Procedures Development and Maintenance

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Background

Starting with the first commercial Westinghouse-design nuclear power plants, Westinghouse has been involved in the development of generic, as well as plant specific, guidance for response to plant events. Following the Three Mile Island (TMI) accident, the U.S. Nuclear Regulatory Commission (NRC) issued NUREG-0899, which provided requirements for utility preparation and implementation of emergency operating procedures (EOP), including development, writing and maintenance. This was followed by NUREG-1358, in which the NRC reinforced its expectations with respect to the plantspecific technical guidelines, EOP writers guide, EOP verification and validation (V&V) and EOP training. Together, these regulations comprise the plant-specific procedure generation package (PGP).

Description

As the NRC requirements developed and matured, the Westinghouse EOP group developed a wide range of experience in the field of EOPs. Our involvement has included:

Development of Revision 1 of the emergency operating instructions (EOIs) in 1979
Creation of the exceptional emergency operating instructions (E²OIs) in 1980
Creation of Revision 1 of the emergency response guidelines (ERGs) in 1983, as well as subsequent revisions through Revision 2 in 2005
Creation of the ERG footnote basis document
Creation of the sump blockage control room guideline (SBCRG)
Creation and continued oversight of the ERG maintenance program
Review and development of plant-specific EOPs and EOP setpoints for various plants
Evaluation of plant-specific EOP programs for compliance with the generic ERGs, NUREG-0899 and NUREG-1358
Creation of CE emergency procedure guidelines (EPGs), CEN-152

Symptom-based EOPs

Westinghouse was a leader in converting event-based EOPs to the new symptom-based format. Today, procedure guidance must be symptom based, while addressing multiple events, multiple failures, inadequate core cooling events and anticipated transient without scram (ATWS). The EOPs and related program documentation must be developed, written and maintained in accordance with NRC requirements and must include appropriate provisions for V&V and training. Plant-specific documentation must be verified for power uprates, instrumentation design changes and other plant modifications and changes to human performance protocols.

Benefits

Westinghouse is intimately familiar with the evolution of the Westinghouse ERGs, the CE EPGs and the NRC guidance and requirements for EOP programs.We are uniquely qualified to evaluate plant EOP programs to provide complete compliance with NRC expectations regarding:

EOPs
EOP background documents
EOP-ERG deviation documents
EOP setpoint documents
EOP V&V
We have the capability to provide services associated with:
Plant-specific implementation of new revisions to the ERGs
Replacement steam generators (RSGs) for
Westinghouse and CE designs
Power uprates
EOP evaluations and assessments, including independent review of EOP procedure generation packages in preparation for outside audits
New plant EOP development and maintenance
Upgrades to plant-specific EOP documentation such as EOP setpoints
Instrument design changes (e.g., instrument uncertainties)
Plant equipment modifications such as reactor vessel upper head replacement
Development of AP1000™ EOPs
EOP review and assessment program for EOP audits to assess plant readiness for an EOP audit by the NRC
EOP versus design bases review to provide that the plant-specific EOPs are consistent with the plant design bases
EOP technical accuracy review where plant consistency of EOPs with the strategies employed in the vendor-specific guidelines is assessed
EOP simulator validation support where we assist the performance of simulator validation of plantspecific
EOPs
Introduction to EOP writing principals for new EOP coordinators workshop to familiarize new plant EOP coordinators with the principals and special considerations of EOP writing
Normal operating procedures, abnormal operating procedures and alarm response procedures development and maintenance

Experience

Westinghouse developed and is responsible for maintaining the vendor-specific guidelines used for writing plant-specific EOPs for the Westinghouse and CE fleet. Additionally,Westinghouse has helped write and review plant EOPs for other vendor designs around the world. This experience and knowledge level enables our EOP group to write and/or maintain procedures for normal operations, abnormal operations and alarm responses. Recent Westinghouse experience in plant support of EOP programs includes: