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Forwards Addl Info Re Crdr Implementation Plan,Per Suppl 1 to NUREG-0737 in Response to NRC 850523 & 860624 Concerns. Human Factors Consultant & Other Consultants Identified & Roles Discussed
	ML20203L406
Person / Time
Site:	Millstone
Issue date:	08/12/1986
From:	Willie Lee, Opeka J, Opeka W; NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Thadani A; Office of Nuclear Reactor Regulation
References
	RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.1, TASK-TM A02959, A04929, A2959, A4929, TAC-56139, NUDOCS 8608260174
	Download: ML20203L406 (31)
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P.O. box 270 H ARTFORD. CONNECTICUT 061410270 k k J $2,',C7.[,'cCI, (203J 665-5000 August 12,1986 Docket No. 50-336 A02959 A04929 Office of Nuclear Reactor Regulation Attn: Mr. Ashok C. Thadani, Director PWR Project Directorate //8 Division of PWR Licensing-B U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Control Room Design Review Implementation Plan Response to NRC Staff Comments On February 26,1985,(I) Northeast Nuclear Energy Company (NNECO) provided the NRC Staff with the Control Room Design Review (CRDR) Implementation Plan for Millstone Unit No. 2. The results of the NRC Staff's review of the CRDR Implementation Plan for Millstone Unit No. 2 were provided to NNECO on May 23,1985.(2) The NRC Staff indicated that the CRDR Implementation. Plan was generally acceptable, however, the NRC Staff identified some areas where additional clarifying information was necessary. In addition, the NR'C Staff stated that NNECO would be contacted in the near future regarding a meeting to discuss these items.

At the time of receipt of the NRC Staff's May 23, 1935 letter, NNECO was also conducting a CRDR for Millstone Unit No. 3. Similar NRC Staff concerns existed on behalf of Millstone Unit No. 3 and a meeting was initially scheduled to discuss both the Millstone Unit No. 2 and No. 3 items simultaneously since the NRC Staff technical reviewer was the same person for both units. Subsequently, it was decided that Millstone Unit No. 3 concerns should be addressed first and any remaining Millstone Unit No. 2 concerns would be addressed at a later time.

The NRC Staff found in Supplement No. I to the Millstone Unit No. 3 Safety Evaluation Report that the CRDR for Millstone Unit No. 3 was acceptable, except for the four items identified in that Supplement. A meeting was held on July IS,1985 with the NRC Staff to discuss these four items. A summary of the 8608260174 860812 PDR ADOCK 05000336 P PDR (1) W.G.Counsit letter to 3.R. Miller, " Supplement I to NUREG 0737, Control Room Design Review Implementation Plan", dated February 26,1985.

(2) E.G.Tourigny letter to 3.F.Opeka, " Detailed Control Room Design Review 993 Program Plan for Millstone Unit 2," dated May 23,1985. F 1i

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l i information provided to the NRC Staff at that meeting for each of the four ;

items was submitted on August 13, 1985.(3) Additional information regardigg i these four open items was provided to the NRC Staff on September 12,1985,W

[ as part of Addendum No. I to the CRDR Summary Report for Millstone Unit No.3. Based upon the NRC Staff's review of these submittals, a subsequent ,

l meeting was held on October 17, 1985 between the NRC Staff and j representatives of NNECO. Information provided to the NRC Staff at this meeting adequately was documented on resolved remaining)NRC October 28,1985.U TheseStaff four concerns.

open itemsSuch wereinformation closed out

by the NRC Staff in Supplement No. 4 to the Safety Evaluation Report for Millstone Unit No. 3.

As a result of the closure of those items for Millstone Unit No. 3, it was

.l determined that additional meetings to resolve similar Millstone Unit No. 2 NRC q

Staff concerns were no longer necessary. Although a formal response to the May 23, 1985 letter was not requested, NNECO judged it appropriate to formally ,

document responses to the NRC Staff concerns delineated in the May 23, 1985 '

letter. A draft response had been prepared during the early part of 1986. Due to a new NRC Staff Project Manager and technical reviewer for Millstone Unit No.

2, it became appropriate to further discuss the status of these items, and our 1 draft response was discussed with the NRC Staff on June 24, 1986. The purpose !

of this submittal is to document our responses to the NRC Staff concerns I identified in the May 23, 1985 letter as modified to reflect discussions with the )

NRC Staff on June 24,1986. ,

, On December 10, 1985,(6) we responded to a NRC Staff concern identified as j part of their review of the Millstone Unit No. 2 Emergency Operating Procedures Generation Package (PGP) and pertaining to the identification of the operator's information and control needs. Although similar Information will be provided in 4 the CRDR Summary Report for Millstone Unit No. 2, we believe adequate I

information is contained in this submittal to assist the NRC Staff in resolving

that item. On a related matter, it is important to note that the CRDR is being ;

! performed based on the existing upgraded Emergency Operating Procedures j (EOPs) for Millstone Unit No. 2. Concerns related to the preparation of the

EOPs in the NRC Staff's May 23, 1985 letter have been previously addressed l during the NRC Staff's review of the PGP for Millstone Unit No. 2.

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! (3) 3.F.Opeka letter to B.3.Youngblood, " Supplement I to NUREG-0737, l Control Room Design Review," dated August 13,1985.

l (4) 3.F.Opeka letter to B.3.Youngblood, " Supplement I to NUREG-0737, Control Room Design Review, Addendum No. I to the Summary Report,"

dated September 12,1985.

l (5) 3.F.Opeka letter to B.3.Youngblood, " Supplement I to NUREG-0737, Control Room Design Review," dated October 28,1985.

(6) 3. F. Opeka letter to A. C. Thadani, " Supplement I to NUREG-0737, Emergency Operating Procedures Generation Package," dated December 10,1985.

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'We believe that the attached information is responsive to the NRC Staff concerns. Should you have any questions, please contact us.

Very truly yours, &

NORTHEAST NUCLEAR ENERGY COMPANY 3 Q Opeka v Sen)ior Vice President

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By: W. F. Fee Executive Vice President I

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i Docket No. 50-336 Attachment 1 Millstone Nuc19ar Power Station, Unit No. 2 Control Room Design Review Implementation Plan Response to NRC Staff Comments August,1986

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RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE MILLSTONE UNIT NO. 2 CRDR IMPLEMENTATION PLAN REVIEW TEAM The qualifications and multidisciplinary nature of the review team seem good.

However, the Program Plan should include the following:

Item 1: Identify the human factors consultant and his role and the identities and expertise of other consultants.

Response

Since the initial submittal of the Millstone Unit No. 2 CRDR Implementation Plan, an internal reorganization of personnel has occurred within the Northeast Utilities Service Company (NUSCO) organization. In addition, with the completion of the Millstone Unit No. 3 CRDR, experienced personnel have 1

become available to participate in the Millstone Unit No. 2 review. Personnel changes are discussed below.

Mr. W. C. Mission, project engineer for the Millstone Unit No. 3 CRDR, will replace Mr. Z. Ufnal as project engineer for the Millstone Unit No. 2 review.

Mr. Mission is a consultant who will provide architect-engineer expertise. His resume is provided in Attachment 2. Mr. R. K. McCarthy has replaced Mr. Ufnal as the controls engineer on the core team and will represent the controls discipline on the core team. Mr. McCarthy's resume is also included in Attachment 2. Mr. R. Sabeh is a consultant that will assist Mr. A. M. Stave on the core team as a human factors specialist. Mr. Sabeh's resume is provided in Attachment 2. No other consultants are planned for the CRDR core team or support group.

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Item 2: Identify the person (s) responsible for the final approval and sign-off of HED resolutions.

Response

The Program Manager, Mr. T. A. Shaffer, is responsible for signing and approving the HED resolutions. With his approval, the HED resolutions become the recommendations of the review team to upper management for final review and implementation, in accordance with our procedures.

Item 3: Explain the exclusion of a nuclear engineer from the Core Review Team.

Response

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l Mr. T. 3. Honan has been added to the discipline support group for the CRDR.

Mr. Honan will serve as the nuclear engineer for the group. Experience gained ,

from the Millstone Unit No. 3 CRDR disclosed that the presence of a nuclear engineer as a full-time member of the core team was not required. The nuclear engineer shall remain immediately available for consultation on any item concerning his discipline during the review.

Item 4: Detail the levels of efforts of the CRDR participants.

Response

The level of effort of the CRDR participants can best be detailed by explaining the function of the core team. The core team will participate in the review as a unit with each member providing his expertise. The team participates in all

phases of the review, from investigation through reporting, with each member involved in such activities as assessment, prioritization, correction, etc.

Individual tasks may be assigned to each participant, depending upon his expertise, with the results of the task being reviewed by the whole core team.

Consequently, the time required of the members of the core team is quite extensive. During the Millstone Unit No. 3 CRDR, it was apparent that full-time participation of the nuclear engineer and the training specialist on the core team was not required. Supplementing this core team as needed are other disciplines including mechanical, electrical, instrumentation and nuclear reactor engineering, computer operations, and licensing. All members of the discipline support group are immediately available when consultation is desired or necessary. During the course of the review, any additional specialist (e.g.,

lighting, acoustics, etc.) required for specific tasks are made available.

Item 5: Provide details regarding the methods and duration of instruction during the review team orientation.

Response

A course in human factors fundamentals was provided for all members of the core team and was conducted by the human factors member, Mr. A. Stave. The duration of the course was four (4) hours and included a review of the causes of human error, the recognition of potential human error situations and the types of changes that reduce the chances for human errors.

Orientation for plant familiarization was available for the human factors members of the core team. The other members of the core team were knowledgeable about the plant and its systems as a result of their normal working assignments. A 2-day orientation was conducted by the Millstone Unit No. 2 Training Department under the direction of Mr. M. Wilson, the training participant of the review team. The objectives of the orientation course were to:

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a. Understand the purpose of the systems on each panel in the control room;

b. Understand the major flow paths of each system, given a

diagram or using the control board mimic as a guide; and

c. Understand the major components (controls and indications) located on the control boards or panels.

FUNCTION AND TASK ANALYSIS The Program Plan lacks sufficient, detailed information regarding the proposed Function and Task Analysis for an adequate evaluation of this activity.

l The following should be addressed by NNECO:

Item 1: What specific event scenarios will be covered by the CEOG EPGs?

Response

The Combustion Engineering Owners' Group (CEOG) Emergency Procedures Guidelines (EPGs) were used to write the upgraded Millstone Unit No. 2 Emergency Operating Procedures (EOPs). The scenarios to be reviewed in the task analysis phase are those scenarios addressed in the Millstone Unit No. 2 Emergency Operating Procedures. In addition, Abnormal Operating Procedures 2551, Shutdown From Outside the Control Room; 2552, Cooldown From Outside the Control Room; 2553, Natural Circulation Cooldown From Outside the Control Room; and 2559 for a fire in the Control Room will be reviewed.

Item 2: The personnel and their qualifications involved in identifying and analyzing deviations from the CEOG EPGs.

Response

The CEOG Emergency Procedure Guidelines (EPGs) were developed to satisfy item I.C.1 of NUREG-0737. On August 29,1984, the Combustion Engineering Owners' Group (CEOG) and the NRC agreed that the CEOG EPGs constitute an adequate function analysis for emergency operations. The EPGs provide the basis for the Emergency Operating Procedures (EOPs) and the specific event scenarios needed for the task analysis of the CRDR.

As a result of the agreement between the NRC and the CEOG, a second task was undertaken. The task was designed to support the CRDR at CE plants by developing generic information and control requirements with their characteristics. The results of this task are contained in CE-NPSD-299, which provides the methodology and the information and control requirements to perform a task analysis based upon the emergency operating procedures.

On September 6,1985, CEN-307, "CE Owners' Group Generic Information Characteristics Review" was submitted for NRC review. This report gives a thorough description of the model and method employed in conducting the generic task analysis, including the generic operating information and control characteristics requirements. The task analysis phase of the Millstone Unit No. 2 CRDR was revised to take advantage of the work performed by the CEOG.

Combustion Engineering has converted the generic operator information and control requirements to plant-specific requirements for Millstone Unit No. 2.

The personnel involved in identifying the deviations from the generic EPGs are the same as those who developed the generic guidelines, CE-NPSD-299. Their qualifications are available as part of the information provided with the submittal of CEN-307.

Item 3: The task analysis methodology used to identify para-meters and other information and control needs.

Response

The methodology to be used to determine the deviations and plant-specific requirements will be the same as used for the development of the generic guidelines (reference CEN-307). Figure 6.1 of CEN-307 provides the generic to plant-specific conversion process to be used. This conversion was performed independent of the instruments or controls installed on the Millstone Unit No. 2 control panels or the inventory of this equipment.

Item 4: The Task Data Forms lack the necessary space for record-ing information and control requirements resulting from the Function and Task Analysis.

Response

As stated in the CRDR Implementation Plan, the methodology for performing the CRDR Task Analysis will be similar to that performed for Millstone Unit No.3. Revisions to the task analysis methodology and forms have been made based on experience gained during the Millstone Unit No. 3 review.

The Task Sequence Chart (Figure 7 of the Implementation Plan) has been eliminated. The Task Data Form (TDF) has been revised. The individual operator tasks required to accomplish the current step of the EOP will be documented in the requirements section of the task data form. Examples of this will be included in the CRDR Summary Report.

When all steps of a procedure are recorded on TDFs, the core team will walk through the operator tasks on the forms. During this phase, the specific instruments and controls used to perform the task will be recorded on the forms in the Plant Equipment Used column. At the same time, the core team will review the task and the equipment used for its human suitability. Tasks and equipment that do not meet the guidelines of NUREG-0700 will be documented i as a HED. Missing information or control equipment needed to satisfy the l

l requirements will also be recorded as a HED.

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Upon completion of the plant-specific information and control requirements, Combustion Engineering will generate a' Consolidated Report for Millstone Unit No. 2. The Consolidated Report will list all of the necessary characteristics for each information and control requirement (e.g., range, resolution, availability, reaction time, etc.). With all of the characteristics compiled, the required characteristics are then available for comparison with the Millstone Unit No. 2 instruments and controls. This comparison will be performed by the core team by adding to the list the instrument or control used to satisfy the requirement along with its actual characteristics. HEDs will be produced from this comparison for those situations where instrumentation and control needs are not adequately addressed.

The process of consolidating the required characteristics allows one walk-l through instead of repeating the comparison for each procedural step that uses the instrument or control.

i COMPARISON OF DISPLAY AND CONTROL REQUIREMENTS WITH A

. CONTROL ROOM INVENTORY Item 1: The methodology described by NNECO appears adequate.

, However, the success of this activity depends upon the adequacy of the Task Analysis.

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Response

i i No response to this statement is necessary.

Item 2: The verification of corrections appears to occur prior to the HED assessment and resolution activities, i

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Response t

See the response to the item listed under the " Verification of Design Improvements" category and the corrected schedule attachment.

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, CONTROL ROOM SURVEY The control room survey appears acceptable, but the discussion of the control room survey should address the following concerns:

Item 1: Use of other guidelines besides NUREG-0700.

Response

The control room survey for the Millstone Unit No. 2 CRDR will be performed by utilization of the checklists provided in Section 6 of NUREG-0700. Other guidelines, such as NUTAC documents, MIL Standards, etc. were used as supplemental information only. In all cases, the guidelines of NUREG-0700 will have precedence.

Item 2: Human factors staffing and their role in the survey.

Response

i The control room survey will be administered by the two human factors specialists, with assistance as necessary by other core team members.

Item 3: " Classification" in reference to documenting core team member opinions.

! Response Some degree of assessment (or classification) will occur during the control room survey, i.e., obviously necessary corrections will be noted. Any core team member can document opinions concerning the existence of a potential HED, I

which may be in conflict with the opinion of the majority of the team; however,

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_9 any comments of this nature will be reviewed by the full core team during the assessment phase of the review.

Item 4: Means for addressing all dynamic criteria in NUREG-0700 (and other guidelines).

Response

A matrix has been developed to assign all of the items of Section 6 of NUREG-0700 to their appropriate phase of the review (i.e., Operating Experience Review (OER), Control Room Survey (CRS), and Task Analysis (TA).

In many cases, an alternative phase has been listed to provide the team with the option of obtaining data from more than one source. For most of the dynamic

type criteria, the OER was signified as the preferred or primary source of obtaining the data. These dynamic criteria have been included in the Operators Questionnaire or during the interviews which are to follow. A portion of this matrix is attached.

ASSESSMENT OF HEDS Item: The description of the HED assessment lacks detailed information, and as outlined, does not meet the require-ments of Supplement I to NUREG-0737 for the reasons detailed in the attached report. In addition, it appears from Figure 6 of the Program Plan that the assessment activity which evaluates the HEDs ends before the Task Analysis has been completed and the resultant HEDs identified.

Response

There are seven (7) concerns addressed specifically in the report prepared by the

NRC Staff's consultant, SAIC, regarding the assessment phase of the Implementation Plan. The following discussion addresses each of those concerns; however, it is important to note that the assessment phase methodology used in l

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) Millstone Unit No. 3 CRDR, which has been accepted by the NRC Staff f (reference Supplements 1 and 4 to the Millstone Unit No. 3 Safety Evaluation Report). !

Concerns 1 and 2: The Structure and Content of the Four Categories and Assignment Methodology The four (4) categories of priorities are the same as those used for the Millstone Unit No. 3 CRDR and, with one change, they have been reviewed and accepted i

l by the NRC Staff. This change is discussed under Priority 3 (Minor Consequence) 4 in the following summaries.

Priority 1 (safety significant) is the priority that will be assigned to most HEDs found during task analysis because the EOPs are being reviewed in the task analysis. In addition, with the completion of the plant-specific information and ,

control documentation, an inventory is produced of all the emergency instruments and controls. This documentation will be collated by the data base I

management system into an alphanumeric listing (inventory) of emergency i instruments and controls. Any HED involving one of these devices found in the OER or CRS will be apparent to the core team as an emergency device and will normally be placed in a Priority I category as well. In addition, a computerized .

master file of HEDs will be created for comparison with the emergency equipment inventory. This sorting of HEDs will allow the core team to identify all HEDs applicable to a particular instrument and/or control and obtain the I source.

l Not all HEDs found during the task analysis will be assigned a Priority 1. For example, during the Millstone Unit No. 3 review, a HED was written which stated that the background color of the auxiliary shutdown panel was different f than the main control boards. The HED was dispositioned as non-significant; the HED was assigned a Priority 4, although it involved a safety panel, because it did not adversely affect the performance of emergency operations.

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c 1 Priority 2 (operational / reliability) is the category for HEDs which have caused problems or could cause a problem during operation. If this problem occurs during emergency operations or involves an instrument or control on the emergency inventory, it would be assigned a Priority I category. A problem is defined as an incident involving control room equipment that has or could cause an operator undue hardship in performing his task from a human factors aspect.

Every HED is a potential problem. For this reason, we anticipate that the HEDs assigned to this category will probably result from the OER or the CRS. A HED in this category is still considered significant, as stated in the guidance of NUREG-0300, but is not necessarily a safety concern.

Priority 3 (minor consequence) was revised during our Millstone Unit No. 3 review and has been revised for this review also. Priority 3 HEDs are now defined as HEDs that can be determined to have minor effect on the reliability of operations. Priority 3 HEDs are not safety significant. HEDs placed in this category and the Priority 4 category (no consequence) are those judged by the core team to be as stated in the explanation of the categories. As an example, a HED written against a device which provides demand feedback rather than status feedback may be designated as Priority 3. If supplemental status feedback is provided, the consequence of the HED will not impact emergency operations, and will have a minor effect on the reliability of such operations. For example, a HED involving a pump light which indicates demand for the pump would be of minor consequence if a flow meter was available for use by the operator in restarting the pump.

Finally, the methodology for assigning HEDs to these priorities is as stated in the explanation of each priority. The core team will examine each HED for their relationship to these explanations and assign the appropriate priority to them.

Concerns 3,4, and 5: The Triage The Triage approach has been fully discussed, reviewed, and approved by the NRC Staff in their review of the Millstone Unit No. 3 CRDR. The following is a brief address of concerns related to the triage assessment.

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Triage is a medical term for the separation of the severely wounded from the less severe. In the case of the CRDR, a triage approach is needed to enable the core team to accomplish the extensive amount of work involved in assessing 500 to 1,000 HEDs. This method was successfully used in the Millstone Unit No. 3 CRDR. The answers to the questions in the triage assessment are based on the judgment of the core team. The triage approach does not ignore the significance of operator performance in the assessment of HEDs. On the contrary, the operational characteristics of each HED are considered in answering the questions of the triage assessment. The operational and safety significance of each HED is a fundamental consideratien in the evaluation of each question in the assessment. Therefore, no specific question addressing operation and safety is necessary, i

If the resolution of an HED is obvious (e.g., correct the spelling of a label), the triage approach allows the core team to recognize that solution. As a result, the core team can then concentrate its energies on the HEDs that require in-depth consideration. The key to triage is the determination of whether the HED i requires further study and assessment. If so, the HED will be further reviewed upon completion of the triage. It should be noted that the triage approach does not represent the ultimate assessment of HEDs, but rather is a screening process employed to facilitate the processing of HEDS.

Concern 6: Tie Breaker Ratings Concern was expressed about the lack of functional meaning for the I to 10 significance ratings. The significance ratings represent tie breaker criteria that were introduced to establish the significance of a HED, thereby assisting in the resolution of core team judgmental differences. Such tie breaker criteria were not needed during the Millstone Unit No. 3 CRDR, so the criteria were i eliminated. The tie breaker criteria will be deleted from the Millstone Unit T

No. 2 CRDR.

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j Concern 7: Schedule See the response to the item listed under the " Verification of Design Improvements" category.

i SELECTION OF DESIGN IMPROVEMENTS j Item: The Program Plan provides a listing of a variety of ways for selecting design improvements. NNECO should iden-tify and submit to the NRC for review which methodology

will be used in the selection of design improvements, as l well as the criteria upon which NU management will base i its decisions for approval.

Response

, The method for selection of design improvements for Millstone Unit No. 2 is the 2

- same as the methodology used in the Millstone Unit No. 3 review. This

} methodology was found acceptable by the NRC Staff in Supplements I and 4 to

the Millstone Unit No. 3 Safety Evaluation Report. This methodology is summarized below.

i When selecting a design improvement to resolve a HED, the following items are considered by the core team, with each discipline providing their respective inputs:

l. Which category of resolution h applicable?

, 2. Will the suggested design improvement enhance operability?

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) 3. Will the suggested design improvement introduce new HEDs?

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4. Does the suggested design improvement stand a reasonable chance of surviving the scrutiny of the verification process?

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5. Is the suggested design improvement consistent with plant operating philosophy?

6. Is the suggested design improvement technically feasible?

7. Does the improvement meet NUREG-0700 guidelines?

3. Is the design improvement possible utilizing standard plant components?

This process is dynamic in nature and is accomplished by the cooperative efforts of the core team members with each member contributing their respective discipline knowledge. Where other discipline inputs are needed, they are provided by the identified discipline support organizations.

VERIFICATION OF DESIGN IMPROVEMENTS Item 1: The verification process for corrections appears to occur prior to the HED assessment and resolution activities.

Response

The verification process was not reflected in Figure 6 of our February 26,1985 submittal. Figure 6 has been revised to reflect this information and is attached.

The verification process, although an ongoing effort, is primarily accomplished during the corrections phase of the review.

Item 2: The Program Plan does not address the methodology and criteria of verifying that design improvements provide the necessary correction and do not introduce new HEDs.

Response

The discussion of the Millstone Unit No. 2 verification process was inadvertently ommitted from the Implementation Plan. The verification process for Millstone

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Unit No. 2 will be implemented using the Millstone Unit No. 3 methodology as stated in Addendum No. I to the CRDR Summary Report for Millstone Unit No. 3, which has been accepted as in compliance with Supplement I to NUREG-7 0737.

The verification activity is an integral part of the correction phase. As the class and individual improvements are being selected, they will first be implemented, whenever practical, on the full-scale control room mock-up for review and approval by the core team. This review and approval will be by inspection or by rewalking the operator's task when applicable. An important part of the approval is to verify that each corrective action resolved ' the HED in question and does not introduce a new HED. Those of a nature unsuitable for implementation on the mock-up (e.g., computer software, circuit modifications, e tc.) will be reviewed and verified on the control boards as they are implemented.

For any enhancement, class improvement, or discrepancy design that is warranted, it will be performed in the same manner as was done for Millstone Unit No. 3. Namely, it will be conceived by the cqre team utilizing the expertise of the A/E discipline on scale drawings. These drawings will then be reviewed by all members of the core team as well as the operators of the plant. The comments received will then be incorporated on the drawings and resubmitted to all for final comment. The corrections are then installed on the full scale mock-up for verification of the design by the core team. Once the verification is completed, the design beccmes an integral part of the CRDR with recommendations for implementation on the actual control boards.

COORDINATION WITH OTHER PROGRAMS Item: The coordination of activities as described in the Program Plan is acceptable. However, NNECO does not identify who is responsible for the integration of changes and what mechanism is available to process these changes.

n Response .

Implementation of Supplement 1 of NUREG-0737 necessitates the integration of control room improvements with certain other post-TMI activities. Specifically, these activities are:

o Emergency Operating Procedures (EOPs);

o Regulatory Guide 1.97 Provisions (R.G.1.97);

o Safety Parameter Display System (SPDS); and o Emergency Response Facilities.

Integration of these post-TMI activities occurs naturally within the framework of our organization due to the overlapping nature of depar: mental and individual responsibilities for such activities. However, the Manager of Generation Projects is responsible for assuring the coordination of all CRDR activities with those other post-TMI activities described above. The Manager of Generation Projects assures that affected disciplines and individuals are aware of the status of the various post-TMI activities by holding periodic meetings to discuss the status of these activities and promotes effective communication within our organization. Further, correspondence between the NRC Staff and our organization is disseminated by our Generation Facilities Licensing group to disciplines and individuals involved in the above post-TMI activities. This effort provides additional assurance that incoming and outgoing correspondence receive a comprehensive review.

A part of the integration will occur during the walk-through or verification stage of the task analysis as recommended in Supplement 1. The CRDR team includes personnel involved with certain aspects of the Supplement I to NUREG-0737 activities including the operations representative involved with the writing of the upgraded EOPs and the Human Factors specialist involved with the development of the SPDS. During the assessment and correction phases of the

CRDR, disciplines involved with other facets of Supplement I will supplement the core team in the resolution of HEDs.

Any hardware modifications or enhancement resolutions will 'n rerified by an additional walk-through by the core team with a subsequent verification to be accomplished by having operators perform a walk-through on the full scale I mock-up. Upon satisfactorily completing this phase, the task analysis documentation will assist the Operations Department in modifying, if necessary, the plant-specific EOPs.

Also as part of the CRDR, the control room instruments that are intended for use under accident conditions will be reviewed and where necessary, appropriately highlighted, to enable the operators to easily identify them, as requested by Regulatory Guide 1.97.

In summary, the resolution of HEDs (integrating all inputs from Supplement I to NUREG-0737 activities) could include:

o Plant Process Computer /SPDS display additions; o Training to enhance operators' cognitive analysis; o Requirements of additional or modified staffing; o Utilization of Regulatory Guide 1.97 instrumentation; o Modification of specific EOPs; and o Control board additions / deletions / enhancements.

NNECO believes that the coordination mechanism described above provides adequate assurance that coordination activities will be successfully accomplished.

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MILLSTONE UNIT 2 (MP2) ,

l DETAILED CONTROL ROOM DESIGN REVIEW CitITEltlA MATRIX 6.1 Control Room Workspace NUREG-0700 DATA COLLECTION COMMENTS / REFERENCE METIIOn 6.1.1 General Layout OER CRS TA 6.1.1.1 Accessibility of Instrument S S P 6.L.l.1 a & bi Equipment Related to 6.5.1.1 a 6.1.1.2 Consistensy of Manning with S S P 6.1.1.2 b:

Equipment Layout OER/CRS maybe primary source for this item 6.1.1.3 Furniture and Equipnient Layout S P 6.1.1.3 as Related to 6.7.2.3 i 6.1.1.4 Document Organization and Storage S P 6.1.1.4 a(1) : -

Related to 6.7.1.8 a(l) 6.1.1.5 Spare Parts, Operating Expendables S P and Tools 6.1.1.5 b & c Related to 6.5.4.1 e

- P refers to Pr$ nary Source for obtaining data S refers to Secondary Source for obtaimng data

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Docket No. 50-336 Attachment 2 Millstone Nuclear Power Station, Unit No. 2 Personnel Resumes - Core Team Members August,1986

i-WALTER C. MISSION EDUCATION:

1951 Graduate of Architectural Engineering from Wentworth Institute, Boston, Massachusetts, Associate Degree Level

SUMMARY

OF EXPERIENCE:

1983 - Present Northeast Utilities Service Company and Nuclear Consultant, Project Eng. - Millstone Unit 3 CRDR.

1974 - 1983 Northeast Utilities Service Company, Berlin, CT, Generation Electrical Engineering.

Generation Specialist, Controls Group.

Responsible for providing design and installation services for all power plants, predominantly the four nuclear units.

1967 - 1973 Communications Manager, Administration Department, Northeast Utilities (merger of HELCO, CL&P, and WMECO).

Responsible for the coordination of all telecommunications for the system companies.

1957 - 1967 The Hartford Electric Light Company (HELCO), Electrical Engineering Department.

Responsible for performing the engineering for substation and fossil power plant installations.

1951 - 1959 Marchant & Minges, Consulting Engineers, West Hartford, CT.

Design Engineer.

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e = .

ROBERT KARL McCARTHY

SUMMARY

OF EXPERIENCE:

1978 - Present Northeast Utilities Service Company, Berlin, CT, Generation Electrical Engineering - Generation Engineering Specialist.

Assignment of Project Engineering responsibilities for Nuclear, Fossil and Hydro plant, backfit and betterment projects.

Responsible for:

- Development of logic, loop, schematic diagrams and instrumentation installation details.

Preparation of plant design change reauests and associated job packages required for implementation.

Provisions of on site coverage / supervision of safety and non-safety related equipment installation.

Provision of technical support and information for various NRC submittals. Assignment to. Connecticut Yankee I&C shop for outage assistance.

Assignment to Millstone Unit No. 3 Project group to provide I&C assistance and direct the implementation of CRDR deficiency resolutions at Millstone Unit No. 3.

The specification, procurement and installation of a solid state control house for the Middletown Station gas turbine.

Performance of independent design verifications for discipline-related category IE plant design changes.

- Performance of human engineering reviews of changes to the Haddam Neck Plant, Millstone Unit No. I and Millstone Unit No. 2 main control boards.

Assigned as:

I&C representative for Millstone Unit No. 3 Engineering Assurance Audit Team.

Core Team Member for NUREG-0700 Control Room Design Review of the Haddam Neck Plant, Millstone Unit No. I and Millstone Unit No. 2.

c. . e ,

ROBERT KARL McCARTHY Page 2

SUMMARY

OF EXPERIENCE (Continued):

Major Project Engineering Assignments include:

- Haddam Neck Plant Auxiliary Feedwater Flow Indication.

Replacement of Middletown Jet Control Room.

- Millstone Unit No.1 Replacement of RX Building Limit Switches.

Installation of Env. Qual. Limit Switches & Solenoid Valves on Millstone Unit No. 2 Containment Isolation Valves.

- Haddam Neck Plant Automatic Initiation of Auxiliary Feedwater.

- Millstone Unit No. 2 Automatic Initiation of Auxiliary Feedwater (AC Independence).

1/78 - 7/78 Nuclear Manpower Corporation Millstone Unit No. 1 -

Engineering Technician.

Assisted plant engineering personnel in preparation of outage-related Plant Design Change Requests job packages, product acceptance test procedures, installation procedures, drawing revisions and plant /craf t liaison. Assigned as shift coverage supervisor for. fuel pool cleanup and cask handling and assisted Unit 1 I&C on off-gas system H2 monitoring.

8/77 - 1/78 Nuclear Manpower Corp., Boston Edison Company, Pilgrim Unit I Station - Dosimetry Specialist.

Provided on-site readout of thermo-luminescent radiation detectors; assisted in daily update of personnel expos 0re records, completion of NRC form 4's, personnel termination exposure history, and total radiation assessment program.

Yankee Atomic TRAP II System.

1971 - 1977 Military Schools - United States Navy Basic electricity and electronics school Electricians mate "A" school Nuclear Power School Nuclear Prototype - SIC Sound and Vibration Analysis School l Magnetic Amplifier School l

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ROBERT KARL McCARTHY Page 3

SUMMARY

EXPERIENCE (Continued):

Military Experience:

Participated in two ship's power plant overhaul and reactor refueling at Electric Boat Company.

Qualified as shutdown reactor plant operator, electrical plant operator and propulsion plant operator. Completed 85% of engineering watch supervisor qualification.

Performed routine and corrective maintenance and testing on the reactor, electrical, propulsion and auxiliary plant control systems.

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RAYMOND SABEH EDUCATION:

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PH.D (Candidate), Experimental Psychology, Ohio State University (1955)

M.A. Industrial Psychology, Ohio University (1950)

B.S. General Psychology, Davis and Elkins College (1949)

SUMMARY

OF EXPERIENCE:

2/85 - Present Northeast Utilities Consultant. Responsible to provide support to: the Millstone Unit No. 3 ERIS/SPDS Project in the human factors area to assist in display development (Phase II), OFIS reviews, and verification and validation, the Millstone Unit No. 3 CRDR project in the human factors area in accordance with the CRDR project plan, Millstone Unit No. 2 and Haddam Neck in the CRDR projects in the human factors area as required and directed by NUSCO and the operating plants.

Work to include review of programs, human error events, PDCR procedures, human reliability, etc. In addition to the above, provided human factors support to the Millstone Unit No. 3 SPDS Man-in-the-Loop Validation test program.

2/83 - Present Consultant for Torrey Pines Technology. Responsible for developing and conducting the Operation Personnel Questionnaire, the Interviews and the Control Room Survey to conform with NUREG-0700 Guidelines for the Pilgrim, Kewaunee, Indian Point #2 and Clinton Nuclear Stations.

Participated in the Human Factors Survey of the Emergency Response Facilities for Kewaunee.

Responsible for special studies and operations personnel validation via operator questionnaire interview evaluations for the Palo Verde Plants. In addition, responsible for conducting a Human Factors review of the Palo Verde Safety Parameter Display System in conformance with NUREG-0700 and NUREG-0835 and the environmental survey of Palo Verde.

In all of the above, participated or will participate as a non-voting member of assessment and implementation team. .

11/81 - 2/83 Senior Scientist for Northeast Utilities. Responsible for preparing and implementing the human factors portion of the NUREG-0700 plan for three NU nuclear operating plants and a fourth NTOL plant. Served as the human factors team member on the NU Safety Parameter Display System (SPDS) program that was to be designed, developed, and implemented for a consortium of some 10 separate utility plants. Prepared Human Factors Engineering Orientation Course material used for instructing nuclear engineers and reactor operators.

v o - .

RAYMOND SABEH Page 2

SUMMARY

OF EXPERIENCE (Continued):

While at Northeast Utilities - served as project leader and carried out nuclear operations analysis assignments concerning nuclear regulatory requirements to conduct human factors study, analysis and review of all activities affecting man-

, machine power plant design and operation. In this capacity was appointed as subcommittee chairman to technically monitor and direct the Westinghouse Corporation's efforts for developing a generic system function and task analysis on their PWR plants under contract to Westinghouse Owner's Group.

6/81 - 9/81 Consultant. Responsible for human factors design of a control center for the storage and retrieval of nuclear waste.

The above directly related nuclear power plant experience was acquired from June 1981 to the present. Prior to the nuclear power plant experience, the work history includes some 27 years with civil service as a Human Factors Engineer or Engineer Psychologist. The human factors effort was in research, design and development directly applicable to command, control and communications centers. Results of this effort have been documented in some 29 government publications. The locations of the civil service and commercial experience include:

o Aero Medical Laboratory, Wright-Patterson AFB, Ohio, March 1951 thru April 1955 (Engineering Psychologist).

o Human Factors Laboratory, Rome Air Development Center, New York, April 1955 thru December 1960.

(Engineering Psychologist).

o Electronic Systems Command, Hanscomb Field, Mass.,

December 1960 thru June 1963. (Supervisory Human Factors Engineer).

o National Military Command Center, Defense Communications Agency, Virginia, June 1963 thru Suly 1970. Command Control Specialist (Human Factors).

o Human Factors Laboratory, Naval Ocean Systems Center, CA, July 1970 thru August 1977. (Supervisory Human Factors Engineer).

o Systems Exploration incorporated, San Diego, CA, August 1977 thru November 1981. (Manager Human Factors Engineer).

1

OS RAYMOND SABEH Page 3 PROFESSIONAL ASSOCIATIONS American Nuclear Society

. Human Factors Society Operations Reserach Society of America National Academy of Sciences Armed Forces-NTD Committee on Vision Southwest Regional Director, Society for Information Displays PUBLICATIONS Review of the Safety Parameters Display System for Palo Verde, Torrey Pines Technology, GA-C17368, November 1983.

Human Factor Review of the Palo Verde ERFDADS Terminal CRT Display and the ESFAS Annunciator Window Box, Torrey Pines Technology, JGA-C17154, June 1983.

Control Room Operator Personnel Survey for Palo Verde Nuclear Generating Station, Torrey Pines Technology, GA-C17155, June 1983.

Human Factors Review of the Foxboro 250 Series Indicators and Controllers for Palo Verde, Torrey Pines Technology GA-C17072, May 1983.

Human Factors Engineering Orientation, Northeast Utilities, October, 1982.

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P.O. box 270 H ARTFORD. CONNECTICUT 061410270 k k J $2,',C7.[,'cCI, (203J 665-5000 August 12,1986 Docket No. 50-336 A02959 A04929 Office of Nuclear Reactor Regulation Attn: Mr. Ashok C. Thadani, Director PWR Project Directorate //8 Division of PWR Licensing-B U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Control Room Design Review Implementation Plan Response to NRC Staff Comments On February 26,1985,(I) Northeast Nuclear Energy Company (NNECO) provided the NRC Staff with the Control Room Design Review (CRDR) Implementation Plan for Millstone Unit No. 2. The results of the NRC Staff's review of the CRDR Implementation Plan for Millstone Unit No. 2 were provided to NNECO on May 23,1985.(2) The NRC Staff indicated that the CRDR Implementation. Plan was generally acceptable, however, the NRC Staff identified some areas where additional clarifying information was necessary. In addition, the NR'C Staff stated that NNECO would be contacted in the near future regarding a meeting to discuss these items.

At the time of receipt of the NRC Staff's May 23, 1935 letter, NNECO was also conducting a CRDR for Millstone Unit No. 3. Similar NRC Staff concerns existed on behalf of Millstone Unit No. 3 and a meeting was initially scheduled to discuss both the Millstone Unit No. 2 and No. 3 items simultaneously since the NRC Staff technical reviewer was the same person for both units. Subsequently, it was decided that Millstone Unit No. 3 concerns should be addressed first and any remaining Millstone Unit No. 2 concerns would be addressed at a later time.

The NRC Staff found in Supplement No. I to the Millstone Unit No. 3 Safety Evaluation Report that the CRDR for Millstone Unit No. 3 was acceptable, except for the four items identified in that Supplement. A meeting was held on July IS,1985 with the NRC Staff to discuss these four items. A summary of the 8608260174 860812 PDR ADOCK 05000336 P PDR (1) W.G.Counsit letter to 3.R. Miller, " Supplement I to NUREG 0737, Control Room Design Review Implementation Plan", dated February 26,1985.

(2) E.G.Tourigny letter to 3.F.Opeka, " Detailed Control Room Design Review 993 Program Plan for Millstone Unit 2," dated May 23,1985. F 1i

j = ,

l i information provided to the NRC Staff at that meeting for each of the four ;

items was submitted on August 13, 1985.(3) Additional information regardigg i these four open items was provided to the NRC Staff on September 12,1985,W

[ as part of Addendum No. I to the CRDR Summary Report for Millstone Unit No.3. Based upon the NRC Staff's review of these submittals, a subsequent ,

l meeting was held on October 17, 1985 between the NRC Staff and j representatives of NNECO. Information provided to the NRC Staff at this meeting adequately was documented on resolved remaining)NRC October 28,1985.U TheseStaff four concerns.

open itemsSuch wereinformation closed out

by the NRC Staff in Supplement No. 4 to the Safety Evaluation Report for Millstone Unit No. 3.

As a result of the closure of those items for Millstone Unit No. 3, it was

.l determined that additional meetings to resolve similar Millstone Unit No. 2 NRC q

Staff concerns were no longer necessary. Although a formal response to the May 23, 1985 letter was not requested, NNECO judged it appropriate to formally ,

document responses to the NRC Staff concerns delineated in the May 23, 1985 '

letter. A draft response had been prepared during the early part of 1986. Due to a new NRC Staff Project Manager and technical reviewer for Millstone Unit No.

2, it became appropriate to further discuss the status of these items, and our 1 draft response was discussed with the NRC Staff on June 24, 1986. The purpose !

of this submittal is to document our responses to the NRC Staff concerns I identified in the May 23, 1985 letter as modified to reflect discussions with the )

NRC Staff on June 24,1986. ,

, On December 10, 1985,(6) we responded to a NRC Staff concern identified as j part of their review of the Millstone Unit No. 2 Emergency Operating Procedures Generation Package (PGP) and pertaining to the identification of the operator's information and control needs. Although similar Information will be provided in 4 the CRDR Summary Report for Millstone Unit No. 2, we believe adequate I

information is contained in this submittal to assist the NRC Staff in resolving

that item. On a related matter, it is important to note that the CRDR is being ;

! performed based on the existing upgraded Emergency Operating Procedures j (EOPs) for Millstone Unit No. 2. Concerns related to the preparation of the

EOPs in the NRC Staff's May 23, 1985 letter have been previously addressed l during the NRC Staff's review of the PGP for Millstone Unit No. 2.

1

! (3) 3.F.Opeka letter to B.3.Youngblood, " Supplement I to NUREG-0737, l Control Room Design Review," dated August 13,1985.

l (4) 3.F.Opeka letter to B.3.Youngblood, " Supplement I to NUREG-0737, Control Room Design Review, Addendum No. I to the Summary Report,"

dated September 12,1985.

l (5) 3.F.Opeka letter to B.3.Youngblood, " Supplement I to NUREG-0737, Control Room Design Review," dated October 28,1985.

(6) 3. F. Opeka letter to A. C. Thadani, " Supplement I to NUREG-0737, Emergency Operating Procedures Generation Package," dated December 10,1985.

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3

'We believe that the attached information is responsive to the NRC Staff concerns. Should you have any questions, please contact us.

Very truly yours, &

NORTHEAST NUCLEAR ENERGY COMPANY 3 Q Opeka v Sen)ior Vice President

/ $

By: W. F. Fee Executive Vice President I

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i Docket No. 50-336 Attachment 1 Millstone Nuc19ar Power Station, Unit No. 2 Control Room Design Review Implementation Plan Response to NRC Staff Comments August,1986

i ,

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE MILLSTONE UNIT NO. 2 CRDR IMPLEMENTATION PLAN REVIEW TEAM The qualifications and multidisciplinary nature of the review team seem good.

However, the Program Plan should include the following:

Item 1: Identify the human factors consultant and his role and the identities and expertise of other consultants.

Response

Since the initial submittal of the Millstone Unit No. 2 CRDR Implementation Plan, an internal reorganization of personnel has occurred within the Northeast Utilities Service Company (NUSCO) organization. In addition, with the completion of the Millstone Unit No. 3 CRDR, experienced personnel have 1

become available to participate in the Millstone Unit No. 2 review. Personnel changes are discussed below.

Mr. W. C. Mission, project engineer for the Millstone Unit No. 3 CRDR, will replace Mr. Z. Ufnal as project engineer for the Millstone Unit No. 2 review.

Mr. Mission is a consultant who will provide architect-engineer expertise. His resume is provided in Attachment 2. Mr. R. K. McCarthy has replaced Mr. Ufnal as the controls engineer on the core team and will represent the controls discipline on the core team. Mr. McCarthy's resume is also included in Attachment 2. Mr. R. Sabeh is a consultant that will assist Mr. A. M. Stave on the core team as a human factors specialist. Mr. Sabeh's resume is provided in Attachment 2. No other consultants are planned for the CRDR core team or support group.

i ,

Item 2: Identify the person (s) responsible for the final approval and sign-off of HED resolutions.

Response

The Program Manager, Mr. T. A. Shaffer, is responsible for signing and approving the HED resolutions. With his approval, the HED resolutions become the recommendations of the review team to upper management for final review and implementation, in accordance with our procedures.

Item 3: Explain the exclusion of a nuclear engineer from the Core Review Team.

Response

1

l Mr. T. 3. Honan has been added to the discipline support group for the CRDR.

Mr. Honan will serve as the nuclear engineer for the group. Experience gained ,

from the Millstone Unit No. 3 CRDR disclosed that the presence of a nuclear engineer as a full-time member of the core team was not required. The nuclear engineer shall remain immediately available for consultation on any item concerning his discipline during the review.

Item 4: Detail the levels of efforts of the CRDR participants.

Response

The level of effort of the CRDR participants can best be detailed by explaining the function of the core team. The core team will participate in the review as a unit with each member providing his expertise. The team participates in all

phases of the review, from investigation through reporting, with each member involved in such activities as assessment, prioritization, correction, etc.

Individual tasks may be assigned to each participant, depending upon his expertise, with the results of the task being reviewed by the whole core team.

Consequently, the time required of the members of the core team is quite extensive. During the Millstone Unit No. 3 CRDR, it was apparent that full-time participation of the nuclear engineer and the training specialist on the core team was not required. Supplementing this core team as needed are other disciplines including mechanical, electrical, instrumentation and nuclear reactor engineering, computer operations, and licensing. All members of the discipline support group are immediately available when consultation is desired or necessary. During the course of the review, any additional specialist (e.g.,

lighting, acoustics, etc.) required for specific tasks are made available.

Item 5: Provide details regarding the methods and duration of instruction during the review team orientation.

Response

A course in human factors fundamentals was provided for all members of the core team and was conducted by the human factors member, Mr. A. Stave. The duration of the course was four (4) hours and included a review of the causes of human error, the recognition of potential human error situations and the types of changes that reduce the chances for human errors.

Orientation for plant familiarization was available for the human factors members of the core team. The other members of the core team were knowledgeable about the plant and its systems as a result of their normal working assignments. A 2-day orientation was conducted by the Millstone Unit No. 2 Training Department under the direction of Mr. M. Wilson, the training participant of the review team. The objectives of the orientation course were to:

_4

a. Understand the purpose of the systems on each panel in the control room;

b. Understand the major flow paths of each system, given a

diagram or using the control board mimic as a guide; and

c. Understand the major components (controls and indications) located on the control boards or panels.

FUNCTION AND TASK ANALYSIS The Program Plan lacks sufficient, detailed information regarding the proposed Function and Task Analysis for an adequate evaluation of this activity.

l The following should be addressed by NNECO:

Item 1: What specific event scenarios will be covered by the CEOG EPGs?

Response

The Combustion Engineering Owners' Group (CEOG) Emergency Procedures Guidelines (EPGs) were used to write the upgraded Millstone Unit No. 2 Emergency Operating Procedures (EOPs). The scenarios to be reviewed in the task analysis phase are those scenarios addressed in the Millstone Unit No. 2 Emergency Operating Procedures. In addition, Abnormal Operating Procedures 2551, Shutdown From Outside the Control Room; 2552, Cooldown From Outside the Control Room; 2553, Natural Circulation Cooldown From Outside the Control Room; and 2559 for a fire in the Control Room will be reviewed.

Item 2: The personnel and their qualifications involved in identifying and analyzing deviations from the CEOG EPGs.

Response

The CEOG Emergency Procedure Guidelines (EPGs) were developed to satisfy item I.C.1 of NUREG-0737. On August 29,1984, the Combustion Engineering Owners' Group (CEOG) and the NRC agreed that the CEOG EPGs constitute an adequate function analysis for emergency operations. The EPGs provide the basis for the Emergency Operating Procedures (EOPs) and the specific event scenarios needed for the task analysis of the CRDR.

As a result of the agreement between the NRC and the CEOG, a second task was undertaken. The task was designed to support the CRDR at CE plants by developing generic information and control requirements with their characteristics. The results of this task are contained in CE-NPSD-299, which provides the methodology and the information and control requirements to perform a task analysis based upon the emergency operating procedures.

On September 6,1985, CEN-307, "CE Owners' Group Generic Information Characteristics Review" was submitted for NRC review. This report gives a thorough description of the model and method employed in conducting the generic task analysis, including the generic operating information and control characteristics requirements. The task analysis phase of the Millstone Unit No. 2 CRDR was revised to take advantage of the work performed by the CEOG.

Combustion Engineering has converted the generic operator information and control requirements to plant-specific requirements for Millstone Unit No. 2.

The personnel involved in identifying the deviations from the generic EPGs are the same as those who developed the generic guidelines, CE-NPSD-299. Their qualifications are available as part of the information provided with the submittal of CEN-307.

Item 3: The task analysis methodology used to identify para-meters and other information and control needs.

Response

The methodology to be used to determine the deviations and plant-specific requirements will be the same as used for the development of the generic guidelines (reference CEN-307). Figure 6.1 of CEN-307 provides the generic to plant-specific conversion process to be used. This conversion was performed independent of the instruments or controls installed on the Millstone Unit No. 2 control panels or the inventory of this equipment.

Item 4: The Task Data Forms lack the necessary space for record-ing information and control requirements resulting from the Function and Task Analysis.

Response

As stated in the CRDR Implementation Plan, the methodology for performing the CRDR Task Analysis will be similar to that performed for Millstone Unit No.3. Revisions to the task analysis methodology and forms have been made based on experience gained during the Millstone Unit No. 3 review.

The Task Sequence Chart (Figure 7 of the Implementation Plan) has been eliminated. The Task Data Form (TDF) has been revised. The individual operator tasks required to accomplish the current step of the EOP will be documented in the requirements section of the task data form. Examples of this will be included in the CRDR Summary Report.

When all steps of a procedure are recorded on TDFs, the core team will walk through the operator tasks on the forms. During this phase, the specific instruments and controls used to perform the task will be recorded on the forms in the Plant Equipment Used column. At the same time, the core team will review the task and the equipment used for its human suitability. Tasks and equipment that do not meet the guidelines of NUREG-0700 will be documented i as a HED. Missing information or control equipment needed to satisfy the l

l requirements will also be recorded as a HED.

t l'

Upon completion of the plant-specific information and control requirements, Combustion Engineering will generate a' Consolidated Report for Millstone Unit No. 2. The Consolidated Report will list all of the necessary characteristics for each information and control requirement (e.g., range, resolution, availability, reaction time, etc.). With all of the characteristics compiled, the required characteristics are then available for comparison with the Millstone Unit No. 2 instruments and controls. This comparison will be performed by the core team by adding to the list the instrument or control used to satisfy the requirement along with its actual characteristics. HEDs will be produced from this comparison for those situations where instrumentation and control needs are not adequately addressed.

The process of consolidating the required characteristics allows one walk-l through instead of repeating the comparison for each procedural step that uses the instrument or control.

i COMPARISON OF DISPLAY AND CONTROL REQUIREMENTS WITH A

. CONTROL ROOM INVENTORY Item 1: The methodology described by NNECO appears adequate.

, However, the success of this activity depends upon the adequacy of the Task Analysis.

i

Response

i i No response to this statement is necessary.

Item 2: The verification of corrections appears to occur prior to the HED assessment and resolution activities, i

I

Response t

See the response to the item listed under the " Verification of Design Improvements" category and the corrected schedule attachment.

l i

, CONTROL ROOM SURVEY The control room survey appears acceptable, but the discussion of the control room survey should address the following concerns:

Item 1: Use of other guidelines besides NUREG-0700.

Response

The control room survey for the Millstone Unit No. 2 CRDR will be performed by utilization of the checklists provided in Section 6 of NUREG-0700. Other guidelines, such as NUTAC documents, MIL Standards, etc. were used as supplemental information only. In all cases, the guidelines of NUREG-0700 will have precedence.

Item 2: Human factors staffing and their role in the survey.

Response

i The control room survey will be administered by the two human factors specialists, with assistance as necessary by other core team members.

Item 3: " Classification" in reference to documenting core team member opinions.

! Response Some degree of assessment (or classification) will occur during the control room survey, i.e., obviously necessary corrections will be noted. Any core team member can document opinions concerning the existence of a potential HED, I

which may be in conflict with the opinion of the majority of the team; however,

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_9 any comments of this nature will be reviewed by the full core team during the assessment phase of the review.

Item 4: Means for addressing all dynamic criteria in NUREG-0700 (and other guidelines).

Response

A matrix has been developed to assign all of the items of Section 6 of NUREG-0700 to their appropriate phase of the review (i.e., Operating Experience Review (OER), Control Room Survey (CRS), and Task Analysis (TA).

In many cases, an alternative phase has been listed to provide the team with the option of obtaining data from more than one source. For most of the dynamic

type criteria, the OER was signified as the preferred or primary source of obtaining the data. These dynamic criteria have been included in the Operators Questionnaire or during the interviews which are to follow. A portion of this matrix is attached.

ASSESSMENT OF HEDS Item: The description of the HED assessment lacks detailed information, and as outlined, does not meet the require-ments of Supplement I to NUREG-0737 for the reasons detailed in the attached report. In addition, it appears from Figure 6 of the Program Plan that the assessment activity which evaluates the HEDs ends before the Task Analysis has been completed and the resultant HEDs identified.

Response

There are seven (7) concerns addressed specifically in the report prepared by the

NRC Staff's consultant, SAIC, regarding the assessment phase of the Implementation Plan. The following discussion addresses each of those concerns; however, it is important to note that the assessment phase methodology used in l