ML17305A706

Rev 1 to Human Factors Engineering Dcrdr Final Supplemental Technical Evaluation Rept,Palo Verde Nuclear Generating Station.

ML17305A706
Person / Time
Site:	Palo Verde
Issue date:	09/30/1989
From:	Johnson G, Johari Moore LAWRENCE LIVERMORE NATIONAL LABORATORY
To:	NRC
Shared Package
ML17305A705	List: ML17305A706
References
UCID-21509, UCID-21509-R01, UCID-21509-R1, NUDOCS 9004260194
Download: ML17305A706 (28)

Text

~ . ENCLOSURE E

'UCID-21509 Rev.'

Human 'Factors Engineering Detailed Control Room Design Review Final Supplemental Technical Evaluation Report Arizona Public Service Company Palo Verde Nuclear Generating Station G. L. Johnson J. W. Moore Lawrence Livermore Nationai Laboratory September 1989 9004260194 900420 PDR ADOCK 05000528 P PDC

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Table of Contents Page

1. Background.

2. Assess m ent of DCRDR Activities 2.1 DCRDR Review Team. .3 2.1.1 Requirement.. .3 2.1.2 Discussion.

2.1.3 Conclusion .3 2.2 Function and Task Analysis .3 2.2.1 Requirement .3 2.2.2 Discussion.. .4 2;2.3 Conclusion .4 2.3 Comparison of Control and Display Requirements with Control Room Inventory.... .4 2.3.1 Requirement. .4 2.3.2 Discussion. .5 2.3.3 Conclusion. .5 2.4 Control Room Survey. .5 2.4.1 Requirement. .5 2.4.2 Discussion.. 6 2.4.3 Conclusion 7 2.5 Assessment. 7

.2.5.1 Requirement. 7 2.5.2 Discussion. 7 2.5.3 Conclusion. 8 2.6 Selection of Design Improvements. 8 2.6.1 Requirement. 8 2.6.2 Discussion 8 2.6.3'onclusion................................................................................. 9 2.7 Verification That Design Improvements Provide Necessary Correction and Do Not Introduce New HEOs 9 2.7.1. Requirement. 9 2.7.2 Discussion. 9 2.7.3 Conclusion. 10 2.8 Coordination of the OCRDR:with Other Programs 10 2.8.1 Requirement. 10 2.8.2 Discussion... 10 2.8.3 Conclusion........................................................................ 10

3. Summary.

4. References ..12'

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Human Factors Engineering Detailed Control Room Design Review Final Supplemental Technical Evaluation Report Arizona Public Service Company Palo Verde Nuclear Generating Station

1. Background Licensees and applicants for operating licenses shall conduct a Detailed Control Room Design Review (DCRDR). The objective is to Improve the ability of nuclear power plant control room operators to prevent accidents or cope with accidents if they occur by improving -the information provided to them,"

NUREG-0660. Item I.D.1.'he need to conduct a DCRDR was confirmed in NUREG-07372 and Supplement 1 to NUREG-0737.3 DCRDR requirements in Supplement 1,to NUREG-0737 replaced those in earlier documents. Supplement 1 to NUREG-0737 requires each applicant or licensee to conduct a DCRDR on a schedule negotiated with the Nuclear Regulatory Commission (NRC).

NUREG-0?004 describes four phases of the DCRDR, and provides applicants and licensees with guidelines for its conduct. The phases are:

Planning

2. Review

3. Assessment and Implementation

4. Reporting Criteria for evaluating DCRDRs are contained in Appendix A to Standard Review Plan (SRP), Sec. 18.1 of NUREG.0800.s A Program Plan is to be, submitted within two months of the start of the DCRDR.

Consistent with the requirements of Supplement 1 to NUREG-0737, the Program Plan shall describe how the following elements of the DCRDR will be accomplished:

1. Establishment of a qualified,multidisciplinary review team.

2. Function and task analysis to identify control room operator tasks and information and control requirements during emergency operations.

3. A comparison of display and control requirements with a control room inventory.

4. A control room survey to identify deviations from accepted. human factors principles.

5. Assessment of human engineering discrepancies (HEDs) to determine which HEDs are significant and should be corrected.

6. Selection of design improvements.

7. Verification that selected design improvements will provide the necessary correction and do not introduce new HEDs.

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8. Coordination of control room improvements with changes from other programs such as SPDS, operator training, Reg. Guide 1.97 instrumentation, and upgraded emergency operating procedures (EOPs).

Licensees are expected to complete Element 1 during the DCRDR's planning phase, Elements 2 through 4 during the DCRDR's review phase. and Elements 5 through 7 during the DCRDR's assessment and implementation phase. Completion of Element 8 is expected to cut across the planning, review, and assessment and implementation phases.

A Summary Report is to be submitted at the end of the DCRDR. At a minimum, it shall:

1. Outline proposed control room changes.

2. Outline proposed schedules for implementation.

3. Provide summary justification for HEDs with safety significance to be left uncorrected or partially corrected.

The NRC evaluates the organization, process, and results of the DCRDR. Evaluation will include review of required documentation (Program Plan and Summary Report), and may also include reviews of additional documentation, briefings, discussions, and on-site audits. In-progress Audits,may be conducted after submission of the Program Plan, but prior to submission of the Summary Report. Evaluation will be in accordance with the requirements of Supplement 1 to hgJREG-0737. Additional guidance for the evaluation is provided by NUREG-0700 and NUREG-0800, Appendix A to SRP Sec. 18.1. Results of the NRC evaluation of a DCRDR will be documented in a Safety Evaluation Report (SER) or SER Supplement.

Significant HEDs should be corrected. Improvements which can be accomplished with an enhancement program should be done promptly. Other control room improvements should be done on a schedule acceptable to the NRC.

2. Assessment of DCRDR Activities In response to the Detailed Control Room Design Review (DCRDR) requirements of NUREG-0737.

Supplement 1 Arizona Public Service Company (APS) performed a preliminary Design Assessment (PDA) of the Palo Verde Nuclear Generating Station, Unit1 (PVNGS1) and supplemented this assessment with a system factors review to address the suitability of control room devices to support operator needs.

NRC review of these activities and discussions with APS during a preimplementation audit at the PVNGS1 site in October 9-12, 1984 concluded that APS had fulfilled Supplement 1 DCRDR requirements with the following exceptions:

~ The APS system factors review did not totally satisfy the need for a systems function and task analysis.

~ The control room environmental and lighting survey was not yet complete.

The NRC review team disagreed with APS concerning the acceptability of the planned resolutions for a Iew human engineering discrepancies (HEDs).

~ The NRC review team disagreed with the APS schedule for resolving certain HEDs.

~ Development of Plant Emergency Operating Procedures and operator training was not sufficiently coordinated with the DCRDR process.

Additionally, the NRC review'team suggested that APS make more effective, use of the control room simulator in verifying the acceptability of proposed control room modifications. These comments were

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transmitted to APS in NUREG-085?, Supplement 7,'"Safety Evaluation Report (SER) Related to the Operation of Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3,6 dated December 1984.

APS responded to the NRC comments by completing:

~ A systems function and task analysis.

~ The control room environmental surveys.

~ A reevaluation of the proposed action for correcting HEDs where the NRC review team was not in agreement, with the planned solutions or schedules.

These activities were reported in the "Palo Verde Nuclear. Generating Station Detailed Control Room Design Review Final Supplement Report."7 APS further clarified the Final Supplement'Report in a letter dated January 23, 1987 and a telephone conterence on August 3, 1989. Lawrence Livermore National Laboratory (LLNL) has reviewed this additional information to complete the evaluation ot APS's overall fulfillment of NUREG-0737, Supplement1, DCRDR requirements. This supplemental: Technical Evaluation Report summarizes the APS activities and LLNL's evaluation of the adequacy of these activities in the fulfillment ot NUREG-0737, Supplement 1 requirements.

2.1 DCRDR Review Team 2.1.1 Requirement Supplement 1 to NUREG-0737 requires the establishment of a-qualified multidisciplinary review team.

Guidelines, for review team selection are found in NUREG-0700 and NUREG-0800, Appendix A to SRP Sec. 18.1. NUREG-0700 guidelines state that support ot the applicant's management is needed to provide the DCRDR team with all of the information, equipment, and categories of manpower needed to conduct a control room review.

2.1.2 Dlscusslon ln a previous submittal.9 APS identified DCRDR team members and'their respective roles in the DCRDR process. As a result of reviewing this submittal and discussion of the team makeup with APS during the preimplementation audit. the NRC review team concluded that the APS DCRDR team met the multidisciplinary team requirements of Supplement 1 to NUREG-0737. Since that time, the composition of the DCRDR team has been changed somewhat. However, the makeup continues to include considerable experience in operations, systems engineering, IB,C engineering, and human factors.

2.1.3 Conclusion The changes made to the APS DCRDR team do not affect the previous conclusion that the team makeup fulfills the multidisciplinary team requirement of Supplement 1 to NUREG-0737.

2.2 Function and Task Analysis 2.2.1 Requirement Supplement 1 to NUREG-0737 requires the applicant to perform a function and task analysis to identify control room operator tasks and control room operator information. and control requirements during emergency operations. The function and task analysis. serves as. the basis for developing emergency

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operating procedures (EOPs), technical guidelines, and plant-specific EOPs to define these requirements.

2.2.2 Discussion In response to NRC recommendations provided in Supplement 7 to.the SER, APS has completed a systems function and task analysis for PVNGS. This task analysis was.based,upon~the. Combustion Engineering (CE) Owners Group Emergency Response Guidelines (ERGs); All:CE ERGs were addressed by, the task analysis. These ERGs include:

~ Guidelines for maintaining critical safety functions.

~ Event based optimal recovery guidelines..

~ Guidelines for maintaining vital auxiliaries.

APS reviewed each ERG to develop a corresponding listing of plant specific operation tasks. Plant operators and system engineers reviewed the task listing to divide each task down into specific operator steps that would achieve-the task. Where several alternative ways of accomplishing the task were identified,'the step sequences for'each alternative were listed. The listing of operator steps was examined to determine. which parameters. operators must observe or control to accomplish each step and to identify the characteristics that control or display devices must have:to support the operator's information.and control needs. The identification. of needed device characteristics addressed the following items:

~ Parameter description.

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Engineering units for the parameter, including the range over which the parameter must be displayed or controlled.

~ Need for historical information.

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Type of control needed (discrete vs continuous).

~ Needed display accuracy.

The final supplemental report provides sample documentation for these activities. Review of. the sample documentation indicated that APS implemented, the described process in a complete and rigorous manner.

2.2.3 Conclusion The task analysis process described by APS satisfies the task. analysis provisions of Supplement.1 to NUREG-0737.

.2.3 Comparison of Control and Display Requirements with Control Room inventory 2.3.1 Requirement Supplement 1 to NUREG-0737 requires the applicant to prepare a control room"inventory and to compare the operator display and control requirements determined:from the task analyses with the control room inventory,to determine the availability and suitability of controls and displays. Guidance in

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NUREG-0700 calls for a review of the human factors suitability of instruments and controls used to satisfy operator information and control requirements.

2.3.2 Discussion For each operator step identified by the task analysis, APS identified all'possible control room devices that

.provide display or control of the desired parameter. These devices were identified without regard.to the display or control characteristics needed to support any, particular operator actions.

The characteristics of each device identified, by the above review were ascertained by review of engineering documents and recorded in a control and display inventory. Each device in the inventory was examined in the control room to verify the accuracy of'the inventory information. The characteristics addressed by this inventory are:

~ Control board upo'n which the device is located.

~ Device identification tag number.

~ Power source {vital vs nonvital).

~ Control board label description of the device.

~ Range in indicated engineering units.

~ Display resolution.

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Type, color coding, and labeling of control position indication.

In addition, normal environment instrument errors for each instrument display were determined and documented separate from the inventory. Severe environment loop:errors were accounted for during EOP development, and thus did not need to be addressed as part of this DCRDR.

Each operator step was reviewed to verify:

~ Control or display of the required parameter is present in the control room.

~ The characteristics of the available control room device{s) are suitable to fulfill the operator information and control needs identified by the task analysis.

If a needed display of control device.was not available in the control room or it the available device did not have the. needed characteristics, the problem was recorded in an Information and Control-Requirements Discrepancy Report.

2.3.3 Conclusion The APS process for comparing available instrument and control characteristics against operator display and control needs. satisfies the requirements of Supplement 1 to NUREG-0737.

2.4 Control Room Survey 2.4.1 Requirement Supplement'1 to NUREG-0737 requires that a control room survey be. conducted to identify deviations from accepted human factors principles. NUREG-0700 provides guidelines and criteria for conducting a control room survey.

2.4.2 Discussion At the time of the NRC preimplementation audit, the control room survey was complete except for the control room environmental and lighting survey. The NRC SER concluded that the APS survey process would satisfy the requirements of NUREG-0737, Supplement 1 once:

The environmental and lighting surveys are acceptably completed NRC audit team questions regarding the acceptability of the selected correction for a few specific HEDs are resolved.

Control display relationships identified by the systems function and task analysis are evaluated.

Operator provided enhancements,to the control'boards.that were noted by the audit team are evaluated and incorporated into the control room design as appropriate.

Each of these items has been addressed by APS as discussed below.

APS has completed an environmental survey of the qpntrof room using the review criteria of NUREG-0700, Section 6.1.5. This effort was reported via APS letter to NRC dated October 29, 1984.

This review identified two HEDs: one related to glare on meter faces, and the other related to an excessively loud annunciation alarm. Both HEDs had also been previously noted during the NRC preimplementation audit. The loud alarm HED was corrected. The HED relating to meter glare was partially corrected as discussed below.

APS has reviewed the HED corrections questionedby NRC. With three exceptions the items questioned have been corrected by APS. The three exceptions are:

~ Glare on some meter faces.

Steam generator water level instrumentation that reads in percent of range instead of engineering units.

Parallax problems with Foxboro 250 series indicators that result in difficulty with reading the instrument scale markings from some viewing angles.

ln response to the glare problems, APS tested the effectiveness of several potential solutions. Only one of the. improvements tried, the installation of'nonglare bulbs, reduced the glare on the meter faces without introducing new human engineering problems. Although this solution did not completely eliminate glare on meter faces, the environmental survey concluded that the remaining glare does not significantly interfere with the readability of the affected. displays. APS, therefore, decided to install the nonglare bulbs as the only practical method available to reduce glare problems.

APS review of the scale units used on the steam generator water level instruments concluded that use of engineering units would be misleading to the operator because the control room contains two sets of instruments that are calibrated for different plant conditions; therefore; if these instrument scales were marked with engineering units, the two sets of displays would always be in disagreement. To assist plant operators in interpretation of the percentage scales, APS has posted (on the control boards) an operator aid that provides a correlation between the wide and narrow range level instruments for different plant operating. conditions.

The parallax problems with the Foxboro 250 series indicators were reviewed by the utility's human factors consultant using review criteria from NUREG-0700. This review concluded that the readability of the indicators is acceptable.

~ t ig 2.4.3 Conclusion APS has completed the control room survey process and has performed the reassessment of selected HEDs as requested by Supplement 7 to the SER. The results of this reassessment are acceptable.

therefore, the APS control room survey process has satisfied the provisions of Supplement 1 to NUREG-0737 in this regard.

.2.5 Assessment 2.5.t Requirement Supplement 1 to NUREG-073? requires that HEDs be assessed to determine which HEDs are significant and should be corrected.

2.5.2 Discussion The APS HED assessment process as described in the original summary report was reviewed and also discussed with APS during the preimplementation audit. As discussed in Supplement 7 to'the SER, this process was found to fulfillthe assessment requirements of NUREG-0737, Supplement 1. The result of the assessment of any new HEDs identified during the completion of the DCRDR were to be. reviewed by NRC. Additional HEDs were identified by the control room environmental survey and the systems function and task analysis. The results of the environmental survey HED assessment were discussed in Sec. 2.4.

The discrepancies identified by the systems function and task analysis and comparison with the control room inventory fall into several categories.

1. Deviations from plant drawings noted during the control room walk downs.

2. Operator tasks that are supported by instruments and controls that are. within the control room area but not on the main control boards.

3. Operator tasks that are supported only by devices located outside of. the control room.

4. Operator tasks for which the required devices do not exist.

5. Displays and controls that have design characteristics that are inappropriate for the operator tasks they support.

6. Displays that have design-characteristics'that do not satisfy the recommendations of Regulatory Guide 1.97.

7. Instrument loops. that tail to support the needs of theiSPDS; The results of the APS assessment of these items were reported in an APS letter dated November 27.

985 LO Review of the APS assessment of'these discrepancies shows that:

~ APS intends'to correct most'of the items of the type noted in Item 1 above'before startup from first refueling outage.

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~ APS plans to evaluate alternatives to improve the accessibility of information for Item 2 above.

APS has not, however, committed to make corrections.

The discrepancies noted in Item 3 are for the most part associated with alternative methods of performing EOP tasks that would not normally be used. Therefore, the deficiencies need not be corrected to allow complete implementation of the EOPs. APS has not committed to correct any of these items, but has committed to further evaluate the desirability of correcting some items.

APS has committed to correct one of four discrepancies of the type noted'n Item4.

Reference 10 justifies leaving the remaining three discrepancies uncorrected.

APS has committed to correct 13 discrepancies of the type noted in Item 5. Reference 10 justifies leaving the remaining HEDs of this type uncorrected.

APS further reviewed the discrepancies of the types noted in Items 6 and 7 and concluded that these HEDs were not valid, Reference 10 discusses the additional review.

2.5.3 Conclusion The APS HED assessment process fulfills the requirement of Supplement 1 to NUREG-0737 has not changed.

2.6 Selection of Design improvements 2.6.1 Requirement Supplement 1 to NUREG-0737 requires the selection of control room improvements that will correct significant HEDs. It also states that. improvements that can be accomplished with an enhancement, program should be done promptly.

2.6.2 Discussion The APS methodology for selecting design improvements was evaluated as part. of the review of the original summary report. This review concluded that the selection methodology fulfills the requirements of NUREG.0737 in this regard. However, Supplement 7 to the SER identified two design improvements that should be implemented sooner than originally planned by APS. These items are:

~ Implementation of meter zone banding.

~ Installation of functional demarcation or grouping of indicators on the remote shutdown panel.

These items were completed on the schedule recommended by NRC as reported by an APS letter dated May 28, 1985."

Review of the design improvements proposed to correct HEDs which were discovered as a result of the task analysis identified the following items. for which the proposed correction does not clearly resolve the HED.

~ HED 201 concerns the lack of Essential Cooling Water System (ECWS) source tank level and pump discharge pressure indication. The proposed resolution is to provide the needed, level indication. It is not clear how this corrects the lack of flow indication on a specific train of AFW.

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HED 218 relates to the lack of flow indication for one-train of auxiliary feed water (AFW). The proposed resolution would label what appears to.be a total AFW flow indicator in different units. It is not clear how this corrects the lack of flow indication on a specific rain of AFW.

HEO 219 deals with Reactor Make Up Water Tank level being displayed in different units than are used in the procedure. The proposed correction is.to provide meter barding to indicate the acceptable range of tank levels. Provision of meter barding may be appropriate, however, APS should also address the general principle of maintaining consistency between the measurement units displayed on the control boards and those used in proceoures.

In Ref. 10 APS further described how the proposed corrective actions would correct th e id eniie t'f' problems.

2.6.3 Conclusion The APS selection of design improvements fulfills the requirements of Supplement 1 to NUREG-0737.

2.7. Verification That Design Improvements Provide Necessary Correction and Do Not Introduce New HEDs 2.7.1 Requirement Supplement 1,to NUREG-0737 requires verification that selected design improvements will provide the necessary correction, and will not introduce new HEOs into the control room.

2.7.2 Discussion The AP process for verifying that control room modifications implemented to resolve HEDs correct the he APS identified problems, and do not introduce new HEOs, was discussed in the onginal summary report. This process was reviewed during the preparation of the original OCRDR SER and was discussed with APS during the preimplementation audit. This review noted that several of the modifications implemented to resolve HEDs did not completely resolve the HED.or introduced new HEDs. Additionally, the review noted that APS was not consistently making effective use of the control room. simulator in verifying the acceptability of HED resolutions.

In response to the above concerns the APS Final Suplemental Report further explained their process for verifying the acceptability of HED corrections. APS pointed out that all HED corrections have been reviewed by a human factors consultant to verify that the identified problem has been corrected and that no new HEDs were introduced. Also, modifications were evaluated by formally questioning plant operators regarding the effectiveness of the changes made. APS also indicated that this verification process was supplemented by the procedure validation effort in the plant simulator, although the plant simulator had not been modified to include HED corrections. ApS plans to use.the human factors review and operator survey process to evaluate the acceptability of design changes made to correct HEDs resulting from the environmental survey and systems function and'task analysis. APS also indicated that they plan to upgrade the plant simulator to incorporate HED corrections that have been implemented on the plant control boards. APS also developed human factors criteria and conventions to be used during engineering of all future plant modifications.

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2.7.3 Conclusion The APS verification process satisfies the requirements of NUREG-0?37 Supplement 1.

2.8 Coordination of the DCRDR ~ith Other Programs 2.8.1 Requirement Supplement.,1 to NUREG-0?37 requires that control room improvements be coordinated i with c h anges from other t r p rograms, e.g., Safety Parameter Display System (SPDS), operator training Regulatory Guide 1.97 (R.G. 1.97) instrumentation, and upgraded emergency operating procedures.

2.'8.2 Discussion The APS program for coordinating NUREG-0737, Supplement 1. control room improvements was discussed in the original summary report. As part of the process. of. preparing. the DCRDR evaluation in Supplement 7 to the SER, this. process was reviewed and was further discussed with APS during:the preimplementation audit. This review concluded that the. DCRDR program was not adequately coordinated with other,NUREG-9737, Supplement 1 activities.

In response to this comment, APS has reviewed the coordination of changes affecting control room operations. The following improvements in the coordination process have been made:

~ A systems function and task analysis has been completed using as its basis. the same ERGs from which the plant specific EOPs were developed. This process verified the availability and suitability of displays and controls needed to implement. the EOPs.

~ APS has reviewed the nomenclature used in.EOPs against, nomenclature used on control board labels and corrected any inconsistencies that were noted.

Upgrade of the PVNGS simulator to achieve consistency with the plant control room as modified in response to,the DCRDR has been initiated..

During the systems function and task analysis,'the availability of. the instrumentation required by Regulatory Guide 1.97 was reviewed.

The characteristics of SPDS parameter displays were compared against. operator information needs developed during the systems function and task analysis; The operator tasks identified during the. systems function and task analysis, have been submitted to training for verification that the current training for these tasks is adequate.

2.8.3 Conclusion The improvements made by APS in the coordination process address the previously identified concerns.

Consequently, the. APS DCRDR satisfies the coordination requirements of Supplement1 to NUREG-0737.

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3. Summary APS.has satisfied the Detailed Control Room Design Review Requirements of Supplern en t1 t o NUREG-0737.

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4. References NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident, May'980, Rev. 1, August 1980.

2 NUREG-0737, "Clarification of the TMI:Action Plan Requirements," November 1980; 3 NUREG-0737, "Clarification of TMl Action Plan Requirements," Supplement 1, December 1982.

4 NUREG-0700, "Guidelines for Control Room Design Reviews," September 1981.

5 NUREG.-0800, "Standard Review Plan for the. Review of Safety Analysis Reports for Nuclear Power, Plants," Sec. 18.1, Appendix A, "Evaluation Criteria for Detailed'Control Room'Design Reviews,"

September 1984.

6 U.S. Nuclear Regulatory Commission, NUREG-0857; Supplement.7, "Safety Evaluation Report Related to the Operation of Palo, Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 (Supplement 7)," December 1984.

7 Arizona Public Service Company, "Palo Verde Nuclear Generating Station, Detailed Control Room Design Review, Final'Supplemental Report," August 1985.

8 Letter, J. G. Haynes (APS) to G. W. Knighton (NRC), ANPP-39830-JGH/PGN/98.05, dated January 23, 1987.

9 Letter, E. E. VanBrunt, Jr., (APS) to G. W. Knighton (NRC), ANPP-29252-WFC/KEJ, April 9; 1984.

10 Letter, E. E. VanBrunt, Jr. (APS) to G. W. Knighton (NRC), ANPP-34121-EEVB/SKO, dated November 27., 1985.

,1 1 Letter E. E. VanBrunt, Jr. (APS) to G. W. Knighton (NRC), ANPP-32741, dated May 28, 1985.

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