ML20096C201

Forwards Suppl to 831019 Detailed Control Room Design Review Program Plan & Revised Section 4.3, Sys Function Review & Task Analysis, in Response to Suppl 1 to NUREG-0737 & Generic Ltrs 82-33 & 83-18

ML20096C201
Person / Time
Site:	FitzPatrick
Issue date:	08/31/1984
From:	Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Vassallo D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, TASK-1.D.1, TASK-TM GL-82-33, GL-83-18, JPN-84-57, NUDOCS 8409050152
Download: ML20096C201 (23)

Text

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August 31, 1984 JPN-84-57 4

Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

'Mr. Domenic_B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No.L50-333 Supplement No. 1 to NUREG-0737, Item 1.D.1, Detailed Control Room Design Review (DCRDR)

References:

1.

NRC letter, D.

B. Vassallo to J. P. Bayne, dated February 22, 1984 regarding NRC staff comments on the FitzPatrick DCRDR Program Plan.

2.

NYPA letter, J. P.

Bayne to D.

B. Vassallo, dated October 24, 1983 (JPN-83-90), regarding DCRDR Program Plan.

3.

NRC June 27, 1984 Summary of the Detailed Control Room Design Review Program Plan Meeting on May 10, 1984 for FitzPatrick.

Dear Sir:

ThbAuthoritysubmittedaProgramPlanfortheFitzPatrickDetailed Control; Room Design Review (DCRDR) as an attachment to Reference 2.

This Program Plan was written to describe the esse ~ntial elements of the program while considering the work previously completed during the BWROG Control Room Survey Program.

Via Reference 1, you provided NRC staff coaments on the Frogram Plan.

In general, these comments focused on a lack of detail, as opposed to an incomplete or ineffectual program.

The Authority considers the level of detail provided in the FitzPatrick DCRDR Program Plan appropriate and necessary at this stage in the development of any major plan.

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8 Asfyou: suggested in. Reference 1,.a meeting was held May 10, 1984 to idiscuss'the plan andJyour comments (Reference.3).- Although'a written response'~was not requested, the Authority has prepared a 4 DCRDR Program Plan ~ Supplement to' address your comments and to

- clarify the' program.~.This supplement is, Attachment 1 to this-

.letterixAttachment No. 2 is a' revised Section 4.3 of our DCRDR Program Plan _(Reference 2).

?The DCRDR Program Plan Supplement was written to reflect.the re'sults

~

of our meeting with. members.of your staff.May ~ 10,-1984.

However, as-

'aEparticipat'ing' member-of both the BWROG and INPO NUTAC's,.we z

< understand.that different:NRC. staff positions have been stated at v.other meetings.with licensees.

These differing positions deal Japecifically with the requirements for a system function and task-analysis _(SF&TA).

As of.this date, a formal NRC position on.the' requirements.for, and a definition ~of'a SFETA has not been issued.

LAstdescribed.in Generic Letter No.83-18, the BWROG clearly stated i

Lit's proposed methodology.for the planning and review phases of the' i

CRDR.- :The Authority plans to use the methods described by the BWROG

-inithis supplement,and in the Program Plan.to conduct the

[

-FitzPatrickf DCRDR.-

. Bach of'the schedules'the Authority has submitted for items

' associated :with supplement 1 to NUREG-0737 are based on the requirements' delineated in Generic Letter 82-33.. Changes or-additions to those requirements may require that new schedules be

[

' prepared.

This. iso especially true.in this ~ case due to the close

.r'elationship of the five Supplement 1 items.

The' Authority has.

l formally committed to submit.a DCRDR Summary, Report byx

-November! 15, 1985 (Reference 2).-

This date was subsequently c

confirmed-by the~ Commission's June 12, 1984 order.

,s 3

.In addition to:the information described in Section 6 of the DCRDR Program Plan,'the DCRDR Summary Report will detail!DCRDR

. methodologies, personnel assignments, criteria =and coordination'with other. improvement programs as summarized by Reference 3.. Appendix B toithe Program-Plan (resumes of DCRDR, team members) will be;provided

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as soon as all members have been selected.

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'If youJhave any questions, please contact Mr. J. A. Gray, Jr. of my

.s ta f f.-

.Very truly yours,

'J.P.B e

rat Executive Vice President Chief Operations. Officer cc:. Office of the Resident Inspector' 4

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U.S. Nuclear Regulatory Commission P.O. Box 136

'Lycoming, New-York 13093 k

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'NEW YORK POWER AUTHORITY HJam3s A.-FitzPatrick Nuclear Power Plant Supplement to Detailed Control Room Design Review (DCRDR)

" Program Plan dated October 19, 1983 Attachment N%.1 to JPN-84-57

' This: attachment. responds to each of the issues discussed in 3

- Reference 1.

.I' I.

Background

No/ additional information is required for this section.

II.-[Discu$sionA.

[

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No additional informbtion is required'foththis section.

(

III.-General Ccmment:

"Th,e JAF Program > Plan does, not. describe the ' --

proposed review program i,n enough detail to 1

allow' staff reviewers to,fdlly understand how

_the'.DCRLR objectives will be accomplished."

-Response:

.Th'e:JAF Program Plan was based on the BWROG Control Room Survey as reviewed by the NRC in Generic Letter 83-18 (Reference 6).

Supplement 1 to NUREG-0737~and NUIEG-0700-

' request-that the methodologies for' conducting i

all DCRDR phases-~ should be summarized.

TheAuthorityco'nsiders\\khelevelof. detail i

,providqd in the'DCRDR' Prog' ram Plan appropriate for other reason's.- AJprogram

~

' pian is necessarily the firetqstep'in g

developing any major program.'It's purpose should be to descri'ne the. essential elements of the program uitnout becoming burdened with details at this early sta'ge.

Procedures must prescribe; precise methods for accomplishing-specific tasks if they arewto1be affective.

This level of detail is. clearly inappropriate for.a program plan.-

When the FitzPatrick DCRDR Program Plan was developed, a human factors contractor had not been selected.

Therefore, specific methodologies ~and personnel assignments could not be included in thtiprogram plan.

When a contractor;has been hired, the Authority will be able'to finalizy pr,ogram details.

1 Procedures will developed during the initial phases of the DCRDR;and are dependent on the contractor' selected,and on management s<appr? val during the actual conduct of the DCRDR.

~.

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The Authority han-form 211y-conitted-to

'submitLa DCRDR Summary Report by

-November. 15,=1985~(Reference 2).-

In addition c

-c Jto:the'information described in Section 6 of the -Program Plan, ' th~e: DCRDR. Summary Report

will; describe in detail:

o o-Personnel (or discipline) assignments to DCRDR

? activities... (Preference will be given to a matrix or li 1 table = style: format forothis.information).

no Sys't'em_-Function and Task Analysis methodology

'L(includingLverification of. task: performance s

capabilities)~.

{ocMethodology and-criteria used for assessing HEDs.

'o Methodology and criteria used to select,HED correction.:

-o How HED corrections were assured not-to introduce new

<HEDs.

o How DCRCR was coordinated with EOP and SPDS programs.

o Howicontinuity was assured between 1981 BWROG Survey

' work-and DCRDR.

' Commen t: -

"A human fac' tors' evaluation of the design of 1 --

the remote shutdown capability provided.to

. meet-10 CRF Part 50, Appendix A, GDC-19, and '

/101 CFR Part 50 ^, Appendix R. is not

-specifically identified as a requirement in Supplement 1 to-NUREG-0737.

Staff review'of

.this issue is not complete.-

In_the-interim, we-recommend that%the scope of/the DCRDR include a' human factors evaluation of the

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_ ' ' ' design lof the remote shutdown capability.

To

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the' extent practicable, without delaying-

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' completion'of'the DCRDR, it should also d'

n 3 address and~ control room modifications-and

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' additions (suchiasicontrols and displays for

-inadequate core cooling and reactor system ve'ts) made or planned as a result of other n

post-TMI' actions, and _ the l'essons learned from. operating. reactor events such as the Salem ATWS events."-

Response

_ Modifications to install remote shutdown 7",

Leapabilities'are currently in the'desig~n and -

, 1,-

engineering phases.

A human' factors engineer

- will review the~ panel using the criteria of NUREG-0700.

This review will be conducted usingLcriteria-similiar'to that planned for

-use on the DCRDR.

Therefore, the remote shutdown panel is specifically excluded from the DCRDR program's scope.

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' Control ' Room modifications directly resulting from the o

Salem ATWS.' event.oripost-TMI: items-will be included in theLDCRDR if=the actual modifications to the control-room have be'en completed or, if the modification is sufficiently complete,-to allow meaningful review.

A

. list of all "open" modifications that were reviewed as

part of the DCRDR will be included in the DCRDR Summary Report.

~

IV.

~ Qualifications and Structure of the Review Team Comment:-

- The. qualifications of thenproposed review team are adequate.

However',fthe qualifications of the instrumentation 'andf control ' engineer'(s ) were: n'ot described.

The~ staff' recommends that the person or persons-filling this role: f(l) have a bachelor's degree in engineering,.(2)thave five years of applied-

' experience,'(3)'be familiar withjregulations, standards and. design. constraints that have an impact on nuclear power Plant control room design, and (4) be

.a full-time member of'the review team."

JResponse:

'The Authority will assign an electrical engineer;with a bachelor's degree in. engineering and several. years

" experience in nuclear; plant applications to be a

, full-time member of-the review' team.

Comment:

"The' assignment of individual disciplines (e.g., human-

?

factors' engineering,, reactor operations, etc.) to'each activity'in the DCRDR, and their. levels of effort per

. activity;were not presented."

~

tResponse:-

DCRDR Summary-Report will include-a. description.of those' individuals or disciplines associated with each'

'DCRDR activity.- Prefe'rence will be~given to a matrix orstable style: format for1this=information.

The disciplines described in;Section'2 of the DCRDR Program Plan will be. involved"in those phases of the DDCRDR where their discipline is relevant to that portion of.the' program.. Involvement by any one individurl will necessarily vary. depending on the HEDs identifL d.

.While some individuals will be specifically "part-time", the' Summary Report will r

describe-in general terms the extent of involvement of

~

each individual.

. There is-no mention.in the Program Plan of whether

' Comment: '

personnel involved in the 1931 BWROG Survey will be-included on-the' review team.

If possible, this should be done to provide continuity to the JAF Program."

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Response

Mr. Fish (Assistant Superintendent of Power at M

'FitzPatrick) was involved as-an Owner's Group Team

. Leader in five:1981 BWROG surveys (including the 1981 FitzPatrick survey) and is-anticipated to provide the continuity desired.

The other' participants in the 1981 survey, eachlof whom worked for a different company, are no longer.available.

I-ll. -

System Function cnd Task Analysis Comment:

"PASNY' states that the task analysis portion of the SF&TA will use the INPO NUTAC CRDR Task Analysis Guidelines as a reference.

Since the tw~ has not-reviewed the~NUTAC document, reference to that s

document is not. descriptive or meaningful to the staff.

The licensee should submi.c the INPO NUTAC CRDR Task-Analysis Guideline.on.its uucket if that document

-will be used to support the PASNY/NRC briefing."

Response

.An; April'll, 1984 letter.(Reference 5) from Mr. Voss Moore, Jr. (NRC' Human Factors Engineering Branch Chief) to Mr. H. Fish _of the Power Authority, states that the NRC staff has reviewed and commented on the INPO NUTAC " Control Room Design Review and Task Analysis Guideline" (INPO 83-046 ) and three other 'INPO NUTAC documents on CRDRs.

- Comment:

"The inputs for SF&TA, such as types of events or transi;nts, are mentioned in the Program Plan, but lack detailed information.

The staff recommends that the scope of the SF&TA be comprehensive enough to result in an analysis of all operator tasks necessary to successfully implement all emergency functions, and that all operator interfaces involved in these tasks are-defined in terms of operator information and control, requirements."

Response:.

The Authority has based the FitzPatrick DCRDR on the work of both the BWROG Control Room Survey and the BWROG's generic Emergency. Procedure Guidelines (EPGs).

2 The EPGs were developed as-symptom-oriented procedures to mitigate (as opposed to diagnosis) an accident.

EPGs therefore address all. operator tasks necessary to perform emergency functions.

Because these guidelines were prepared by the BWROG for use on many different

-BWR plants, they describe the operator.information and control requirements in generic terms rather than referring to'a specific instrument or switch.

This assures that.these information and control requirements were developed independently of any specific plant control room.

A meeting was held May 4, 1984 between the NRC and members of che BWROG, EPG and CRDR committees to discuss the task analysis requirements of Supplement No. 1 to NUREG-0737 (Reference 10). -At that meeting, the Owners' Group described how the EPG development effort and CRDR program addressed operator information and control needs.

Reference 10 summarized the NRC staff's conclusions as a result of this meeting as follows: __

_ 7 p

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.! Revision -3 of the :EPG provides a functional analysis'that identifies on a high level, generic "o

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information and' control.needs.

-Because detailed i

plant-specific information and control needs cannot be.

extracted directly from the EPGs,.' plant-specific analysis is-required" (emphasis added).

In addition, the FitzPatrick plant specific'EOPs

.(Emergencyf0perating Procedures,'which are-based on.

the generic EPGs)'will'also be used during.the.DCRDR

- as one means of determining precisely how the

~

information and1 control requirements of the EPGs are fu11 filled by the EOPs.-

In some instances, EOPs reference other normal plant mF

_operat ng proce ures.

The Authority does not intend i

d to review all portions of procedures referred to in this-way as part of the DCRDR program.

Rather,

-referenced. procedures will be logically followed to accomplish.the intentions of the-EOP.

t Using the approach outlined above, the benefits.of an J-

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independent SF&TA will be realized in the DCRDR

-program.

'T Comment:-

"The Program Plan proposes to. identify systems and.

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subsystems and functions by using the JAF-FSAR.

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However, detailed inforaation on the methodology for performing ~this task is not provided by the licensee,.

thus.no evaluation could-be made at this time."

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Response:

The updated FitzPatrick'FSARiclearly' state the

-functions of plant systems.

The methodology 1for

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identifying;these functions is' simply to reference the c.

applicable sections > of the-PSAR=. - The FSAR~has been

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. totally revised and updated in 1982~and~ revised annually since.

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(' '. Comment:-

"The Pbogram Plan =also does not-describe how the systems / functions identification will be used as a s

reference base for the subsequent task analysis. 'In

-other words, it'is-not clear how the functions, identified from the FSAR will be actively used as part

~ f.the analytical process.

The' licensee mentions o

" discrete tasks""in the task analysis process.(p.

^'

e-32), but an operational-definition of this term is not given to clarify its role.in the task analysis. LThe licensee does not describe'how required information 90 '

and control capabilities and characteristics will be identified.

There is some doubt that this last step will be done at all..The task analysis form presented on page 35,'does not provide spaces for recording the detailed information needed by the operator to make decisions, take corrective actions, etc.

i.

. '. -. ~ - _ _ _ _ _.,. _

_a In summary, the depth, scope, and methodology to be used in the JAF System Function and Task Analysis were 17 not sufficiently described." (emphasis added)

Response:-

uAs previously described, the FitzPatrick DCRDR will be based-on the. work of.both the BWROG Control Room-

~ Survey',1the BWROG's. generic EPGs'and plant-specific EOPs.-

Generic.EPGs and plant-specific _EOPS together will be used to. identify how the information and control requirements of.the EPGs have been fulfilled.

f(A' revised Section 4.3 of the-Program Plan, " Systems L unction Review and Task Analysis" is attached).

The F

program plan indicates specifically that-the

'information and controls required to execute EOPs will

' tut identified (pages_31-39, 8 pages) and references the INPO NUTAC Task Analysis Guidelines (INPO 83-046 NUTAC) that also describes how this'will be done.

The comment "There is some doubt that this last step will be'done at all" is unwarranted.

NYPA intends 1to conduct.a.

t'echnically sound'DCRDR project.

The FitzPatrick DCRDR Program Plan used the terminology-

" instrumentation'and. control requirements" as opposed to "information and control requirements."

The NRC

. staff's comments indicate that the task analysis form

-does not provide space to note the above information.

-This is a preliminary form (p. 33) to be revised as~the DCRDR-progresses.

This form has space to record operator: decisions or actions etc. and will be used as Lsuch.

A revised preliminary form is attached to

' address-this concern.

LA discrete task is defined as a single unique behavior

-by a-member of the operating crew. ' Discrete tasks will be-identified from the plant-specific EOPs which were derived from the NRC approved EPGs.

EPGs were developed from symptoms (not necessarily events or functions) that an operator must respond to and control.

VI. - Comparison of Display and Control Requirements with the Control Room Inventory.

' Comment:

- "The licensee proposes to accomplish this function 'as Y

.part ofEthe task; analysis effort and the related verification and validation efforts.'

On-page 34 the c

licensee states that in the first phase of the verification, 'the presence or absence of the Instrumentation and Controls that were noted in the

<3-Task Analysis will be confirmed.'

Since the method by which the required instrumentation and controls were "noted" was'not described, the staff is uncertain whether this= function will be effectively accomplished.

The acceptability of this approach is contingent on performance of an adequate function and task analysis,-since it is the function and task analysis which should actually define the appropriate characteristics of instrumentation, controls and equipment required for emergency operation."

,,;.9 T

,, ~ -

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" ~

ya RU5poniot

' Ssction.4.4.2.l ' ("IECDAvailcbility' on page 36 ) of the Progrcm Plan dascribes how1tho' required instrumsnt and

'1, f '

" Si controls will be'noted. 'The1 presence or absence'of any particularDinstrument'or control-will be recorded on a LTask Analysis Form.

Instruments or controls not 2,.

Lavailable to'the_ operator will be. identified:as an HED.

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-As. discussed:during,our May 10, 1984Lmeet'ing, a new

~

. column >1abeledl"Information and Control Requirements" will beLadded.to the CRDR Task Analysis Worksheet.

Appropriate! instrument and control characteristics will be$ recorded on Task Analysis forms.

?VII. Control Room' Survey-Comment:

- "The licensee states that the 1981;BWROG Control 1Roomi

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Survey:will be updated using'the 1983 BWROG Supplement

~

checklist'which is-drawn from guidelines provided in.

NUREG-0700 ( pp.- '3 0-31 ).

Ifin fact this -is. the. case',

the staff concludes that the proposed control room survey will;be1 comprehensive in coverage and detail, and if. appropriately.-implemented by qualified Lpersonnel, should= result in an effective survey of the

.JAF. control room.. Ourfsingle area of concern'regarding r

the survey is the< identification of HEDs from the 1981

-BWROG survey.. It was not stated >how the.BWROG data would be used to identify HEDs.

The staff recommends

-that any item which.was not found to be in ' full 2C Jcompliance' during the 1981 survey be considered to be an HED."

' Response:

A final approved version'of/the.BWROG' Control Room

-Survey " Checklist Supplement"~has been distributed to s'

-members of.the owners' group (Reference 11).

The

Authority will use this-checklist supplement as described in the Program Plan.

_The relationship between the BWROG control room checklist and NUREG-0700'was described,on pages 10 and 11 of the enclosure to Generic Letter No.83-18 (Reference 6).

The " Checklist Supplement" was compiled to~ address those NUREG-0700 items not directly.

1 addressed by the BWROG Control Room Survey Program.

The " raw data" sheets for this survey consist.of'the FH

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BWROG Check List forms.

Each check list sheet (including those from the 1981 survey) will be reviewed by appropriate disciplines of'the CRDR team including'a

~ human. engineering consultant.

Following this

' individual' review, the team will then meet as a group.

to determine which discrepancies from.the checkslist should be formally identified as.HEDs.

As described on

~

~

pages 25 and 26 af the. Program Plan, all instances of non-compliance are documented at the time of review on the check list, regardless of the " potential for error" multiplier value assigned to that particular item.

1

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-It i:s'the CRDR team,= including a human-engineering j

consultant, which will review-these checklists and

' identify HEDs which require formal resolution.

This team has not assembled at this time.

Therefore, it is 1

inappropriate-to prescribe, in advance, any-specific

-formal ~ procedures or criteria fot identification of EHEDs from.the raw data.

We expect that the team, as.a~

-whole,;will review all data and reachLautual agreement on the identified HEDs.

Since a human engineer ~

^ ~

consultant will be a member of the team we feel

~

confident.that a fully professional review and identification of'HEDs will be accomplished.

-IIX.- Assessment of Human Engineering Discrepancies

~ Comment':

"The methodology farcassessing and categorizing HEDs is not descr'ibed.

The categories proposed for the-assessment process seem to be appropriate.

However, sinceHthe methods and criteria for judging the potential for-error and the possible consequences of error were not described, the staff cannot ascertain-42 whether the proposed assessment process will be-effective. On page 8, Section F, the Program Plan states that 'HEDs identified as having safety implications orJpotential for safety implications will be categorized.'

However, it does not seem that-this.

N'

~

criterion is implemented in the methodology presented.

in Section 5, page 40..Also, the definitions of certain m

. terms used in the categorization of HEDs such as-

'significant' operating error (Category I, p. 40) and-3~

' serious'1 consequences (Category.'III, p. 41) are not provided."

Response:'

'A complete-description of the methods used to categorize and assess HEDs will be included in the DCRDR Summary Report.

This.information was not

providedlas part of the Program Plan because a' human factors contractor had not been: selected when the plan was written.

The methods and criteria used'to assess HEDs'will generally; follow'the guidance of draft NUREG-0801-(

Reference:

18 ) ~.

Draft NUREG-0801 was used to develop portions of-the DCRDR Program; however, a statement to this.effect was not included'in the Program Plan.

In keeping with this point, the terms "significant" and

" serious"~are also defined'in NUREG-0801.

IX..' Selection of Design Improvements Comment:

"Although the Program Plan states that recommendations will be provided for each identified HED, there is no mention made of who will make these recommendations.

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~.The' licensee-states that enhancement-type corrections will be mocked up via drawings.

The staff suggests

that mock-ups, both part-task and full-scale, may be-

_ necessary for the design of control room improvements._

1Overall, the proposed approach seems appropriate, but some details-_are not explicitly described.

For-example, how are the criteria " weighted" to allow for reliable, unbiased selection of improvements, who recommends improvements, and what are the approval and

~

Lquality control mechanisms?"

Response:i The DCRDR team members will make initial

= recommendations for selection of design improvements.

This point was not explicitly stated but was implied i

for all phases of the:DCRDR.

Details concerning the selection of improvements and quality control mechanisms"are not part of the DCRDR program.

DCRDR-team _makes initlaf recommendations which will then be reviewed by normal engineering

. design change process personnel.

Any modifications resulting from the DCRDR will be processed in accordance with Authority; procedures.

Approval and.

quality. control mechanisms will also~ follow est'ablished procedures..

X.-

~ Verification that Selected Improvements Will Provide the Necessary Corrections and that Control Room Modifications Do Not Introduce New HEDs

'~'

' Comment:

"The Program Plan-provides no description of formal, structured procedures to verify HED improvements before and/or after implementation. However, there are indications that.the= licensee has incorporated these procedures.in the HED correction phase'(p. 42). It is very difficul fdetermine the effectiveness of the

-verification paase'without'a clear cut,' structured

, methodology. We suggest the licensee address the verification of improvements in a mere structured way C

which clearly indicates how the. licensee will conduct this activity, and how and when it will be integrated into the overall DCRDR. process."

Response:-

Proposedz improvements will undergo a human factors evaluation in addition to normal engineering evaluations prior to implementation.

Final engineering J-fdesign change packages will be reviewed by the DCRDR team and/or other qualified individuals.

Operator feedback,will also be solicited at this time.

x

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' lXI.. Coordination of~the DCRDR with Other Improvement Programs Comment:

"The licenses seems to-recognize'that other-improvement programs, such as SPDS, EOPs, etc., should be.

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. coordinated with the DCRDR.

However, the actual

0 procedures for such coordination are not given in-the

' Program rian.

For example, there is no description of an information exchange procedure for integrating HEDs

~

. corrections.with inputs from other improvement programs."

Response:'

-As-_we.have previously stated, procedures are outside of

,.s the level of detail appropriate for-any. program plan.

a

'The. Authority described its plans for integrating the five Supplement No. 1 items in our April 15, 1983

" Implementation and Integration Plan" (Reference 7 ).

Specifically, our'SPDS/ EPIC program may (where appropriate) be used to correct HEDs identified during the DCRDR program.

Control room modifications resulting from the post-accident instrumentation program will be included in the-DCRDR.if the actual-modifications to the control have been completed, or if the modification 11s sufficiently complete to allow meaningful' review.

EPGs and EOPs form the basis for much of the DCRDR program.

i.

.The integration of these programs will be overseen by H

Authority plant and headquarters office management as an ongoing process.

..XII. NRC Conclusion

^

Comment:

"The' staff's review of'theLProgram Plan' indicates ~that specific areas of the' plan have not been described in.

v.s -

' sf enough detai~1 to provide. assurance'that the licensee

+

will meet the requirements.

The licensee has not~

+

demonstrated in the Program Plan that appropriate

' review methodologies have been developed to fulfill all of thefDCRDR requirements of_ Supplement 1 to NUREG-0737."

. Response:

The FitzPatrick DCRDR Program Plan as supplemented by this report and the references listed below provides a greater level'offdetail.

Further details will'be included in the DCRDR' Summary Report.

k l

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XIII.-

References

1. --

NRC, letter,MD.B. Vassallo'.to J.P.

Bayne, dated February 22, 1984"regarding. review of Program' Plan for

' Detailed Control Room Design Review.

Includes attachment.

entitled "NRC Staff Comments on the James A. FitzPatrick

-Detailed ControllRoom' Design Review Program' Plan."

.2.

NYPA' letter, J.P. Bayne-;to D.B. Vassallo, dated

' October-24, 19831(JPN-83-90).

Transmits FitzPatrick DCRDR Program ~ Plan, dated October' 19,.1983.

-3.

NYPA letter, J.P. Bayne :to ~ D.B. Vassall'o,: dated

. March 28, 1984 (JPN-84-20) regarding Supplement No.1 to

NUREG-0737 Item -I.D.1 - Control Room Design Review.

Commits to provide DCRDR Summary: Report and schedule'for

-implementing final recommendations by November 15, 1985.

-4.

,NRC-Generic Letter'No. 82-33, dated December 17, 1982, D.G.1Eisenhut to All Operating Reactors transmits Supplement No.1 to'NUREG-0737.

5.

NRC-letter, V.A.LMoore to H.C. Fish, dated April 11, 1984-transmits NRC. staff comments on: " Control Room Design Review-Implementation Guide"-INPO 83-026 (NUTAC); " Human Engineering Principles for Control Room Design Review"-INPO 83-036 (NUTAC); " Control Room Design Review Task Analysis Guideline"-INPO 83-046 (NUTAC)-and;'

" Component Verification and System Validation Guidance"-INPO 83-047 (NUTAC).

Also requests meeting to i

-discuss comments.

'6.

NRC Generic Letter No.83-18, dated April 19, 1983, D.G.

Eisenhut to All-BWR Licensees regarding NRC-staff-review of'the.BWR Owners' Group (BWROG) Control Room Survey Program.

g 7.-

NYPA letter, J.P.

Bayne to D.B. Vassallo, dated April 15, 1983 (JPN-83-33) transmits initial response to NUREG-0737, Supplement ~No,1.

8.

NYPA letter,iJ.P. Bayne to D.B. Vassallo, dated June 3, 1983~(JPN-83-50) regarding NUREG-0737 Item I.D.1, Control Room Design Review.

~9.

General Electric Co. letter, G.W.

Burnette to BWROG committee members and CRDR primary representatives, dated October 17, 1983 (OG3-271-3) transmits final approved version of " Human Factors Engineering Control Room Survey Supplement".

u 10.

NRC memorandum, S.H. Weiss to V.A. Moore, regarding task analysis requirements of Supplement 1 to NUREG-0737, May 4, 1984 meeting with BWR Owners Group Emergency Procedures Guidelines and Control Room Design Review Committee.

. 1.

_BWROG letter, G.W.

Burnette to BWROG members, dated 1

October 17, 1983-(OG3-271-3) regarding NRC Generic Letter 83-18 includes final approved version of control room survey " Checklist Supplement".

12.

PASNY letter, J.P.

Bayne to S.S. Hanaver,, dated January 5, 1982 (JPN-82-3) provides comments on draft NUREG-0801, " Evaluation Criteria for DCRDR-October 1981."

= 13.

PASNY letter, J.P.

Bayne-to D.B. Vassallo, dated June 30,1983 (JPN-83-60) transmits EOP Generation Package and Technical G idelines for EOPs.

14.

INPO 83-036'(NUTAC), " Human Engineering Principles for

. Control Room Design Review".

15.

INPO 83-026 (NUTAC), " Control Room Design Review Implementation Guide".

16. -.

INPO.83-046 (NUTAC), " Control Room Design Review Task Analysis Guideline".

17.

INPO 83-047 (NUTAC), " Component Verification and System

_. Validation Guidance".

18.

NUREG-0801, " Evaluation Criteria for Detailed Control Room Design Reviews," October 1981, draft report. :_..

?:'

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.NEW' YORK POWER AUTHORITY James A. FitzPatrick Nuclear = Power Plant s

~ Attachment No.2 to' JPN-84-57 Revised.Section14.3 "Sys' tem" Function Review and' Task Analysis"-to L" Detailed Control Room Design Review: Program Plan for the

. James A.tFitzpatrick Nuclear Power Plant" dated October 19,-1983 b

p-4.3 Systems Function Review and Task Analysis 4.3.1 Purpose The pitrpose of the Systems Function Review and Task Analysis portion of the Control Room Design Review is to determine the input and output requirements of the control room crew for emergency operation and to ensure that required systems can be efficiently and reliably operated under the conditions of emergency operation by available personnel. This will be accomplished by performing an analysis of tasks contained in the JAF Emergency Operating Procedures (EOPs).

The steps which comprise the System Function Review and Task Analysis are shown in Figure 1 and are described below.

4.3.2 Systems Functions Description

'4.3.2.1 Identify Plant Safety Related Systems and Functions Plant systems and subsystems in the JAF control room that the operator must access during emergency operations will be identified. Existing plant documentation (i.e., James A. FitzPatrick FSAR) relating to safety systems will serve as a prime information sourCO.

Descriptions of the functions for each of the systems identified above will be prepared. These system descriptions will include Tha function (s) of the system Under what conditions the system is used A brief explanation of how the system operates The description of systems functions in this manner will serve as a reference base for subsequent task analysis.

In addition, the systems list will be used to assist in the selection of operating scenarios for each walk-through.

4.3.2.2 Define Representative Scenarios The BWR Owners Group Emergency Procedures Guidelines and the list of JAF safety and safety-related systems will be used to define a set of scenarios which adequately sample various emergency conditions and the plant systems and system functions used in those conditions.

The related JAP plant-specific EOPs will be identified as well in this step.

g_ _ -

In; addition, a brief narrative description of each scenario will be prepared that establishes the limits

'and conditions of the events'to be analyzed.. This

_ overview will be especially beneficial for orienting operators to the scenarios prior to walkthroughs. It will include:

initial plant conditions sequence initiator progression of action final plant conditions major systems involved 4.3.2.3 Identify Residual Task Residual operator tasks (unique tasks) from the plant specific EOPs not covered in the scenarios will be identified and later analyzed for associated information and control requirements. 'The analysis of residual tasks will be done to ensure that all operator

+

interfaces have been examined even if those interfaces are not exercised in the sample of emergency scenarios selected for validation. Verification of equipment availability and suitability.will be performed for these residual. tasks as well as for tasks embedded in the emergency scenarios.

4.3.3 Task Analysis

-4.3.3.1 Develop. Task Analysis Worksheets-Task Analysis Worksheets (see Figure 2) will be developed'which' indicates the operational steps required in each scenario along with the appropriate information and control requirements, means of operation, and I&C present on the control boards. The opertor tasks will be analyzed using generic EPGs and plant-specific EOPs as a starting point. The Task Analysis Worksheets will be prepared in the following manner

~1.

Discrete steps in the JAF EOPs and corresponding

- EPGS will be identified 'in ' order of performance.

These steps will be recorded in the " Procedure Number" column of the Task Analysis Worksheet, and branching points 1noted depending on the plant transient being~ analyzed in the " Scenario Response" column. Note that there may be more tasks subsequently, identified in Step 2 below than there are procedural steps. In this case, a dash will be

=

entered in the column when no explicit procedure step is present'in the EOPs and/or EPGs.

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A brief description of the operator's tasks (in order of procedural steps) will be recorded in the

" Tasks /Subtaska" column of the Task Analysis Form.

All tasks, both explicit and implicit, will be documented by SRO subject matter experts, human factors' specialists using-plant-specific EOPs, EPGs, JAF FSAR and System Descriptions.

3.

The operator decisions and/or actions that are

!1 inked to task performance are then noted in the

" Decision and/or Contingent Action Requirements" column..: System functional-response is described when-appropriate in this column.- This set of data also includes branching points in the EOPs that determine the outcome of the operating sequence.

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. 4.

Input and Output requirements for successful task

. performance are noted in the "Information and Control Requirements" column. These would typically be parameters, components or procedural information that are necessary for operators to adequately assess plant conditions or system status'(e.g.,

reactor vessel water level, reactor coolant systems flow, pressure, etc.).

Specific values for parameter readings or control selection will be noted. Several documents and sources, in addition to EOPs and Technical Specifications, will assist the task analyst in determining-task information and control requirements.. These are displayed in Figure 3.

5.

Once the Tasks, Decision Requirements, and Information and Control requirements have been specified, the specific instrumentation and controls (IEC) that the operator requires per procedural step will.be documented. All IEC needed to either (1) initiate, maintain or remove a system 'from service, (2) confirm that an appropriate system response has or has not occurred, i.e., feedback, or (3) make a decision regarding plant or system status will be listed. The "Means" column refers to how the information and control requirements are presented of oon'the control boards (e.g., switch, meter, etc.).

The "I&C Identification" column provides the specific panel number and identification' number of.

'the control or instrument.

It is important to not that Step 1 through 4 are completed on the Task Analysis Worksheet using independent sources of data other than the actual IEC present in the control room. Step 5 essentially

. completes the first step:in the Verification Process

. to identify whether or not the necessary I&C for task performarse is available in the control room.

Revised 8/84 4

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The remaining columns of the Task Analysis Workseet will be utilized during the Verification of Task Performance Capabilities, which is. described in

Section 4.4.'

These columns are briefly described

~

' belowr

15. - Verification: column"(used during V&V phase)

" Availability" of the necessary IEC for successful m

operator task performance is noted by a check in this' columns." Suitability" of the Isc.to meet the information and control requirements of operator task:is noted by a check in this column. -

'7.

Comments / Candidate'HEDs-Comments or candidate HEDs can be noted in this

-column ~during any step of the Task Analysis of V&v phases.;-- Data for HEDs will be recorded.

The. Task Analysis Worksheet thus serves as the

- complete record of operator tasks, decisions, information and control requirements, and IEC availability and suitability during the selected emergency operating sequences. This record is developed through the series of steps described above.

4.3.'3.2

-Conduct Walk-through.of Scenarios t.

Using the Task Analysis Worksheets, human factors

engineers will perform a walk-through of.each scenario with JAF control room operators. During this walk-through, the tasks; required will be analyzed in

terms of _ the presence of necessary instruments and

. controls or other equipment or job aids- (the verfification of Task Performance Capabilities specified in NUREG-0700) and the suitability of equipment, job aids and control room design for reliable execution of

~the required tasks (the validation of Control Room

Functions!specified in NUREG-0700).

'Real-time walk-chroughs will then be conducted to fully document the tasks involved for all crew members. A complete description of the walk-through method is described in the validation process in Section 4.5 of

~

the Program Plan. The task data is subsequently examined in both the verification'and validation process described in the sections that follow.

'4.3.3.3 Control Room Inventory The-function' intended for a control room inventory in the DCRDR is to determine whether the instrumentation and controls needed to support operation under emergency conditions actually exist.

(See INPO NUTAC Revised 8/84

4 A

Implementation Guideline.) This function will be.

accomplished as part of the task analysis effort and the related verification and validation efforts. The determination of I&C availability is described in Section 4.4, Verification of I&C requirements.

In addition, a complete set of control board photgraphs will be taken to provide an as-built inventory of the

- JAF instrumentation and controls during the DCRDR.

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1.

I'

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Revised 8/84 i:=

hientify Plant Safety.

Related Systems and Functions 1 f Define Representative

• Scenerlos and Related EOPsfor Analysis I

Y Identify ResiduelTasks i f Develop Tak Analysis wetsheets 1 f-Conduct Walkthroughs of Scenerlos 1 f Verify Task Performonos capabliities i f validate control Room Functions i

Figure 1.

Systems Fianctions Review and Task Analysis Steps Revised 8/84

_. _. _ _. _ _ _.. _ _ _ _ _ _ _ - ~ -..

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s 11 11 5

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T**k Analynge g,y, Revised 8/84 1

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EPRI Regulawry Graphics Display Plent Specific Guices Development PSAR 1A7 Propam I f Task information

& Control Requirements Figure 3.

Task Information and Control Requirements Revised 8/84