ML18003B185
| ML18003B185 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/13/1985 |
| From: | Buckley B Office of Nuclear Reactor Regulation |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8512190126 | |
| Download: ML18003B185 (53) | |
Text
Docket No. 50-400 OEc 1 3 uses Mr. E.
E. Utley, Executive Vice President Power Supply 5 Engineering 5 Construction Carolina Power and Light Company Post Office Box 1551
- Raleigh, North Carolina 27602
Dear Mr. Utley:
0 DISTRIBUTION NRC PDR Local PDR PAD-2 rdg HThompson OELD EJordan BGrimes JPartlow BBuckley JLee ACRS (10)
Tech Branch Gray File 6 g~ b en S fai q
Subject:
Detailed Control Room Design Review (DCRDR) - Shearon Harris, Unit 1
Our consultant, Lawrence Livermore Laboratory, has reviewed and prepared a
draft Technical Evaluation Report (TER), copy enclosed, on your September 13, 1985 submittal on the above subject.
The draft TER delineated certain areas where additional information is required in order for the NRC staff and our consultant to continue our review.
It is requested that you be prepared to respond to the issues discussed in the enclosure and/or provide a schedule for response during the upcoming announced meeting of December 20, 1985.
Enclosure:
As stated Bart Buckley, Project"Manager PWR Project Directorate P2 Division of PWR Licensing-A cc:
See next page PM:PAD-2 BBuckley:hmc 12/)) /85 L
ln 2/j5/85 85i2190i26 85i213 PDR ADOCK 05000400 F
Mr. E.
E.
Ut1 ey Carolina Power 5 Light Company CC George F. Trowbridge, Esq.
Shaw, Pittman, Potts 5 Trowbridge 1800 M Street, NW Washington, DC 20036 Richard E. Jones, Esq.
Associate General Counsel Carolina Power 8 Light Company 411 Fayetteville Street Mall
- Raleigh, North Carolina 27602 Jo Anne Sanford, Esq.
Special Deputy Attorney General State of North Carolina Post Office Box 629
- Raleigh, North Carolina 27602 Thomas S. Erwin, Esq.
115 W. Morgan Street
- Raleigh, North Carolina 27602 Resident Inspector/Harris NPS c/o U.S. Nuclear Regulatory Commission Route 1, Box 315B New Hill, North Carolina 27562 Charles D. Barham, Jr.,
Esq.
Vice President 5 Senior Counsel Carolina Power 5 Light Company Post Office Box 1551
- Raleigh, North Carolina 27602 Mr. John Runkle, Executive Coordinator Conservation Council of North Carolina 307 Granville Road Chapel Hill, North Carolina 27514 Mr. Wells Eddleman 806 Parker Street Durham, North Carolina 27701 Mr. George Jackson, Secretary Environmental Law Project School of Law, 064-A University of North Carolina Chapel Hill, North Carolina 27514 Shearon Harris Mr. Travis Payne, Esq.'23 W. Johnson Street Post Office Box 12643
- Raleigh, North Carolina 27605 Mr. Daniel F.
Read CHANGE Post Office Box 2151 Raleigh, North Carolina 27602 Bradley W. Jones, Esq.
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street Atlanta, Georgia 30303 Richard D. Wilson, M.D.
725 Hunter Street Apex, North Carolina 27502 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street Suite 2900 Atlanta, Georgia 30303 Mr. Robert P. Gruber Executive Director Public Staff -
NCUC Post Office Box 991
- Raleigh, North Carolina 27602 Dr. Linda Little Governor's Waste Management Board 513 Albermarle Building 325 North Salisbury Street
- Raleigh, North Carolina 27611
TECHNICAL EVALUATION REPORT OF THE
~ DETAILED CONTROL ROOM DESIGN REVIEW FOR CAROLINA POWER AND LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT i ~ 4
~
L li&b ~ ~
~ ~
UNIT 1
NOVEMBER 4, 1985 JACK W. SAVAGE Law ence Livermore National Laboratory for the United States Nuclear Regulatory Commission 171 03085MU
Table oi Contents 1.0 Background..........................................................1 2.0 Disc scussiono
~ ~ eo ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ t ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ y ~
~ ~ ~ ~ ~ ~
~ ~ ~ ~ ~ ~ ~ 3 2.1 Establishment of a Qualified Hultidisciplinary Reviev Team.....4 2.2 System Function and Task Analyses...........................,,.5 2 ~ 3 Comparisori of Display and Control Requirements vith a Control R
I oom nventory.................................................
10 2.4 Control Room Survey............................................11 2.5 Assessment of HEDs.............................................15 2.6 Selection of Design Improvements...............................18 2.7 Verification that Design Improvements Provide Necessary Correction and Do Not Introduce Ne~ HEDs....................,..21 2.8 Coordination of The DCRDR With Other Programs..................23 3 ~ 0 Conc usions
~ ~ ~ ~ ~
~ ~ ~
~ ~
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
~ ~
~
~ ~ ~ ~ ~ ~ ~ ~
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o25 ncius References...............................................................28 Appendix A...................
~.. ~...
~ ~. ~.............,...................29
~ ~
~
~
~ ~ ~
~
~ l ~
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
~ ~
TECHNICAL EVALUATION REPORT OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR CAROLINA POWER AND LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1
1.0 BACKGROUND
Licensees and applicants for operating licenses shall conduct a Detailed Control Room Design Review (DCRDR).
The obgective 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).
The need to conduct a DCRDR was confirmed in NUREG-0737 and Supplement 1 to NUREG-0737.
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-0700 describes four phases of the DCRDR and provides applicants and licensees with guidelines for its conduct.
The phases are:
- 1. Planning
- 2. Review
- 3. Assessment and implementation
- 4. Reporting
Supplement 1 to NUREG-0737 requires that the DCRDR include the following elements:
- 1. Establishment of a qualified multidisciplinary review team.
- 2. Function and task analyses to identify control room opera r tasks and information and control requirements during emergency operations.
3.
A comparison of display and control requirements with a control room inventory.
4.
A contr ol r oom survey to identify deviations from accepted human factors principles.
- 5. Assessment of human engineering discrepancies (HEDs) to determine which 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.
- 8. Coordination of control room improvements with changes from other programs such as the safety parameter display system (SPDS), operator training, Reg.
Guide 1.97 instrumentation, and upgraded emergency operating procedures (EOPs).
Licensees are expected to complete Element 1 during the DCRDR' planning
- phase, Elements 2 through 4 during the DCRDR's review phase, and Elements 5
through 7 during the DCRDR' 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.
As a minimum it shall:
- l. Outline proposed control room changes.
- 2. Outline proposed schedules 1'or implementation.
- 3. Provide suaaaary Justifioation for Hgns uith safety signikanoe to be left uncorrected or partially corrected.
The NRC staff evaluates the or ganization,
- process, and results of the DCRDR.
Results of the evaluation are documented in a Safety Evaluation Report (SER) published within two months after receipt of the Summary Report.
2.0 Discussion By letter NLS-85-325 of September 13, 1985, Carolina Power and Light Company (CPKL) submitted a
CRDR Final Summary Report for Shearon Harris Nuclear Power
- Plant, (SHNPP) Unit 1.
Also submitted were two enclosures, a "Background and CRDR Licensing Chronology", (Enclosure 1), and a "Response to SHNPP SER Supplement No.
1, open Item No. 14.
Subpart 1.D.l: Control Room Design Review" (Enclosure 2).
These aggregated responses to the NRC audits, reports and correspondence are intended by CPKL to adequately address the satisfaction of CRDR requirements.
Note that the NRC acronym "DCRDR" and the CPAL acronym "CRDR" have the same meaning.'he evaluation in this report is based on thy Shearon Harris Unit 1 Final Summary Report and Enclosures
- 152, above)
This evaluation considered the following:
o Ag>assessment of the SHE~
CP8L conveyed by the text of the Summary Report to audibly comply with Supplement 1 to NUREG-0737.
o An assessment of the degree of audible step by step detail of CRDR processes.
o An assessment of the audible nature, details, and completeness, of CRDR revie~ criteria.
o An assessment of the audible details of systematic and comprehensive execution of the CRDR processes.
The Summary Report conveys a definite intent by CPEL to comply with the NRC requirements.
Host of the following critical comments stem from not being able to find examples or descriptions of audible details of the above items in the CPKL Final Summary Report.
2.1 Establishment of a Qualified Hultidisci linar Review Team Supplement 1 to NUREG-0737 requires the establishment of a multidisciplinary review team.
Guidelines for team selection are found in NUREG-0700.
2.1.2
~Findin s CP8L established a multidisciplinary review team for the DCRDR of the Shearon-Harris Nuclear Plant.
The team consisted of CP8L and Essex Corpor ation personnel, representing a cross-section of the required disciplines.
The team was supported, by the Architect and Engineer (ALE) (Ebasco),
the Nuclear Steam Supply System (NSSS) vendor (Westinghouse) and other qualified individuals, as appropriate.
The qualifications of the review team members are contained in Appendix F of the CPKL summary report, and a description of the review team composition is stated in Section 2 of the Summary Report.
The review team was divided into the following three groups:
o Human Factors Evaluation Group.
o Human Factors/Operations Support Group.
o Pro)ect Management/Nuclear Operations/Plant Engineering and Design Group.
Figure 2-1 of the CPKL report describes the structure of the CRDR completion/reassessment dedicated'core team.
Figure 2-2 of the CP8L report outlines the task responsibilities of team members and team leaders in the categories of primary and support responsibilities and approval authority.
Section 2.2 of the CPSL Report describes the CPKL management support given to the review team.
Tasks appear to have been assigned to team members with the appropriate expertise to effectively accomplish DCRDR tasks, but there are not task/team assignments stated specifically.
2.1.3 Conclusions The CP5L summary report confirms the conclusion stated in the on-site Audit Report of 3-28-84 that the CPhL review team has met the requirement of Supplement 1 to NUREG-0737 to establish a multidisciplinary review team to conduct a DCRDR.
2.2 S stem Function and Task Anal sis Supplement 1 to NVREG-0737 requires the applicant to perform system function and task analyses to identify control room operator tasks and operator
information and control requirements during emergency operations.
Furthermore, Supplement 1 to NUREG-0737 recommends the use of function and task analyses that had been used as the basis for developing emergency operating procedures, technical guidelines, and,plant-specific emergency operating procedures to define these requirements.
2.2.2
~Findin s CPIL used the Westinghouse Owners Group (WOG) Emergency
Response
Guidelines (ERG), Revision 1, and the MOG High Pressure (HP) Basic System Review and Task Analysis (SRTA) as the basis for developing and performing the SHNPP Systems Function and Task Analysis (SFTA).
We interpret Section 6.4 of the summary report to state that CPSL used the WOG generic analyses as a bases ior the following:
o Construct, from the WOG generic ERG HP Basic SRTA Hatrix and Element
- tables, a SHNPP plant-specific version of the SRTA Task/System Sequence Matrix tables and Element tables.
(Figures 6-1 and 6-2 of the Summary Report).
Figure 6-1 identified the tasks and subtasks associated with each ERG guideline.
Figure 6-2 identified the data needed to determine action and information requirements.
o Create a set of SHNPP-1 plant-specific ERGs.
o Create an EOP/ERG "Transition Document" which consists of these sections:
A list of differences between the WOG ERG HP reference plant and SHNPP-1.
- A set of deviation forms that explain the variances in tasks and task steps between SHNPP-1 ERG steps and WOG ERG steps.
A list of parameter value deviations between the SHNPP-1 EOPs and the SHNPP-1 ERGs.
o Combine the above items with "related background information" and "generic task analytic background information".
o Create lists of plant specific Action and Information Requirements details (AIRDS) (Figure 6"3 of the summary report).
o Create from the AIRDS a computer ized data base and use it for selecting and sorting to summarize information and action requirements across tasks and elements.
It is stated that this AIRDS data base was used during the verification of task performance capabilities to:
o assess the availability and suitability of instruments and equipment used by control room operators and-o to assist in the selection of event sequences to be analyzed during the validation of control room functions.
The above responds to the concerns expressed in the NRC on-site audit report of March 28,
- 1984, and describes the CPKL methodology to identify the characteristics of information and control needs independently of what exists on the control board.
However, the summary report lacks examples or a level of detail sufficient to demonstrate how the documents and review team efforts were interfaced to satisfy the requirements of Supplement 1 to NUREG&737 have been met.
Some specific concerns are:
o The "Transition Document" is stated to contain descriptions of differences and deviations of SHNPP-1 from the generic guidelines.
However there are no examples, descriptions, or )ustifications of the
differences given, nor is there any indication of how the differences were determined, how it was ensured that the analysis was complete and
- accurate, or how the characteristics of needed information and controls were generated in an audible manner.
The quality of this work is highly dependent on the qualifications of team members, but ther/ is no statement describing who did the work.
o It is stated that information to support the SFTA was obtained from "related background information" and "task analytic background information".
However,,these sources are not specifically listed and described, nor is it explained how they were used to identify the characteristics of needed instrumentation and controls.
o The SHNPP-1 SFTA was stated to have been used to support the scenarios/event sequences chosen to be analyzed in the validation process described in Section 6.7 of the smaaary report.
These important events are listed in Section 6.7.2.2 of the Summary Report, and are critical to the adequacy and completeness of the validation effort.
However no descr iption is given of how the analysis and selection was made to ensure that the selected events/scenarios are complete and comprehensive enough for contr ol room operators to respond effectively to all emergency operations and that all HEDs will be identified for corrective action.
o It is not clear that the detailed identification of component characteristics needed is comprehensive enough to allow a one-to-one comparison with existing inventory.
(e.g.
whether the comparison would identify needs and equipment to suitable pr ecision of measurement readout and suitable control capability).
I o
The methodology and criteria used with the AIRD (Figure 6-4) print-outs to make the comparisons and identify HEDs is not clear.
o It is not clear where the HEDs identified by the comparison process are listed in the appendices.
In order that it can be determined that CPKL has acceptably met the SFTA requirement of Supplement 1 to NUREG-0737, the SFTA processes arg methodology should be clearly understood by the NRC.
The applicant's descriptions should i'nclude the following:
o Descriptions of the approaches and information sources used (e.g.,
documents, guidelines, operations personnel, multiple approaches, plant-specific calculations, etc.).
o The rationale and methodology used in the selection and verification that the selected plant-specific sequences adequately cover the complete range of SHNPP-1 systems needed to mitigate abnormal plant conditions.
o The processes used to identify the functions, systems, subsystems, and events selected for analysis.
o Descriptions of how the independent reference
- sources, the information and control needs and characteristics, and the inventory process were coordinated to ensure independence, completeness, and accuracy.
The lists of needs and characteristics should allow a one-to-one comparison with the inventory characteristics in all respects.
It is possible that the concerns stated above would be clarified by filled-out examples of all plant specific SHNPP-1 working documents
- used, referenced to an appropriate diagram which shows the progress/review/team/document interfaces.
I An essential part of the above is the method by which the independent reference sources ~ere documented and used to ensure the independence of the identified characteristics of the information and control needs from those
of existing equipment.
2.2.3 Conclusions GPC should be prepared to reinforce their explanation of the metaodology used by CP8L to conduct their SFTA.
Evidence to support the identification of operator information and contr ol needs that have been determined from a SFTA is needed for CPSL to meet the requirements of Supplement 1 to NUREG-0737.
2.3 Com arison of Control and Dis la Re uirements with a Control Room
~Inventor 3
Supplement 1 to NUREG-0737 requires the applicant to make 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 used to satisfy operator information and control needs.
CPKL conducted a systematic inspection and review of the control room and relevant documentation to develop the control room inventory.
Sections 6.1.3.4, 6.5.
and 6.6 of the Summary Report contain short statements of the inventory method, but there are no examples which illustrate that the inventory format and content is sufficiently detailed to allow a one-to -one comparison of control room equipment with the characteristics of the information and control requirements generated by the SFTA.
It is not clear how the CPSL methodology ensured that an exact and complete matching of existing equipment with SFTA needs was accomplished, discrepancies and HED corrective actions identified and recorded, and audible records maintained.
The descriptions should cover, but not be limited to:
o Be complete and current.
< >g*>~ g<f 4 o d con%co o
Accurately depict theg8C)equipment which exists on the cc4trol panels.
o Comprehensively describe the IEC equipment character istics (e.g.,
- scales, ranges, accuracies, parameters,
- steps, control characteristics, etc.).
o Serve as a proper basis for comparison with IbC needs to identify discrepancies eligible for corrective action.
o Be effectively used by competent DCRDR team members to accurately and completely identify existing HEDs and as a basis to initiate effective corrective actions.
2.2.3 Conclusions In order to meet the requirement of Supplement 1 to NUREG-0737 CP5L should be prepared to demonstrate to the NRC that the inventory is accurate and
- complete, and fulfills the requirements of Supplement 1 to NUREG-0737.
2.4 Control Room Surve Supplement 1 to NUREG-0737 r equires 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~F1ndtn s
CPKL per formed SHNPP-1 control room surveys in 1980 and 1981 using NUREG/CR-1580 guidelines (Section 3 of the Summary Report).
In June to December 1983 they surveyed 13 Back Panels (Summary Report Sections 1.2.5,
- 4) kd the Auxiliary Control Panel (Sunmary Report Sections 1.2.6,
- 5) using NUREG-0700 guidelines.
During the above time period, the NRC issue'd various updated guidance and conducted an on-site In-Progress Audit in August, 1983.
CPKL responded by reviewing their prior work, updating their CRDR plans, and initiated CRDR Completion/Reassessment activities in December, 1984 (Summary Report Sections 1.2.7, 6,7).
The surveys are complete except for 4 surveys which will be conducted prior to fuel load because they must wait for CR construction to be completed.
Due to the circumstances described above the CPKL methods and HF guidelines have been appropriately modified to meet current NRC requirements.
Correspondence during the above time between CPSI and the NRC is sunmarized in a reference list in Section 1.1.1 of the summary report.
The CPSL Completion/Reassessment program was subdivided into the following tasks:
Task Summar Re ort Section Operating Experience Review Conduct Surveys System Functions and Task Analysis Control Ro'om Inventory Verification of Task Performance Validation of Control Room Functions
.SPDS Review 6.2 6.3 6.4 6.5 6.6 6.7
- 6. 3. 3.10 These tasks are abstracted in Section 6.1.3 of the summary report, and detailed in the sections tabulated above.
The Completion/Reassessment control room surveys were planned to follow the guidance oi NUREG"0700, Section 6.0.
The surveys that were performed are:
1.
Morkspace 2.
Anthropometrics 3 ~
4 ~
5.
Emergency Equipment Maintainability Annunciator System 6.
Controls 7.
Displays 8.
Labels and Location Aids 9.
Computer System
- 10. Conventions The following surveys have not yet been conducted because of the unfinished status of the CR.
1.
Ambient Noise 2.
Illumination 3.
HVAC 4.
Communi cati ons Each survey was directed by a task plan containing procedures covering the following areas, as appropriate:
1.
Measurements 2.
Observations 3.
Questionnaires/Interviews 4.
Document Reviews Details of the task plan organization and procedures are described in Section 6.3.2 and Appendix E of the senary r eport.
The HEDs'dentified are summarized in narrative form in the Summary Report Sections listed below, and in more detail in appendices A-1 through A-26 and Appendix B of the summary report.
The HEDs were identified by the intermingling of the seven survey tas processes described in section 6.1.3, of the summary report Our review of the Appendices is summarized in Appendix A of this report.
Sub ect Summar Re ort Section o
HF Design Evaluation of SHNPP-1 (1980-81) o Back Panels (1983) o Auxiliary Control Panel (RSP)
(1983) o Operating Experience review o
Control Room Surveys o
Verification o
Validation 3.2.4 4 '
5 '
6.2.2.4 6.3.3 6.6.4 6.7.3 The HEDs fall into the following areas:
o CR generic HED types which exist in various combinations on several CR panels.
o HEDs resulting from individual surveys of specific CR panels/systems.
o HEDs resulting from specific CRDR activities (e.g., Operating Experience Review (OER) Verification, Validation, In-progress audit, Safety Parameter Display System (SPDS).
There are no HEDs specifically identified as having originated from the SFTA/Inventory comparison.
2.4.3 Conclusions CPSL has planned and executed a detailed and comprehensive CR survey which is complete except for the four areas yet to be finished.
When CPhL completes and reports to the NRC the four remaining surveys in the Cc same manner as the ten completed survey~
The control room survey requirements of Supplement 1 to NUREG 0737, will be met.
2.5 Assessment of HEDs Supplement 1 to NUREG-0737 requires that HEDs be assessed to determine which HEDs are significant and should be corrected.
NUREG&700 contains guidelines for the assessment process.
Section 2.5 and Exhibit 2.2 of Appendix A to SRP Section 18.1 contain additional assessment guidance.'he obJective of the assessment process is go identify HEDs that can individually or interactively impact plant safety, operator physical performance, sensory/perceptual performance, and/or cognitive performance.
Examples of significant task variables are communications
- needs, task duration and frequency, delay or absence of
- feedback, accuracy and speed requirements, and concurrent task requirements.
2.5.2
~Ftndin s s
The present Completion/Reassessment program differs from the originally stated CPKL policy to fix all HEDs during the re-design process so as to end up with an "HED-Free" design.
The stated CPSL policy was to correct every HED by designing it out of the system, with the obJective of achieving an HED-free board.
The execution of this philosophy obviates the necessity to follow the NVREG-0700 recommendations of formally assessing each HED for importance, potential safety consequences, the cumulative impact of minor HEDs, determination of priorities, setting implemerltation schedules, etc.
The in-aQ SeC5oh 1~', + I f+ Ppid+LCCf P ~
'ggEg progress audit team report of March 25, 1984 concluded that the original~+"SQ~~
A policy was acceptable.
The modified policy states, in Section 7.2 of the summary report, that the HED Assessment Team (HEDAT) assessed all HEDs, evaluated their relative significance, and placed each HED in a category determined by safety consequences, violation of technical specifications, and potential f'r degradation of performance or operator error.
Following assessment, the HEDs were reviewed and decisions made concerning the extent to which corrective actions would be selected and implemented.
The par aphr as ed cat egor ies ar e:
~Cate or Comment Violation of a technical spegif ication, or might lead to a safety significant error Determined to be oi valid concern Low probability of error IV No probability of error and no impact on operator perf ormance The HEDs were reviewed as follows:
Category IV HEDs were assessed and appropriately recategorized if found to have cumulative and interactive effects.
All HEDs collected in Categories I, II, and III were analyzed and identified for disposition as follows:
o Correct by enhancement, training, and/or procedural revisions o
Correct by design improvement alternatives The above method is described in Section 7e2 and Figure 7-1 of the Summary
- Report, and outlines the steps used to identify HEDs which should be corrected.
However the degree of detail given in the summary report is insufficient to allow an evaluation of how the steps were documented and executed in a complete, orderly, and methodical
- manner, and what criteria were used in making decisions.
There is no statement which describes how the I
modified methodology and criteria differs from the previously approved methodology/criteria.
0
2.5.3 Conclusions The NRC must be able to evaluate the equivalence of the modified assessment process compared to the assessment process that was previously found to be acceptable by the NRC audit team during the DCRDR In-Progress Aukt. CPKL should be prepared to convey to the NRC an acceptable understanding of the criteria, the process, and its execution and documentation.
2.6 Selection of Desi n Im rovements Supplement 1 to NUREG-0737 requires selection of control room design 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
~Findin s As stated in the NRC in-progress audit report, alternate design improvements for each HED were considered during the CPKL redesign review process, executed during the redesign of the Harris MCB.
NUREG-1580 criteria, along with the Essex developed Human Engineering Requirements Specifications (HERS) were used to support the review team choice of resolutions for each HED.
The conduct of the redesign effort was similar to the determination of a new design.
It was stated that part of the redesign effort included ongoing discussions with operators to verify that the MCB redesign details and HED corrective actions were compatible with operational
- needs, and left no discrepancies uncorrected.
This included verification that any equipment found missing was, or would be, installed. before the redesign was considered complete.
The
'olicy of correcting all HEDs during the execution of the redesign process prior to operation obviated the necessity of selecting an implemynting schedule.
The NRC audit team concluded that the applicant would satisfy requirements of Supplement 1 to NUREG-0737 if the SHNPP DCRDR summary report completely documents the methodology and results of design improvement selection so that the NRC can confirm that the requirements have been satisfied.
The staff concluded in Section 18 5.2 of Supplement 1= to Safety Evaluation or(C)(~4<
'eport for SHNPP-1 that the gr ocess ior selection of design improvements was acceptable.
The selection process descry ibed in Sections 7.2 and 7.3 of the summary report included consideration of the following criteria, regardless of HED priority ranking:
o The limit to the number of changes that could be made.
II o
Cost-benef it ~
o Scheduling considerations.
o Analyses for correction by enhancement/design alternatives.
o Integr ation with other Supplement 1 to NUREG-0737 programs.
o Potential constraints (e.g. availability of equipment.
o Impact on operator training, safety consequences, and probability of operator error.
o The extent of the proposed correction.
The methodology for using the above criteria were not described in the Summary Report. It is recommended ghat CP8L be requested to demonstrate that the methodology described in the Summary Report is equivalent to the previously accepted methodology.
Corrective actions for all HEDAT approved HEDs were stated to be scheduled for implementation prior to fuel load.
The schedule was determined according to the HED priority and in con/unction with SHNPP-1 manpower and work schedules.
When corrective actions were completed the site prospect coordinator was notified and arranged for the correction to be reviewed by a hman factors specialist.
It is not clear whether this was done before or after implementation of the corrective action.
Discrepancies which were not fully corrected were stated to have been
)ustified.
These HEDs and Justifications are not specifically identified in the report. It is recommended ~t CPKL be requested to identify and submit for NRC review the incompletely corrected HEDs and resolutions and their J us tifications.
The following items are not described in sufficient detail to evaluate and support a conclusion that the NRC requirements for selection and implementation of design improvements have been systematically met:
o The selection and specification of corrective actions.
o The method used to choose an acceptable action from among alternate proposals.
o The method for recording HEDs and following the progress to the completion of implementation.
o The system for coordinating and correlating changes with EOPs and operator training.
o The approach to explore the interaction of HEDs and proposed corrective actions with other HEDs.
o The method of using HED categories to determine implement@g priorities and schedules.
2.6.3 Conclusions The SHNPP-1 summary report briefly describes a generally acceptable approach to the selection of design improvements.
~vCv The NRC must be able to evaluate the equivalence of the modified selection process compared to the selection process that was previously found to be acceptable by the staff.
CP8L should be prepared to convey to the NRC an acceptable understanding of the criteria, the process, and its execution and documentation.
2.7 Verification of Control Room Desi n Im rovements Supplement 1 to NUREG-0737 requires verification that selected control room design improvements will provide the necessary corrections of HEDs and will not introduce new HEDs into the control room.
2.7.2
~Findin s The In"progress Audit Report stated that the execution of the CPEL MCB redesign process to design HEDs out of the system incorporates HED assessment, the consideration of alternate designs in the selection and implementation of design improvements, and the use of the mock"up to study and confirm MCB rearrangements.
As explained to the NRC audit team, it 4s inherent in this process that HED corrective actions will be verified to provide the necessary corrections of HEDs without introducing new HEDs.
Section 6-6 of the Summary Report briefly describes the obJectives of the CpaL verification task.
Section 7.3.4 of the summary report briefly gates that in determining the backfit for each HED the HEDAT verified that no new HEDs were
- created, other corrections were not invalidated, and that the correction is in compliance with NUREG-0700 guidelines.
HEDAT verification was supplemented where possible by using mockups, computer aided design systems, the simulator, and HB Robinson EOPs.
There is insufficient detail to indicate how differences between the SHNPP1-CR and EOPs, and the simulator and HB Robinson EOPs were identified and accommodated.
Some obJectives of verification are to confirm that:
o The corrective action chosen will correct the HED.
o The correction does not generate new HEDs.
o The corrective actions follow accepted human factors practices.
o Effects on operations, training and procedures are identified and corrected.
o Plant operation and safety are enhanced.
o Interactions among HEDs and corrective actions are considered.
o Plant and control room conventions exist and are consistently followed.
It is not clear whether the modified "categorize and assess HEDs" policy described in Section 2.5 of this report has altered the originally deemed acceptability of the CPKL verification process.
It is recommended that additional dialogue between the NRC and CPKL be initiated to resolve this situation.
2.7.3 Conclusions The NRC must be able to evaluate the equivalence of the current verification C ~gcged process and its execution by the CRDR team to the previously acceptable process.
CPEL should be prepared to convey to the NRC a complete and unambiguous understanding of the criteria, the process, and its execution and documentation.
2.8 Coordination of Control Room Im rovements with Other Pro rams Supplement 1 to NUREG-0737 requir es that control room improvements be coordinated with changes from other programs; (e.g., safety parameter display system (SPDS),
oper ator training, Regulatory Guide 1.97 (R.G.
1 ~ 97)
~ and emergency operating procedures (EOPs) ).
2.8.2
~Findin s The Lead Discipline Engineer (LDR) served as coordinator between the CRDR and NUREG-0737 activities.
Section 1.3 of the summary report states that CPhL recognizes the interface between the CRDR and the other programs, and that the CRDR organization includes consideration of the need for coordination with other activities to implement NUREG-0737 activities to satisfy NUREG-0737 requirements.
The summary report briefly describes the integration (coordination) of the CRDR human factors effort with the SPDS, Reg. guide 1.97, EOPs, operator training, and the ERF.
The summary report does not include detailed statements concerning the step-by-step conduct of integration actions among the various initiatives.
Neither is a comprehensive system described whereby the LDR was. formally consulted and/or advised by others concerning matters which should be coor dinated.
2.8.3 Conclusions The NRC in-progress audit report of March 28, 1984, stated that the intent of the coordination process was adequately recognized and planned.
CPhL should be requested to demonstrate to the NRC that an audible and comprehensive coordination effort was executed to meet the requirements of Supplement 1 to NUREG-0737.
"24"
- 3. 0 Conclusions O P~ P~.Q It is apparent that CPIL intends to meet the requirements of Supplement 1 to NVREG-0737 and to follow the guidelines of NUREG-0700 and the Standard Review Plan NUREG"0800 Section 18.1, Appendix A, Their updated CRDR Prpram Plan is organized with this in mind and generally describes a process and methodology which is capable of meeting the NRC requirements.
However the Summary Report does not describe the total effort in sufficient detail to support a conclusion that the program plan was executed and documented to meet all requirements to the satisfaction of the NRC.
In order to satisfy the NRC, CPKL should be prepared to demonstrate that they have executed and documented a
CRDR which is complete, and systematic, and have r esponded to the NRC CRDR policy which requires audible compliance with Supplement 1 to NUREG-0737.
The CRDR will become acceptable when CPJL has demonstrated to the NRC the following:
o Comprehensive and systematic documentation of the processes used for the execution of the remaining CRDR tasks.
o Detailed and systematic documentation of the criteria, factors and guidelines used by the CRDR team in executing the CRDR tasks.
o The identification of audible records of all phases of the CRDR.
The following is acceptable:
o Establishment of a qualified multi-disciplinary review team The following are provisionally acceptable:
o A contr ol room survey to identify devations from accepted human factors principles, Hrovided that the unfinished surveys are completed in the same manner as the completed surveys and reported on a schedule acceptable to the NRC.
The unfinished survey areas are:
Ambient noise Illumination HVAC Communications o
Assessment of HEDs to determine which HEDs are significant and should be corrected, ~rovided that CPaL demonstrates the equivalence of the modified process to the previously acceptable process.
o Selection of Design Improvements, provided that Cpai demonstrates the equivalence of the modified and the pr eviously acceptable process.
o Verification that control room design improvements will provide the necessary correction of HEDs and will not introduce new HEDs, ~revised that CPKL demonstrates the equivalence of the current and the previously acceptable process.
o Coordination of control room improvements with changes from other programs, ~rovided that CpaL demonstrates the acceptability of their execution of the previously accepted plan.
The remaining areas to be completed and reported are:
o Function and task analyses to identify control room operator tasks and information and control requirement during emergency operations,
o Comparison of control and information requirements with a control room inventory.
It is recommended that the above demonstrations of compliance with the NRC requirements be conducted during an on-site pre-implementation agdit.
The following items should be addressed and resolved by CPKL in a manner acceptable to the NRC.
Some open HEDs are noted in Appendix A to this report as follows:
o A13-31F8-2115 o
A16-31AC-2105 o
A17-3100-0502 o
A17-31F8-2120 o
A17-3100-0507 o
A17-3100-2120 o
A24-31G1-5069 o
A26-31BO-5060 o
Appendix B wrong reference items The HEDs listed in A16 which are related to ACP Appendix R operations.
Other HEDs in Appendix A of this report should be addressed by CPKL and resolved in a manner acceptable to the NRC.
CPEL should submit for NRC review the identification and Justification of incompletely corrected HEDs.
REFERENCES 1.
Human Factors Design Evaluation Report for Shearon-Harris Unit 1 Control Room, January 23, 1981, revised September 16,
- 1981, and APril 14,
- 1983, 2.
Supplement 1 to NUREG-0737, '"Requirements for Emergency
Response
Capability" (Generic Letter No. 82-33),
December 17, 1982.
3.
NUREG-0700, "Guidelines for Control Room Design Reviews," September 1981.
4.
NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants", Section 18.1 Appendix A, "Evaluation Criteria for Detailed Control Room Design Reviews",
September 1984.
5.
CPKL letter LAP-83"156 to H. R. Denton, supplemental information to the DCRDR summary report entitled, "Human Factors Design Evaluation Report for the Shearon-Harris Unit 1," June 1, 1983.
6.
CPKL letter LAP-83-426 to H.
R. Denton, information r equested by the NRC audit team, September 27, 1983.
7.
NUREG-1580, "Human Engineering Guide to Control Room Evaluation," July 1980.
8.
"Meeting Summary Task Analysis Requirements of Supplement 1 to NUREG-0737March 29, 1984 Meeting with Westinghouse Owners Group Procedures Subcommittee and Other Interested Persons,"
Memorandum from H.
Brent Clayton, to Dennis L. Ziemann, April 5, 1984.
9, CP5L letter NLS-85-315 to H. R. Denton, "Response to SER Supplement No.
1, open item No. 14, Subpart I.D1. Control Room Design Review" with 3 enclosures including the CRDR Final Summa y Report, September 13, 1985.
10.
LLNL In-Progress Audit report of March 28, 1984.
Il ~
64'-C,
<e4+ev W 5K Ot~Cy lSS~a e~ ~q X~~rie~e + i S8+ 00-I )'~Lq f) IQ p~
l&-7.
)
~, q~
~~
~
~
~~~j
~Aendix A
This appendix contains LLNL reviewer comments on HEDs reported in Appendix A
of the SHNPP-1 summary report.
HED's are included below if it was felt that the disposition was not complete enough to evaluate, a fix was spple, the HED might have safety implications, or the HED is still open.
The listed HEDs should be addressed by CP8L and an acceptable resolution reached with the NRC.
Many of the summary texts presented in Appendix A of the Summary Report do not contain enough information to allow a valid Judgement to be made.
It is recommended that the NRC initiate discussions with CPKL to resolve the dispositions of these HEDs.
~Aendix HED Number Comment A-1 GROUPING AND SEQUENCING HEDS No comment A-2 HEDs BASED ON THE HARRIS SIMULATOR These "old simulator" HEDs do not apply directly to the SHNPP-1 CR or to the new simulator now being delivered.
CPKL should be prepared to discuss with the NRC whether the new simulator is an exact duplicate of the CR, and how differences will be accommodated and/or )ustified in relation to simulator vs actual CR training and walk/talk throughs.
HEDs listed below concern operational characteristics which may be important to safety.
They should be reconsidered and reviewed and CPSL should be prepared to addressed them in communications with the NRC.
3100-2204 3100-2205 Meters do not fail off-scale.
r
31E1-2206 3100-2207 Meter parallax Pointers obscure index marks and scale numbers 3100-2302 31B2-2409 3100-2410 3100-2413 31E1-3101 3100-3403 31B1-3409 No "push-to-test" feature Strip chart color code inconsistencies Symbols not legible Use of gr ease pencil labels Inaccessible Set-point scales.
Administrative "fix" for legend plate interchangeability 3100-3406 3100-3407 31B1-3408 Legend push button size,vs consequence oi'isoperation Push button shape vs consequence of misoperation Training as solution for push button/legend light misidentification A-3 AUXILIARYEQUIPMENT PANEL HEDs 31D9-1110 Engraving does not meet criteria 31D9-111 31D9-1112 31D9-2016 31D9-2109 31D9-2306 31D"3412 Is the stated disposition ok fram safety standpointV Maintenance procedure fix for uncoded tiles No bulb test facility Push button resistance is too high A-'4 INCORE MONITOR HEDs 31 E1-1 401 31 E1-3022 31E-3023 Un-named components too high Disposition does not address safety issue
.Control movement is backwards Torque less than criteria 31E-3211 31E-5010 Fixed pointer and moving scale.
Insufficient description given to support a
J udgment Components too high A-5 NUCLEAR INSTRUMENTATION SYSTEM HEDs 31E2-2307 Non-standard abbreviations A"6 RECORDER PANEL HEDs 31E6-2216 31E6-2217 31E6-2221 Recorder scales do not meet criteria 31E6-3026 31E6-5012 Functional switch movement reversed Inconsistent grouping A-7 STARTUP TRANSFORMER PROTECTION RELAY PANEL HEDs 31F1-1701 Light do not meet criteria 31F1-3213 Knob does not meet criteria 31F1-5016 Incomplete labels A-8 GENERATOR PROTECTION RELAY PANEL HEDs 31F2-2223 31F2-5017 31F2-5018 Meter scales do not meet criteria Grouping is not obvious Misleading labels A-9 GROSS FAILED FUEI DETECTOR PANEL HEDs 31E3-1702 Indicator lights do not meet criteria.
Is indicator needed?
31F3-5020 31F3"5022 31F3-5024 31F3"5026 Alarm light missing.
Is a secondary indication adequate?
Possible to lock out all alarms Inconsistent meter scale lables Use of training to address inconsistent color coding A-10 LOOSE PARTS MONITOR HEDs 31F4-1150 31F4-1706 31F4-3027 31F4-5028 Missing labels No bulb test.
Unkeyed lenses permit interchanging Moving scales increase to the left.
Use of training to address inconsistent color coding A-11 RCP VIBRATION MONITOR HEDs 31F6-1151 Missing labels A"12 SEISMIC MONITOR PANEL HEDs 31 F7-1 1 31 31F7-1148 31F7-1149 Missing label Labels/lettering do not meet criteria 31F7-3210 31F7-3212 Incorrectly oriented switches 31F7-5036 Use of training to address inconsistent color coding A-13 COOLING TOWER MAKEUP CONTROL PANEL HEDs 31F8-1705 Indicator lights do not meet criteria 3128-2'I15
~Oen item unr eeolved 31F8-3215 Switch torque to high.
A-14 RADIATION MONITORING SYSTEM HEDs 31E4-1184 Labels do not meet criteria 31E4-1185 31E4-1188 A-15 AXIAL POWER DISTRIBUTION MONITORING SYSTEM HEDs 31E3-1175 No label 31 E3-1 1 77 31E3-1319 31E3-1320 31E3-171 3 31E3-2310 Label does not meet criteria Use of training to address inconsistent color coding Indicator light do not meet crgteria Ambiguous messages and improper use of indicator lights A-16 AUXILIARYCONTROL PANEL HEDs 31AC-2103 31AC.-2105 31AC-2204 31AC-2207 31AC-3201 31AC-3202 31AC-3206 31AC-3207 Lack of demarcation lines.
Not enough information given to evaluate lack of corrective action abbreviation for two meanings.
Meter pointer clearance does not meet criteria Meter graduation marks do not meet criteria.
Insufficient information to evaluate lack of replacement Control movement opposite fr cm convention (note some switches with same HED have been changed (e.g.
31AC"3203)
Control knobs do not meet criteria. It is not stated how the search for an eventual replacement will be administered.
31AC-5021 31AC"5032 Pump indication arrangement different from MCB Mirror engaged indicators 31AC-5033 31AC-5034 31AC-5035 31AC-5036 31AC-5037 31AC-5038 t
Components arranged differently from MCB.
e a
31AC-5039 The following HEDs are related to operator tasks involved in a remote shut down/Appendix R operation which is beyond the scope of a human factors review.
These s(ould be referred to other reviewers.
31AC-2110, 31AC"5002, 31AC-5003, 31AC-5005, 31AC"5007, 31AC 5008g 31AC 501 1 g 31AC 501 4g 31AC 5015
~
31AC 501 9g 31 AC 5020
~
31 AC 5028
~
31 AC 5029 e
31 AC 5030
~
31 AC 5040 ~
31AC05041 A-17 OPERATOR EXPERIENCE REVIEW HEDs 3100-0201 3100-0502 Inadequate sound powered telephone system description not complete enough to evaluate disposition.
~0 en item to be reviewed in communication survey.
31FB-2120 3100-3217
~Oen item to be r eviewed during noise survey.
Control switch torque/design above criteria see A-16 31AC-3202 for comment.
31C1-3222 31A2-5052 3100-5053 3100-5054 3100-5056 Disposition may not adequately address this Safety Infection actuation switch.
Information provided on Computer instead of via Conventional indication 3100-0507 3100-2120
~Oen item to be evaluated during communication survey
~Oen item to be evaluated during noise survey.
A-18 ANTHROPOMETIRC HEDs 3100-1409 3160-1411 3160-1410 Controls are out of reach of 5th percentile female operators Knee-room are sit-down console is less than criteria A-19 EMERGENCY EQUIPMENT HEDs No Comment A-20 ANNUNCIATOR HEDs 3100-2123 3100-2125 3100-2128 3100-2132 Space between lines of engraving is too small Annunciators have more than 50 tiles per matrix Annunciator system has multi-input alarms Annunciator tile engraving letter height does not meet criteria.
The response does not address the HED.
A-21 CONTROL HEDs 3100-3216 31A1-3218 3100-3417 31AA-3419 3100-3421 Control knob characteri sti cs do not meet criteria.
How will search for new knobs
- bee, administered' Control/switch torques/resistance does not meet criteria Annunciator controls are not coded A-22 DISPLAY HEDs 3K1-2308 3100"2309 Legend light engraving has more than three l
times of text A-23 LABELING HEDs 3100-1154 Engraving does not meet criteria A-24 ERFIS AND SPDS COMPUTER HEDs 3162" 1162 31GO-1165 31GO-1314 31 62-1 71 2 3160-3422 31G1-5068 31 G1-5069 31G1"5071 Engraving does not need criteria No position labels Key sequence reversed and inconsistent styles on. keypad.
Legend lights can be interchangd Legend light and legend pushbutton not distinguishable Character size hard to discriminate
~0 en items in investigation is on-going A-25 CONVENTION HEDs 31 A1-1 317 Control switches movement are opposite to convention A-26 VERIFICATION AND VALIDATION HEDs 31BO-5060 3100-5064
~0 en item investigation on-going t'
'r
~Aendtx In-Pro ress Audit Re ort
~FAndi n HED Comment NRC IN-PROGRESS AUDIT REPORT HEDs The HED responses listed below as "wrong references" do not address the HED.
They should be corrected by CPhL and the NRC advised so an evaluation can be made.
3.4 4.2 4,3 5.1 5.3 5.4 6.3 6.28 6.29 6.30 B-463 B-212 B-225 B-204 B-215 B-203 B-224 B-226 B-228 B-235 CPEL A22"12 (3100-3421) is a wrong reference See CPEcL (A25"8) (31Al-1317)
CPKL Appendix A22-6 (31B1-2224) is a wrong reference CPKL A17-20 (3100-3106) is a wrong reference.
A3-35 (31D9"3107)
OK CPEcL A6-8 (31E6-2216)
OK A23-5(3100-2414) is a wrong reference See CP5L A2-20 (3100-2302)
See CPSL A2-31 (3100"2413)
See CP!kL A23-1 (3100-1154)
Pushbutton labels on panel
- 1B2, not readable, have four lines of text CP8L A23-4 (3100-2309) is a wrong reference 6.31 B-243 See CPKL A20-10 (3100-2123)
See CPKL 20-11 (3100-2132)
See CPIL 20-11 (3109-2135)
OK 5.34 B"230 See CPKL A17-25 (3100-3221)
See CPhL A16-43 (31AC 3202) 9.1 B-256 See CPIL A17-24 (31D1-3220) 37
Harris r
np above listings include groups of HED related/c on categories as follows:
Meters do not fail off scale, par allax, pointers obscure index/scale, Scales do not meet cr iteria Al-3100-2207, A6 31 E6 221 6 ~ 1 7 21 )
A8 31 F2 2223
~
A9 31 F3 5024 A-16-31AC-2204)07 2.
~En rav1n Does not meet criteria, or uses non-standard abbreviations A3 3109 1 1 1 0 ~ 1 1 1 2)
A5 31E2 2307
~ A15 31E 3 231 0)
A20 31 00 21 23 A20 31 00 21 32)
A22 3K1 2308
~ A22 31 00 2309
~
A21 3100 1 1 54)
A24 3162 1 1 62 ~
A24 31 61 5068 3.
Labels/Aids Labels, legend plates, legend/indicator lights, color code inconsistencies gr ease
- labels, missing labesl II g A7-31F1-5015, A11-31F6-1151, A15-31E3-1175,1177, A2 31 B2 2409
~
A1 3 31 F8 1705
~
AS 31F2 5018)
A1 2 31F7 1 1 31 ) 48) 49)
A2 3100 241 3 ~
A15 31E3 171 3)
A10-31F4 1150, A14-31E4"1184,85,88 Administrati ve/trai ni n substi tued for a corrective action A2-3100-3403, 31B1-3408,09, A3-31D9-2109, A9-31F3-5026, A10-31F4-5028, A12-31F7-5036, A15-31E3-1320 5.
Control Knob Do not meet criteria Al6 31 AC 3202 ~ 6) 7 A21 31 00 321 6 It is recommended that the NRC confirm by discussions with CPKL that the stated resolutions are acceptable.