ML20035F926
| ML20035F926 | |
| Person / Time | |
|---|---|
| Site: | 05200002 |
| Issue date: | 03/22/1993 |
| From: | Higgins J, Ohara J BROOKHAVEN NATIONAL LABORATORY |
| To: | Polk H Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20035F916 | List: |
| References | |
| CON-FIN-E-2090 E2090-T2-5-3-93, NUDOCS 9304230070 | |
| Download: ML20035F926 (8) | |
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Advanced Reactor Human Factors (FIN E-2090)
Task Order No. 2: ABB-CE System 80+ Review BNL Technical Report E2090-T2-5-3/93 l
Draft TechnicalEvaluation Report i
Review of the ABB CE System.80+
l OperatingExperience Review j
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U.S. Nuclear Regulatory Commission j
Office of Nuclear Reactor Regulation Washington, D.C. 20555 l
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i Prepared by:
i James Higgins &~ John O'Hara Department of Nuclear Energy Brookhaven National Laboratory Unton,NY 11973 I
March 22,1993 I
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1 PREFACE
'Ihis draft echnical mpon (DTR) has been pmpamd by Brookhaven National Laboratory for the Human Factors Assessment Branch of the U.S. Nuclear Regulatory Commission's (NRC's)
Office of Nuclear Reactor Regulation. This n port is submitted under the Advanced Reactor Human factors Review Project (FIN E-2090) as pan of Task 2 " Review of the ABB-CE System 80+ Advanced Reactor Human Factors Program." The DTR addmsses Subtask 2 "Resiew and Evaluate Responses from ABB-CE" by providing a draft TER evaluanng ABB-CE's operating l
experience mview. The NRC Project Manager is Harold Polk, the Project Engineer is Clam
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Goodman, and the Technical Monitor for Task 2 is Garmon West. The BNL Principal Investigator is John O'Hara.
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I Draft TERfor Element 2 OER (March 22,1993)
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INTRODUCTION
'Ihe NRC Human Factors Engineering Program Review Model (PRM) for advanced evolutionary reactors specified that an Operating Experience Review (Element 2) should be performed. The staff's Draft Safety Analysis Report (DSER) review of the CESSAR has identified Operating Experience Review as a open issue (DSER Issue 18.4)..
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OBJECTIVES The objective of this preliminary review is to provide an evaluation of the CE-ABB efforts related to PRM Element 2 - Operating Experience Review.
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- 3. METHODOLOGY 3.1 Material Reviewed i
The following ABB-CE documents were used in this review:
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Operating Experience Review for System 80+ Design (NPX80-IC-RR790-01, Rev. 00),12/8/92. (OER) 2.
CESSAR DC Chapter 17, Appendix A, Closure of Unresolved and Generic Safety Issues, through Amendment K, October,1992. (DC) 3.
Letter ABB-CE to NRC, LD-92-120, Closure of System 80+ DSER Issues, dated December 18,1992.
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Human Factors Program Plan for the System 80+ (TM) Standard Plant Design, NPX80-IC-DP790-01, Rev.1. December 15,1992 5.
System 80+ Shutdown Risk Report, FSP-92-131, July 31,1992 3.2 Review Scope This review focused on (1) the overall scope, structure, and completeness of the CE documents, and (2) the evaluation of the documents with respect to the PRM. In conducting this review, absolute adhemnce to the PRM was not considered to be mandatory. Differences in approach
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would be considered acceptable provided (1) the program can still meet the HFE commitment and
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goals, (2) the difference between the proposed enteria and those contained in the PRM are adequately justified, and (3) there is no adverse impact on other program elements.
Due to the fact that the CE System 80+ plant and control room design is quite far along, there is a considerabl.: amount of actual design material available. CE has chosen to submit much of this design information along with the control room HFE Program description. Hence, the scope of.
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the documents reviewed go beyond the " submittal requirements" of the PRM. We have organized our review to be model driven, i.e., we have in general reviewed just *, hose portions of the documents that were within scope of the PRM and have not addressed the details of the control room design. These details will be reviewed at the appropriate time as part oflater program elements (e.g. Elements 4 - 8). In a few cases, where particular aspects of the design presented obvious questions, these questions are delineated herem, in order to give as much time as possible i
to evaluate the issues in question before design decisions become " locked in."
J Draft TERfor Element 2 OER (March 22,1993)
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3,3 Review Procedure
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l The OER was reviewed utilizing the PRM. The BNL draft TER was also used since it identified open issues with an earlier version of CE's OER. Further, since the OER addresses various NRC unresolved and generic safety issues, a number of CE and NRC documents, covering these items were also reviewed. The unresolved and generic issues were myiewed for the satisfactory msolution of their human factors engineering (HFE) aspects.
The BNL draft TER identified a concern regarding the adequacy of CE's review of operating experience relevant to System 80, the immediate predecessor of the System 80+ plant. As a result, BNL collected and reviewed LERs from System 80 and visited a System 80 plant to intersiew their t
operators regarding their opinion of the HFE and operating experience of their plant. The results of this effort is contained in a separate report (document 5 below).
The following materials were consulted as part of the evaluation:
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NUREG-1492 Draft Safety Evaluation Report, September,1992. (DSER) 2.
Public Meeting minutes from September 10-11,1992, hereafter referred to as the f
" September meeting."
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NRC Program Review Model for Evolutionary Reactors (PRM).
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Preliminary Technical Evaluation Report for ABB Combustion Engineering's Human Factors Program Plan and Operating Experience Review for System 80+,
BNL Draft Technical Report, O'Hara and Higgins, November 25,1992. (BNL draft TER) 5.
System 80 Operating Experience Issues Based upon Interviews with System 80 Operators, BNL Draft Technical Report, O'Hara and Luckas, March 17,1993 4.
RESULTS I
i 4.1 DSER Issues Review 4.1.1 DSER Issue In the staff's initial review of this element reported in the DSER, Open Issue 18-8 was defined, indicating that ABB-CE had not submitted an OER. In the September meeting, CE agreed to 3
address the open issue by:
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(a)
Identifying past problems'and lessons learned (in an organized coordinated usable, and auditable form) for the control room, remote shutdown panel, and local control stations.
(b)
Give examples and the rationale for problems and issues encountered in similar systems of previous designs that wem identified and analyzed so that they are i
avoided or in the case of positive features, to ensure their retention.
(c)
Address the criteria of PRM element 2 (d)
Submit the following documents: Nuplex 80+ Design Basis Document and NUPLEX 80+ Information System Design Basis Document.
Draft TERfor Elernent 2 OER (March 22,1993)
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3 4.1.2 Issue Resolution Items (a), (b), & (c):
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Identifying past problems and lessons learned (in an organized coordinated usable,
and auditable form) for the control rocm, remote shutdown panel, and local control stations.
(b)
Give examples and the rationale for problems and issues encountered in similar i
systems of previous designs that were identified and analyzed so that they are avoided or m the case of posidve features, to ensure their retendon.
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(c)
Address the criteria of PRM element 2 Evaluation: The CE OER, document 1 in paragraph 3.1 above, contains the information identified in these three items. The review as to the adequacy of the OER submittalis discussed below.
Status: These three items are closed, i
e Irem (d): Submit the following documents: Nuplex 80+ Design Basis Document and NUPLEX 80+ Informadon System Design Basis Document.
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Evaluation: Rese two documents were submitted to the NRC and are currently being used by BNL for the review of other PRM elements.
Status: This item is closed.
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4.2 PRM Criteria-Based Evaluation l
The ABB/CE Operating Experience Review for System 80+ MMI Design, Nov 4,1992 (CE OER)
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was evaluated according to the criteria of the NRC HFE Program Review Model (PRM). Table 2 lists the 10 components of the pertinent sections of the OER.
4.2.1 Implementation Plan Criterion: An OER implementation plan shall be developed.
Evaluation: As per the review of the ABB-CE Human Factors Program Plan, implementation plans for HFE program elements currently underway or completed are not required. Instead, a description of the methodology used is to be incorporated in the report. In sections 1,2, and 5.2 of the OER document, CE describes their OER process. This sansfies the need to document the scope and process of the OER for System 80+, and hence a separate implementation plan is not t
needed.
As to the scope and details of the OER,it is generally comprehensive. The OER states that guidance and associated design resolutions apply to the entire Nuplex 80+ design, which is considered appropriate. It also states that all areas of the plant are being subjected to a detailed operability and maintainability review. His is considered good design practice. Further the commitment, to continue to review new industry and govemment reports and other applicable documents from this time forward,is considered an excellent pracuce.
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Drafr TERfor Element 2 OER (March 22,1993)
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A few areas were identified however, whem the scope of the OER was too limited. These areas i
are:
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remote shutdown panels (RSPs),
local control stations (LCSs), and
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review of System 80 expenence.
a The review of System 80 experience will be discussed under other topics below. Regarding the l
RSPs and LCSs, the review was somewhat weak. The limitation (identified on p. 8) to only those IfSs identified in the EPGs is too narrow and the statement on p. 9 that only "a limited set of problems and issues related to LCSs" is indicative of too narrow a scope. The coverage of both environment and communications issues relative to RSPs and LCSs appears particularly slim. He r
OER should myiew some of the more recent documents on LCSs developed m the review of the HF generic issue on LCSs, and noted in paragraph 4.2.5 below. Funher, the CE OER design
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resolutions appeamd to somewhat narrowly exclude LCSs and RSPs from their scope (see paragraph 4.2.2 for specifics.) Related to this issue is CE's msponse to Human Factors Generic Issue HFI 5.1, Local Control Stations in their submittal to the NRC dated 12/18/92. This states i
that the issue is addressed because LCSs are within the scope of the CE "HFE Standards Guidelines and Bases for System 80+." However this document was briefly reviewed and it appears to be quite weak in the area of guidelines for LCSs. As an example there does not appear to be anything regarding labeling of valves or valve position indication.
Status: This item is open (pending the resolution of scope issues).
4.2.2 Analysis Results Report Criterion: The analysis of operating experience shall be conducted in accordance with the plan and
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the findings shall be documented in an evaluation report.
t Etaluationt The OER is the evaluation repon for this element of the PRM. His mpon contains the
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objectives, methods, results, conclusions, and recommendations / implications for HSI design of l
the OER as required by the PRht
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Section 3 of the CE OER contains the detailed results of the OER analysis. There are a considerable number of human factors /HSI issues addressed. As noted above, a decision has been
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made not to review at this time the technical design resolutions of the various OER issues.
However, it should be noted that CE appears to have given careful consideration to many of the identified issues and thus many should have reasonable design resolutions identified. Despite the i
fact that the design resolutions have not been reviewed in detail, the following observations were i
made and are provided here as preliminary information.
- 1. The use of touch screens in the' design seems quite prevalent for process control. Given the fact that touch screens have some well-noted drawbacks, have flexible alternatives been provided in the design for other input methods?
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- 2. Section 3.1.16, on RCP seal failures looked at references 11 & 17, which are the i
documents that describe the RCP seal generic issue. However, the OER did not refemace any of the more recent documents associated with the generic issue, which provide a much more detailed description of the problem and which provide many recommended solutions.
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Some example documents are NUREG/CR-4544 and NUREG/CR-4948. An example of an item in these documents is the recommendation for seal flow line valve position indication and RCP shaft vibration disheement or velocity. The lack of more recent documents was also noted in the disca non of other genene issues in Appendix A.
Draft TERfor Element 2 OER (March 22.1993)
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- 3. Section 3.5.1, General Access. His is cenainly a problem ama with current plants.
There is not enough detail in the resolution here, particularly with regard to other types of personnel and work which can distract the control room operators, such as: maintenance work and personnel, testing, development and issuance of tagouts, various other administrative tasks, and communications both within and extemal to the plant.
- 4. Section 3.5.3, Noise. This item identifies the purchase of quiet fans for the MCR. CE should ensure that the control room noise concems identified in document no. 9 above are I
addressed by this resolution.
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i 5, Section 3.5.5, Storage. Another item identified in document no. 9 above is the lack i
sufficient permanent laydown area in the MCR for procedures. This item should address that concem, but currently does not.
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- 6. Section 3.6.1, Inconsistent Coding Comentions. His item should also be applicable to LCSs.
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- 7. Section 3.6.2, Insufficient Tag legibility, should be clarified to say that it applies the MCR, the RSP, and other local control stations.
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- 9. Section 3.9.2, Low Power Automated Feedwater Control. This item states that Main Feedwater is designed for fully automatic control at low power (down to 1% power),
however, other CE documents indicate that there is a separate stanup feedwater system for low power operations. This should be clarified.
i Status: his item is open.
4.2.3 HSI Design Team Report Review f
Criterion: The analysis shall be reviewed by the HS1 Design Team and shal! be documented in an I
Evaluation Repon.
Evaluation: CE did not initially provide in their Program Plan a description of a formalized Design Team Review of the final analysis repe is of each Process Element. CE stated at the NRC meeting of Nov.19,1992 that they do perform an interdisciplinary dcsign team review of each of the major l
design element results, and that this review is formally documented. ney funher stated that their review process would be described in their HF Program Plan.
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in the CE HF Program Plan Section 1.3.1.3, Design Review Meetings, CE describes a process f
which is basically a working meeting with three to 20 reviewers present. Minutes and action items are documented. This type of review does not appear to suffice for the more formalized and documented HS1 Design Team Evaluation envisioned in the NRC HFE PRM. His item is currently open in Element 1, Human Factors Program Plan as it applies to the Design Team Repon Review of all PRM elements.
Status: His item is open.
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Draft TERfor Element 2 OER (March 22,1993)
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4.2.4 List of Issues (Appendix A)
Criterion he operating experience review issues listed in Appendix A of the PRM should be included in the OER as pan of the design and implementation process.
Evaluation:
The CE OER, Appendix A discusses the list ofissues from the PRM, including each of the types ofissues documents: USIissues,Dilissues, NRC Generic Letters AEOD Studies, and Low Power and Shutdown Issues. All of the USIs, TMI issues, and NRC Generic Letters listed in the PRM were addressed in Appendix A of the OER. Appendix A also addressed AEOD studies and Low Power and Shutdown studies.
Status: This item is acceptable and it is recommended that hTC close it.
4.2.5 Review of Issues Criterion: The operating experience issues that am identified shall be reviewed for:
Human performance issues, problems and sources of human error shall be identified.
Design elements which suppon and enhance human performance shall be identified.
Evaluation: This evaluation will address in turn each category ofissue: USIs,TMIissues, NRC Generic Letters, AEOD studies, and Low Power and Shutdown issues USTs and TMIissues De CE OER treats USIs and TMI issues similarly. They am divided into the following groups of items by CE: HFE tracking system issues, issues addressed by and incorporated into the NUPLEX 80+ design, COL applicant issues, and issues that are not applicable (NA.) Those l
classified as going into the HFE tracking system are discussed in the paragraph on the tracking system, below. Those incorporated into the design were reviewed in some detail immediately below. Those designated as COL applicant issues am summarized in Appendix A to this report.
CE should provide a summary list of all COL issues to ensure that they are properly tracked.
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Those issues designated as NA were reviewed on a sampling basis and no problems were identified.
He next paragraphs discuss those items identified as incorporated into the design. The discussions in the DSER, the OER, and the CESSAR DC were reviewed. Often the issues appear to be resolved by hardware / systems types of fixes. Also, the discussions ofjust how an item has been resolved in the design are somewhat sketchy, especially concerning the human factors aspects of the resolution. Funber, at times the references seem to list only the material which generated the unresolved issue and not the technical fin, dings documents, which resolve or panially resolve the issue.
Item B-17 was not addressed in the DSER or the DC, and is not covered in sufficient detailin the OER.
Item GI-23 was open in the DSER and is not covered sufficiently hem (see also discussion in section 4.2.2 above.)
GI-57 and GI-130 are listed in the OER as incorporated in the design, however the DSER lists them as COL issues. This is a discrepancy; also them is no information as to how GI-57 is incorporated.
Draft TERfor Elemer.t 2 OER (March 22,1993)
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t GI-75 and 76 are not in the DSER nor the DC and are inadequately addressed in the OER.
TMI issue 2iv is not in the DSER and is currently being reviewed elsewhem by the NRC.
Item 2xix was a DSER open item and is not adequately addressed in the OER.
However, it is also being reviewed elsewhem by the NRC.
Items 2v,2xi and 2xviii were acceptable in the DSER.
i Item 2xxv states that the MMI design of the TSC and OSC is complete. However, while the TSC may be covered by the CE HF Program Plan (see HFPP review),
i the OSC does not appear to be.
j NRC Generic Letters Three Generic Letters are addressed in the OER. For letters 91-06 & 91-1Ithe OER states that monitoring, surveillance, equipment status, and testing are COL issues. This is an extremely broad transfer of responsibility to the COL. Certainly there are HF aspects of these four areas which need to be addressed in the design. To defer all consideration of these issues to procedural type resolutions that a COL would create does not seem appropriate. Letter 91-07 on RCP seals is discussed is paragraph 4.2.2 above.
AEOD Studies Tne PRM specifies a review of recent AEOD studies in the human performance area. A brief discussion of this report series is contained in the OER. A bit more detail as to how the items identified were incorporated into the design would be desirable. Further, AEOD has mcently issued the final summary report (NUREG-5953) in this series, which generalizes the findings to a level applicable to most all plants. Based on ABB-CE's commitment to continue to review new documents and the importance of this summary report, the reviewers expect that CE will review l
this new report.
Low Power and Shutdown Issues CE's review of this area is described in a separate report, System 80+ Shutdown Risk Report, FSP-92-131, July 31,1992. Based upon a brief review, the document was deemed to be reasonably thorough and comprehensive. The list of reference documents was also appropriate l
and extensive. One item noted was, that considering the OER commitment to continue to be updated as new information and documents come out, there are two documents that would be particularly valuable to include, hey are: the final version of NUREG-1449 and the 12/91 NUMARC " Guidelines for Industry Acti'ons to Assess Shutdown Management."
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Status: His item is open.
4.2.6 Interview Topics Criterion: This item lists the topics which should be included in the operator interviews.
Evaluation:
The original version of the CE OER stated that operator interviews were not I
conducted per se. Operator input was, however, noted to be utilized to some extent. The BNL draft TER raised the question as to why operator interviews with System 80 operators were not i
l Draft TERfor Element 2 OER (March 22,1993)
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conducted, since System 80 is the direct predecessor of the System 80+. At the Nov.19,1992 meeting between NRC, BNL and CE the issue of System 80 operator interviews was discussed and CE reiterated their position that the use of other plant operators and their own staff with i
operating experience was sufficient. As a result, the reviewers conducted interviews with licensed i
System 80 operators regarding their experience with the System 80 plant and its operations. A repon has been issues which aetails the results of these interviews and raises a number of questions and issues relative to the incorporation of System 80 experience into the System 80+.
His item will remain open pending CE's response to this repon.
In the cunent version of the OER, CE makes further statements regarding operator interviews, which are not justifiable and which indicate an approach to operating experience which is not appropriate. As an example, section 5 states that, "By definition, funher problems that might be identified during operator interviews are not safety related; the plants operating today are detennined safe.." One should recognize that safety problems cannot be defined away. If this l
logic were correct, neither the TMI accident nor any subsequent incident or LER could be considered to contain a safety problem. Hus the overall approach to operating experience should be clarified to correct the impression given by this and a few other isolated sections of the OER.
Status: His item is open.
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4.2.7 Literature Review
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Criterion: The review shall include a literature review.
Evaluation: From the documents listed,it appears that a substantial literature review was conducted. However, the list of references appears to be lacking in documents from CE System j
80 plants. Since System 80 is the direct predecessor to System 80+ it is especially imponant to i
consider System 80 experience. As an example, there appears to be valuable information in the System 80 LERs, as noted in document no. 9.
j Status: his item is open.
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4.2.8 Sources Criterion: This item identifies those industry wide and plant or subsystem relevant sources that should be included in the OER.
Evaluation: This item was closed in the DSER.
l Status: Closed by the NRC.
4.2.9 Tracking System j
4 Criterion: Each operating expedence issue shall be documented in the HFE tracking system.
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Evaluation-Section 2.0 of the OER states that any unresolved design issues identified dudng the reviews, which may impact the design, will be entered into the HFE tracking system for i
subsequent resolution and documentation. Section 5.0 of the OER states that the tracking system was implemented in early 1992. Many items in Sections and Appendix A of the OER are listed as being included in the tracking system, This all appears appropriate and programmatically the tracking system is acceptable and is closed.
Draft TERfor Elemera 2 OER (Mcrch 22,1993)
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During a trip to CE on March 11,1993 BNL attempted to vedfy the use of the tracking l
system for OER items as desedbed in the OER report. However, CE stated that the system was L
undergoing improvements, was not fully operational, and was not immediately available for review. Thus, this item is kept open in order to verify proper implementation of the system for tracking OER items as noted in the OER report.
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Status: Closed programmatically in the HFPP review, however, the item is Open for implementation verification.
j 4.2.10 Reference Documents Criterion This item lists four doeuraents that the OER program should use in developing the implementation plan.
Evaluation:
The OER has satisfactority utilized the four identified documents.
Status: This item is acceptable and it is recommended that NRC close it.
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CONCLUSION
-A evaluation of the *CE Operating Experience Review for System 80+ MMI Design" was completed using the NRC HFE PRM as guidance. Overall, the CE OER was quite impressive and showed a detailed review oi many aspects of peninent commercial nuclear power plant experience, and the subsequent incorporation of appropria.'e design features into the System 80+ design. Not all aspects of the PRM were completely addressed however, and so several components of the PRM remain'open. Table 1, below, summarizes the status of each component of the NRC HFE PRM for the CE Operating Etperience Review. Also listed is the Section of this TER where that component is discussed.
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Summary of Element 2 Evaluation Status l
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COMPONENT SECTION 1 Implementation Plan 4.2.1 Open 2 AnalysisResultsReport 4.2.2 Open l
l 3 IISITeam Report Review 4.2.3 Open j
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4 ListofIssues(Appendix A) 4.2.4 Acceptable '
5 Review ofIssues 4.2.5 Open 6 InterviewTopics 4.2.6 Open.
7 Literature Review 4.2.7 Open 6
8 Sources 4.2.8 Closed by NRC 9 Um of Tracking Sysem 4.2.9 See Note below t
10 Reference Documents 4.2.10 Acceptable l
Note: Programmatically closed but the implementation remains open
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Draft TERfor Element 2 OER (March 22,1993) page jo i
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l APPENDIX A j
I LIST OF COL ISSUES FROM CE OER i
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Generic Issues: GI-75, GI-l 16, GI-I 17, B-32 TMIitems:
2xxv,2xvv Generic Letters: 91-06,91-11 4
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