ML20039G248
| ML20039G248 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1982 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1045, NUDOCS 8201150419 | |
| Download: ML20039G248 (75) | |
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1 UNITED-STATES OF-AMERICA 2
NUCLEAR REGULATORY COMMISSION J
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
261st GENER AL MEETING S
6 Nuclear Regulatory Commission i
1717 H Street, N.W.
7 Washington, D.C.
8 Frid a y, January 8, 1982 9
The 261st meeting of the Advisory Committee on 10 Reactor Safeguards was convened at 5:27 p.m.
11 PRESENT FOR THE ACRS s 12 J.J. RAY, Chairman J.C.
MARK 13 C.P. SIESS
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R.C. AXTMANN 14 D.W. MOELLER W. KERR 15 M.W. CARBON W.H.
MATHIS 16 D.A. WARD J.C.
EBERSOLE 17 D. OKRENT H. LEWIS 18 DESIGN ATED FEDERAL EMPLOYEEa 19 R.F.
FRALEY 20 21 l
22 23 24 l
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MR. RAY:
So we will open the meeting and turn the 3 mee ting over to Mr. Wa rd.
4 MR. WARD:
Thank you, Jerry.
5 On Janua ry 5 the Human Factors Subcommittee met.
6 Present at the meeting for the Committee were Mr. Ray and 7 Nr. Mathis and myself.
Consultants were Mr. Keyserling, 8 Pearson and Debons, and from our Committee staff we had Mr.
9 Major, Mr. Kirby and Mr. McElvoy.
10 We heard presentations from the staff on three 11 NUREG documents: 0700, Guidelines for Control Room Design 12 Reviews; 0801, Evaluation Criteria f or Detailed Control Room 13 Revievss and 0835, Human Factors Acceptance Criteria for the O
14 Saf ety Parameter Display System.
15 We received some cursory briefings at an earlier 16 meeting back in November on these NUREGS.
This time we had 17 a more in-depth review in addition to hearing staff 18 responses to comments which our consultants had made af ter 19 the Novembor 2 meeting.-
20 We also heard a presentation from a representative 21 of the CRGP, the Committee To Review Generic Requirements, 22 on the draf t position that committee has prepared on 23 emergency response capability in f acilities, which includes
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24 to at least some extent the subject of the three NUREGS we 25 were reviewing.
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1 And then finally we heard a presentation from 2 representatives of Westinghouse on their particular SPDS
/~T 3 design which they have built in the lab and sold, have sold
'V 4 nine of them to five utilities, they said.
5 I will summarize some of what we heard, but you 6 will then hear presentations from, I believe, Voss Moore of 7 the Division of Human Factors Safety, and from Ed Blackwood 8 of the CRGR.
9 The first document, NUREG-0700, is essentially a 10 handbook of good human engineering principles for control 11 room design.
This document has been out for public comment 12 a nd has been issued in final form.
The Commission is to 13 decide, as we understand it, later this month on whether to O
14 require all licensees to use NUREG-0700 as a basis for 15 reviewing existing control rooms and developing programs for 16 correcting deficiencies.
If they so decide, the second 17 N UR EG, 0801, will serve as a basis f or making these reviews.
18 It has been out for public comment since October 19 of last year, and 0700 will also be available ar a guide for 20 new control room design and is expected to be updated as 21 appropriate in future years.
22 I tnink I can say that the consensus of the -- the 23 opinion of the Subcommitee and its consultants was that 0700
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24 should be used as a basis f or control room reviews. There 25 was some lukewarmness about it, about the importance of it, O
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1 but there is general agreement that it would be useful.
2 However, the Subcommittee, again I think the
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3 reasonable consensus believes the control room fixes should 4 be negotiated between the staff and licensee, and the staff 5 should use considerable flexibility. in imposing the 8 guidelines and not treat them as absolute requirements.
7 Some items that came out of the discussion.
8 First, the incentive for improving control rooms came 9 largely from THI, post-TMI recommendations.
They were not 10 necessarily incentives indicated in the reactor experiences 11 embodied in the LER data bank, and probabilistic risk 12 assessments have not directly in themselves indicated the 13 need for control room improvements.
The da ta just are not 14 available to -- so that they could.
15 There is another point tha t came out.
In existing 16 control rooms there seems to be a very wide quality range in 17 the human factors attributes, and this quality does not 18 correlate with the newness or the oldness of the plant.
It 19 exists even in the most recent plants.
It does, the staff 20 told us, however, seem to correlate with whather or not a 21 particular licensee, a particular utility furnished input in 22 the design of the control room.
Where the future operator 23 was directly involved in design in general you have a 24 control room with good human factors attributes.
25 There is some concern over whether the review and O
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I the control room fixes in this program migh t have some 2 negative safety impacts.
The staf f believes that that would
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3 be only short term and that training and procedures would 4 take care of any problems there.
5 There were some estimates made of the cost of the 6 review to each utility and to the staff and the cost of 7 possible upgrades that might be required, and I think Voss 8 Hoore will present a summary ef those in his presentation.
9 Turning to the SPDS, NUREG-0835 provides human 10 f actors design guidelines for the SPDS.
It augments 11 NUREG-0696, which gives functional criteria for the several 12 dif ferent emergency response facilities which will be 13 required.
The Subcommittee and its consultants generally O
14 endorse the guidelines, human factors guidelines for the 15 SPDS' with, I think, two comments.
One is that the NUREG 16 seems to presuppose tha t the SPDS will incorporate a 17 computer-driven CRT display.
l 18 There was some indication, particularly on the
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19 part of a couple of our consultants, that conventional data 20 displays -- and I think we all know what conventional 21 displays are - might have some ' superior attributes for an 22 SPDS, and there is no indication that the choice for 23 singling out the CRT was made on a technical basis.
24 The Subcommittee also expressed -- seems to 25 believe that the SPDS will be more effective if it includsd l ()
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1 some automatic diagnostic capability.
Neither the automatic 2 diagnostic capability or the use of conventional displays is 3 precluded by the NUREG.
In other words, utilities could
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4 include both and still be in conformance widt the guidelines 5 of the NUREG.
And in fact, an interesting presentation by 6 Westinghouse on the design of their SPDS proposal does in 7 f act incorporate some diagnostic capability.
8 Turning for a minute to the CBGB, and you will i
9 hear a talk from Mr. Blackwood representir2 them, that 10 committee has draf ted a proposal for implementing the 11 guidelines and requirements.
As I understand it, they vare 12 to present that to the Commission yesterday but it was 13 postponed because it has not yet been reviewed by all of the O
14 other offices within the Agency.
And as a matter of fact, 15 the Division of Human Factors Safety had not had a chance to 16 review their proposal at the time of our Subcommittee 17 meeting so they had no comment on the CBGR proposal.
18 My impression of the CRGR proposal is tha t it 19 f avors going ahead with issuing these documents as 20 gridelines for review but not as strict requirements, and 21 emphasizing the changes shocid be negotiated between NER and 22 the licensees.
They, as I understand, do recommend tha t 23 some sort of SPDS, however, would be required.
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24 We had one strong public comment from a human 25 f actors consulting firm expressing concern that the CRGR O
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(_j 1 proposal represents an unacceptable backing off from the 2 human f actors -- giving the human factors concerns the
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3 priority they deserve.
4 I do not think that the Subcommittee and its 5 consultants necessarily shared tha t concern, a t least to 6 tha t degree.
I think one issue that, although it appears to 7 no it may not be any particular problem in this case, but I 8 think one thing that you need to consider is just how in 9 this case and in future cases is this committee going to 10 interf ace with the CRGR.
11 At the present time on this particular issue we 12 are in the position of giving recommendations to the 13 Commission in parallel with the CRGR, and I think we need to l ()
l 14 think about whether that is the position we want to be in l
15 for this issue and any others.
l l
1s So before turning it over to the staff for their 17 presenta tion, let me ask -- just a minute.
Let me ask Mr.
l 18 Ray or Mr. Mathis if they have any comments.
i 19 MR. MATHIS:
I do not have anything.
20 MR. RAY:
No, I think your report is complete.
21 OKay, yes, sir.
22 MR. MILLER:
I am James Miller from Westinghouse, l
23 I would like to correct that inpression, I O
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24 belie ve, and that is that the Westinghouse SPDS system is 25 designed so that the reactor operator does the diagnostic O
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i work, end the srDs is intended to supp1y informetion se that 2 the operator can carry out the diagnostic operations.
3 MR. WARD:
Okay, thank you, Mr. Miller.
4 Hugh Thompson, would you like to carry on?
5 MR. KERR What was the impression I had that was 6 being corrected?
I as not sure.
Do you know?
7 MR. WARD:
I think I lef t the impression, which 8 was my impression --
9 MR. MILLER:
I am sorry. Yes, I thought Mr. Ward 10 had made the statement that the Westinghouse SvDS system 11 does have some diagnostics capability with it, and that is j
l 12 strictly an information -- provides information, yes.
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l 13 MR. KERR Okay.
Now I know what my impression
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I 14 was, yes. Thank you.
15 MR. RAY:
I would like a clarification of the 16 clarification.
j l
17 (Laughter.)
l 18 Is the inf ormation orien ted toward the diagnostic 19 purpose?
20 MR. MILLER:
It provides information that the 21 operator can use to carry out a diagnostic process.
It is 22 simply a display of information.
23 MR. RAY:
Yes, but is it a display of informa tion 24 over and above the minimum requirements in the NUREG?
That 25 is the point I was trying to make.
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1 canaat ans cr that question. 1 as 2 sorry.
3 MR. RAY:
Thank you.
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4 HR. THOMPSONt Thank you, Mr. Ward.
5 In view of the time, I would like to just turn the 6 presentation over now-to Voss Moore to give us the rundown 7 on the first of the NUBEG requirements.
8 (Slide) 9 ER. HOORE:
What I would like to talk about are 10 the efforts that have been going on to improve the human 11 f actor aspects of the control room, particularly or 12 specifically three documents that Dr. Ward montioneds the 13 guidelines that we propose that the utilities use in O
14 evaluating their control rooms; the evaluation criteria 15 which we the staff propose to use to evalua te the licensee's 16 control room review and control room upgrades, which has the 17 side effect of aiding the utilities also; and the third 18 document, the acceptance criteria for the safety parameter 19 display panel.
20 I think that as I talk you should bea r in mind, 21 and I think there perhaps was a little bit of confusion at 22 the Subcommittee meeting, that this is not the entire human 23 f actors program that affects the control room.
It is not on 24 the agenda today but there is a program for emergency 25 ope ra ting procedures for upgrading training and O
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1 qualifications for operators and fer upgrading utility 2 management of operations.
3 So this is just a piece of it which does integrate 4 with tha rest of it.
5 With regard to the CRGR and its recommendations 6 that Dr. Ward mentioned, some of the things that I will be 1
7 saying may very well be in conflict with CHGB 8 recommendations because wha t I will be talking about are 9 docusents that are on the street right now and the thinking 10 that went behind them, so it is possible that the programs 11 may not work out as I discuss because of changes based on 12 CRGB.
13 Okay.
Before I get deeply into this, let me give O
14 you a little bit of background on how we got here. As most 15 of you who have been on the Committee very long know, prior 16 to TMI the NRC did not do much of or hardly looked at the 17 human f actors aspect of the control room at all.
We did 18 look at some of the equipment aspects, the physical 19 separation, equipment qualification, machine kind of 20 considerations, and frankly, the utilities did not do an 21 awf ul lot in the human factors area.
22 But af ter THI, three of the post-mortems or 23 recommendations did come up with some human factors lO 24 recomnendetions.
l 25 I
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1 Tue tresident s commission, the xemenr Commission, 2 certainly critized us for tolerating outdated technology and 3 for neglecting the human f actors aspect of control rooms.
4 (Slide.)
5 The Bogovin Committee, which was appointed by th e 6 Commission, also made recommendations concerning human 7 f actors engineering and control room -- and control room 8 instrumentation improvements.
9 (Slide.)
10 Now we are going to get to some of my human 11 f actors slides that I made last night.
I hope you can read 12 them.
13 The lessons learned Task Force of the NRC staff O
14 made two recommendationss one, that control rooms be 15 evaluated and improved from a human factors standpoint; that 16 the NRC develop guidelines to aid the utilities in the 17 performance of these reviews.
18 A second purpose or second recommendation was that 19 licensees install an SvDS, safety pa rameter displa y panel.
20 At that time it was called a safety state vector.
In fact 21 when you look at my slides you will see tha t the saf ety 22 parameter display panel is called by thre: tifferent names:
23 the safety sta te vector, the safety parameter display panel, w) 24 and the safety parameter display system.
25 (Slide.)
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1 Okay.
As a result of the recommendation of these 2 three committees NRC developed two task action plans, I.D.1
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3 and I.D.2.
One is the control room design review; the other 4 is, the safety parameter display, called console here.
5 (Slide.)
6 Okay.
Now the guidelines that have been developed 7 over the last year and a half, I suppose -- I think maybe I 8 should go a little bit into the fact that since NRC really, 9 and the nuclear industry, did not have any history in human 10 f actors, we went to NASA, National Bureau of Standards, 11 def ense installations.
We toured Cape Canaveral, Houston; 12 talked with the people who have developed guidelines; and 13 used documents of theirs as the base for developing 14 guidelines, although it took a remarkable amount of effort 15 to convert those guidelines to apply to nuclear power plant 16 control rooms.
17 In fact, our first draf t of this document that 18 went out, a few places " cockpits" slipped out where it was 19 intended to be " control room."
We did find that there was 20 the necessity to generate some additional g uidelines, that 21 there were some needs in control rooms that really had not 22 been addressed by aerospace.
23 0700 really contains recommended procedures for 24 the various parts of the control room review.
The planning 25 is the establishment of a multidisciplinary team by the O
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1 utility.
It involves the developing of plans so that each 2 of the disciplines can be heard and that there is a process 3 for arriving at consensus editions and that there is a
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4 program that will cover the complete review of the control 5 room.
8 The review process, this is the process, and I 7 vill be discussing it in somewhat more detail of reviewing 8 control rooms and identif ying human engineering 9 discrepancies.
These human engineering discrepancies are 10 devia tions f rom established good practices that have been 11 developed by the human factors community.
12 Assessment and implementation.
Assessment is the 13 assessment of these human engineering discrepancies to O
14 identif y those that are significantly important to safety.
15 Lots of people say that every human engineering discrapancy 16 has some effect on the operator's capability of operating 17 the plant safely.
But our approach has to be, since these 18 are olants that are built and have been operating, that one 19 really needs to look to find the human engineering 20 discrepancies that are really significant to saf ety.
So 21 assessment is that process.
22 Implemen tation is the developing of a program for 23 correcting the really safety-significant human factors
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24 discrepancies.
There is a reporting section and this 25 bottom, the human engineering guidelines.
That really, that ALDERSON REPORTING COMPANY,INC.
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i constitutes the du1k of the document, 1 wou1d =er two-thiras 2 or three-fourths of the documen t, and these are a listing of 3 good human factors practices.
4 These are -- this is really the guts of the 5 document, that people evaluate their control room against 6 these practices.
7 (Slide.)
8 Now, before I get any deeper into the guidelines I 9 vant to mention something, go back to something I mentioned 10 earlier, that the control room review and the SPDS is not 11 the whole story.
It really does not stand alone and has to 12 be integrated with emergency operating procedures.
13 This slide was prepared saying " control room."
O 14 Control room improvements have to be integrated with all of 15 these items here, and this is really quite true.
The 13 analysis that goes into the development of the symptom-based 17 emergency operating procedures fits right into the control 18 room review, because it identifies the operator's functions, 19 the f unctions the operator has to perform in the control 20 room, and what his display and control needs are.
21 So it is a single analysis that fits inte both 22 programs.
Obviously, you make changes in the control room, 23 y ou have to retrain the crew or you will have made it O
u w-se.
25 Control room staffing.
This analysis that goes O
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1 into the emergency operating procedures and the control room 2 review and the verification of the ability to perform these g
3 procedures, may impact on the control room staffing.
So I 4 cannot emphasize the coordination and integration enough, 5 because that is kind of th-watchword of our whole program.
6 (Slide.)
7 Well, wha t is the re view process?
It is to 8 determine whether the control room is a pla ce that you can 9 -- that the operator can accomplish his task, and whether 10 there are characteristics in the control room that detract 11 f rom the operator's performance.
12 (Slide.)
13 In the review process, we fairly arbitrarily have O
14 broken it up into several parts of the process.
One we call 15 the foundation process involves a review of the operating 16 experience at the plant.
This comes from reviewing 17 d oc umentation, logs, LER 's, intervie wing operators, reading 18 events f rom similar facilities, and to try to isolate or 19 establish whether there are errors and incidents where there 20 w as human error that involved a -- that called out 21 particular deficiencies in the control room.
22 Another one of the foundation processes I 23 men tioned earlier was this systems f unctional review and 24 analysis of the operator's tasks, and the reason -- and the 25 way this is used in the control room review is that in that O
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s iave torr or ta co trot reo to ter to riae out it 4 something that is really needed, and particularly really 5 needed in an emergency, whether it perhaps is missing, and 6 that would constitute a human engineering discrepancy if it 7 vere.
8 (Slide.)
9 The investigative process.
The control room 10 survey, which is part of this, is the comparison of the 11 control room with the guidelines in order to identify human 12 engineering discrepancies.
The verification and valida tion 13 here, verification is the verifying that it is possible to 14 accomplish the particular emergency, namely emergency task, 15 with the control room as designed.
16 The validation involves the multitude of tasks 17-tha t may be going on and whether the integrated control room 18 crew is capable of accomplishing those control room 19 f un ctions.
20 (Slide.)
21 The assessment I think I hit earlier.
Certainly 22 it is an important facet of this, because there are human 23 engineering discrepancies in control rooms that really, by O
24 golly, ough t to be fixed.
And there are others tha t it just 25 is not cost beneficial to fix.
It is necessary to do an O
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i assessment and in thet esseesment it is necessarr to deve1o, 2 a justifica tion or a rationale for not fixing the ones you Q
3 are not going to fix.
4 (Slide.)
5 HR. KERR Voss, I understand how you assess the 6 costs of changes, but how do you assess the benefit when you 7 have concluded it is not cost effective?
8 MR. HOORE:
Okay.
The assessment process involves 9 a looking or asking yourself a number of questions that are 10 geared toward steering you toward the potential f or the 11 human engineering discrepancy for causing an operator error; 12 sort of the probabilities, a qualitative feel for the 13 probability, and other questions that you ask yourself 14 concerning the consequences.
15 If this human engineering discrepancy occurs, what 16 kind of consequences could it cause you to make?
Is it 17 recoverable ?
Does it reveal itself?
Is it not related to 18 saf ety?
19 So the assessment -- and I will be discussing this 20 under NUREG-0801 -- is sort of a screening process to sort 21 of categorize your human engineering discrepancies from the 22 t op, the ones that are very importan t to sa fety, to the ones 23 where it would be right nice to fix them but it would be O
24 herd to define their sefety 1.pect.
25 (Slide *I
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Another part of the 0700 is.-- describes the 2 reports which we are recommending be sent to NRC.
You vill 3 notice it is a two-step process and the program plan calls 4 f or that being submitted early in the proedsst.
Now, this 5 departs from our normal process at NRC.
We usually look at 6 the finished product, but it turns out that in control, room 7 reviews, a troical control room, you -will identify hundreds
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8 of human engineering discrepancies -- tso', th'ree, is that
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9 about right, four hundred human engineerin's discrepancies.
10 And with the NRC audit there really 'is no vay?.that-in depth 11 ve can go into the utility's assessment of.all, say,,300 12 human engineering discrepancies to be sure that all the 13 justifications for not fixing are valid and all the fixes O
14 are very good fixes.
s 15 So an awful lot rides on the qualificat' ions of the 16 utility 's review team and whether they do'have? processes for 17 resolving conflicts and finding a good consensus.
We a re 18 not recommending that that be submitted for approval, but we 19 are recommending that it be sent in and we are a'greeing that 20 where we find real deficiencies in their procram cr in their 21 qualifications tha t we vill notify them.
22 The second is the more conventional.
It is a 23 report identif ying the human engineering discrepancies that O
24 in de cxtected..he t th e cxtecuene uem het the 25 proposed schedule is, and providing the justification f or ALDERSoN REPoRTINS CCUPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGYoN, D.C.MI4 (202) 554 2345
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1 not fixing the ones that will not be fixed.
2 (Slide.)
(3 3
Okay.
Let's move on to NUREG-0801, which are the
\\J 4 evaluation criteria for the control room design review.
5 This is an aid -- it was written as an aid to the NRC staff 6 in determining the adequacies of the control room upgrades.
7 But clearly it is of assistance to the utilities.
It _ d oes 8 provide a rating scheme and it helps them know how NRC will 9 be evaluating their work.
10 (Slide.)
11 NUREG-0801 provides guidance on the adegracy of 12 these aspects, and a couple of kore on the next slide, of 13 the utilities ' evaluation, such as the team qualifications, O#
14 program plan.
The bulk of this document is contained in the 15 assessment of the human engineering discrepancies, because 16 here is where we do provide a methodology for screening 17 hum an enoineering discrepancies.
l 18 Now, we have talked with ownerc groups and some l
19 utilities who have moved pretty f a r in to their control room i
l 20 reviews, and some of them have dif ferent rating schemes than 21 ours which look like they will be conpletely adequate, and 22 that there is no magic rating scheme.
But the thing that l
l 23 came thrugh loud and clear in our control room reviews is
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24 because of the variations in control rocms and the 25 variations in the ways that you can correct the human l
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1 engineering discrepancy -- you know, one pe rson may very 2 well choose to fix his board, move a meter or a switch, and
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3 another may choose training.
4 Certain things obviously you have had difficulty 5 training a person to do, but certain things are amenable to 6 training.
The SPDS, if they have a particularly good SPDS, 7 some of the discrepancies that might involve the detection 8 f unction -- observing whether you are leaving normal and 9 going into a transient -- that might be the fix for that.
10 So what really came through because of this 11 variation was that we were not going to be able to develop x
12 go-no go criteria that say when you have this kind of 13 arrangement you fix it to be this way.
It just was not k_)
14 feasible, and I think you have to recognize that there is l
'15 some flexibility and some subjectivity.
16 The assessment of the basis for not correcting 17 discrepancies.
We have some -- we have a process here, but 18 I do not think all reasonable men will always agree tha t 19 this HED ought to be fixed or not fixed.
20 MR. KERR Suppose you turn two good human 21 engineers loose on the same control room at separate times.
22 How much correlation would there be among the list of HED's 23 that each identified?
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24 MR. MOOREs That is rather difficult.
I think 25 there would be a fair amount of correlation.
I think there O
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i o=1d de a ereat dee1.
- o ve are findine --
2 MR. KERRa I assume you have had some experience.
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3 MR. MOORE:
Yes, on operating licenses.
4 Yes, Leo.
5 MR. BELTRACCHI Leo Beltracchi, human factors 6 s ta ff.
7 I think what we can state in response to your 8 question, Dr. Kerr, is that in many of the reviews that the 9 staff has been involved in we have found that there has been 10 a repetitive pattern and we have correlated many of the 11 problems and, in terms of the reviews that we have had, for 12 example annunciator panels, correlation of alarms with 13 respect to the particular panel, and that seems to be O
14 repetitive over many of the plants that we have been in, 15 aany of the control rooms.
16 There are other type problems tha t go along.
I 17 only use that as an example.
18 MR. MOORE:
Another --
13 MR. KERR I do not want to spend a lot of time on 20 this, but I think the question you are answering is what 21 correlation do you find among control rooms.
The question I 22 an asking is what correlation do you find among the results 23 produced by human engineers who look for HUD's?
24 MR. BELTRACCHI We have used several different 25 personnel in our review teams and it does come up with the O
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1 same type of results.
2 MR. MOOREa I think another little thing that
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3 would shed some light on this, in doing the near-ters 4 operating license reviews the utility does a preliminary 5 design assessment, identifies human engineering 6 discrepancies.
We send a team out to spend a week in the 7 control room.
We vill have reviewed those, but very 8 briefly, because we want to do sort of a fresh review of the 9 control room, and we come up with a number of common 10 discrepancies that both of us identified, and then,wie 11 generally identify more of them.
12 In general, we identif y all of the discrepancies 13 their consultants have, plus some more.
And then after we 14 get into discussions with the utilities we of ten learn that 15 the consultants have identified those and those have been 18 screened out before they were sent in because, as we start 17 t alking about, the utility usually knows a great deal about 18 wha t we have identified.
19 So I would say there is a fair amount of 20 correlation.
Now, with regard to ability with two human 21 f actors engineers or two human systems f actors engineers, 22 would they come to the same conclusion with regard to the 23 importance of an HED, on the opera tino license control room A(/
24 reviews we have a more simplified approach than that that is 25 outlined in 0801.
We only have three categories, and they
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1 are ranked in order of their importance to safety and 2 potential for operator error, one, two and three.
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3 The ones and twos, we usually require that 4 co,rrections be made prior to the issuance of an OL.
The 5 threes, we ask the utility to complete those and study then 6 during their detailed control room review.
But we find tha t 7 our team has remarkable consistency.
I just do not find the 8 five members of the team, somebody saying it is a one, 9 somebody saying it is a two, somebody saying it is a three.
10 It is usually all five agreeing or four to one.
11 So I think tha t, although there is subjectivity, I think for 12 the most part there is agreement, pa rticula rly when you use 13 a structured process.
O 14 MR. MOELLER:
What is the composition of an NRC 15 team?
I mean, are these f ull-time employees or consultants 18 that you hire?
17 HR. MOORE:
The answer is yes, both.
18 MR. MOELLER:
Both.
19 MR. M00RE4 We have on our staff, we have both 20 systems engineers, reactor engineers, the old retreads like 21 myself working on reactors and are starting to learn human 22 f actors, and about half the branch are relatively new 23 employees who are either human f actors engineers or humsa
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24 f actors psychologists, whom we have sent to-the ICE reactor 25 systems courses and the simulators and so forth.
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1 So we normally have an NRC person as the team 2 leader, and he or she may be either one of these, reactor l
()
3 engineers or psychologists.
4 We have consultants, Lawrence Livermore, and they 5 have a human f actors outfit, Biotech, as their 6 subcontractor.
And in general the Lawrence Livermore people t
l 7 are sort of reactor systems types who now have been in human i
8 f actors work about a year.
And Biotechnology are human 9 f actors psychology types who have been working on reactors 10 for about the last two years.
11 So it is a mixture of about a five-man team, and 12 they break up into suboroups, each one assigned to a 13 licensed operator, to go review different aspects of 14 dif ferent panels.
And the whole team reviews the work of l
15 each of the subgroups and rates the human engineering l
16 discrepancies.
l 17 MR. MOELLER:
Thank you.
18 MR. MOORE:
Just two more parts of 0801.
The 19 justification for the HED's that are not corrected, and it 20 gives you some assistance in evaluating the adequacy of the 21 schedule for the corrections.
22 (Slide.)
23 I would like to move to NUREG-0835, which are the 24 human engineering criteria, acceptance criteria for the 25 SPDS.
A little bit of review as to what the SPDS is.
It is O
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a a=er tor 14 to
===1=t the over tor ta tne aetectioa or 2 whether the plant is in a normal condition or whether it is 3 about to depart from a normal condition.
4 And the method for doing this is by providing a 5 concentration of sa fety information, of plant parameters, 6 whereby the operator can very quickly assess whether the 7 plant is in normal operation or about to go into a loss of 8 coolant accident, rapid cooldown, secondary problems.
It is 9 not a diagnostic -- it is not really a diagnostic tool; it 10 is a detection tool.
11 (Slide.)
12 It is not a yes/no detection tool, trouble /no 13 trouble.
It is normal or loss of coolant or inadequate core 0
14 cooling.
And for the diagnosis and for the mitigation the 15 operators have to go to the control boards.
Now that is the 16 requirement.
17 I
l 18 19 2G 21 22 l
23 O
u 25 O
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i ve knov there are a numher of diaono tic schemes 2 being researched and developed, and one of the 3 recommendations in our document is that people retain some 4 flexibility in their SPDS so that when these tools become 5 f ully developed, that they can easily be applied to the 6 safety parameter display system.
7 As I mentioned earlier, the SPDS was defined in 8 the Lessons learned Study.
The functional criteria were 9 issued in a document, NUREG-0696, that was issued about a 10 year ago, which contains the functional criteria for the 11 SPDS along with the functional criteria for the emet 7ency 12 response f acilities.
13 And this document tha t we are talking about now, O
14 0835, -are the acceptance criteria that have been issued 15 within the last month and a half or so f or comment.
16 MR. MARKS How many parameters, roughly, are 17 followed, and how large a space is involved in display?
18 MR. MOORE:
Well, we are not spelling out what the 19 parameters are.
What has been developed is a concept of 20 critical safety functions like whatever parameters you need 21 to be assured that the core is being cooled.
22 MR. MARK:
Roughly how man y does this amount to, 23 than?
24 MR. MOORE:
It can be 7 to 15 or thereabouts.
25 MR. MARK:
On how many scopes?
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1 MR. MOORE:
We do not specify how many. Some 2 systems we have seen have one.
Typically they have two, 3 don't they, Leo?
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4 MR. BELTRACCHIa Yes.
5 MR. M00 ret It is a little bit hard for me to talk 6 about because nobody yet has proposed just a bear SPDS i
7 system that just barely meets our requirements.
I was going 8 to discuss this later.
People seem to be taking advantage 9 of installing the SPDS to generally upgrade their plant 10 computer and their data handling system, so it is a little 11 hard to tell what is j ust the SPDS.
12 (Slide) 13 Okay.
The acceptance criteria respond to the i ()
14 functional criteria, and this addresses one of Dr. Ward 's 15 comments that 0835 is limited to acceptance criteria for a l
l 16 com puter-ba sed, CRT-displayed SPDS.
And we did not do tha t 17 because we think a hard wired system is not feasible or that 18 we would not permit it.
We just found in talking with 19 owners groups, vendors and individual utilities, virtually 20 everybody was proposing a CRT-type system.
So just to 21 conserve staff resources, we wrote our evaluation criteria 22 around this type of system.
l 23 Now, we really do not think we would have any
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24 trouble if somebody proposes a hard wired system of adapting 25 these criteria or certainly not adapting the functional l
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172 1 criteria, because we think we can handle it; but we think i the acceptance criteria as written will address most of the O
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4 (Slide) 5 One of the sections of the acceptance criteria, 6 the general acceptance criteria, provides some guidance for 7 enhancing the operator's performance and gives guidance for 8 developing displays; that it is very clear to the operator 9 in a very short time that either the plant is in a safe 10 condition or it is dephrting into a transient.
11 (Slide) 12 General acceptance criteria do provide guidance to 13 meet those recommendations that I just discussed in the area 14 of display patterns, scaling, perceptual aids and so forth.
15 (Slide) 16 Another section of the document, the specific 17 acceptance criteria, there is a one-to-one correla tion 18 between the functional criteria in 696 and acceptance 19 criteria and another column in that section ref erring you to 20 applicable sections of NUREG-0700.
So the functional 21 criteria, some much more specific acceptance criteria, and 22 than a reference to human factors guidelines in NUREG-0700.
23 Now, the functional criteria fall in all of these 24 categories.
25
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1 We anticipate a one-step review of the safety 2 parameter display panel, which entails an assessment of the 3 licensee's verification and validation progrsa and audit of 4 his design and the development test work that he has done in 5 developing the SPDS.
6 Well, that finishes my run-through, and it has 7 been sort of a run --
I hope I have not talked so f ast you 8 could not understand me -- of these three documents, but the 9 Subcommittee did ask me to discuss briefly the cost and, if 10 possible, the benefits of doing these reviews.
I want to 11 talk not just about the control room review and the SPDS but 12 I want to talk about the emergency operating procedures 13 because I have a great deal of trouble splitting them out, O
14 and if the control rooms get improved and you did not 15 improve emergency operating procedures, you really have not 16 won the battle.
17 There is a lot of variation, variability in th'ese 18 reviews.
None of them have been completed yet, not the 19 detailed control room reviews, so what I did was to call a 20 number of utilities and owners groups that are well into 21 their review, some consultants who are working with the 22 utilities on these reviews, and ge t their estimates of costs.
23 I have broken this down between the cost of doing
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24 the review, the cost of the so-called enhancement 25 corrections.
These are more the surface corrections, the O
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i eaviroa eat 1, the aoise, tightiag rtoat o.1 the coatrot 2 boards, demarcation, color coding, p rio ri ti zing.
That does 3 not involve cetting into the wiring in back of the panel, 4 which you would have to do if you relocated the instruments 5 on controls. And the third item is the relocation and 6 additions.
7 I found an interesting pattern.
The larger 8 utilities with large staffs tended to estimate lower costs 9 than the smaller utilities who were using all consultants.
10 N ow, part of this is probably in the accounting in that the 11 utilities f eel they are paying their consultants, whereas 12 the small utilities -- the large utilities did not figure 13 the cost of the various plants and that sort of thing.
So I O
14 think some of it is real, but I do believe that the big 15 utilities will have a cost somewhat lower than this, the i
16 small utilities somewhat higher.
But the average was about 17 five mar sars, which I translated into $500,000.
18 Enhancements.
There was remarkable convergence on 19 this because all of the licensees, recent licensees'have 20 done enhancements prior to licensing, and their estimates 21 all came very close to $100,000.
Relocations and 22 additions.
This is probably the wildest one of them all 23 because until you finish the control room review and do all O
24 the eseesement, you do not know whet you ere going to move 25 around or whether you are going to move anything.
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1 still ask for estimates, and the average of them, dithough 2 there was a tremendous spread, it was $300,000.
3 So it looks like control room reviews and upgrades O
4 on average would cost about $900,000 per unit.
Well, I have 5 repeated that number here in order to compare it with SPDS 6 and upgrade of emergency operating procedures.
The SPDS, we 7 ran into something interesting, and that was the fact that I 8 have alluded to a little bit earlier.
Nobody seems to be 9 planning to put in an SPDS that just barely meets the NRC's 10 requirements.
They, most of them, find that this is a good 11 opportunity to upgrade their own on-site computer and their 12 data handling that involves parameters other than the safety 13 parameter display panel.
14 So I have seen estimates f rom $2 million to 15 $10 million f or the upgrades that involve the SPDS, but in 16 trying to parce out what is just the SPDS, I got estimates 17 of from one-half million to a million dolla rs, so I used 18 $750,000 as my estimate here.
19 Upgrade of emergency operating procedures, the 20 owners groups estimate about $560,000.
'?ha t is about what 21 we estimated in NUREG-0660.
It would be much higher than 22 this if virtually all of the analysis and much of the work 23 were not being done generically by owners groups and
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24 vendors.
So you see, the results is slightly more than $2 25 million.
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1 Okay, benefits.
You see, these a re a little hard 2 to pin down.
Safety benefits are even tougher.
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3 Subjectively, we have gone back to two, I believe, of the 4 ne,ar-term operating licenses where they have made 4
5 significant upgrades of their control room.
We talked with i
6 the shif t supervisors and the operators when we reviewed it i
7 the first time and then came back to verify the upgrades, 8 and they were all very, very positive, the operations types.
9 Now, some of the people higher ". the company who 10 spend the money perhaps would not have been so enthusiastic, 11 but the operators were very enthusiastic.
Now, they felt 12 they really had a safer plant, but you have to recognize 13 that this may be the first time they have'been listened to 14 in a long time.
Our team goes out and talks with them.
So 15 we think they are real improvements, but part of it may be 16 that they consider it is their control room after the 17 announcements have been put in.
But that is very subjective.
18 One thing I did was to try to com pare this cost 19 with the cost of -- you see, this is sort of a cost of 20 upg rading the human component of safety, and I tried to get 21 a little 3tt of a handle on the cost of upg rading or the 22 cost of the machine part of safety, and I had heard over the i
23 yea rs, and I cannot prove it at all, but I have heard people 24 say that the cost of the safety equipment in a plant or a 25 unit is about 10 percent of the cost of the plant, which O
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2 and so forth, which would make the cost of the safety 3 machinery of the plant about $150 million.
4 So this is a little more than one percent of the 5 cost of the machine part of safety.
Certainly I think it is 6 the intuitive reaction of anybody who has been on procedure 7 reviews or control room reviews that when these programs are 8 complete the risk will, we feel, be reduced ty more than one 9 percent.
Certainly we have read numbers recently about the 10 contribution of risk from human error as being about 50 11 percent of risk.
I notice the latest was the Subcommittee 12 of the President 's Ove rsigh t Committee that quoted that 13 num ber.
14 So with those numbers, that comparative review, we 15 tend to feel it is cost effective, but that is certainly not 16 a rigorous review.
It just campares the cost effectiveness 17 of it with the cost effectiveness of the mechanical gear, 18 but it is the best we can do.
Certainly we do get the 19 intuitive f eel that there is f ar more reduction in risk than 20 the one percent that looks like it would be required to make 21 it cost effective on a comparative basis.
22 That is all I have to say, gentlemen.
If you have l
23 any questions, I would be happy to try to answer them.
! ()
24 MR. EBERSOLE:
May I ask just one little question?
25 What I hear you saying about human factors and rearrangement
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1 of control rooms and use of multiple colors and CRTs and so 2 forth, it never gets back to whether you are upgrading the 3 quality of the signals that are incoming to the control, to
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4 th,e operator himself.
Are you going to 1E levels of 5 standards for the input to the operator's eyeballs?
Are you 6 putting them on tech spec standards of inspection and 7 control drif t and other things?
Are they about the same 8 level as they were before we started all this business, 9 which was non-1E?
10 MR. MOORE:
In general we are not requiring 11 upgrading to 1E.
Mow, there are certain places that we do 12 improve the quality of the signal in that we are looking for 13 a direct reading rather than indirect reading.
We certainly O
14 do not -- we would look for flow if that is what we were 15 interested in rather than a valve position and that sort of 16 thing, but no, we are not changing the quality s ta nda rd s.
17 In fact, we may indeed be bringing the operator to use more 18 of the non-Class 1E because we are really stressing using 19 the best inf ormation that you can get, things that ars 20 diverse, and yot know very well how many in ciden ts -- w ell,
21 we have been saved in a number of incidents by non-Class 1E.
22 MR. EBERSOLE:
If the plant has a fire and you do 23 not separate circuits and all at once we find out that all
(
24 of this new instrumentation has been thrown onto a single 25 cable tray, where is the operator left?
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1 MR. MOORE:
We are not degrading the NUREG-1.97.
2 I have to keep my brain straight here.
I am not the ICC 3 engineer anymore, I am a human factors engineer.
And Faust b~
4 Rosa still has the same requirements for the Class 1E 5 components in the control room.
And I do not believe I 6 mentioned it.
I latended to.
Phea we look-at the 7 corrections, we have to be sure that the correction meets 8 the other requiresents, the non-human f actors requirements, 9 like physical separation, seismic qualifica tion and that 10 sort of thing.
So we are not downgrading it, but certainly 11 we think we are providing a better six of information. But 12 we are not requiring more Class 1E equipmen t.
13 MR. KERRa Although it seems to me that your unit O
14 is not necessarily the one that would take lead 15 responsibility f or this, is somebody worrying about 16 specifying some sort of reliability for these systems to 17 which Mr. Ebersole refers?
18 ME. BELTRACCHIa Yes.
Well, let me add two 19 things. One, we are requiring rela tive to the safety 20 parameter display system that the implicative signalc be l
21 validated wherever reasonable, and in those cases where they 22 cannot be validated, then it would be so signified to the 23 opera tor.
This would tell the quality of the data you would O
24heve-25 Relative to the second, the question you bring O
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5 MR. BELTRACCHIs I think we gave the example that 6 ve could compare redundant sensors.
7 HR. EBERSOLEs What do you do with redundant 8 sensors when they contradict each other?
9 HR. BELTRACCHI:
That very definitely is a e
10 pro bles, and the operator would have to ref er to maybe a 11 1.97 backup.
12 ER. KERBS If you have a sign tha t says " invalid" 13 --
14 HR. BELTRACCHI Pardon?
15 MR. KERR If a sign flashes and it says " invalid" 16 --
17 MR. BELTRACCHI Well, we have not specified wha t 18 kind of design.
We have asked tha t the designers so signify 13 if the data is invalid so that the operator would be made 20 aware of it.
21 With regard to your second question, would you 22 repeett that again, please?
23 MR. KERH:
What I asked was whether anybody was 24 giving thought to apprcpriate reliability standards for 25 systems that maybe should not necessarily be Class 1E but O
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1 should have high reliability.
2 HR. BELTRACCHIs Yes.
We ask the systems have an 3 una vailability of
.01, that this system have an 4 unavailability of
.01, and that is stated in 0696.
5 HR. MOOREs There is further a requirement 6 presently, a recommendation on the safety parameter display 7 panel that there be a seismic Class 1E backup Is it Class 81E or is it just seismic?
A backup on the control boards 9 that are human factored so that if the SPDS itself is not a to seismic design, that there would be --
11 HR. KERR Are you implying that operators be 12 Class 1E?
13 (Laughter.)
14 MR. MOORE:
No.
15 HR. KERE:
Then all this stuff is not going to 18 help in the case of an earthquake.
17 MR. WARD:
Voss, one question.
As I understand 18 i t, the Commission has not yet decided whether to require 19 the 0700 review of all licensees.
You indicated a number of 20 licensees have started making the review alread y.
21 HR. MOORE:
That is correct.
22 MR. WARD:
How many?
Can you estimate how many 23 have started?
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24 MR. MOORE:
Oh, I think half a dozen or so.
25 Anybody from industry or NRC staff got any better judgment?
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1 Any of the consultants?
I would guess about, oh, eight or 2 ten units.
I know some of the utilities are using cne
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3 review team for all of their units, but I think that, of 4 course, is in addition to the near-term Ols, which must be 515 or 18, who have not done the detailed review but have 6 done a preliminary assessment, which is probably a quarter 7 of the way through the whole thing.
8 MR. RAYa Do you think, Voss, tha t you could maybe 9 average the response of eight to ten units to about 10 10 percent of the operating plants?
11 ER. HOORE:
I must --
12 MR. RAYa Okay.
13 HR. MOORE:
I am afraid I may be wrong in my 14 memory.
15 HR. RAY:
Peace.
16 HR. MOORE:
I know several utilities who have 17 programs with multiple units, and I know of one owners 18 group, and I am quessing it is probably eig ht or ten or 19 twelve units.
20 MR. WARD 4 And ha ve you reviewed their plans as 21 you plan to do?
22 MR. MOORE:
No, sir.
We have not. They have not 23 submitted them yet.
Only one did submit a program plan and
()
24 withdrew it very quickly, so we have not reviewed any 25 program plans yet.
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MR. MARK What is the NBC's cost in man-years per 2 review?
3 MR. MOORE:
I had that with me at the Subcommittee 4 meeting and I do not believe you have them in your notes.
I 5 have them in my briefcase.
let me show it to you at a break' 6 time, because I have it, I just do not have it committed to 7 memory.
8 MR. MARKS Unless the Subcommittee members 9 remember it.
Probably not.
to MR. MOORE:
It is, I believe, for the program 11 plan, and here I am really relying on my memory, that it is 12 about a stsff week of time plus about two weeks of 13 consultant 's time.
That is for reviewing the program plan.
14 We are going to have to use consultants.
15 Now, for reviewing the details, about twice that.
16 MR. WARD:
For the program plan you have a total 17 of about 18 man-days for staff and consultants.
18 MR. MOOPE:
And consultants, right.
19 MR. WARD:
And for review of enhancements, about 20 28 man-days.
21 MR. MOORE:
And that is per unit.
22 MR. MARK:
Okay.
23 MR. WARD:
I guess there was some discussion that O
24 came out or tne sudcemmittee eetiae, ere enere e=ouoa nume=
25 factors experts in the world to staff all of these teams?
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2 MR. MOOREs It is close, but there probab17 are 3 about enough.
4 MR. WARD Okay.
Wel1, thank you, Ross.
i i
5 Ed Blackwood of the CRGR has some words for you.
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1 (Slide) 2 MR. BLACKWOOD As was noted earlier, the 3 Committee to Review Generic Requirements did not meet
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4 yesterday.
We will be meeting next Wednesday, so the 5 material that I want to present to you today is 6 substantially the same as what I presented to the 7 Subcommittee on Tuesdray morning.
8 The Committee to Review Generic Requirements had 9 identified in one of its meetings in early December the need 1
10 to clarify requirements regarding emergency response 11 f acilities and capabilities and also to clarify the wa'y in 12 which the NUREGs and regulatory guides should be used.
13 The CRGR believes that improvemen ts in O
14 coordina tion among the various activities or initiatives in 15 the emergency response area is necessary.
And as a result, 18 they requested that the DEDROGR, which stands for Deputy 17 Executive Director for Regional Operations for Generic l
18 Requirements -- Victor Stello, in other words -- that his 19 staff develop or - propose some basic requirements and also an l
20 implementation plan for implementing these requirements.
l 21 (Slide) 22 The scope of the initiatives which the CPGR 23 considered are divided into three broad categories.
SPDS is
()
24 one category.
Control room improvements, which include the 25 design reviev, implementation of Regulatory Guide 1.97 and l
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1 1.23 as the second category.
And the emergency response 2 f acilities es a third category, which would include the 3 acronyms here stand for the technical support center, the 4 emergency operations f acility, the on-site support center, 5 and the nuclear data link.
G We did -- I have not listed here the operator 7 capability because it transcends all of these categories, 8 and the CRGH believes that the hardware aspects of the 9 emergency response initiatives are the aspects which should 10 be addressed now.
11 We are not selling the operator short, but rather 12 keeping in perspective the fact that all of these hardware 13 fixes and changes and everything else are ultimately or 14 should ultimately be designed to aid the operator in 15 responding to emergencies.
16 (Slide) 17 Some very broad milestones in the process which we 18 see in the f uture is the review by program offices, which 19 vill be completed by next Monday, a review at the next 20 Committee meeting, which will be next Wedne sd a y.
From that, 21 the Committee will make a recommenda tion to the executive 22 director for operations, who will decide.
And following 23 t h a t, whatever Commission interaction is necessary fo r
()
24 either information purposes or the Commission taking action 25 would follow.
And after that, implementation of the O
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1 requirements for emergency response facilities.
2 (Slide) l
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3 The proposed basic requirements which I would like 4 to discuss briefly with you now are those elements which the 5 Committee believes are critical enough to call regulatory 6 requirements for these emergency response f acilities.
7 Now, for the SPDS the Committee believes that it l
8 is an aid to the operator; that it can be separated from the 9 other initiatives that are associated with emergency 10 responses that no seismic or Class 1-E qualification is 11 necessary; and the single-f ailure criterion would not have
(
12 to be met, primarily because in the SPDS is an aid or 13 augmentation to control room instruments existing already.
O 14 So the single-failure criterion would necessarily apply, so 15 you do not have to worry about Class 1-E qualifications.
16 The Committee feels that a limited number of 17 variables should be -- only a limited number of variables 18 should be included in the SPDS because essentially we feel 19 tha t the purpose of the SPDS is to ellow the operator to cut 20 through the maze of indications, alarms, and everything elce 21 that has been stuffed into the control rooms to determine l
22 very rapidly plant status and comprehend what is going on.
i 23 Now, along with separating the SPDS from the other
()
24 activitics and making it a reg ula tory requirement, it is 25 something that would be done in the somewha t near -- on O
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1,somewhat of a near-term basis.
Also, no future changes 2 would be anticipated or required of the SPDS.
It is simply 3 that the operator -- or, excuse me, tha t the licensee would
[}
4 design, build, install, train people on and use without fear 5 of next month or two years from now the ERC coming back and a saying, "What you have is inadequate.
Put these additional 7 things into it, things like this."
8 And so, in order, I think, for the Commission to 9 require an SPDS, some statement to the effect that what the 10 licensee does in f act install if it meets the basic 11 requirements of the NRC is adequa te vithout fear of major 12 ba.kfits sometime in the future.
13 (Slide)
O 14 The SPDS, as you mention, Dr. Ward, is not a 15 regulatory requirement right now.
And the Committee feels 16 that NUREG-0835 does have adequate information in it, but it 17 is not a requirement.
It should not be used by the Staff as 18 a set of inflexible acceptance criteria, and it should be 19 provided to licensees for information only.
20 Regarding control room improvemen ts, there are 21 human engineering documents that have been published.
22 NUREG-0700 and 0801 are a couple of them.
EPRI has an 23 ongoing series of human f actors documents that are relevant
(
24 to control room design.
The Committee feels or has proposed 25 a t this point that licensees -- that the Dacic requirement Ov ALDERSoN REPoHTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) $54-2345
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1 be that licensees be required to review these documents and 2 decide what further actions they feel they have to take.
3 In cases where safety-significant discrepancies
{)
4 have been identified, the licensee would describe 5 modifications that the licensee would plan to take to 8 correct significant -- or correct the discrepancies that 7 have an adverse impact on safety.
8 As far as cost-effectiveness is concerned, I have 9 thought about this a little bit, and I believe that a 10 relevant cost-benefit analysis would probably be more in 11 terms of the cost of making the improvements versus the 12 future expected savings to the licensee in terms of, one 13 a rea wo uld be, plant reliability, availability, on-line O
14 time.
Another area would certainly be the safety benefits.
15 But I be1.ieve that the relevance of cost benefit is not to 16 compare it to the sunk cost tha t you may have put into a 17 plant ten years ago but rather the expected benefits you 18 expect in the future.
19 Regarding the modifications --
20 MR. MARK 4 Does CRGR regard the fact that an 21 operator may have to peer or squint or shield his eyes is a 22 thing of saf ety significance?
~
23 MR. BLACKWOOD:
I do not know.
(
24 MR. KERR I do not understand the statement you 25 just made about sunk costs versus something-or-other.
Could O
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1 you repeat what you said, please?
2 MR. BLACKWOODs Regarding tge cost-b'enefit 3 analysis, I believe tha t a relevant analysis wou'id Fe the O
4 costs that would be put out in the future, the cost 'of 5 future improvements versus the expected benefitswhich could 6--whichwouldaccruetothelicenseeinthefhurein. terms 7 of safety and other benefits.
^
8 MR. KERRs Is there some way you see for attaching 9 a quantitative value to that latter?
10 MR. BLACKWOODs It isv.ery difficult from the 11 standpoint of improving safety.
12 MR. KERRs Then how does one do the cost-benefit 13 analysis?
What do you compare with what?
You can compare O
14 -- you can, I assume, cost out the change in dollars, but 15 how do you then compare that wi~th"something else?
16 MR. BLACKWOODs As I un'derstand, the benefits of 17 the control room design review.vould not only enhance safe ty 18 in some way, shape, or form, but it would also, in reducing 19 the rate of human errors, have'some positive effect on plant 20 availability, a reduction in the rate of forced outages 21 caused by emergencies and things. of this na ture.
One thing 22 ve might consider are the fixes that are under 23 consideration.
()
24 MR. KERRs I am sorry, I thought you said you had 25 given this a good bit of thought and you were convinced it h
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I could be done in a quantitative way.
2 MR. BLACKWOODs No, I do not think so.
3 MR. KERR.
Okay, I misunderstood you.
Fxc ose me.
~4 MR. BLACKWOOD Other than requirements f or NBC 5 approval under 10 CFR 50.59, which is the regulation on 4 changes, tests, and experiments, no approval, no prior 7 approval of NRC to make changes, make modifications to 8 improve control room designs would be required.
9 Begarding Seg Guide 1.97, the lis t of pa rameters to in Reg Guide 1.97, I think, are -- well, they are something 11 which should be considered and probably implemented within 12 the control room sometime.
Deg Guide 1.97 does not -- Rev.
13 1 has not been implemented yet, and there are some
()
l 14 exceptions to those listings in that reg guide which have i
15 not been r* solved yet.
16 MR. KERRa Now, it appears from that that Reg 17 Guide 1.97 is being treated somewhat as a requirement.
18 MR, BLACKWOODs If the parameters in Reg Guide 19 1.9'! are im porta nt, if they are essential to energency 20 response, then I see no reason why they should not be 21 requirements.
22 MR. KERR I have been told from my youth that 23 regulatory guides were not requirements.
Is this a change l ()
24 in policy of the Commission?
25 MR. BLACKWOODs No.
If Commission desires to
()
l ALDERSON REPORTING COMPANY. INC, l
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- rea=1re eat, r wou1a =uovo e it 2 not to be issued, not to be issued just as a regulatory 3 guide but rather issued with more force than a regulatory 4 guide.
5 MR. SIESS:
That line underneath Reg Guide 1.97, I 6 think I figured out that "EQ" is " environmental 7 qualification."
8 MR. BLACKHOOD:
That is right.
9 MR. SIESS:
I suggest you not do that, because 10 depending on what we were discussing last, it might be 11 " earthquakes."
12 (Laughter.)
13 MR. BLACKWOOD:
Thank you.
O 14 MR. SIESSs That is the other category we worry 15 about, seismic.
16 MR. MOELLER:
You said that the SPDS was not to be 17' req uired to be seismically resistant.
18 MR. BLACKWOOD:
That is right.
Ihat is what the 10 Committee said.
20 MR. MOELLER:
What would be the difference in the 21 cost if Icu had -- if you gave to it the capacity to 22' withstand a seismic event?
23 KR. BLACKWCOD:
I do not know.
I do not have tha t 24 information.
25 Regulatory Guide 1.23 has three parameters in it O
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1 which the Committee feels are important to instant or 2 emergency response decisionmaking.
And those ares 3 windupeeds wind direction; and atmospheric stability.
And
{)
4 only those three parameters would be imposed or would be 5 required rather than everything else in Reg Guide 1.23.
6 MR. THOMPSON:
Ed, before you leave that 7 particular discussion, I think Mr. Ward said earlier that 8 changes were going to be negotiated between the Staff and 9 the utility-proposed changes.
I think the proposal that the 10 CRGR has is that the Staff would not be in any pre-review 11 but only in a post-review posture.
12 MR. BLACKWOOD Other than for NRC approval 13 required pursuant to 50.59, that is correct.
O 14 MR. SIESSs Can you clarify something on Reg Guide 15 1.23?
As I read the material that accompanied Ste11o's 18 letter, I thought that every reference to 1.23 was preceded 17 by the words " data accuracy of Heg Guide 1.23."
For 18 example, I am looking at one particular* area, and it says, 19 " Meteorological data is specified in Eeg Gu ide 1. 97, 20 consisting of wind direction, vindspeed, and a tmospheric 21 s ta bilit y, with data accuracy of Reg Guide
- 1. 23. "
22 So the way it is worded, it did not seem to get 23 those three parameters out of Reg Guide 1.23 but only got 3
(y,/
24 the data accuracy out of 1.23.
25 MR. BLACKWOOD:
That is the proposal, yes, that is O
ALDERSoH REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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[}
2 plus or minus so many percent.
3 HR. SIESS:
But the th ree parameters are not 4 specified in 1.23.
They are specified in words here.
It 5 does not say they come from 1.23.
6 MR. BLACKWOOD:
The parameters are specified in 71.23 along with a bunch of other stuff.
Reg Guide 1.97 8 specifies only those three parameters.
9 MR. SIESS:
Okay.
The references to Reg Guide 101.23 do not designate a revision number.
Is that the 11 existing 1.23?
12 MR. BLACKWOOD:
No; it is the one that is out for 13 comment, which I believe is Rev. 2.
14 ER. SIESSs Oh.
15 MR. WARD:
I wonder if I can inte rrupt just a 1s moment.
Maybe I can ask Mr. Thompson, would you expand a 17 little bit on the difference batseen what you mean by 18 " post -review" a nd " pre-review," for my education, I think.
l 19 MR. THOMPSON:
Well, the proposal would be, I 20 think, presented by Voss Moore earlier, that the utility 21 would identif y the proposed changes that he would be making 22 and then discuss those with the Staff, and we would use the 23 regulatory NUREG document in a flexible manner to determine
()
24 which changes he was proposing not to make and the 25 justification for that.
And then he would implement the O
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I changes in the control room.
2 Under the alternative proposal, we would not look
(]}
3 at those changes until he had completed his control room 4 review and modifications, and then he would document to us 5 that he had done that and here is the documentation of his 6 completed control room review.
7 HR. WARDS Okay.
And the practical implication of 8 that is that the NRR staff is more likely to buy off en his 9 proposal af ter he has spent the money and put it in than 10 beforehand, or what?
If you do not like it af terwards, what 11 are you going to do about it compared to what you would have 12 done about it if you had looked at it prior to the change?
13 MR. THOMPSON:
That clearly is a different 7sU 14 perspective that you have on it, and the shif ting of the 15 burden of the proof tends to be away from the utilty and 16 onto the Staff for requiring additional changes.
17 MR. WARD:
Thank you.
18 (Slide) 19 MR. BLACKWOOD Emergency response facilities.
20 The basic requirements which the Committee has proposed are 21 for the technical support center, the emergency operations 22 f acility, and the OSC.
Those attributes are characteristics 23 which the Committee feels are important enough to impose as
()
24 requirements, such things as are listed here.
25 Instrumentation essential to the function.
The SPDS is not O
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1 necessary in the technical support center or the emergency 2 operations f acility.
3 And also requirements on the rest of these,
[}
4 location, size, structure being not necessarily seismically 5 qualified.
Operability, communications, and documentation.
6 Staffing by pre-designated people in a time frame that would 7 be as soon as possible or as soon as practicable, with a 8 one-hour target.
9 And, okay, I mentioned the structure would not 10 necessarily have to be seismically qualified.
The 11 instrumentation is not necessarily Classs 1-E, and the 12 single-f ailure criterion would not be required.
13 As far as the nuclear data link is concerned, that O
i.
14 is kind of off by itself, and the proposed requirement there 15 is that whatever data system the licensee decides to use, l
l 16 that the licensee would provide a second plug or second 17 receptacle to enable transmission to some other site 18 sometime in the future.
19 MR. KERR.
Let me put that in context.
As 20 chairman of the Fe rmi-2 subcommittee, I recently received a 21 copy of a document transmitted from NRR, I guess, signed by 22 Mr. Youngblood to one of the vice presidents of Detroit 23 Edison.
And it is entitled " Evaluation of Emergency
, ()
24 Response Facilities for Enrico Fermi 2."
And it is about l
25 1.5 cen timeters thick.
l i
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1 And it has a whole series of questions somewhat 2 lik e the following s "What equipment is provided to display
()
3 data in the ERS CRT terminals?
Vendor name, model number, 4 the minimum CRT characters should be 80 characters by 24 5 lines.
Keystroking point to be used.
What is the visible 6 screen size?
Is there control of the character brightness?
7 If a terminal is intelligent, describe any special features 8 tha t would be used and how."
9 One would ge t the impression that nobody had ever 10 told Detroit Edison -- I sssume this is in response, I think 11 it is, to Edison 's proposal.
But nobody must have told 12 Edison how to propose, to begin with, if they are beine 13 asked questions this detailed.
O 14 Can you help me?
Wha t -- wha t --
15 MR. BLACKWOOD:
I have not seen that letter, but 16 many of those things sound very similar to items which vera 17 included in NUBEG-0696 and --
18 MR. KERRa But Edison did not have a copy of that 19 or -- I guess about the only thing I conclude --
20 MR. WARD:
That is not in 0696.
It is in 21 NUR EG-0814.
22 MR. BLACKWOOD:
Excuse me.
23 MR. KERRs But the utilities must not have copies
()
24 of this, appa rently.
25 MR. BLACKWOODs That is a draft NUREG.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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MR. KERR4 Then they must not believe it.
(}
2 MR. RAYS They did not read it.
3 MR. KERRs That is unreal.
4 (Laughter.)
5 And I have seen several others since then.
6 MR. MARKS I got the impression that nobody told 7 Youngblood that CRGR was taking a ra ther relaxed view of 8 this whole question.
9 MR. KERRa I really -- if I were a utility and got to something like this, I would not know whether to commit 11 suicide or choot somebody.
12 (Laughter.)
13 MR. BLACKWOOD:
I think that issue is exactly what 14 the CRGR is trying to address by saying that NUREGs are not 15 regula tory requirements and they should not be used as 16 inflexible criteria by reviewers.
And I would --
17 MR. KERR Three cheers for CRGR.
18 (Laughter.)
19 ER. BLACKWOOD:
Thank you.
20 (Slide) 21 MR. K ERR I thought the thing had been sent cut 22 as a mistake and was a joke.
And ! called, and it is for 23 real.
24 MR. BLACKWOOD:
I am afraid that is not the case.
()
25 As far as implementation is concerned, the CRGR believes O
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1 that it should be reemphasized not only to licensees but 2 also to the Staff that NUREGs and regulatory guides are not
{}
3 requirements and they are not inflexible review criteria.
4 The way in which the ED0's decision on basic 5 requirements would be promulgated to licensees would be by 6 generic letter.
The deadline dates f or completion of 7 emergency response f acilities and the other initiatives 8 which would be required would be developed interactively 9 between the licensee, the project manager, and wha tever 10 technical staff is associated with that particular 11 initiative.
12 That is a departure from the hard deadline dates 13 which have -- do exist in the regulations right now, many of O
14 which have been somewhat unrealistic, and we are finding out 15 tha t licensees do not have any hope of meeting them.
16 To reiterate, flexibility in implementation is 17 something that the CRGR feels is essential.
And back to 18 emergency operating procedures, the capabilities of the 19 operator, it is essential that these emergency response 20 f acilities and the other hardware changes which licensees 21 make be integrated effectively with emergency operating 22 procedures, operator training, things of this nature, such 23 that the operator does have the capability to comprehend 24 pla nt conditions, plant status, and to respond properly to 25 these events.
OV ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON, D.C. 20024 (202) 554 2345
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1 Questions?
2 MR. WAED:
Okay, thank you very much, Mr.
3 Black wood.
4 Are there any questions?
5 (No response.)
6 MR. WARD 4 I guess I have a question for the 7 Committee then.
I would like to hear what you think about 8 whether we need to do this.
The Committee responded to 9 information we have heard.
Do we have anything we would 10 like to advise the Commission in this regard on the subject 11 and also relative to the fact that the CRGR is still 12 reviewing?
13 MR. RAYS Question, David, has the Staff indicated O
14 anything they would like to have through us from the 15 Commission?
Are they requesting action of us?
16 MR. WARD:
Are you, Mr. Thompson, are you 17 expecting anything from us?
18 MR. THOMPSON:
No, we have not requested 19 anything.
I think this came f rom the Commissioners.
20 MR. MARK:
There is a suggestion that one can draw 21 from the latter that Dade is cherishing.
You might wan t to 22 take this opportunity to commend the Commission and the 23 Staff on its approach.
()
24 MR. SIESS:
The CBGR anyway.
25 MR. WARDS That is a possibility.
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^=r other co eat =2 2
(No response.)
3 MR. WARDS I turn the meeting back over to you, 4 Mr. Ray.
5 MR. RAYS We have nothing more scheduled in this.
6 session at such a late hour.
I would like to express our 7 appreciation for the Staff having waited so long and agreed 8 to come and make their presentations in the first place and 9 having waited so long for that opportunity today in the 10 second place.
The circumstances were something we could not 11 avoid.
12 However, before I close the meeting, I think maybe 13 it might be in order for Carson to give us just a few words O
14 on what transpired.
15 (Whereupon, at 7:03 p.t..,
the Subcommittee was 16 adjourned. )
17 18 i
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22 23 24 25 O
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