ML20008F673

Comments on Suppl to Draft NUREG-0659,rept Re Engineering Guide to Control Room Evaluation.Guidelines Fail to Address Development of Human Engineering Stds for Nuclear Power Applications

ML20008F673
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/10/1981
From:	Cavanaugh W ARKANSAS POWER & LIGHT CO.
To:	Froelich R Office of Nuclear Reactor Regulation
References
RTR-NUREG-0659, RTR-NUREG-659 R&D-355, NUDOCS 8104210489
Download: ML20008F673 (2)

Text

v ARKANSAS POWER & LIGHT COMPANY FIRST NATIONAL BUILDING /PO. 90X SSi/LITTLE ACCK. AAKANSAS 722C3/(50113714422 April 10,1981 ,2..

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,A r WILLIAM CAVANAUGH,111 o f

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Senior Vice Presiden; j/./ g y[t h Energy Supply , () -

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cmmm R. W. Froelich E /2 Division of Human Factors Safety Office of fluclear Reactor Regulation U.S. fluclear Regulatory Commission

%4/Q Washington, D.C. 20555

Subject:

Staff Supplement to the Draft Report on Human Engineering Guide to Control Room Evaluation, fiUREG-0659

Dear Sir:

Arkansas Power and Light has reviewed the subject document and has pre-pared the following comments. These comments are provided so that act-ivities undertaken by utilities pursuant to flVREG-0700 will achieve the desired goals. These goals are threefold: (1) To improve the man / machine interface in nuclear power plant control rooms and thereby reduce the poten-tial for human error; (2) To improve the interface within an acceptable time-frame; and (3) To improve the interface in a cost-effective manner .

consistent with maintaining plant safety and availability. Since both of Arkansas Power and Light Company's nuclear units are in commercial opera-tion, our coments are generated from the vantage point of backfitting existing control rooms.

Generally, the guidelines are only applicable to plants in the early stages of design and cannot be applied, in any constructive sense, to an operating nuclear unit. The document offers some common sense fixes utilizing exist-ing technology to correct problems, but ignores the development of new indus-try standards necessary to include state-of-the-art instrumentation techno-logies in control interfaces. In other words, the flUREGs do not address the c'evelopment of human engineering standards for nuclear power applications to replace the military standards now being used.

To backfit existing plants, a method for determining the significance of an HED (Human Engineering Deficiency) must be presented. Criteria must then be supplied which relates HED significance to HED backfit priority. Unless the HED assessment can address HED significance and an associated backfit pricr-ity, an implementation plan prepared to respond to a design review will be arbitrary in the selection of an implementation schedule, i.e. potentially significant HED's will be indistinguishable from those of lesser importance.

This concen was identified by industry reviewers of flVREG/CR-1580 but has s been inadequately addressed in NUREG-0659. 0

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R&D-355 4/1 0/81 R.W. Froelich Post of the human factors engineering data have been derived from the de-fense industry. Generally, the data have not been validated for nuclear plant operators. Correspondingly, modifications initiated in response to a design survey will be based on the same defense industry data without validation in the nuclear industry. Valid data for the nuclear industry should be developed prior to extensive application of defense industry data.

As in the case above, this situation was identified earlier but inadequately addressed in flVREG-0659.

The NRC staff has presented the data in NUREG/CR-1580 and NUREG-0659 as guidelines - not as standards. Since they are guidelines, we assume they are advisory and discretionary (as guidelines normally are), and that they are examples rather tnan specific actions to be taken. We assume that the staff will recognize this distinction between guidelines and standards and not attempt to use NUREG-0700 as if it is a book of standards.

These comments represent a collective review of several cognizant groups within AP&L. We appreciate the opportunity to provide them to you. If you need additional clarification, please contact me.

V ry truly yo ,s 4 4 ;WJ < -

William gh, III WC:ds l

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