NEI Industrywide Process Description

SS003 Sub-Process

Procedure
Process Description

NEI AP-907-001
Rev. 0

January 2006
NEI Industrywide Process Description
SS003 Sub-Process

Nuclear Energy Institute

Procedure
Process Description

NEI AP-907-001
Rev. 0

January 2006
 ACKNOWLEDGEMENTS
The Nuclear Energy Institute wishes to thank the following utilities and industry organizations
for providing the personnel and resources necessary to perform this project.

AmerenUE
American Electric Power
Arizona Public Service
Constellation Generation Group
Dominion Generation
Duke Energy
Entergy
FirstEnergy Corporation
Nuclear Information Management Strategic Leadership (NIMSL)
Ontario Power Generation
Scientech, LLC
STP Nuclear Operating Company
TXU Power

NOTICE

Neither NEI nor any of its employees, members, supporting organizations, contractors, or
consultants make any warranty, expressed or implied, or assume any legal responsibility for the
accuracy or completeness of, or assume any liability for damages resulting from any use of any
information apparatus, methods, or PROCESS disclosed in this report or that such may not
infringe privately owned rights. Copyright 2006.
 FOREWORD
In August 2005, at the direction of the Nuclear INFORMATION MANAGEMENT Strategic
Leadership (NIMSL) steering committee, Institute of Nuclear Power Operations (INPO)
Community of Practice (CoP), an industry task force was chartered to address the broader scope
of the PROCEDURE PROCESS through the development of an industry PROCESS description.
This task force was composed of representatives from the NIMSL CoP and SUBJECT MATTER
EXPERTS from PROCEDURES, records management, document control and information
technology PROCESS areas.

This document describes seven components of a PROCEDURE PROCESS to assist the nuclear
utility industry in PROCEDURE development activities for the operation and support of nuclear
plants. Two Key Performance Indicators along with several DIAGNOSTIC MEASURES are
included in this document for use. Industrywide PERFORMANCE MEASURES are used for
PROCESS performance comparison and as comparative analytical tools (plant to plant).
DIAGNOSTIC MEASURES are intended to be used as analytical tools by PROCESS OWNERS
when measuring the health of the PROCESS (internal use) and when performing self-
assessments of the utility’s PROCEDURE PROCESSES.

An important consideration in managing a company’s PROCEDURE PROCESS is tied directly

to safety and the basis for revenue generation and shareholder value. The financial drivers for
each of these are different for regulated (rate-based) versus non-regulated (profit-based)
businesses. NEI-AP-907-001 does not specifically address the decision-making basis associated
with managing the PROCESS within these two environments.
 TABLE OF CONTENTS
FOREWORD ........................................................................................................................ i

1 PURPOSE ................................................................................................................... 7
2 APPLICATION OF NEI-AP-907-001 ............................................................................ 9
3 PROCESS DESCRIPTION FLOWCHARTS ................................................................. 13
3.1 CONTEXT FLOWCHART LEVEL 0 – PROCEDURE PROCESS ..............................................
3.2 TOP-LEVEL FLOWCHART LEVEL I - PROCEDURE PROCESS ...........................................
3.3 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II EVALUATE REQUEST ........................
3.4 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II PLAN DEVELOPMENT .......................
3.5 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II RESEARCH AND DEVELOP ...............
3.6 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II REVIEW DRAFT .................................
3.7 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II APPROVAL .........................................
3.8 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II CHANGE MANAGEMENT ....................
3.9 INTERMEDIATE-LEVEL FLOWCHART - LEVEL II ISSUE FOR USE......................................

3.10 DETAILED FLOWCHART TEXT DESCRIPTIONS - LEVEL III PROCEDURE PROCESS .......

APPENDICES
A. GLOSSARY OF TERMS AND DEFINITIONS ................................................................ A-1
B. TASK FORCE LIST ...................................................................................................... B-1
C. PROCESS MODELING AND FLOWCHART CONVENTIONS ........................................ C-1
D. PERFORMANCE MEASURES ....................................................................................D-1
E. REFERENCE AND CROSS-REFERENCE LIST ............................................................ E-1
F. PROCEDURE DECISION TREE ................................................................................... F-1
G. DOCUMENT HIERARCHY ..........................................................................................G-1
H. HISTORY, REVISIONS, AND MAINTENANCE OF AP-907 ..........................................H-1

FIGURES
FIGURE 1-3 NEI SNPM PROCESS ARCHITECTURE .......................................................... 2
 PROCEDURE PROCESS
DESCRIPTION NEI-AP-907-001
1 PURPOSE
The purpose of this PROCEDURE PROCESS description is to document industry consensus on
a standard PROCESS for managing PROCEDURES within the nuclear industry.

NEI-AP-907-001 is a general PROCESS guideline and is intended to be used by nuclear plant

owners and/or operators to assess their organizations management of PROCEDURES as defined
in the NEI/EUCG Standard Nuclear Performance Model (SNPM Figure 1-3). This PROCESS
description establishes a baseline for consistent PROCEDURE activities and discusses
PERFORMANCE MEASURES.

NEI-AP-907-001 is intended to be used as a tool for performing effective self-assessments or

benchmark visits. An effective PROCESS description enables standardized comparisons to be
made and provides a basis for improvement suggestions.

NOTE: Words capitalized throughout this document may be found in Appendix A, Glossary of
Terms and Definitions.
Figure 1-3 NEI Standard Nuclear Performance Model (SNPM) Process Architecture
Revision 4, July 2004
2 APPLICATION OF NEI-AP-907-001
NEI-AP-907-001 may be applied to support CONTINUOUS IMPROVEMENT when
performing PROCEDURE PROCESS functions. The following steps are suggested for
CONTINUOUS IMPROVEMENT modeling:

 Step 1: Applicability Check – Define the scope of the current assessment or

benchmark visit. Initiate a current-state assessment of the PROCEDURE PROCESS
by identifying the PROCESSES, key performance indicators, and DIAGNOSTIC
MEASURES identified in NEI-AP-907-001 that apply to the site PROCESSES.
 Step 2: Baseline Assessment – Perform an assessment using both qualitative and
quantitative data to determine gaps, areas of strength and areas for improvement.
Analyze the differences.
 Step 3: Plan Development – Review the results of the baseline assessment to identify
areas of relative weakness. Select and validate areas of interest and develop a plan
for process improvement. The assessment may identify areas that will require both
long-term and short-term efforts. Long-term areas should be noted and may be
reassessed prior to developing a plan for improvement. A plan for the short-term
goals should be developed. Short-term plans should be specific and achievable
within a six-to-twelve month time period.
 Step 4: Plan Implementation – Monitor the improvement plans as they are
implemented; they may require adjustment to assure their success. Reinitiate the
assessment process (return to Step 1) as part of a CONTINUOUS IMPROVEMENT
program.

The suggested PROCESS steps and good practices are intended to be applied at sites as
appropriate, considering corporate and site-specific policies and objectives. NEI-AP-907-001
content should be considered for incorporation into site-specific PROCEDURES that capture
institutional knowledge, as required. It should be noted that these steps are a general guide.
Each station is encouraged to assess their own VERIFICATION expectations and practices and
to adapt this information as appropriate to best meet its unique needs.
The following summary provides a high-level structure that can be used as a guideline to develop
a PROCEDURE PROCESS program. The intent of this example is to identify program elements
that should be considered, not to provide an all-inclusive list.

The seven basic steps in this PROCESS description apply whether the document being reviewed
is a PROCEDURE, policy or business practice. However, the LEVEL OF DETAIL required is
greatest for PROCEDURES. Therefore, this description is written for PROCEDURES and the
detailed requirements would not all apply to other documents.

1.0 Evaluate Request for New or Revised Procedure

A change request is received and placed into a single tracking system along with a minimal set of
attributes which uniquely identify the request. A general review of the technical and
administrative aspects of the request determines the validity and priority along with a review of
impact on other PROCEDURES. Feedback on the request is provided to the submitter.

2.0 Plan Procedure Development

Select the appropriate PROCEDURE(s) to be revised by reviewing the BACKLOG and

evaluating task priority, quantity, and other COMMITMENTS. Determine the type of change
and appropriate work flow based on the technical level of request. The task is assigned to a
PROCEDURE WRITER.

3.0 Research Request(s) / Develop Procedure Draft

The assigned PROCEDURE WRITER assembles a PROCEDURE change package and validates
the scope of the assigned work. The writer determines the change to the PROCEDURE by
reviewing applicable OPERATING EXPERIENCE, outstanding issues, REFERENCES,
HUMAN PERFORMANCE challenges and technical content. The writer then develops the
detailed draft of the PROCEDURE using the correct TEMPLATE and the WRITER’S
MANUAL.

4.0 Review Procedure Draft

Determine the appropriate review(s) for the PROCEDURE change and route accordingly.
Determination should be made which reviews are in series and which may be performed in
parallel. The PROCEDURE REVIEWERS will perform reviews and provide documented
COMMENTS. The PROCEDURE WRITER ensures that COMMENTS are returned and
resolved .

5.0 Approve Procedure

The PROCEDURE approval PROCESS is designed to ensure that the format and content of the
PROCEDURE are correct, the PROCEDURE OWNER is identified, and applicable reviews
were obtained and properly documented, prior to submitting the PROCEDURE for approval.
PROCEDURES which impact nuclear safety may require review by the station onsite safety
review PROCESS prior to final approval. The designated APPROVAL AUTHORITY is
responsible for final approval of the PROCEDURE.

6.0 Implement Change Management

While CHANGE MANAGEMENT should be considered throughout the PROCEDURE

PROCESS, the CHANGE MANAGEMENT plans may not be finalized and the implementation
tools put into place until the PROCEDURE change is approved. CHANGE MANAGEMENT
activities include implementation planning; communications; training; coordination between
departments and stations; update of affected documents and work products; and transition plans
for products or services started under the old PROCESS and completed under the new
PROCESS. Effective CHANGE MANAGEMENT will include concurrence from
STAKEHOLDERS and a mechanism for tracking completion of implementation plan
milestones.

7.0 Issue Procedure for Use

Depending on the needs of the station, a PROCEDURE may be approved and staged in advance
of its intended EFFECTIVE DATE. Once approved, the PROCEDURE can be submitted for
ISSUANCE and distribution with an immediate or delayed EFFECTIVE DATE. The
EFFECTIVE DATE is based on completion of key CHANGE MANAGEMENT activities.
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3 PROCESS DESCRIPTION FLOWCHARTS
The PROCEDURE PROCESS is part of an overall set of integrated PROCESSES for the
operation and support of nuclear plants. It is the PROCESS by which activities important to the
business are evaluated, planned, researched, reviewed, approved, communicated, and issued.
The PROCEDURE PROCESS Description was developed to assist companies in capturing cost
and comparing PROCESS related information. This section describes the steps to define and
implement that PROCESS. The flow charts describe the activities. The PROCEDURE
PROCESS is represented in the following LEVELS OF DETAIL and includes:

 Evaluate Request for New or Revised PROCEDURE

 Plan PROCEDURE Development
 Research Request(s) / Develop PROCEDURE Draft
 Review PROCEDURE Draft
 Approve PROCEDURE
 Implement CHANGE MANAGEMENT
 Issue PROCEDURE for Use
The PROCESS model was developed by industry SUBJECT MATTER EXPERTS and capturing
their knowledge by using a simplified version of the Institute of Electrical and Electronics
Engineer’s standard Integrated Definition for Functional Modeling (IDEF0) process modeling
convention. This model was then converted to the standard flow chart methodology used by NEI
and INPO. The resulting model consists of a four-tiered hierarchy of documents as follows:

 Level 0 “Context” flowchart displays the data flow and requirements that interface
with the overall PROCEDURE PROCESS. At this level significant input, controls
and outputs to the PROCEDURE PROCESS are shown (Section 3.1).
 Level I process flowchart expands on the top-level diagram, presents all high-level
process objectives and contains the activities, inputs and outputs necessary to deliver
the products and services (Section 3.2). The high-level flowchart represents an
overview of the major process activities and their relationships.
 Level II intermediate-level flowcharts expand on the Level I process activities and
add a LEVEL OF DETAIL necessary to achieve the process objectives (Section 3.3-
9).
 Level III detailed text descriptions describe the Level II flowchart elements and
include input, process and output descriptions (Section 3.10). The Level III process
text descriptions include control mechanisms, where applicable.
For simplicity of presentation, feedback is not routinely shown on the flowchart. Rather,
feedback is considered a natural and expected activity. Continuous process improvement is not
explicitly shown but is assumed to occur at every level of the PROCESS. Appendix C defines
the conventions used in the flowcharts presented in this PROCESS description.

Electricity Production
$$$$$$$$
Regulatory
Legal
Insurance
DATA AND INFORMATION Business
Other
Requirements/
Core Operate Plant Needs
Processes (INPO)
INPO 01-002 Conduct
of Operations
Unmanaged Information Provide
Information
Management
Configuration Work Equipment Create Services
Reliability Enter IM SS003
Management Management Managed
(INPO) (INPO) Process? Information
(ANSI/NIRMA Yes Types of Information, e.g.,
(AP-928) AP-913,Rev 1) Update
CM 1.0-2000)  Video
(revise,  Voice
No
analyze)  Graphical
 Textual
 Documents
Materials and  Records
Services (NEI)
(AP-908, Rev. 1))

Enabling Processes Make

Management Decisions
Processes and Loss Training Nuclear &
Support Services Prevention (INPO) Fuel Perform
(NEI) (NEI) (AP-921) (NEI) Work

SS001 Provide Information Technology Services

SS002 Provide Business Services
SS003 Provide Information Management Services
SS004 Provide Human Resource Services
SS005 Maintain Grounds, Facilities, and Vehicles
SS006 Support Community and Government Services
SS007 Support Industry Professional and Trade Associations

DATA AND INFORMATION

Figure 3.1 Interface Diagram – Relationship between the Standard Nuclear Performance
Model and the PROCEDURE PROCESS
3.1 CONTEXT FLOWCHART LEVEL 0 – PROVIDE PROCEDURE PROCESS

Level 0 Flowchart displays the data flow and requirements that interface with the overall PROCEDURE PROCESS. At this level
significant input, controls and outputs are illustrated. Detailed flowchart descriptions are given in Section 3.10.

Regulatory, Controls
Business, Other
Requirements

Inputs Outputs

Dispositioned
Request
Procedure Process
Request Description
AP-907-001
Approved Procedure
with Alteration Package
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3.2 TOP-LEVEL FLOWCHART LEVEL I - PROVIDE PROCEDURE PROCESS

Prioritized Assigned 3.0 Drafted

1.0 2.0
Procedure Procedure Procedure Research Procedure
Evaluate Request Plan Procedure
Alteration Request(s) and A
Change for New or Altered Change Development Alteration
Request Request Task Develop
Procedure
Procedure Draft

Rejected
Procedure
Change
Request

Requestor Feedback

5.0
Approve Approved
Procedure Procedure
4.0 Alteration
Package 7.0
Review Procedure Updated Issue Procedure
A Draft Procedure for Use
Draft
Approved
6.0 Implementation
Implement Plan
Change
Management

Documented
Resolution of
Comments
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 3.3 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II EVALUATE REQUEST FOR NEW OR REVISED PROCEDURE (STEP 1.0 IN LEVEL
I CHART)

1.2 1.3
1.1 yes 1.4
Tracked Perform Screened Evaluate yes Accepted
Procedure Change yes
Procedure Initial Procedure Request Procedure Determine Priority
Request Receive Request
Change Screening Change Change
Request Request Request

no no
Prioritized
Procedure
Change Request

Rejected Procedure Rejected Procedure

Change Request Change Request
2.1

Requester Requester
Feedback Feedback
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3.4 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II PLAN PROCEDURE DEVELOPMENT (STEP 2.0 IN LEVEL I CHART)

2.1 2.2 2.3

Prioritized Selected
Procedure Procedure Appropriate
1.4 Evaluate Backlog Determine Assign Work
Change for Workflow Determined
and Select Next Workflow
Request Alteration
Priority Tasks

Assigned Procedure Alteration Task

3.1
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3.5 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II RESEARCH REQUEST(S) / DEVELOP PROCEDURE DRAFT (STEP 3.0 IN LEVEL I
CHART)

3.2

Identify Applicable Applicable

Operating Operating
Experience Experience
(Internal / Identified
External)

3.3
Issues
Evaluate
Identified
Outstanding
Issues

3.1 3.4 3.7

Assigned Validated
2.3 Procedure Procedure Validated
Validate Scope Validate Develop Detailed
Alteration Alteration References
References Draft
Task Task

3.5 Drafted Procedure Alteration Package

Technical
Determine
Information
Technical Content
for Draft

4.1

3.6
Human
Evaluate Human Performance
Performance Information
Challenges for Draft
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 3.6 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II REVIEW PROCEDURE DRAFT (STEP 4.0 IN LEVEL I CHART)

4.1 4.2 4.3

Draft ed Drafted
Provide Comment
3.7 Procedure Procedure Review Comment
Determine Perform Resolve Review Resolution to
Alteration Alteration Comments Resolution
Appropriate Reviews Comments Reviewers
Package and Package and
Reviews
Designated Designated
Reviews Reviews

Updated Procedure
Alteration Package

5.1 6.1
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3.7 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II APPROVE PROCEDURE (STEP 5.0 IN LEVEL I CHART)

5.2
5.1 Obtain yes 5.3
Updated Procedure
Procedure Onsite Procedure
4.3 Ensure Procedure Alteration Obtain Onsite
Alteration Safety Alteration
is Ready for Package Safety Review
Package Review, if Package
Approval required?

no
Procedure Alteration Package
including Onsite Safety Review
Recommendation

Procedure Alteration
Package
5.4

Approve
Procedure

Approved Procedure
Alteration Package

7.1
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3.8 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II IMPLEMENT CHANGE MANAGEMENT (STEP 6.0 IN LEVEL I CHART)

6.1
Updated 6.2 6.3 Approved
Procedure Change Develop Implementation Implement
4.3 yes Implementation 7.1
Alteration Mgmt Plan Change Plan Change Plan
Package Needed? Management Management

no
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3.9 INTERMEDIATE-LEVEL FLOWCHART – LEVEL II ISSUE PROCEDURE FOR USE (STEP 7.0 IN LEVEL I CHART)

5.4 Approved Procedure

Alteration Package

Information
7.1 Completed 7.2 Management
Procedure Approved Procedure
Authorize Submit for With Alteration Process
Issuance Alteration Issuance AP-907
Package Package

Approved Dispositioned Procedure

6.3 Implementation Change Request
Plan

Requester
Feedback
3.10 DETAILED FLOWCHART TEXT DESCRIPTIONS - LEVEL III PROVIDE PROCEDURE
PROCESS

This section contains instructions for the PROCEDURE development PROCESS and describes
the inputs and outputs associated with each activity.

Procedure Change A request to alter or develop a PROCEDURE. This includes

Request technical and administrative PROCEDURES.

Inputs: procedure change requests

1.0
A change request is received and placed into a single tracking
Evaluate
Request for system along with a minimal set of attributes which uniquely
New or Altered identify the request. A general review of the technical and
Procedure
administrative aspects of the request determines the validity and
priority along with a review of impact on other PROCEDURES.
Feedback on the request is provided to the submitter.

Outputs: prioritized procedure change request, rejected procedure

change request

1.1 Inputs: procedure change request

Receive Request
Process: When a PROCEDURE CHANGE REQUEST is
received, it is placed into a single tracking system and assigned a
unique number. The tracking system includes a minimal set of
attributes for each PROCEDURE CHANGE REQUEST,
including:
 PROCEDURE Number
 Clear Description of Issue
 Date Issue Identified
 User or Contact

Outputs: tracked procedure change request

 1.2
Inputs: tracked procedure change request

Perform Initial Process: Once the PROCEDURE CHANGE REQUEST and

Screening
associated attributes are entered into the single tracking system,
the technical and administrative aspects of the request are
reviewed to determine whether the request is reasonable and
appropriate. If the PROCEDURE CHANGE REQUEST is
determined to be reasonable and appropriate, it is evaluated
further. If the PROCEDURE CHANGE REQUEST is
determined not to be reasonable or appropriate it is rejected.
Feedback on the status of the PROCEDURE CHANGE
REQUEST is provided to the requester.

Outputs: screened procedure change request, rejected procedure

change request

Inputs: screened procedure change request

1.3
Process: The screened PROCEDURE CHANGE REQUEST is
evaluated and either accepted or rejected. The evaluation of the
Evaluate Request
screened PROCEDURE CHANGE REQUEST includes an
evaluation of the impact of the proposed ALTERATIONs on
other PROCEDURES. The following are potential reasons for
rejecting a request:
 Cost versus benefit
 Risk versus benefit
 Duplicate request
 Technically incorrect
 Format changes without HUMAN
PERFORMANCE benefit
 Personal preference ALTERATIONs with
insufficient management approval
 Training issue
 Individual accountability issue
 Non-procedural issue (does not meet
PROCEDURE definition, Appendix F)
An accepted PROCEDURE CHANGE REQUEST is statused as
such in the single tracking system. A rejected PROCEDURE
CHANGE REQUEST is closed in the single tracking system or
referred to another department for consideration and input.
Feedback on the status of the PROCEDURE CHANGE
REQUEST is provided to the requester.

Outputs: accepted procedure change request, rejected procedure

change request
 Inputs: accepted procedure change request
1.4
Process: Key attributes of the accepted PROCEDURE CHANGE
Determine Priority REQUEST are evaluated to determine the risk and importance
that the request presents to the station. Some key attributes are:
 Stop work issue
 Reactivity
 Safety
 Potential for a direct impact on generation
 REGULATORY REQUIREMENT
 Next scheduled use of the PROCEDURE
 Refueling Outage Activity
 Engineering Change Request related activity

Once the risk and importance has been determined, scheduling

should be considered. The appropriate priority for the accepted
PROCEDURE CHANGE REQUEST is then assigned. Typical
priorities are:
 Technically incorrect such that the PROCEDURE must be
revised to complete the task.
 Enhancements that provide additional LEVEL OF
DETAIL that if not added could pose a condition adverse
to quality
 Enhancements that are not adverse to quality
 EDITORIAL CORRECTIONS

Outputs: prioritized procedure change request

Inputs: prioritized procedure change request

2.0
Plan Select the appropriate PROCEDURE(s) to be revised by
Procedure reviewing the BACKLOG and evaluating task priority, quantity,
Development
and other COMMITMENTS. Determine the type of change and
appropriate work flow based on the technical level of request.
The task is assigned to a PROCEDURE WRITER.

Outputs: assigned procedure alteration task

2.1 Inputs: prioritized procedure change request
Evaluate Backlog
And Select Next Process: Outstanding PROCEDURE CHANGE REQUESTS
Priority Tasks (BACKLOG) are reviewed by priority, by age, and by the total
number of PROCEDURE CHANGE REQUESTS per
PROCEDURE. Outstanding PROCEDURE CHANGE
REQUESTS are also reviewed for other considerations, such as:
 Outage goals
 Management expectations
 Cultural inputs
Based on the REVIEW of outstanding PROCEDURE CHANGE
REQUESTS, the appropriate PROCEDURE(s) are selected for
ALTERATION.

Note: Total number of PROCEDURE CHANGE REQUESTS

against an individual PROCEDURE may be general indicator of
overall PROCEDURE quality.

Outputs: selected procedure for alteration

2.2 Inputs: selected procedure for alteration

Determine
Workflow Process: Based on the technical level of all planned
ALTERATIONs, time available to PROCESS the
ALTERATION, and duration of the ALTERATION, the
appropriate workflow is determined. Typical workflows are:
 NEW PROCEDURE / MAJOR REVISION
 MINOR REVISION
 EDITORIAL CORRECTIONS

NOTE: Consideration should be given to utilize the MAJOR

REVISION PROCESS for CHANGES OF INTENT,
methodology, majority of steps; and time since last MAJOR
REVISION.

Variations on these workflows may include but are not limited to:
o IMMEDIATE CHANGE typically involves a stop
work situation or business need of the plant that
requires an IMMEDIATE CHANGE to the
PROCEDURE.
o LIMITED USE change is an ALTERATION of a
PROCEDURE that is valid only for the job
package being worked or specified period of time.

Outputs: appropriate workflow determined

 Inputs: appropriate workflow determined
2.3
Process: Once the workflow type is determined, the work is
Assign Work
assigned to a PROCEDURE WRITER.

Outputs: assigned procedure alteration task

Inputs: assigned procedure alteration task

3.0
Research The assigned PROCEDURE WRITER assembles a
Request(s) and PROCEDURE change package and validates the scope of the
Develop
Procedure Draft assigned work. The writer determines the change to the
PROCEDURE by reviewing applicable OPERATING
EXPERIENCE, outstanding issues, REFERENCES, HUMAN
PERFORMANCE challenges and technical content. The writer
then develops the detailed draft of the PROCEDURE using the
correct TEMPLATE and the WRITER’S MANUAL.

Outputs: drafted procedure alteration

Inputs: assigned procedure alteration task

3.1
Process: The assigned PROCEDURE WRITER begins to
Validate Scope
assemble a PROCEDURE ALTERATION PACKAGE and
performs the following actions, depending upon the workflow, to
validate the assigned work. At this point, a questioning attitude is
essential.
 Verify type of workflow to be followed
 Determine appropriate LEVEL OF USE
 REVIEW the plan with the PROCEDURE OWNER and
requester to ensure issues are being addressed
 REVIEW material with the SUBJECT MATTER
EXPERT and appropriate STAKEHOLDERS (i.e.,
Licensing, Engineering, Safety Analysis, Training, etc.)
 Identify impacts on other documents (i.e., Design Basis
Documents, other PROCEDURES, etc.)
 Identify impacts to PROCESSES (i.e., Work
Management, Design Change, etc.)
 Identify training impacts
 Ensure due dates are identified and valid

Outputs: validated procedure alteration task

 Inputs: validated procedure alteration task
3.2
Process: The assigned PROCEDURE WRITER reviews
Identify Applicable
Operating Experience applicable OPERATING EXPERIENCE that addresses issues
(Internal / External) related to the validated PROCEDURE ALTERATION task. This
includes the following actions:
 Search external databases for related issues (i.e., INPO,
WANO, NRC, etc.)
 Search internal resources for related issues (i.e.,
Corrective Action, Post-Job Critiques, TACIT
KNOWLEDGE, Self-Assessments, Benchmarking, etc.)
 Identify applicable OPERATING EXPERIENCE

NOTE: To be effective, the REVIEW considers not only the

event but the error-likely situation and its precursors for
applicability. Carefully reviewed OPERATING EXPERIENCE
can be used to identify error precursors and their associated
organizational weaknesses. The REVIEW can take the form of
facilitated discussion of operating event precursors and flawed
defenses and how the jobsite tools of the particular utility would
prevent the event. Gaps indicate a need for modified or additional
tools.

Outputs: applicable operating experience identified

Inputs: validated procedure alteration task

3.3
Process: The assigned PROCEDURE WRITER evaluates
Evaluate
Outstanding Issues outstanding issues related to this PROCEDURE and determines if
they should be incorporated into this ALTERATION. This
includes the following actions:
 REVIEW open PROCEDURE CHANGE REQUESTS
 REVIEW the PROCEDURE to determine compliance
with station WRITER’S MANUAL and other
administrative changes
 Evaluate other work in PROCESS on this PROCEDURE
(i.e., pending licensing amendments, modifications, etc.)

Outputs: issues identified

 Inputs: validated procedure alteration task
3.4
Process: The assigned PROCEDURE WRITER performs
Validate
References VALIDATION of REFERENCES and updates REFERENCES, if
applicable. This includes the following actions:
 Verify existing REFERENCES are current
 Validate the REFERENCES for this ALTERATION

Outputs: validated references

Inputs: validated PROCEDURE alteration task

3.5
Process: The assigned PROCEDURE WRITER determines the
Determine
Technical Content technical content to be incorporated into the PROCEDURE.
Depending upon the extent of the ALTERATION, the writer
should perform the following when developing this content:
 Identify performance objectives
 Identify necessary activities
 Identify LEVEL OF DETAIL, taking into account the
following:
o Worker knowledge and skill. The PROCEDURE
should be written for the least qualified worker.
However, the writer must recognize that worker
knowledge and experience is expected to decline
with the aging of the workforce. TACIT
KNOWLEDGE must be captured while the
opportunity exists.
o Complexity and frequency of task
o Consequence of error
o Identification of instrumentation
o Level of oversight
 Define and refine PROCESSES
 Identify interfaces with other PROCESSES and work
groups
 Identify critical steps
 Identify control points (for example, QC, HP, Engineering
hold points, Supervisory permission)
 Identify expected plant responses, including effects on
reactivity and nuclear safety.
 Identify configuration management and equipment status
control requirements (for example, independent
VERIFICATION of as-left positions)
 Identify job hazards from radiological and industrial
safety points of view. Special precautions and personnel
protective equipment should be identified.
  Identify special methods of communication
 Identify environment and location where work will be
performed
 Identify unique PROCEDURE use and adherence
requirements (for example, working out of sequence, use
of “Not Applicable”)
 Identify unique management controls (refer to SOER 91-
01, Conduct of Infrequently Performed Tests or
Evolutions)

Note: If incorporating a new methodology or creating a NEW

PROCEDURE, a task analysis and PROCESS flow map may be
warranted.

Outputs: technical information for draft

3.6 Inputs: validated procedure alteration task

Evaluate Human
Performance Process: The assigned PROCEDURE WRITER identifies and
Challenges develops defenses to HUMAN PERFORMANCE challenges.
This includes identifying latent weaknesses and potential ERROR
TRAPS, such as:
 In-field decisions without clear guidance
 Excessive in-field decisions
 Steps are vague or missing critical detail (consider
whether the job is knowledge-based and over-relying on
the skill-of-the-craft)
 Excessive physical challenges
 Inappropriate use of VERIFICATIONS and PEER
CHECKS
 Inadequate defense-in-depth (termination criteria not
specified)
 Excessive branching
 Inconsistent place-keeping methods
 Having information in prerequisites, Notes, Cautions, and
Warnings that does not add value
 Un-related actions in the same step.
 Actions or acceptance criteria embedded in Notes,
Cautions or Warnings.
 Complex calculations without PEER CHECK
 Atypical steps or terms
 Vague interpretive guidance (verbiage that could be
perceived as giving tacit management acceptance of
human behaviors such as shortcuts and non-compliance,
or require the user to act based upon perceptions and
 background leading to knowledge-based errors)
 Time constraints

Notes:
 Administrative and TECHNICAL PROCEDURES have
different purposes and thus contain different error
potentials.
 ADMINISTRATIVE PROCEDURES have the potential
to contain embedded latent organizational weaknesses.
These weaknesses may be difficult to identify from a
cursory glance and require an extensive evaluation of the
intent of the PROCEDURE and the verbiage used to
convey the intent.
 TECHNICAL PROCEDURES direct activities at the
man/machine interface. As such, they can directly impact
HUMAN PERFORMANCE and actions, and are more
susceptible to ERROR TRAPS.

Outputs: human performance information for draft

3.7 Inputs: applicable operating experience identified, issues

identified, validated references, technical information for draft,
Develop Detailed
Draft human performance information for draft

Process: From the information gathered in the previous steps, the

assigned PROCEDURE WRITER creates a draft that will be used
for the REVIEW PROCESS. The PROCEDURE WRITER
performs the following actions:
 Determines the correct TEMPLATE based on hardware,
software, the type of PROCEDURE being altered, and the
type of ALTERATION being made
 Complies with the WRITER’S MANUAL (for example,
PROCEDURE numbering, organization, format, and
writing style)
 Updates BASES and REFERENCES, if applicable
 Assembles a PROCEDURE ALTERATION PACKAGE,
which includes the draft PROCEDURE, description of
changes, and supporting documentation
 Performs a Self-Check to ensure quality of the drafted
PROCEDURE ALTERATION

Outputs: drafted procedure alteration package

Inputs: drafted procedure alteration package

 Determine the appropriate REVIEW(s) for the PROCEDURE
4.0 change and route accordingly. A determination should be made
Review Procedure
Draft
which REVIEWS are in series and which may be performed in
parallel. The PROCEDURE REVIEWERS will perform
REVIEWS and provide documented COMMENTS. The
PROCEDURE WRITER ensures that COMMENTS are returned
and resolved.

Outputs: documented comment resolution, updated procedure

alteration package

Inputs: drafted procedure alteration

4.1
Process: The writer recommends the appropriate REVIEWS that
Determine will be implemented for the PROCEDURE ALTERATION, gains
Appropriate
Reviews concurrence and routes accordingly. The following is a list of
possible REVIEWS that may be required depending upon the
extent and type of ALTERATION. This list is not all-inclusive.
 Requester
 Technical REVIEW
 License and Special Programs Impact REVIEWS, such as:
 Tech Specs, Technical Requirements Manual,
UFSAR
 QA/QC
 Appendix R, Fire Protection, Insurance
 EQ
 Security
 Reactivity Management
 Inservice Testing Engineering
 Instrumentation Impact (Reg Guide 1.97)
 Heavy Loads
 Flooding
 Environmental compliance
 Industrial Safety
 Health Physics
 Plant license renewal
 50.59 and Design Basis Documentation
 72.49 and Design Basis Documentation
 CROSS DISCIPLINE REVIEW
 Peer REVIEW/HUMAN PERFORMANCE/Writers
Manual
 VALIDATION by user. Typical VALIDATION methods
include:
 Performance on mock-ups or spare equipment
 Simulator scenarios
  Walkthroughs
 Comparison
 Table Top
 Station Onsite Safety REVIEW
 Probabilistic Risk Assessment and Maintenance Rule
REVIEW
 REVIEWS by other stations, if fleet PROCEDURE

Note: Reviewers, except the Requester, should be knowledgeable

of the information being reviewed.

Outputs: drafted procedure alteration package, designated

reviews

4.2 Inputs: drafted procedure alteration package, designated reviews

Perform Reviews
Process: The designated reviewer(s) perform REVIEWS of the
drafted PROCEDURE ALTERATION and provide COMMENTS
to the PROCEDURE WRITER in such a manner that it can be
tracked for resolution and VERIFICATION.

Outputs: review comments

Inputs: review comments

4.3
Process: The PROCEDURE WRITER ensures that
Resolve Review COMMENTS are resolved by performing the following:
Comments
 Independent and thorough REVIEWS are critical to
ensure a quality product. During the REVIEW
PROCESS, the writer ensures these REVIEWS are
obtained and COMMENTS incorporated, as appropriate.
Significant changes incorporated during the REVIEW
PROCESS may require the PROCEDURE to be re-routed
or additional REVIEWS obtained. If problems occur
during the REVIEW PROCESS indicating lack of or poor
quality responses, the writer should stop further
PROCESSING of the PROCEDURE and escalate the
issue to higher management.
 Provide comment resolution to reviewers. If a comment
cannot be resolved, then the writer escalates the issue to
higher management.
 Provide updated PROCEDURE draft for approval.

Outputs: updated procedure alteration package, comment

resolution
 Inputs: updated procedure alteration package

5.0
The PROCEDURE approval PROCESS is designed to ensure that
Approve
Procedure the format and content of the PROCEDURE are correct, the
PROCEDURE OWNER is identified, and applicable REVIEWS
were obtained and properly documented, prior to submitting the
PROCEDURE for approval. PROCEDURES which impact
nuclear safety may require REVIEW by the station onsite safety
REVIEW PROCESS prior to final approval. The designated
APPROVAL AUTHORITY is responsible for final approval of
the PROCEDURE.

Outputs: approved procedure alteration package

5.1 Inputs: updated procedure alteration package

Ensure Procedure Is
Ready For Approval Process: The PROCEDURE WRITER ensures REVIEW and
comment resolution have been successfully completed and
prepares a PROCEDURE approval package, including the
updated PROCEDURE draft, description of ALTERATIONs, and
supporting documentation. This involves the following actions,
when applicable:
 Ensure concurrence has been obtained (includes cross-
discipline concurrence when another work group(s) is
affected or involved in performing the PROCESS or
PROCEDURE).
 Ensure PROCEDURE is in proper format, (for example,
revision number is correct, page numbering correct, etc.).
 Ensure the owner of the PROCESS or PROCEDURE is
identified.
 Ensure VERIFICATION is satisfactory.
 Ensure VALIDATION is satisfactory.
 Ensure PROCEDURE ALTERATION PACKAGE
documentation is complete.
 Ensure controlled computer files are updated with the
latest version of the draft

Outputs: procedure alteration package

5.2
Inputs: procedure alteration package

Obtain Onsite Safety Process: PROCEDURES which impact nuclear safety typically
Review If Required require REVIEW by the station onsite safety REVIEW
PROCESS prior to final approval.
 Outputs: procedure alteration package

5.3 Inputs: procedure alteration package

Obtain Onsite
Safety Review Process: Deterministic PROCESS utilized to ensure that
PROCEDURE alterations have not compromised nuclear safety
as performed by the ONSITE SAFETY REVIEW COMMITTEE.

Outputs: procedure alteration package including station onsite

safety review recommendation

Inputs: procedure alteration package including station onsite

5.4 safety review recommendation

Approve Procedure Process: Speed and simplicity of PROCEDURE approval are

essential. Appropriate approvals are necessary; however,
multiple approvals dilute accountability and should be avoided.
The approver is the designated APPROVAL AUTHORITY
having responsibility for entities that will implement the
PROCEDURE.

Outputs: approved procedure alteration package

Inputs: updated procedure alteration package

6.0
Implement
Change While CHANGE MANAGEMENT should be considered
Management
throughout the PROCEDURE PROCESS, the CHANGE
MANAGEMENT plans may not be finalized and the
implementation tools put into place until the PROCEDURE
change is approved. CHANGE MANAGEMENT activities
include implementation planning; communications; training;
coordination between departments and stations; update of affected
documents and work products; and transition plans for products
or services started under the old PROCESS and completed under
the new PROCESS. Effective CHANGE MANAGEMENT will
include concurrence from STAKEHOLDERS and a mechanism
for tracking completion of implementation plan milestones.

Outputs: approved implementation plan

Inputs: updated procedure alteration package

Process: While CHANGE MANAGEMENT may have been

considered throughout the PROCESS, this step finalizes and
assures that CHANGE MANAGEMENT is evaluated.
 6.1
Outputs: updated procedure alteration package
Change
Management Plan
Needed?

Inputs: updated procedure alteration package

6.2
Develop Change
Process: This step assures that the appropriate CHANGE
Management Plan MANAGEMENT implementation tools are developed.
Development of a CHANGE MANAGEMENT plan is considered
when the ALTERATION:
 Affects Training (tools and personnel qualifications)
 Impacts other departments or stations
 Impacts scheduled work
 Impacts routinely used work products or services (forms,
software applications, databases, etc.)
 Involves a NEW PROCEDURE or LIMITED USE
PROCEDURE change
 Is safety significant, high risk (SOER 92-1), or complex in
nature
CHANGE MANAGEMENT plans include the following:
 Description of the ALTERATION and the stakeholder
impacts
 Implementation schedule
 Training needs identification
 EFFECTIVE DATE
 Expiration date for LIMITED USE changes or
infrequently performed PROCEDURES
 Verifying BASES documents have been changed, (that is,
drawings, technical specifications, final safety analysis
report, and others)
 Coordinating ALTERATIONs to related PROCEDURES
 Transition plans for products or services that are started
under the old PROCEDURE but will be completed under
the new one
 Verifying equipment modifications and changes are
complete
 Developing a communication plan
 Developing or obtaining special tools, aids, permits, and
other items

Outputs: implementation plan

Inputs: implementation plan

6.3 Process: Stakeholder concurrence is obtained for implementation
Implement of the CHANGE MANAGEMENT plan, adapting the plan as
Change necessary for specific stakeholder requirements. Work
Management
assignments to implement the CHANGE MANAGEMENT plan
are made (involving other PROCESSES as appropriate, e.g.
Training).

Outputs: approved implementation plan

7.0 Inputs: approved procedure alteration package, approved

implementation plan
Issue Procedure
For Use
Depending on the needs of the station, a PROCEDURE may be
approved and staged in advance of its intended EFFECTIVE
DATE. Once approved, the PROCEDURE can be submitted for
ISSUANCE and distribution with an immediate or delayed
EFFECTIVE DATE. The EFFECTIVE DATE is based on
completion of key CHANGE MANAGEMENT activities.

Outputs: approved procedure submitted for issuance, procedure

alteration package transferred to record retention

7.1 Inputs: approved procedure alteration package, approved

implementation plan
Authorize
Issuance
Process: Once the PROCEDURE ALTERATION PACKAGE
and implementation plan are approved, the PROCEDURE
ALTERATION PACKAGE is prepared and authorized for
issuance. This includes the following actions:
 Determine EFFECTIVE DATE(s)
 Release the PROCEDURE ALTERATION for use

Outputs: completed procedure alteration package

7.2 Inputs: completed procedure alteration package

Submit For
Issuance Process: Once the PROCEDURE ALTERATION is authorized
for issuance:
 Approved PROCEDURE is submitted for issuance
 Completed PROCEDURE ALTERATION PACKAGE is
transferred to the record retention PROCESS
 Disposition completed change request(s)
 Feedback to the original requester
Outputs: approved procedure with alteration package,
dispositioned procedure change request
 APPENDIX A
Glossary of Terms and Definitions

Administrative Procedure: A controlled document that specify actions and processes necessary
to implement a program.

Alteration: A generic term used to describe types of activities that modify approved procedures.
(Refer to Level III, step 2.2)

Approval Authority: The individual, by organizational title, designated in writing to approve

procedures.

Backlog: Total quantity of uniquely identified procedure actions within a single tracking system.

Bases: The source of information for or the rational behind procedure step(s) or sequence of
steps.

Change of Intent: A procedure Alteration that modifies what is accomplished by the procedure,
OR changes the method by which processes are performed in a manner that may have safety
significance.

Change Management: The application of tools and techniques that promote the successful
initiation, planning, communication, implementation, and evaluation of change.

Comments: Feedback provided to procedure writer during the procedure review process.

Commitment: Requirements that are uniquely identified to ensure future Alterations do not
inadvertently remove the requirement.

Continuous Improvement: The ongoing betterment of a process based on constant

measurement and analysis of results produced by the process and use of that analysis to modify
the process. Continuous improvement includes the act of monitoring and measuring processes
and products against policies, objectives and requirements for the product and reporting the
results as well as taking the appropriate actions to make the necessary adjustments to improve
the processes and products.

Cross Discipline Review: A review conducted by knowledgeable personnel in organizations

affected by the procedure to verify functional and technical adequacy of those portions of the
procedure that describe the process directly controlled by the affected organizations. This review
also includes the potential impact on any other applicable controlled documents under the
ownership of the affected organization.

Diagnostic Measure: Useful indicators or analytical tools for assessing a process or components
of a process for trending purposes.
Editorial Corrections: Alteration of the procedure which maintains the original intent and does
not change the technical content of the procedure.

Effective Date: The date that an approved procedure can be used to perform a task.

Error Trap: Procedure format or content that challenges the users' ability to successfully
perform a task.

Human Performance: The system of processes, values, behaviors, and their ultimate results that
determine plant performance.

IDEF0: “Integrated Definition for Functional Modeling 0” is a formal process modeling

nomenclature and methodology, that describe the activities and processes that make enterprise
wide and product-data based information flows, in a specific application context and is used to
analyze composite, multi system and multi functions team processes.

Immediate Change: A procedure Alteration which typically involves a stop work situation or
business need of the plant that requires an immediate change to the procedure.

Information Management: The costs and activities that comprise the formal process by which
information important to the business is generated, revised, received, stored, retrieved,
distributed and destroyed. In addition, the process as defined in the SNPM includes office-
related activities such as keying, filing, mail processes, maintaining office supplies, reproduction
and fax services, and other administrative support activities.

Issuance Date: See effective date definition.

Level of Detail: The technical detail necessary within a procedure step to successfully interface
the individual user's knowledge to the technology being manipulated or task being performed.
Additional items to consider include: complexity of task, potential for user error and
consequence of error, degree of standardization desired, and the frequency with which the
procedure is performed.

Level of Use: Designation assigned to a procedure which provides minimum requirements for
using the procedure. Commonly seen procedure use levels are:
 Continuous use, in which each step of the procedure is read
before that step is performed, and each step is performed in the
sequence given. Typically, each step is then signed off or
checked off by the performer.
 Reference use, in which the procedure is referred to
occasionally during an activity to confirm the correct actions
are being performed. Typically, these procedures are in hand or
near the job site during the evolution.
 Information use, in which an activity may be performed from
memory, but the procedure is reviewed prior to the evolution as
needed so the user understands all actions.
Limited Use: An Alteration of a procedure that is valid only for the job package being worked
or specified period of time.

Major Revision: An Alteration, based on the scope and complexity, that requires full and
rigorous reviews.

Minor Revision: An Alteration, based on the scope and complexity, for which limited reviews
are appropriate.

New Procedure: A task that is not currently addressed in any existing procedure and is assigned
a unique identifier.

Onsite Safety Review Committee: Standing committee for the review of items which may
affect the safety of the Plant. (Reg Guide 1.33)

Operating Experience Review: Using internal and industry operating experience and lessons
learned to make organizational improvements.

Peer Check: Series of actions by two individuals working together at the same time and place,
before and during a specific action, to prevent an error by the performer. (AP-931)

Performance Measures: A management technique for evaluating the performance of a

particular function, process, or person.

Procedure: A managed human performance tool that specifies or describes how an activity is to
be performed. (see Appendix F)

Procedure Alteration Package: The information generated for obtaining required reviews and
approval for a new or altered procedure. The Alteration package includes the procedure
alteration and relevant documents (e.g., copy of procedure(s), procedure approval
documentation, procedure review documentation, regulatory compliance documentation,
incorporated procedure change requests, revised forms, bases documents, and commitment
documents). Other items to include could be checklists or guides for performing required
procedure reviews.

Procedure Change Request: A request to alter or develop a procedure. This includes technical
and administrative procedures.

Procedure Owner: The organizational position holder accountable for the integrity of the
procedure throughout its life-cycle.

Procedure Reviewer: Person(s) knowledgeable to perform a specific type(s) of procedure

review.

Procedure Writer: The author or major contributor assigned to develop or alter a procedure.
The procedure writer is responsible for the accuracy and usability of the revised portion of the
procedure, its impact on the unrevised portion, and any other controlled documents. The
individual is also responsible for developing a procedure Alteration package, determining
required reviews, and coordinating comment resolution for the Alteration.

Process: A sequence of behaviors or series of steps designed to produce a product or service in a

predictable, repeatable fashion.

Process Owner: The individuals who coordinate the various functions and work activities at all
levels of a process, regardless of the functional organizations involved. They have the resource
control and job skills to evaluate overall process operation and to evaluate potential process
improvements. They design and manage the process end to end so as to ensure optimal overall
performance. Process owners are responsible for ensuring the total process is both effective and
efficient, and that appropriate performance measures are in place to measure the process
accordingly and ensure performance is continually improved.

References: Information used to develop the contents and support the requirements established
within a procedure.

Regulatory Requirement: A federal, state, or local obligation that must be met.

Review: A critical evaluation of a procedure Alteration package.

SNPM: The Standard Nuclear Performance Model – A Process Management Approach is an

industry guiding document that is the result of a six-year effort by the Nuclear Energy Institute,
the Institute for Nuclear Power Operations and the Electric Utility Cost Group to publish and
maintain a comprehensive model that includes all INPO and NEI process descriptions, an aligned
set of activity-based costing definitions for use in submission of cost data to the EUCG and an
aligned set of key performance indicators consistent with INPO guidance and supported by
industry process owners known as Communities of Practice.

Stakeholders: Individuals representing business areas that could be affected by the proposed
change such that it may alter their behavior or processes as a result of a specified change.
Stakeholders are in a position to provide the necessary input ensuring the final outcome meets
required standards.

Subject Matter Expert: An individual that, by education, training and/or experience, is

recognized as an expert on a particular system or subject.

Tacit Knowledge: Undocumented (tribal) knowledge.

Technical Procedure: A controlled document outlining a series of steps for the operation,
maintenance or testing of a system, structure or component.

Technical Review: A review of the technical requirements and adequacy of a procedure.

Template: A Writer’s Manual tool that determines the basic structure for a document and may
contain document settings such as AutoText entries, fonts, key assignments, macros, menus,
page layout, special formatting, and styles.

Validation: The process of exercising procedures to ensure that they are useable and the
language and level of information is appropriate for the individuals for whom they are intended
and that the procedures will function as intended.

Verification: The process of checking that the procedures are technically correct, that there is a
correspondence between the procedures and the hardware, and that the procedures accurately
adhere to the guidance found in the writer's manual.

Writer’s Manual: A controlled document that provides instructions for the format, human
factoring, and content of procedures.
 APPENDIX B
Task Force List

Mr. Bill Benthall Mr. Dwight Hargett

Dominion Generation – Surry Duke Energy - McGuire
Supervisor, Station Procedures Senior Operations Specialist
Tel: (757) 365-2074 Tel: (704) 875-4032
Email: bill_benthall@dom.com Email: dlharget@duke-energy.com

Mr. Dan Bierbrauer Ms. Cindy Larson

NIMSL Director American Electric Power - DC Cook
Constellation Generation Group Senior Nuclear Specialist
Director, IT Ginna Tel: (269) 465-5901
Tel: (585) 771-3637 Email: celarson@aep.com
Email: daniel.bierbrauer@constellation.com

Mr. Bruce Bredeman Mr. Gerald Lewis

NIMSL Director NIMSL Chair
AmerenUE - Callaway STP Nuclear Operating Company
Superintendent, Procedures Staff Consultant – IE
Tel: (573) 676-8731 Tel: (361) 972-8338
Email: bpbredeman@cal.ameren.com Email: glewis@stpegs.com

Mr. Ron Cutlip Mr. Steve McCord

TXU Power NEI-AP-907-001 Team Leader
Consulting Nuclear Analyst Constellation Generation Group
Tel: (254) 897-8228 Director, Fleet Policies and Procedures
Email: rcutlip1@txu.com Chairman, Westinghouse Owners Group –
Procedures Working Group
Tel: (410) 897-5098
Email: stephen.c.mccord@constellation.com

Mr. John Field Ms. Dianna A. Miller

Dominion Generation - North Anna
Coordinator, Nuclear Procedures
Tel: (540) 894-2158
Email: john_field@dom.com
NIMSL Director
NEI-AP-907-001 Project Manager
Entergy – Waterford 3
Superintendent, Administrative Services
Tel: (504) 739-6620
Email: dmille2@entergy.com

Mr. Jack Hardy Mr. Alan Rabe

Scientech, LLC FirstEnergy Nuclear Operating Company -
Manager, Procedures and Training Corporate
Tel: (803) 641-7010 Administrative Program Manager
Email: jwhardy@scientech.com Tel: (330) 384-4892

Mr. William Russell
STP Nuclear Operating Company
Procedure Group Supervisor
Tel: (361) 972-7324
Email: wsrussell@stpegs.com
Mr. Steve Sawtschenko
Arizona Public Service – Palo Verde
IS Client Manager
Tel: (623) 393-5694
Email: steve.sawtschenko@aps.com
Email: awrabe@firstenergycorp.com
Mr. Randall O. Taylor, MIT
NIMSL Director
TXU Power
Manager, Administrative Services
Tel: (254) 897-8287
Email: rtaylor3@txu.com
Ms. Shelley Tucker
Ontario Power Generation – Nuclear
Manager, Records/Controlled Document
Tel: (905) 839-1151
Email: shelley.tucker@opg.com
 APPENDIX C
Process Modeling and Flowchart Conventions
The process model was developed by interviewing industry personnel with many years of
experience in this discipline and capturing their knowledge by using a simplified version of the
Institute of Electrical and Electronics Engineers standard Integrated Definition for Functional
Modeling 0 (IDEF0) process modeling convention. This model was then converted to the
standard flowchart methodology used by Nuclear Energy Institute. The resulting model consists
of a four-tiered hierarchy of documents as follows:

1. Level 0 “Context” flowchart displays the data flow and requirements that interface with the
overall INFORMATION MANAGEMENT (IM) process. At this level significant input,
controls and outputs to the IM process are shown.
2. Top-level flowchart blocks are numbered 1.0, 2.0, 3.0 and so forth using the rectangle basic
flowchart process icon. ALL blocks except terminators are numbered, unless combined with
a decision block and highlighted to (indicate the decision process step).

3. Intermediate and lower-level flowchart blocks are numbered consistently with the
corresponding higher-level block. For example, intermediate-level expansion of block 4.0
would be 4.1, 4.2, 4.3 and so forth.

4. Activities involving two work groups, with one performing and the other approving, are
shown using the process activity block for the task performance and an approval diamond for
the approval activity. The two blocks are connected in series.

5. Interface connections to another process are shown on the intermediate-level flowchart only,
not the top level.

6. Process data blocks are used to show processing of information/data/to/from key points
within a process. The text in such a block indicates an action to be taken within the process,
such as “update equipment history.”

7. Intermediate and lower-level flowchart blocks as well as Level III text show or discuss the
inputs, outputs, and drivers:
 Inputs represent material or information transformed or consumed by the process to
produce an output.
 Outputs represent materials or information produced by the activity.
 Drivers represent the external requirements that dictate entry into an activity.
 Name: Decision Name: Activity Name: Data

Prompt: Top-Level Diagram Decision Prompt: Top-Level Diagram Prompt: Top-Level Diagram Data Input
or Output

Decision Activity Data

Name: Top MIT Name: Step No. Name: Terminator

Prompt: Top-Level Diagram Prompt: Top-Level Diagram Step Prompt: Universal symbol representing
Monitoring, Inspection, Test, Identifier the start or end of a process
Etc. (MIT) and a location where a specific
number of transactions from
an unspecified source enter
the process

1
Terminator

Name: Display Name: Connector Name: Statement

Prompt: Universal symbol representing Prompt: Universal symbol representing Prompt: Universal symbol
data that is displayed for an exit to, or entry from, representing statements of
human use, such as data on a another part of the same conclusion, intent, or
monitor screen process direction

Display Statement

Name: Data Name: Predefined Process Name: Process Activity

Prompt: Intermediate-level symbol
Prompt: Intermediate-level symbol Prompt: Intermediate-level symbol
representing a connection
representing data that is an representing a process activity
to/from a named process, such
input to or an output from a that includes data fields for
as Configuration Control or
process activity step number and worker level
Work Control*
No. Responsibility No. Responsibility No. Responsibility

Activity - Defined
Data Process Activity
Process

Process Step

* Indicates that a quantifiable number of transactions move from one process to the other.
Name: Evaluation Name: Preparation Name: Schedule

Prompt: Intermediate-level symbol Prompt: Intermediate-level symbol Prompt: Intermediate-level symbol

representing an evaluation representing preparations representing interface with the
performed, such as root such as planning, job integrated schedule
cause determination briefings, collecting
equipment, etc.
No. Responsibility
No. Responsibility No. Responsibility

Evaluation
Preparation Scheduling Activity

S M T W T F S

Name: Process Decision Name: Approval Name: MIT

Prompt: Intermediate-level symbol Prompt: Intermediate-level symbol Prompt: Intermediate-level symbol

representing a process representing process representing monitoring,
decision or switching-type authorization and control inspection, testing, validation,
function decision etc. (MIT)

No. No.
No. Responsibility

Decision Approval
Responsibility Responsibility
 APPENDIX D
Performance Measures

Industrywide Key Performance Indicators

Industrywide key performance indicators are provided for process performance comparison and
as comparative analytical tools.

 The definition of the indicator clearly identifies the purpose for the measure, the
quantity being measured, and the source of the data.
 Rolling averages may be used to correct aberrations in data caused by uneven
schedule loading or brief periods of high emergent work.
 Indicator definitions are provided to help ensure consistent reporting to the extent
possible.
 Measurement periods are based on individual site fuel cycle but are rolling periods
covering the immediately preceding months equal to the site’s fuel cycle.

NOTE: One PROCEDURE CHANGE REQUEST may affect multiple PROCEDURES. For
the purposes of these performance indicators, each PROCEDURE requiring a change as the
result of the PROCEDURE CHANGE REQUEST will be counted individually.

Diagnostic Title: Procedure Quality

Definition: Total number of procedure content problems identified as adverse to quality in the
corrective action system during the previous month. If more than one procedure is affected by
the original request, for the purposes of performance measures they are counted as multiple
requests. For reporting at a plant (site), the number of corporate content problems should
be added to the plant (site) number.
Unit of Measure: 1 per procedure affected by change request
Reporting Frequency: Monthly
Reason for Reporting: Tracked by monitoring Corrective Action Reports written and to identify
technical or functional deficiencies uncovered in approved procedures, this indicator ensures
that adequate, and accurate, reviews and approvals are occurring, before procedures are
released for use.
Calculation: Total Quantity per Month per Plant (site).
Note: For EUCG reporting, report the 12-month rolling average.

Diagnostic Title: Incoming Change Request Quantity

Definition: The total number of change requests received during the measurement period
Unit of Measure: 1 per procedure change request
Reporting Frequency: Monthly
Reason for Reporting: To provide an indicator of a healthy environment for continuous quality
improvement.
Calculation: Total number of change requests received the previous month
Note: For EUCG reporting, report the 12-month rolling average.
Procedure Process Diagnostic Measures (NOT Industrywide)

The following DIAGNOSTIC MEASURES are listed as useful indicators for assessing the
PROCEDURE PROCESS. The measures are provided and intended to be used as a menu of
possible analytical tools to be selected and used by PROCESS OWNERS when performing self-
assessments of the PROCEDURE PROCESSES. The expectation is that measures will be
selected based on the need of the organization. It is a good business practice to have a minimum
set of DIAGNOTIC MEASURES for each Level II PROCESS area. It is recognized that some
current systems may not support measurement of all the DIAGNOSTIC MEASURES suggested.

NOTE: One PROCEDURE CHANGE REQUEST may affect multiple PROCEDURES. For
the purposes of these DIAGNOSTIC MEASURES, each PROCEDURE requiring a change as
the result of the PROCEDURE CHANGE REQUEST will be counted individually.

Diagnostic Title: Completed Quantity

Definition: Number of procedure change requests closed
Unit of Measure: Quantity
Reporting Frequency: Monthly
Reason for Reporting: Ensures that processes within the procedure program are conducive to
execution of work.
Calculation: Count of procedure change requests closed
Note: Includes rejected procedure change requests.

Diagnostic Title: Refueling Outage Readiness

Definition: Refueling Outage procedure change request completion rates
Unit of Measure: Percentage
Reporting Frequency: Variable based on proximity to outage
Reason for Reporting: Indicates if procedure change requests are ready for the outage by the
established freeze date.
Calculation: (Number of Requests Completed / Number of Requests required for the outage)
times 100

Diagnostic Title: Online Readiness

Definition: Measure of the integration of the work planning process with the procedure change
request processes
Unit of Measure: Quantity
Reporting Frequency: Weekly
Reason for Reporting: To ensure procedures are ready to support scheduled surveillances,
maintenance, or plant modifications, e.g. T-4.
Calculation: Number of work orders on hold for procedure issues

Diagnostic Title: Customer Satisfaction

Definition: Measure of customer satisfaction with procedures and procedure-related processes
Unit of Measure: No quantitative values
Reporting Frequency: annually (self-assessment)
Reason for Reporting: To ensure procedures and procedure-related processes meet the needs
of the users.
Calculation: Self-assessment

Diagnostic Title: Total Backlog Quantity

Definition: Total quantity of uniquely identified and approved procedure change requests within
the single tracking system
Unit of Measure: 1 per procedure affected by change request
Reporting Frequency: Monthly
Reason for Reporting: A large backlog may be indicative of procedure change requests that are
not being completed in a timely manner. The increasing backlog challenges the ability to
perform proactive improvements.
Calculation: Total quantity

Diagnostic Title: Priority Backlog Percentage

Definition: Ratio of priority procedure change requests within the single tracking system as
compared to backlog quantity
Priority Procedure Change Requests are defined as:
 Procedure can not be used as written.
 Procedure works but has caused significant identifiable technical or functional
challenges.
 Any conditions adverse to quality.
Unit of Measure: 1 per procedure affected by change request
Reporting Frequency: Monthly
Reason for Reporting: Priority change requests are broken out because they represent actual
risk in the plant. A rising trend on these items may indicate insufficient attention on procedure
deficiencies. This indicator helps maintain a balance between priority change requests and other
activities that may draw the stations attention.
Calculation: Procedure Quality/Total Backlog Quantity times 100

Diagnostic Title: Average Age by Priority

Definition: Average age of approved change requests sorted by priority (typically 4 priority
levels)
Unit of Measure: Days
Reporting Frequency: Monthly
Reason for Reporting: Identifies the procedure requests are incorporated in a timely manner
Calculation: Total number of days for each change request / total number of change requests
 APPENDIX E
Reference and Cross-Reference List
The following documents and books were used as resource materials in the development of Revision 0 of
NEI-AP-907-001.

10CFR50 Appendix B, QA Criteria for Nuclear Power Plants and Fuel Processing Plants

10CRF71.113, Document Control

10CFR 73.55 (b).3, Requirements for Physical Protection of Licensed Activities in Nuclear Power
Reactors Against Radiological Sabotage

ANSI/ANS 3.2, Administrative Controls and QA for Operational Phase of Nuclear Power Plants

ANSI N18.7, Administrative Controls and QA for the Operational Phase of Nuclear Power Plants

Generic Letter 83-28 and Supplement, Required Actions Based On Generic Implications of Salem ATWS
(Anticipated Transient Without Scram) Events

IAEA-TECDOC-1058, Good Practices with Respect to the Development and Use of Nuclear Power Plant
Procedures

INPO 01-002, Guidelines for the Conduct of Operations at Nuclear Power Stations

INPO 90-021, Alarm Response Procedures (OP-217)

INPO AP-907, Processes and Procedures Process Description

INPO AP-931, Verification Practices Process Description

NEI AP-907, Information Management Process Description and Guideline

NEI/EUCG Report, Standard Nuclear Performance Model – a Process Management Approach, -

Revision 4
NSAC-105, Guidelines for Design and Procedure Changes in Nuclear Power Plants

NUREG/CR-1369, Procedure Evaluation Checklist for Maintenance, Test, and Calibration Procedures

NUREG/CR-3817, Development, Use, and Control of Maintenance Procedures in Nuclear Power Plants:
Problems and Recommendations

NUREG/CR-3968, Study of Operating Procedures in Nuclear Power Plants: Practices and Problems

NUREG/CR-4613, Evaluation of Nuclear Power Plant Operating Procedures Classifications and

Interfaces
NUREG-0737, Clarification of TMI-Requirements

NUREG-1358, Lessons Learned from the Special Inspection Program for Emergency Operating
Procedures

Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)

SOER 91-01, Conduct of Infrequently Performed Tests or Evolutions

SOER 92-1, Reducing the Occurrence of Plant Events Through Improved Human Performance
 APPENDIX F
Procedure Decision Tree
1.3

Is the activity
required by yes
Federal, State, Process in accordance
or local with NEI AP-907-001
regulatory
requirements?

no

Does the activity

affect the yes
availability of
systems,
structures, or
components? no Provide guidance using
other processes.
(Refer to App. G)

no

yes
Could the
activity affect yes no
Reactivity or
cause a Unit
Transient?

Does the activity

Did
yes have a past
management
history of
determine that
industry or plant
no a procedure is
performance
needed?
problems?

Does the
activity yes
potentially
affect safety
in an adverse
manner?
no

no
Is the activity
yes
unique or
performed
infrequently?

Does the activity,

if performed yes
incorrectly,
potentially
challenge plant
availability?

no
no

Is the activity
yes too complex to
Does the yes rely on memory,
activity general
challenge instructions, or
station ALARA previous
goals? training?

no

Is the activity yes no

determined to
be an Adverse
Risk activity?

Does the activity

yes involve multiple
tasks to be
no performed in a
specific
sequence?

Is the activity
required by a yes
Commitment for
which
documentation of
acceptance criteria
is required?
 APPENDIX G
Document Hierarchy
The following is a list of the types of documents used in the industry. Each utility establishes
their own hierarchy to describe the relationship of the documents they have selected for
controlling activities.

In this document, AP-907-001, defines PROCEDURE as a managed HUMAN

PERFORMANCE tool that specifies or describes how an activity is to be performed. Typical
examples of documents that may fall outside of this PROCESS are:

 Business Practice: A document that describes a PROCESS or provides direction that is

not required to be documented as a PROCEDURE.
 Charter: A document issued by an authorized authority, creating a committee such as a
Safety or ALARA committee and defining its privileges and purposes.
 Corporate Document: A document outlining the principles, functions, and organization
of a corporate body. It would not necessarily comply with Nuclear Division definitions.
 Deskguide: Guidance used by a group to standardize their function in a low LEVEL OF
DETAIL.
 Form: A document formatted to facilitate consistent collection of information and
controlled by document control. Note that computerized data collection is not a form
and is subject to revision via software control, not document control.
 Guideline: User generated work instructions outside the scope of the PROCEDURE
PROCESS (AP-907-001) and work management PROCESSES (AP-928).
 Handbook: Summary information produced to assist change management
communication plans.
 Instructions: Work Instructions as defined in AP-928.
 Operator Aid: Any posted information not controlled by an approved PROCEDURE
which is used to assist personnel in the operation of plant equipment and system.
 Policy (or Directive): An order or instruction, especially one issued by a central
authority, written to provide management expectations.
 Standing Order (or Directive): Issued by Operations to provide operating guidance for
a fixed period.
 APPENDIX H
History, Revisions and Maintenance of NEI-AP-907
In 1998, the Nuclear Energy Institute (NEI) published The Standard Nuclear Performance
Model – A Process Management Approach (SNPM) in cooperation with Institute of Nuclear
Power Operations (INPO), Electric Power Research Institute (EPRI) and Electric Utility Cost
Group (EUCG). This created a simple and effective set of processes to support an industry focus
on efficiency and CONTINUOUS IMPROVEMENT. The model has become the controlling
reference for all subsequent NEI benchmarking and is updated annually. The SNPM includes:

 INPO and NEI Process Descriptions

 An aligned set of activity based costing definitions for use in submission of cost data
to the EUCG
 An aligned set of industrywide key performance indicators (KPIs) consistent with
INPO guidance and supported by industry PROCESS OWNERS’ groups known as
Communities of Practice (CoP).

INPO-AP-907 Revision 0, “Processes and Procedures”, was originally published by the Institute
of Nuclear Power (INPO) in May 1997. In December 2001, the decision to transfer industry
ownership of AP-907, "Processes and Procedures” from INPO to NEI was agreed upon and
documented

In August 2002 the CoP known as the Nuclear INFORMATION MANAGEMENT Strategic
Leadership (NIMSL) steering committee was formed to enable leadership actions in the sub-
process area "SS003 - Provide Records Management and Document Control". In November
2002, NIMSL submitted to NEI a proposal to rename SS003 to “Provide INFORMATION
MANAGEMENT Services" to more accurately reflect the changing trends within the industry.
The SNPM Task Force agreed and the updated cost definition was included in the third revision
to the SNPM, dated April 2003.

NEI-AP-907 Revision 1 replaces INPO-AP-907 Revision 0 with a document focused on

INFORMATION MANAGEMENT (IM) and transfers responsibility for the IM PROCESS
Description from INPO to NEI. This aligns the process with the Standard Nuclear Performance
Model and develops content specific to INFORMATION MANAGEMENT activities.

The initial issue of INPO-AP-907 Revision 0, Processes and Procedures, will be renumbered to
NEI-AP-907-001 Revision 0.
NEI-AP-907-001 Revision 0 engaged the industry in a REVIEW of the document. Comments
and feedback were received from the following utilities and organizations:

 Absolute Consulting, Inc.

 AmerenUE
 American Electric Power
 Arizona Public Service
 Constellation Generation Group
 Dominion Generation
 Duke Energy
 Entergy
 FirstEnergy Corporation
 Ontario Power Generation
 Scientech, LLC
 STP Nuclear Operating Company
 TXU Power

The Nuclear INFORMATION MANAGEMENT Strategic Leadership Executive Committee will

periodically review and determine the need to revise this document based on input from plant
assist visits and self-assessments.