REVIEW OF EOPs

The IAEA Operational Safety Review Team (OSART) guidelines provide some guidance on the review of EOPs. However, because the scope of an OSART review is very broad, dealing with all aspects of nuclear power plant construction and operation, these guidelines provide only very general guidance for EOPs. 

As mentioned previously, several earlier IAEA nuclear safety publications have partially discussed EOPs and can be used as a basis for reviewing EOPs. However the present publication, which relies on state of the art experience, is intended to comprehensively discuss all aspects of the development, implementation and review of plant specific EOPs for all reactor technologies. Included in the discussion are the limitations and expectations inherent in the review process and the importance of the advance preparatory work. This publication is intended to serve as a reference for IAEA teams of experts in charge of the development or review of EOPs, or for plant managers and operational staff at specific nuclear power plants. 

The topic of EOPs has been addressed in a number of IAEA safety publications, including the revised IAEA Safety Standards Series, in particular safety requirements on the operation of nuclear power plants, operational limits and conditions, and operating procedures. These publications can be partially used as a basis for the development and review of EOPs. However, it was felt that a manual that would comprehensively cover all aspects of the implementation and review of EOP development programmes, that would rely on state of the art experience and that would be applicable to various reactor technologies, was needed. This need was further justified because several Member States were organizing IAEA missions and workshops to discuss and review the completeness and quality of their EOPs. The proposal to develop a corresponding reference publication was also supported at several IAEA workshops organized on this topic. 

The internal V V reports will be prepared by software design organization in accordance with EOP 42-6.00 (Independent Design Verification) and EOP 40-7.00 (Design Reviews) of GE engineering operation procedure (EOP) or equivalent to ensure the quaUty of the design process and the associated documents produced. 

The Joint Commission reqnires hospitals to conduct an annual review of its planning activities to identify snch changes and support decision making regarding how the hospital responds to emergencies. The hospital must also conduct an annual review of its risks, hazards, and potential anergencies as defined in its HVA. The hospital must conduct an annual review of the objectives and scope of its EOP. The findings must be documented. 

In the past, certain Member States invited IAEA missions to review the completeness and quality of EOPs. Several workshops were also organized on the subject of developing EOPs. In particular, participants of the IAEA Regional Workshop on Development and Validation of EOPs, held in Brno, Czech Republic, from 3 to 7 April 2000, recommended that a technical... 

The present pubhcation can also be used by a nuclear regulatory body as a basis for developing specific criteria for review/approval of a set of EOPs. However, it should not be seen as a prescriptive guide for developing or reviewing EOPs for a nuclear power plant. 

Operating experience This source results from a thorough review of the operational feedback from experience collected by the nuclear industry worldwide and application of engineering judgement. All pertinent events should be evaluated in the definition of the scope of EOPs. Examples include ... 

The role of the regulatory body in the review and approval (if required) of EOPs was discussed in Section 3.1.5. However, it should be repeated that early involvement and open discussions with the regulatory body from the beginning of the project will smooth the progress of the entire licensing process. Regulatory body approval is typically a sequential activity ... 

This section provides guidance for an independent review of the development and implementation programme for one particular plant, including a partial review of the technical correctness of the EOPs. This section also describes activities that should be carried out during the review so that both the review team and the plant being reviewed will understand the objectives of the review and the review process itself... 

The review can be scheduled either during the development or the implementation process of the EOP programme. The aim may be the review of an existing set of EOPs to identify deficiencies and issue recommendations for a successful completion of the programme, or for providing recommendations for the improvement of the EOPs. Although the guidance is written primarily for external review, many elements can also be used for internal review in the framework of a self-assessment process. 

The typical duration of an external review is one week. During this period of time it is impossible to review aU aspects of the EOP development programme and/or aU documentation in detail. Therefore, the review should be focused on specific areas of the EOP programme. For example, the review may be oriented towards either administrative or technical aspects of the programme. While the administrative review wiU be mainly focused on a review of the development/implementation process and the QA and methodology used, the technical review will concentrate more on the... 

Review of the EOP programme requires a team of competent experts to deal with different technical areas. The effectiveness of the review will be highly dependent on the quality and adequacy of the reviewers profile. Because of the small number of experts on the review team it is recommended that all of them have adequate background in modern EOP philosophy in addition to their own specialization. The concepts of modern EOP packages are quite complex and the review process should not allow improvisation on the spot. The experts qualifications in terms of their practical and technical expertise can be described as follows ... 

The aim here is to review the scope and adequacy of supporting analyses that were used throughout the development of EOPs. Areas requiring analytical support are specified in Section 3.3. The review should focus on the scope of the analyses, whether they provide sufficient information on the plant s response to various accident conditions and a qualitative assessment of all recovery strategies used in EOPs. Careful evaluation should be made of the applicabihty of computer codes used for the analyses. 

The review of relevant factors influencing the process and the scope of coverage are of particular concern, e.g. initial plant operating modes, operator actions, other factors known to challenge human performance and scenarios that have been adopted to justify the scope of EOPs. 

Review of the human factor related aspects of the entire EOP package or individual procedures. The review team should review the following ... 

The overall process of EOP verification and its documentation should be reviewed. The review should focus on the adequacy of the verification guide and its implementation. The verification report should be reviewed. The subject of verification is addressed in Section 3.5. 

The overall process of EOP validation and its documentation should be reviewed according to the recommendations in Section 3.6. The review should focus on whether the validation guide has been properly developed and applied. A detailed validation review should be carried out for a representative sample of procedures based on the validation report. It is convenient to select those procedures which have been reviewed in-depth as described in Section 4.5.4. 

The review of these areas requires analysis of the documentation developed specifically for the EOP s training programme. In addition, it is also suggested that different personnel involved in the training process be interviewed. The following may be taken into account ... 

It is therefore necessary to review whether the plant has established a process for maintaining consistency of EOPs with the actual plant status. It is... 

The long term maintenance process for the set of EOPs should be prepared in parallel with the development of the procedures. Guidelines dealing with this aspect should be in hne with the QA system at the nuclear power plant. The reviewers will have to evaluate this process developed by the plant to guarantee that the impact of any significant modification is correctly addressed in the EOPs and training documents. 

The review should concentrate mainly on how the process of modification control, which has been established in the nuclear power plant, provides for proper maintenance of EOPs. Possible sources of modifications to EOPs include ... 

As of this writing (Winter, 1985), EPA has received aid evaluated several proposals to conduct small scale field testing with genetically altered microorganisms. In three cases, EPA determined that an EOP would be required and in another case, determined that the product was not subject to the Interim Policy. Two EOP applications are currently utder review. 

EPA has up to 90 days to review each notification of intent to conduct small-scale field testing and to determine whether an EOP is required. The Agency encourages prospective applicants to meet with EPA prior to submission of their notification to discuss their field test and determine what specific data and information would be necessary to evaluate the product. 

As mentioned above, during the definition of the UAs the abnormal and emergency operation procedures were reviewed. At this stage, it was found that the EOPs cover the plant conditions in analyzed accident, the instructions are clear and follow-up is adequate. 

Consistent with the above objectives, this pubhcation reviews all the elements, and especially the practical aspects, that must be considered in any plant specific EOP development programme. This publication is based on best international practices in the field of emergency operation, as well as on specific lessons from various programmes that have been successfully completed at nuclear power plants around the world. This publication reflects a variety of possible approaches, and the material presented therefore provides... 

Several standard or reference systems for EOPs have been developed by various groups of nuclear power plants, utilities and reactor designers around the world. This pubhcation estabhshes that these are not portable as such to all nuclear power plants. The type of reactor technology, the operational culture and staff organizations of the plant are examples of major elements that need to be considered when choosing among these systems. There are two categories of review ... 

Those that focus on providing a review — technical and administrative — of the final plant specific EOPs and possibly provide recommendations for improvements. 

Documentation of these decisions is recommended for inclusion in the EOP s technical basis documents. This will also satisfy quality assurance (QA) and facilitate future reviews. 

The documentation that supplements the plant specific EOPs and provides justification for the EOP development programme can be divided into two groups, the technical documents and the administrative documents. The list that follows is not exhaustive. There is no fixed requirement as to what type of documents should be available. It is up to the nuclear power plant to decide which specific documents will be added for the review, for licensing or QA purposes or any other reasons. Some of the documents logically follow the structure of the EOP reference system and its methodology if such has been used as a basis for the programme. 

Note that involvement of operators and other operating personnel in the development of the EOPs in the framework of reviews, EOF verification, etc., provides valuable initial training as well as feedback to the development team. 

Changes to EOPs should be decided upon very carefully. It often happens that for one particular scenario an easy change in the text of the procedure would make the step sequence more efficient and the response more straightforward. However, many different scenarios can lead an operator to perform the same set of actions. Therefore, it is highly recommended that a consistency review or revalidation be performed before important changes are made to the EOPs. 

The review team needs to have appropriate documentation available prior to and during the review. It is also helpful if the host organization prepares presentations at the beginning of the review. Presentations should contain important information from the EOP s development and implementation process and thus render the team s familiarization process more effective. 

A general safety background capability to review the consistency of the approach used for EOP development with the overall plant safety approach ... 

The review team should compile a list of all these modifications in order to verify their correct implementation. It is recommended that the review team directly verify the adequacy of the modifications and the physical implementation of the EOPs by consulting the documents and visiting the control room or other locations in the plant. 

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