ML19327B676

Technical Evaluation Rept for Boston Edison Co,Pilgrim Station Dcrdr Suppl Summary Rept.

ML19327B676
Person / Time
Site:	Pilgrim
Issue date:	10/03/1989
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:
Shared Package
ML19327B674	List: ML19327B673 ML19327B676
References
CON-NRC-03-87-029, CON-NRC-3-87-29 SAIC-89-1140, TAC-M59329, NUDOCS 8911060174
Download: ML19327B676 (14)

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TECHNICAL EVALUATION REPORT FOR r BOSTON EDISON COMPAhY'S I PILGRIM STATION  !

DETAILED CONTROL ROOM DESIGN REVIEW  :

SUPPLEMENTAL

SUMMARY

REPORT i TAC NO. M59329  !

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October 3, 1989 -

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I Prepared for:

U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 .

Contract NRC 03-87-029  :

Task Order No. 35 l

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U l TABLE OF CONTENTS taction Eggt

1.0 INTRODUCTION

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1.1 Background............................................ 1

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2.0 EVALUAT10N................................................. 2  !

2.1 Establishment of a Qualified Multidisci Review '

Team...................................plinary . . . . . . . . . . . . . . . 2  :

2.2 System Function and Task Analysis..................... 3 l 2.3 Comparison of Display and Control Requirements With 5 q l Control Room Inventory................................ 5 - -

2.4 Control Room Survei................................... 6 i i

2.5 Assessment of Humsn Engineering Discrepancies (NEDs)  !

l to Determine Which are Si Corrected ...............gnificant and Should be 7 l

2.6. Selection of Design Improvements...................... 7

• i s 2.7 Verification That Selected Design Improvements Will Provide the Necessary Corrections..................... 8 2.8 l Verification That the Improvements Will Not Introduce ,

New HEDs................................... .......... 8 ,

9 2.9 Coordination of Ccn'rol Room Improvements With Changes  !

lL From Other Programs Such as the Safety Parameter Display .

System, Operator Training, Regulatory Guide 1.97 Instrumentation, and Upgraded Emer Procedures........................gency Operating

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3.0 CONCLUSION

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REFERENCES........................................................... 11 ,

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TECHNICAL EVALUATION REPORT FOR BOSTON EDISON COMPANY'S PILGRIN STATION 1 DETAILED CONTROL ROOM DESIGN REVIEW l SUPPLEMENTAL SUPMARY REPORT l

1.0 INTRODUCTION

l-This report documents Science Applications International Corporation's  !

evaluation of the Detailed Control Room Design Review (DCRDR) Supplemental  !

l Sumary Report submitted to the huclear Regulatory Comission (NRC) by i Boston Edison Company for Pilgrim Station in April, 1939 (Reference 1). The l purpose of the review was to assess the licensee's progress toward i completing the .nine NUREG 0737, Supplement 1 (Reference 2) requirements -

f since the NRC issued its Safety Evtluation Report (SER), dated May, I'va5 (Reference 3).  ;

1.1 Backaround The following is a et.ronologic41 list of major milestones to date in the Pilgrim DCRDR.

10/83: Program plan for conducting the DCRDR submitted by licensee e

'(Reference 4).

l 3/84: NRC staff comments on program plan issued (Reference 5).

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[ 8/84: Revised program plan submitted by licensee (Reference 6).  ;

L 9/84: . Sumary report on the DCRDR submitted by licensee (Reference 7). '

11/84: In progress audit of DCRDR findings conducted by NRC staff.

5/85: Safety evaluation report (SER) issued by the NRC, documenting open 1 items and requesting date for submittal of a supplemental sumary ,

j report on the completion of those items.  !

l 3/89: In-progress audit of OCRDR conducted by NRC. ,

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4/89: Supplemental Summt.ry Report submitted to NRC.

6/89: Revised DCRDR Program Plan (Reference 8), j k

The in progress audit conducted in November 1984, as documented in the SER, determined thst additional work was neehd to complete eight of the nine DCRDR requirements of NUREG 0737, Supplement 1. The licensee was requested to complete thin work and submit a supplemental sumary report describing methods and results. As of March 1989, the licensee had not submitted a supplenental sumary report. The NRC conducted another in- 1 progress audit, March 20 23, 1989. It was found that little progress had l been made toward complettrg the additional work identified in the May 1985 SER, and that the literasee was planning major revisions in the DCRDR methodology described in the original program plan and sumary report. At -

the time of the March 1989 audit, the NRC determined that the itcensee did i not meet any of the nine FUREG 0737, Supplement 1 DCRDR requirements. )

The Supplemental Sunmary Report, submitted by the licensee to NRC on ,

May 2, 1989 was an updt.te of Sumary Report submitted in September 1984.  ;

The Supplemental Sumary Report provided additional information requested by '

NRC in the May 1985 SER. It described the licensee's DCRDR progress since i

,- 11)84, identified additional work needed to complete the DCRC,A, and provided  ;

i t schedule J for completior, of the next phase of worl;.

The licensee made a comits.ent in the Supplemental Sumary Report, to repeat a substantial amount of the DCRDR program at Pilgrim Station and submit a final Sumary Report in November 1990. The 11:ensee also made a e comitaient to submit a revised DCkDR program plan to NRC, by June '.0,1989.  :

2.0 EVALUATION The status of the Pilgrim Nuclear Power Station DCRDR is evaluated with respect to each of the nine requirements stated in NUREG-0737, Supplement 1,

.in the following sections.  !

2.1 Establ4*hment of a Oualified Multidisciolinary Review Team The organization for conducting a successful DCRDR can vary widely, but

.is expected to conform to some general criteria. Overall administrative 2

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leadership should be provided by a utility employee, who should be given (

sufficient authority to ensure that the DCRDR team is able to carry out its mission. A core group of specialists in the fields of human factors i engineering and nuclear operations and engineering are expected to  !

participate with assistance as required from personnel in other disciplines, i Human factors expertise should be included in the staffing for the technical  !

tasks. Finally, the DCRDR team should receive an orientation briefing on DCRDR purpose and objectives which contributes to the success of the DCRDR. I NUREG 0800, Section 18.1, Appe.. dix A (Reference 9) describes criteria for I the multidisciplinary review team in more detail.

The NRC previously determined (SER, Reference 3) that the licensee ,

estaolished a qualified multidisciplinary review team. However, the  :

licensee plans to establish a different team to repeat the DCRDR activities ,

including the system function and task analysis. At the time of the March l 1989 in progress audit, the licensee had not defined who would be conducting l the additional DCRDR work. No additional information on DCRDR team structure was provided in the Supplemental Summary Report. Therefore, the i DCRDR team structure for the 1989 and 1990 work could not be assessed as i part of the Supplemental Summary Report evaluation. On July 24, 1989, the l licenset submitted a revised DCRDR Program Plan that described thc  ;

j licensee's DCRDR team structure end task assignments, which are acceptable. l

However, the licensee had nct selected the specific human factors l contractor.

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It was the review team's judgment that the licensee should meet the NUREG 0737, Supplement I requirement for establishment of a qualified multidisciplinary review team but, the review team could not evaluate tl.e adequacy of the licensce's human factors contractor because they had not ,

selected the contractor, f

2.2 System Fur.etion and Task Analysis The purposi, of the system function and task analysis is to identify the control room operator's tasks during emergency operations and to determine l the information and control capabilities the operators need in the control row to perform those tasks. An acceptable process for conducting the task analysis is as follows:

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._ '1. Analyze the functions performed by systems in responding to l 3

transients and accidents in order to identify and describe those l tasks operators are evpected to perform.

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2. Determine .what information (e.g., parameter, value, status) signals the operator's need to perform the task, the control  !

capabilitie- **eded to perform the task, and the feedback  !

information needeo to monitor task performance for each task l

identified in Item 1 above.

3. Analyze the information and control capability needs identified in Item 2 above to determine appropriate characteristics for displays  ;

and controls to satisfy those needs.

During the March 1989 audit, the licensee stated that the system l t . function and task analysis activity would bo npeated. The SER identified  :

deficiencies in the original task analysis methods.  ;

In addition, the prsvious analysis was based on plant-specific [

t emergency operating procedures (E0Ps) developed from Revision 2 of the Boiling Water Reactor (BWR) Owners Group generic Emergency Procedures G'uidelines (EPGs). The NRC has approved Revision 3 of the generic EPGs as

.t the minimum acceptable functional requirements baseline for the DCRDR task t

. analysis (Reference 10). A major difference in Revision 3 of the generic [

EPGs it the addition of guidelines for secondary containment control and I l radioact'vity release control. The licensee's original task analysis did [

not address these emergency response requirements.  ;

i The licensee stated in the Supplemental Summary Report that the Pilgrim {

l Station emergency operating procedures were upgraded to Revision 4 of the Boiling Water Reactor Owners Group generic EPGs, which are substantially different from the Revision 2 EPus. As a result, the licensee made a i commitment to perform a new task analysis of the entire set of emergency operating procedures.

l 1he licensee stated that the details of the new methodology were still being developed and would be provided in the revision to the program plan. ,

It was therefore not possible for the review team to a' ass how the licensee -

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planned to identify a comprehensive set of operator informatien and control requirements, and define needed instrumentation and control characteristics.  !

It was the review team's judgment that the licensee did not meet the

,[ NUREG 0737, Supplement I requirement for a system function and task  :

jf analysis, because they had not completed the task unalysis.  !

2.3 Comoarison of Disolav and Control Reauirements with a Control Room  !

Inventon The purpose of comparing display and control requirements to a control l

room inventory is to determine the availability and suitability of disp!ays ,

and controls required by operators to perform their taskc. The success of this element depends on the quality of the function and task analysis and .

the control room inventory. The conti01 room inventory should be a complete i

, representation of displays and controls currently in the control room. The t i

inventory should include appropriate characteristics of current displays and j controls to allow meaningful comparison to the results of the function and  :

task analysis. Unavailable or unsuitable displays and controls should be documented as human engineering discrepancies (HEDs).

Since the licensee plans to conduct an entirely new system function and task analysis, it will also be r.ecessary to conduct a new control room

. inventory. The new inventory activity should consist of comprehensive comparison of operator information and control requirements, as well as needed instrumentation and control characteristics, to the actual control rocm. The purpose of the comparison it to assess the availability and suitability of instruments and controls to meet the operator's needs The licensee stated in general terms, in the Supplemental Summary Report, that they plan to upd.te the computer-based control room inventory, perform a verification of task performance capabilities, and validate control room functions. The methodology for conducting these activities was not included in the Supplemental Summary Report but, the licensee indicated in the report that this item would be described in the revised program plan to submitted to the NRC in July 1989. On July 24, 1989, the licensee  !

submitted a revised Program Plan that described a methodology for conducting the inventory activity, which was acceptable.

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.o e It was the reviw team's judgment that licenseo did not meet the NUREG-0737, Supplement I requirement for a comparison of display and control

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a./ requirements with the control room inventory because they had not conducted i the analysit,.

I 2.4 2ntrol Room Survey I

The key to a suc w.sful control rcom survey is a systematic comparisen l of the control room to accepted human engineering guidelines and human factors prin:1ples. One accepted set of human engineering guidelines is l providedinSection6ofNUREG0700(Reference 12);however,other accepted ,

human factors standards may be chosen. Discrepancies should be documented  !

as HEDs. j l

The licensee previously performed portions of the control room survey  !

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using checklists developed from human engir.eering criteria in NUREG 0700, the BWR Owners Group control room survey checklists, and Nuclear Utility i p Task Action Committee (NUTAC) control room survey documents. The in-progress audit team concluded that the NUREG 0737, Supplement I requirements '

i for a control room survey had not been met because the survey was incomplete l

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in the following respects: l 1

, o Noise survey ,

o Heating, ventilation and air conditioning survey [

o Computer survey  !

o Panel layout survey and control / display integration survey [

l o Survey of equipment installed since 1984.  !

l The licensee, in the Supplemental Summary Report, committed to conduct the l survey activities listed above.  ;

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It was the review team's judgment that the licensee should meet the i NUREG 0737, Supplement l' requirement for a control room survey to identify l ' deviations from accepted human far. tors principles, when they have '

conducted the surveys listed above. *

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j 2.5 Assessment of Human Jnaineerina Discrenancies (NEDs) to Deternine Which  ;

Are Sionificapt and Should Be Corrected l Based on the guidance of NUREG-0700 and the requirements of NUREG-0737, f all HEDs should be assessed for safety significance. The Supplement 1, potential for operator error and the consequence of that error in terms of plant safe;y should be systematically considered in the assessment. Both i the individual and aggregate efftats of HEDs should be considered. The  !

result of the assessment process is a determination of which HEDs should be  !

corrected because of their potential impact on plant safety. Decisions on  ;

whether HEDs are safety-significant should not be compromined by consideration of such issues as the means and potential costs of correcting HEDs. ,

i The assessment process originally used was found in the SER to meet the '

assessment requirement of NUREG 0737, Supplement 1. However, the licensee's l assessment of HEDs will not be completed until they have conducted an assessment of discrepancies identifie, during the new task analysis, inventory, and survey activities. The licensee made a commitment in the  :

Supplemental Summary Report to assess HEDs identified during the new work,  !

and provide justification for any safety significant HEDs to bt- left l u'ncorrected. l It was the review team's judgment that the licensee sht,uld meet the l

NUREG-0737, Supplement ) requirement for assessmtat of HEDs when they i complete assessment of discrepancies identified during new task analysis, inventory and survey activities. l 2.6 iglection of Desian Imorovements  :

The purpose of selecting design improvements is to provide means to .

correct HEDs identified in the review phase of the DCRDR. Selection of design improvements should include a systematic process for the development and comparisen of alternative means of resolving HEDs. Furthermore, according to NUREG-0737, Supplement 1, the liemas should document all of the proposed control room changes.

t The SER determined that the methodology for selecting design improvements, as described in the revised program plan submitted in August 7

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l 1984 was adequate for successful completion of this requirement of NUREG- l 0737, Supplement 1. Many of the previously proposed design improvements j were already in place at the time of the in progress audit conducted in  ;

March 1989. How(ver, as a result of the licensee's new DCRDR work, it will  ;

be necessary to select, schedde, and docmot new design improvements. The  !

licensee made a comitment :n the Supplemental Sumary Report to select, j schedule, and implement corrective actions for safety significant HEDs.

l It was the review team's judgment that the licensee should meet the NUkEG 0737, Supplement I requirement for selection of design improvements, when they identify and schedule improvements for safety significant HEDs.

2.7 yr_tfication That selected Desian Imorovements Will Provide the Necessary Corrections ,

The licensee mada a comitment in the Sumary Report, to verify that the corrective actions provide the necessary corrections. However, during l the in-progress audit in March 1989, the NRC concluded that the licensee did not have a formal process for verifying that the proposed corrective actions l

provide the necessary corrtdions. The licensee provided additional detail  ;

on the verification process in the Revised Program Plan.  ;

s t It was the review team's judgment that the licensee should meet the NUREG-0737, Supplement I requirement for verification that the proposed '

modifications correct the HEDs. '

I 2.8 Verification That the Intprovements Will Not introduce New HEDs As discussed in Section 2.7, the licensee made a comitment to the veriflestion process, in the Revised Program Plan. -

It was the review team's judgment that the licensee should meet the NUREG 0737, Supplement I requirement for verification that the improvements will not introduce new HEDs because they had a formal process for conducting  ;

this activity.

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i 2.9 Coordination of Control Room 1merovements with Channes From other  !

Proarame. such as the Safety Parameter Disolav System. Doerato_r Trainina. Reaulatory Guide 1.97 Instrumentation. and Unoraded Emeroency f

Doeratina Procedures Improvement of emergency response capability requires coordination of [

the DCRDR with other activities. Satisfaction of Regulatory Guide 1.97 require;acnts and the addition of the Safety Parameter Display System (SPDS) [

nec6ssitate modifications and additions to the control room. The  ;

modificatiens and additions should be specifically addressed by the DCRDR. l Exactly how the modifications are addressed depends on a number of factors  !

including the relative timing of the various emergency response capability [

upgrades. Regardless of the means of coordination, the result should  :

include integration of Regulatory Guide 1.97 instrumentation, SPDS ,

equipment, operator training and emergency operating procedures into a  :

consistent, coherent, and effective control room interface with the  !

operators. j The SER documented that the licensee had defined appropriate methods to coordinate the several programs required by NUREG 0737 Supplement 1, to  !

lmprove emergency response. However, the in progress audit team identified  :

doncerns related to coordination of DLRDR with each of the NUREG-0737, Supplement 1 initiatives, j- 'ihe licensee addressed coordination of the DCRDR with the emergency ,

operating procedures program in the Supplemental Summary Report (Section V), I

( but did not describe how the DCRDR program will be coordinated with the '

Safety Parameter Display System, operator training, or Reeviatory Guide 1.97 instrumentation. These i n ues were discussed and resolved in a September l

l 1989 phone conference.  !

E It was the review team's judgment that the licensee should meet the '

NUREG 0737, Supplement I requirement for coordination of control room l improvements with changes from other programs, such as safety parameter {

I display system, operator training, Regulatory Guide 1.97 instrumentation,  !

I and upgraded emergency operating procedures. [

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3.0 CDNCLUSIDN The purpose of this technical evaluation was to assess the NUREG 0737, Supplemerit i status of the Boston Edison Company's Pilgrim Station Detailed

• Control Room Design Review (DCRDR) based on the licensee's April 1989 I Supplemental Summary Report submittal. Science Applications International .

Corporation, as technical contractor to the NRC, evaluated the licensee's Supplemental Summary Report submittal, using NRC Standard Review Plan  !

guidance. i It was the review team's judgment that the Boston Edison Company DCRDR, ,

as described in their Supplemental Summary Report, did not meet any of the l nine NUREG 0737, Supplement 1 Detailed Control Room Design Review  :

requirements. However, based on the licensee's revised CCRDR program plan .  ;

submitted to NRC on July 24, 1989 it was the review team's judgment that the L additional work including several items identified in the Program Plan review should result in a successful DCRDR.

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l REFERENCES

1. Detailed Control Room Design Revie s, supplementary Summary Report, Pilgrim Station, Boston Edison Company, April 1989.

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2. Requirements for emergency response capability. NUREG 0737, Supplement }

1, issued by Generic Letter 82 33. U.S. Nuclear Regulatory Commission, j

1982. '

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3. Safety evaluation by the Office of Nuclear Reactor Regulation of the i detailed control room design review for Pilgrim Nuclear Power Station, l Docket No. 50 293. U.S. Nuclear Regulatory Commission, 1985. I

4. Detailed control room design review program plan. Attachment I to . [

1etter from W.D. Harrington, Boston Edison Company, to Domenic B.

, Vassallo, NRC, Boston Edison Company, October 14, 1983. +

5. Staff comments on the Pilgrim Station 1 detailed control room design ,

review. U.S. Nuclear Regulatory Conrission,1984.  ::

6. Detailed control room design review program plan. BEC084 134 Revision  :

1, forwarded by letter from W.D. Harrington, Boston Edison Company, to l Domenic B. Vassallo, NRC, Boston Edison Company, August 14, 1984.  ;

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7. Detailed control room design review executive summary repurt.  !

BEC0/ESR-1, Revision 1. Boston Edison Company, September 1984. l

8. Detailed Conthi Room Design Review, Program Plan, Revisien 2, Pilgrim ,

Station, Boston Edison Company, Iily 1989.

9. Standard review plan of safety analysis reports for nuclear power plants, Appendix A to Section 18.1, control room design review. NUREG-0800, Revision 0. U.S. Nuclear Regulatory Can..ission,1984.  ;

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.g 10. Meeting Summary Task Analysis Requirements of supplement 1 to NUREG-

'0737 May 4, 1984 Meeting with BWR Cwners Group Emergency Procedure i Guidelines and Control Room Design Review Committees. U.S. Nuclear

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Regulatory Commission, May 1984. i i

11. Guidelines for control room design reviews. NUREG-0700. U.S. Nuclear

. 'i Regulatory Comission,1981.

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