrent steps and (2) diagnostic steps in text procedures. See NUREG-0899, Section 5.7 for further information.

b. Section 4.2.9.a, page 25, states that concurrent steps "should not be beyond the capability of" the control room staff." This statement should be changed to state that the steps should not be beyond the capability of the minimum permissible control room staff.

c. Section 4.2.15, page 27, discusses "steps performed by another," and discusses steps that require an operator to be sent to a remote location to perform an action or to determine the cause of a problem. Section 4.2.15 should be expanded to state the "steps performed by another" should indicate whether the operator should wait for the assigned tasks to be completed or continue in the procedure while the assigned tasks are being performed. Additionally, when steps are performed by another, it may be necessary to provide the other person with a job performance aid (e.g., checklists). The writer's guide should be expanded to ·address the use and formatting of such job performance aids as stated in Audit General Conment 13.

- 14 -

d. Section 5.3.4.c(3), page 45, djscusses retainment steps used in flowcharts. Because operators must remember these steps throughout the procedure, they create opportunities for error. Therefore, the use of retainment steps should be minimized. When retainment steps are used in multiple page flowcharts the steps should be repeated on each page. Section 5.3.4.c{3) should be expanded to address these concerns.

e. Section 5.3.5.d(lO)(b), page 59, described when an operator should return to a retainment step. Section 5.3.5.d{lO) should be expanded to discuss what an operator does after returning to the retainment step, and how the flowchart should be designed to direct his actions {i.e., does the operator perform the retainment step and then return to where he was, or does he re-enter the path from the retainment step).

f. Example 5 in Section 3.8.3.g{S), page 18, provides operators with the option of opening one of three breakers, with the instructions "SEND operator to open appropriate breaker. 11 The term "appropriate" does not provide operators with adequate criteria for selecting a single option from several alternatives. The writer's guide should be expanded to state that procedure should not contain steps that force the operator to decide which alternative to take without indicating the conditions under which each alternative should be taken, and Example 5 in Section 3.8.3.g(5) should be changed accordingly.

g. Section 4.2.13.e, page 26, states that "decision steps are generally used in place of verify and check actions. 11

Section 4.2.13.e should be changed to provide specific criteria for deciding when to use decision steps. Additionally, as stated in Audit General Comment 8, the YES/NO flow paths used in these steps clutter the page and the use of a question format for describing desired actions is difficult to understand. Therefore, writers should not be directed to use this format when a logic statement would present the information more clearly.

10. Section 4.2.3, page 23, discusses sequencing of steps. To minimize confusion, delay, and errors in the execution of EOP steps, additional information should be provided about structuring and organizing steps. The writer's guide should be expanded to address the following concerns:

a. Action steps should be structured to be consistent with the roles and responsibilities of operators.

b. Action steps should be structured to minimize the movement of personnel in the control room (where technical guidelines permit).

- 15 -

c. Action steps should be structured to avoid unintentional duplication of tasks.

d. Action steps should be structured to enable the control room supervisor to follow staff actions and monitor plant status. ·

11. It is important that a consistent method of section heading and step numbering be used throughout EOPs. The manner in which the text is organized and divided should be evident through headings and an alphanumeric numbering system so that operators can keep track of where they are in the procedure and know how to move easily and quickly to other parts of the procedure.

a. Section 2.4.1, page 2, describes a system that allows the operator to know exactly which section, step, and substep within the procedure as a whole is being performed, Audit General Comment 1.a stated that the procedures should conform to this guidance. The examples presented in the writer's guide should be modified accordingly (e.g., Example 3, page 17}.

b. Section 2.4.1 describes the alphanumeric system that will be used to organize documents. So that it is always clear where a step begins, steps should begin at the same level within this alphanumeric hierarchy in each section of a document, Section 2.4.1 indicates that steps may begin at either of two different levels: at the three digit ''subsection of step" level, or at the lettered "step" level. Section 2.4.1 should be changed to describe an alphanumeric system where steps cannot be confused with section headings and are always presented at the same level in the alphanumeric hierarchy as stated in Audit General Comment 12.

c. Section 2.4.2 describes an alphanumeric system that will be used to number the right hand column of dual column procedures. Audit General Conment l.b stated that this section should be modified so that both columns of a dual column procedure are numbered in a consistent manner. Section 2.4.2 should be so modified.

d. Examples 2 in Section 3.8.3.g(2), page 17, shows three numbered substeps under Step a, in the right hand column under Subsection 3.20.

Each of these numbered substeps does not have the same logical relationship to Step a. Substep a(l) is a substep of a, but a(2) and a(3) are contingency actions of their preceding substep. Substeps a(2) and a(3) should be

·.

• - 16 -

rewritten or reformatted to indicate the contingency relationship. The writer's guide should also be expanded to discuss how contingency actions will be fonnatted at this level.

e. Section 4.2.14.c, page 27, states that when an action requires more than one object, then the objects should be listed vertically using the same numbering scheme as steps. An exception to this practice is given: items should not be listed in this way following a higher level step number because the operator may be confused by "non-action items labeled with the three-digit scheme." Section 4.2.14.c should be expanded to describe how the items in such a list should be formatted and an example should be provided.

f. Section 5.3.4.f(2), page 52, discusses substeps in flowcharts, which are "performed to accomplish a high level step." The tenn "higher level step" is not defined, and it is not clear under what circumstances higher level steps with substeps would be used instead of the "series of steps to accomplish a goal" format described in Section 5.3.4(c)(6), page 47. Writers should be provided with specific criteria to determine when they should use the series of steps to accomplish a goal format and when they should use the higher level step/substep format. In text procedures, the format clearly indicates the relative levels of each part of a step through -indentation. This is not the case in flowcharts. When executing flowchart procedures, an operator will perform each task as it is encountered and then proceed; substeps

-will only be encountered after the upper-level step to which they apply has been performed. Consequently, operators may perform each step twice: once when they perform the upper-level step, and again as they perform the substeps that comprise the upper-level step. Furthermore, if only "referenced" substeps are numbered, operators will not be aware that a substep is actually a substep. Such substeps, as defined in the writer's guide, would render flowcharts unusable. -Therefore, unless the use of higher level steps with substeps serves a purpose that cannot be served by the series of steps to accomplish a goal format, higher level steps with substeps should not be used in flowcharts. If higher level steps with substeps are to be used, Section 5.3.4.f(2) should be expanded to provide writers with guidance for formatting flowcharts in a manner that ensures that steps will not be performed twice. ·

12. Operator aids, such as figures, tables, and graphs, assist operators to make decisions and to locate infonnation. Writers should be given sufficient information in the writer's guide

• - 17 -

to produce consistently formatted operator aids that are useful to operators and easily used. Section 4.7, pages 32-34, should be supplemented with an example of how a table in a procedure should be formatted.

13. So that the operator is always certain that the procedure being used is not missing any pages, Section 2.3.1, page 2, should be revised to state that each page in procedures, including flowchart pages, will indicate the total number of pages in the procedure (for example, page 15 of 40).

14. Cover sheets are an important source of information for operators as noted in Audit General Comment 5. Section 2.2.1 references A0-1, Section 2.2.2 which discusses the information to be included on the cover sheet. An example of a properly formatted cover sheet should be provided in the writer's guide.

15. Placekeeping aids can assist operators in keeping track of their position within a procedure. These aids are of particular importance when performing steps or procedures concurrently, and in situations where the operator's attention is diverted.

a.

b.

d.

Audit General Comment 2 stated that the writer's guide should be expanded to describe some type of placekeeping aid. The writer's guide does not describe a placekeeping system for dual-column procedures. The writer's guide and its examples should be modified accordingly.

Section 5.3.4.g, page 52, shows a symbol that should be placed near the lower left corner of each step in a flowchart as a placekeeping aid, but this symbol is not included for one step (START RCP 13 OR 11) in the sample flowchart on page FIG 1-1. This example should be changed to be consistent with the text.

Check-off spaces should not be used for decision symbols in flowcharts as discussed in Section 5.3.4.g, page 52; instead, operators should circle the word YES or NO marking the path taken out of a decision symbol. This convention would remind operators not only of the position of the last decision made, but also of the path taken after making that decision.

Section 4.7.2.i, page 34, discusses checklists, but the writer's guide does not describe how these checklists will be formatted or used. The writer's guide should be expanded to describe the use and formatting of checklists and to provide an example of properly formatted checklist.

16. Punctuation in procedures should facilitate understanding and be consistent.

• • - 18 -

a. Section 3.3.2.d, page 6, describes several different uses of parentheses. Because parentheses can be used in different ways, their meaning would be ambiguous to operators. The use of parentheses to indicate both supplemental detail and alternative items is especially likely to lead to operator confusion. Section 3.3.2.d should be revised to describe a more limited use of parentheses.

b. The example in Section 5.3.4.j(8), page 55, uses ellipses. The use of ellipses in not discussed in the writer's guide. Examples should be consistent with text. The writer's guide should be revised so that text and examples are consistent.

17. Audit General Comment 3.9 stated that Section 4.1.2.d should be expanded to discuss the format to be used when providing location information in procedures and to provide examples. Section 4.1.2.d should be modified accordingly.

18. So that opera tors do not have di ffi cul ty reading EOPs, it is important that the quality of EOP copies (i.e., legibility, completeness, and color) equals the quality of the original procedure. The writer's guide should be expanded to address this concern. See NUREG-0899, Section 6.2.2 for further information.

19. EOPs must be current to be usable. The writer's guide should describe a system that will ensure that the EOPs are promptly updated when changes occur in plant design, in Technical Specifications, in technical guidelines, in the writer's guide, in the control room or in other plant procedures that affect EOPs. See NUREG-0899, Section 6.2.4 for additional information.

With adequate resolution of the above items, the Salem writer's guide should accomplish the objectives stated in NUREG-0899 and should provide adequate guidance for translating the technical guide 11 nes into EOPs that wi 11 be us ab 1 e, accurate, comp 1 ete, readab 1 e, convenient to use, and acceptable to control room operators.

3.0 CONCLUSIONS

The staff concludes that, to adequately address the requirements stated in Generic Letter 82-33 (Supplement 1 to NUREG-0737) and provide acceptable methods for accomplishing the objectives stated in NUREG-0899 in accordance with the guidance provided in the Standard Review Plan (NUREG-0800, Section 13.5.2), the PGP submitted by Public Service Electric and Gas Company for Salem Generating Station in letters from PSE&G to the NRC, dated May 20, 1983 and December 30, 1986, should be revised to address the items described in Section 2 of this report. This revision need not be submitted to the NRC. For items in Section 2 that

I

L

• • - 19 -

the licensee deems inappropriate for inclusion in its PGP, it should develop and maintain documented justification. NRR or Region I will confirm that all items described in this report have been adequately resolved by appropriate licensee action or justification in the.course of routine or special inspections. Licensee implementation of commitments contained in the PGP may also be reviewed--deviations from commitments may result in enforcement action being taken by the NRC. Therefore, all revisions to the PGP should be reflected in plant EOPs within a reasonable period of time. Future changes to the PGPs and EOPs should be made in accordance with 10 CFR 50.59.