ML20099F365
| ML20099F365 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/20/1984 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0700, RTR-NUREG-0737, RTR-NUREG-700, RTR-NUREG-737 NUDOCS 8411260385 | |
| Download: ML20099F365 (19) | |
Text
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Ma ing Address u
e Al: Dam 3 Pow;r Company
~ 600 North 16th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephone 203 783-6090 R. P. Mcdonald Senior Vice President Flintndge Building AlabamaPower t'v sourvm eene c si str' Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 Detailed Control Room Design Review (DCRDR)
Gentiemen:
In accordance with the provisions of Supplement 1 to NUREG-0737, Alabama Power Company submitted a program plan by letter dated October 31, 1983 for conducting a DCRDR at the Joseph M. Farley Nuclear Plant, Units 1 and 2.
By letter dated March 9,1984, the NRC Staff provided comments on I.he Aloisaisia Powt r Company program plan and recommendad that a meeting be held with the NRC to allow for further discussion on the DCRDR.
Specific responses to the NRC Staff comments contained in the March 9, 1984 letter are provided as Attachment 1.
A summary of the Alabama Power Company program plan items that are different from the NUTAC for CRDR guidance was developed as a result of recent discussions with the NRC Staff and is provided as Attachment 2.
On July 25 1984, Alabama Power Company personnel and the NRC Staff met to discuss the jrogran plan for conducting the DCRDR. It is believed that, as a result of his meeting, the NRC Staff has been provided a reasonable description of t.ie Alabama Power Company DCRDR program plan.
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Mr. ' S.E A.- Varga -
November 20, 1984-U. S.- Nuclear Regulatory Commission.
.Page 2-A major topic of discussion during the meeting was Alabama Power Company's intent to utilize the NUTAC " Control Room Design Review Survey Development Guideline" surveys, checklists and questions in lieu of the NUREG-0700 checklists for. the DCRDR survey. 'The NUTAC approach to conducting the DCRDR survey is that utilization of-performance based
. criteria will more appropriately addres: applicable htman factor principles'
'than the NUREG-700 criteria of parameters that are not readily measurable-(e.g., NUREG-0700 requires measurements of geometric distortion and.
resolution of a CRT while the NUTAC guidelines address operator problems-with flicker, glare and readibility).
It was agreed -that Alabama Power Company would use the NUTAC approach to conduct the DCRDR survey while the' NRC Staff would use the NUREG-0700 checklists to audit the survey results.
The NRC would then determine whether the Farley-specific DCRDR survey did adequately " identify deviations from accepted human factors principles" pursuant to the provisions of NUREG-0737, Supplement 1.
These different approaches to the survey should not result in significantly different human factors evaluations of the Farley Control Room.
If there are any questions, please advise.
Yours very tr R. P. Mcdonald RPM /J LO:ddb-DJLO-CRDR
' Attachments cc: lMr. L. B. Long Mr. J. P. O' Reilly Mr. E. A. Reeves Mr. W. H. Bradford s
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Attacnment'l APCo Response to NRC Comments on DCRDR, Dated March 9,1984 1.
NRC Comment:
The DCRDR team has no nuclear systems engineer. The NRC staff recommends that the Human Factor Specialist (HFS) participate in the verification phase and in coordination of the DCRDR with other improvement programs. The NRC staff recommends that' APCo provide engineers with expertise in industrial, reliability, and risk assessment engineering.
APCo Response: APCo will add a nuclear systems engineer to the DCRDR team.
The HFS is extensively involved in the planning phases of the APCo CRDR.
In addition, the HFS is a participating review team member during the survey and HED assessn.ent.
The HFS will participate as needed in the verification phase and.in the coordination of the DCRDR with other improvement programs.
The HFS has a Ph.D. in Industrial Engineering.
The nuclear systems engineer and I&C engineers from the appropriate design _ organizations will provide technical expertise but will not serve as voting team members in the assessment phase. None of the tasks outlined in the APCo DCRDR program plan require experi,ise in either reliability or risk assessment engineering.
2.
NRC Comment:
The NRC Staff had the following coments on the APCo real-time simulation approach to task analysis:
a) Procedures for a complete function and task analysis at a detailed level are not included in the APCo program plan-(reference Section 3.4 of NUREG-0700).
The Staf f concludes that both " Event-Related Guidelines" and " Function-Related Guidelines" are necessary to cover all emergency operations.
b) The method for identifying infomation ano control requirements for emergency plant operation is not explicitly addressed in the APCo program plan.
Procedures need to be developed for the system function analysis and the identification and evaluation of infomation and controls required by the operator to meet tasks responsibilities.
c)
Procedures for generating a contiol room ir,ventory have not been explicitly defined.
It is not clear how the instrumentation defined in the ERP's can be systematically checked during a real-time simulation udng the ERP's. The time available to the operators for each task in a real-time simulation is limited.
(
d)
The data collection foms for documenting task information (i.e., the Tast Sequence Charts) do not indicate that l
infomation and control requirements will be defined.
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tAPCo' Responseto NRCs Comments on DCRDR, Dated March 9,~1984 Page 2:-
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~ JAPCo Response:1APCo has revised the DCRDR task analysis to more readily.
address the NRC staff concerns' related primarily to information and control! requirements. A description of' the revised task analysis which includes the process for identifying the: characteristics of needed instrumentation and controls.is.,provided below2 The scope of-the function and task analysis Jescribed in NUREG-0700,.Section 3.4 is'not consistent with the more limited scope outlined in NUREG-0737, Supplement 1.
>Specifically,'NUREG-0737, Supplement =1 requires "The.use of functions and task analysis -(that had been used as the basis N
for-developing ' emergency operating procedures...) to
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g identify control. room operator tasks and information and control requirements during emergency. operations."
The WOG Emergency' Response Guidelines-(ERG's), Revision 1 have. identified generic tasks and functions. The bases for 4
Farley-Epecific procedures are the WOG symptom-based
-ERG's Revision 1.-It has been assumed in the APCo DCRDR 4
program plan that the WOG ERG's will.be approved for implementation by the NRC PSRB. After such approval, it is not incumbent on ~ APCo to justify the steps in the ERG's.
j.
Given a valid set of Farley-specific procedures derived from l
the ERG's, the DCRCR task analysis will then determine the information and control requirements to complete each i
procedure step and verify that these requirements can be met j
by instruments and controls that exist in the Farley control i
room. The following Farley-specific emergency event l
procedures'(EEP's) and all function restoration procedures (FRP's) will be analyzed using a tahic-top method of L
cnalysis:
i-EEP-0 Reactor Trip or Safety Injection EEP.-1 Loss of Reactor or Secondary Coolant
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EEP-2 Faulted Steam Generator Isolation EE8' 3 Steam Generator Tube. Rupture The output of the table-top analysis will be recorded on Task Analysis Worksheets (TAW's) which provide an auditable means to docur'ent information and controls requirements and the corresponding instrumentation and controls. The TAW's will serve as an auditable record of how the needed i
characteristics of the instruments and controls were determined. An example TAW form is provided as Figure 1.
LAPCo Response to NRC Comments on DCROR, Dated March 9,1984-i Pago 3/
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As part of the table top task analysis, AFCo will identify information and control requirements. These information and control requirements will be identified without regard to the specific controls and displays that exist in the Farley control. room. The DCRDR task analysis will identify the following information and control requirements from the Farley-specific EEP's and FRP's.
Displays - Values (1050, 25, 766,' etc.)'
Units (psi, gpm, 'F, etc.)-
Precision (t 5'F, difference of 10 psi, etc.)
Characterissics (trend, greater than, in range, etc.)
Controls - Type (discrete, continuous)
Positions (on/off, 0-10 in increments of 2, etc.)
The above represent characteristics of instruments and
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controls identified in the EEP's and FRP's that operators need to complete. Unless' indicated as a problem by questionnaires, interviews,'oc operating experience, characteristics such as transfer functions, loop time constants, gain, etc., will not be addressed during the DCRDR task analysis.
The instrumentation and controls that support the t
FNP-specific procedure tasks will be checked as follows:
1)
Review Team members will verify that any information and control requirements identified during the table top analysis are met by specific instruments and controls in the control room. -
2)
Several operators will be walked through the applicable Farley EEP's and FRP's in the simulator.
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APCo' Response to-NRC
- Comments on. DCRDR, Dated March 9,1984 Page~4 During these.walkthroughs, the operators will be asked to point out the instruments and controls they tould use to accomplish the steps called out in the emergency.
. procedures. ' The-instrum'ents and controls identified by the operators will be compared to those instruments and controls identified in the verification of the infomation and -
control requirements.
APCo believes that the above description of the process for using plant-specific emergency procedures, that are based on generic guidelines and background documentation, to identify the characteristics of needed instrumentation and controls is comprehensive and precludes the need to generate a control room inventory. The real-time simulation used for.
ERP validation has verified the operator's ability to use instrumentation and controls necessary for real-time responses to emergency' operating conditions.
3.
NRC Comment:
The sample Checklist / Survey worksheets enclosed ir the APCo program plan appear to lack space for recording the nomenclature / location of the discrepant iten(s) involved.
APCo Response: The worksheets have been revised so that all discrepant items can be identified by panel location and instrument number. An example worksheet is provided as Figure 2.
4.
NRC Comment:
The HFS should be oriented to the FNP control room prior to the survey.
APC0 Response: APCo agrees and will provide an orientation for the HFS prior to the survey.
5.
NRC Comment:
The NRC Staff recommends that the scope of the DCRDR include a human factors evaluation of the remote shutdown capability.
APCo Response: APCo will survey the Hot Shutdown Panels specified in Abnomal Operation Procedure (A0P) 28.0, " Control Room Inaccessibility", during the DCRDR survey and will perform task analysis on A0P 28.0.
L APCo! Response to NRC l Comments on DCRDR, Dated March 9,1984 Page 5 6.
NRC Comment:
- Although the APCo program plan mentions the use of consensus opinion and use of an INP0 NUTAC document.to rate HED's, the.
plan does not include a precise method to systematics 11y assess HED's for significance. The Staff recomends that further documentation be provided to demonstrate that a concrete and valid technique will be employed.
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APCo Response: The method for HED assessment will include the use of several rating scales.
Each HED will be rated on.every scale by as many voting DCRDR team members as possible.
These scales will be 7-point Likert-type scales from which an HED can be consistently categorized as t. its potential for causing serious operator error.
An example HED assessment form is provided as Figure 3.
The details of the assessment method will be included.in the DCRDR sumary report.
7.
NRC Comment:
The NRC Staff is concerned that the APCo program plan does not mention two important criteria for judging HED significance, namely the probability of error occurrence and the seriousness of possible outcome.
APCo Response: The HED assessment scales to be used in the DCRDR will include, but not necessarily be limited to, the probability that en HED will cause an error and the effect of such an error on the operation of the plant.
8.
NRC Comment:
The proposed schedule for resolution of APCo's Category 2 HED's is unacceptable. HED's known to have caused problems should be addressed promptly or a time limitation should be placed on the completion date.
In addition, APCo's Category 3 HED's should be addressed promptly.
APCo Response: During assessment, HED's will be placed in four categories as follows:
Category 1 - HED's judged likely to prevent or delay the operator from completing a procedure step during emergency operation or HED's identified as causing or assessed as likely to cause problems of safety significance during normal operations Category 2 - HED's identified as causing, or assessed as likely to cause problems during normal operation that do not have safety significance S
APCo Response to NRC ~.
- Comments on DCRDR, Dated March 9,1984 Page 6 Category 3 - HED's with problem potential undefined
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Category 4'-- 'HED's not likely to cause problems For HED's which do not require plant modifications (i.e.,
resolutions requiring procedural or training revisions),
resolution will be completed as soon as possible. For HED's requiring plant modifications, APCo has adopted the following goal dates:
Category 1 - As soon as design, procurement and plant conditions allow.
Category 2 - No later than the end of the first refueling
~ outage after the summary report _ is submitted, assuming acceptable lead times are available for design and procurement.
Category 3 - No later than the second refueling outage after the summary report is submitted..The completion date will depend on economic and lead-time considerations.
Category 4 - No change required.
Any control room change and associated completion date is at the discretion of APCo.
It is APCo's position that the critical path of an outage will not be extended for licensing related modifications that do not involve a safety concern.
9.
NRC Comment:
The APCo program plan does not discuss the criteria that will be used to select among candidate improvements to resolve HED's. The staff recommends that a well-defined procedure and criteria be developed.
APCo Response: The selection of the most appropriate design improvement is a complex process, but it is a process that goes on continuously in the APCo design support organizations. The l
process and criteria mentioned briefly in Section 5.3 of the APCo program plan are those used currently to evaluate alternative design improvements for the Farley plant and ensure that modifications are implemented in accordance with the design. HED resolutions will predominantly address physical changes, procedural modifications and or training improvements.
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APCo, Response to NRC Conenents on DCRDR, Dated March 9.-1984
- Page 7 -
It is not the process nor the criteria that should be evaluated from a regulatory perspective, but the result.
Regardless of the process used to resolve HED's, the ultimate judgement should be made on the basis of whether the resolution actually corrects the specific HED's..
- 10. NRC Comment:
While APCo shows some ittempt toward addressing the verification of proposed room modifications, the absence of a description of the procedures or processes required for a successful verification effort does not permit the NRC Staff to assess APCo's understanding of an intent to meet these requirements.
APCo Response: As part of its effort to maintain the human factors configuration of the FNP control room in the future, APCo will develop Farley-specific design dirt.ctives (e.g., switch conventions) for use by design organizations during the design process for all future modifications affecting the control room. The design organizations will also utilize appropriate NUTAC criteria during the development of the design.
Some HED resolutions will not require any verification to ensure that HED resolutions do not create new HED's (e.g., labeling that is replaced to meet specified human factor criteria). For more complex HED resolutions (e.g., functional grouping of displays) visual and/or physical verification will be made.
In major modifications this verification could include the use of mock-ups, detailed conceptual design reviews, walkthroughs, etc. The HFS will be used, as needed, during the verification process for the initial HED resolutions review.
- 11. NRC Comment:
The Staff suggests that verification of HED resolutions on the APCo simulator be performed prior to installation in the control room.
l APCo Response: APCo believes that proper use of design directives, an evaluation of modifications to appropriate NUTAC criteria during the design process and a physical and/or visual verification will provide sufficient confidence in HED resolutions prior to installation in the control room.
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APCo Response to HRC Coaments on DCRDR, Dated March 9,1984 Page 8 The APCo simulator is dedicated tc training at FNP and as such, should reflect, to the extent possible, actual control roem configurations. Additionally, APCo feels preliminary modifications to the simulator would not be cost effective.
APCo, therefore, will not alter the simulator configuration for the purpose of verifying HED resolutions.
- 12. NRC Comment:
The Staff recommends that an information management system be developed to provide a tracking system for HED design modifications.
APCo Response: APCo will implement a system to track HED resolutions.
- 13. NRC Comment:
Although APCo foresees the value of coordinating the DCRDR with other programs, the NRC Staff finds that the actual mechanics of a coordination effort or the intent to actively develop and implement a plan for such coordination have not been demonstrated. To the extent practicable, without delaying the completion of the DCRDR, it should also address any control room modifications and additions made or planned as a result of other post-TMI actions and lessons learned from operating reactor events such as the Salem ATWS events.
APCo Response: The NUTAC " Guidance for an Integrated Implementation Plan for Emargency Response Capability" documeat was used to develop the Farley-specific Emergency Response Capability program. The APCo DCRDR is implicitly integrated with the development of Farley-specific emergency procedures, in that the task analysis activity of the DCRDR will utilize
-d Farley-specific emergency procedures.
Regulatory Guide (R.G.) 1.97, SPDS and inadequate core cooling design efforts will be in progress at the same time as the DCRDR. To the extent that control room changes related to SPDS, inadequate core cooling, and R.G.1.97 are known, they will be evaluated during the DCRDR. The HFS will review aspects of the SPDS and inadequate core cooling design specifications related to human factors to ensure the systems' acceptability from a human factors standpoint. The DCRDR team will evaluate impending R.G.1.97 plant modifications affecting the control room during the DCRUR. The output of the DCRDR (HED's and suggested modifications) will be integrated with the SPDS functional specifications where appropriate.
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- APC0 Responsb to NRC Comments on DCRDR, Dated _ March 9,1984 ~
Page 9 14.
NRC Comment:
The staff has determined that APCo should provide justification for those guidelines in NUREG-0700 not examined.
APCo Response: APCo considers NUREG-0700 to be guidance only and as such feels that no justification is required. APCo believes that the criteria and guidelines used in the DCRDR should stand on their own merit and should be evaluated for compliance with the provisions for human factors principles as embodied in NUREG-0737, Supplement 1.
APCo has evaluated the NUTAC guidance cross-references to NUREG-0700 guidelines and has detemined that only the principles associated with NUREG-0700 guidelines 6.3.1.5A and 6.3.1.5B 1-3 concerning notifying the operator.of cleared alanns may not be adequately addressed in the NUTAC guidance. APCo'will add a question to both the engineering and operator questionnaires regarding the cue (s) that signify an annunciator has returned to normal.
In APCO's judgement, all human factors principles embodied in NUREG-0737, Supplement 1 will be addressed in the APCo DCRDR program following this addition.
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Figure 1 Farley Nuclear Plant TASK ANALYSIS 110RKSHEET Sheet'1 of 2 Information and Control Requirements CHARACTERISTICS (Trend, greater NlNERICAL or less than, CONTROL CONTROL TASK VALUE UNITS range)
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Figure 2 Farley Nuclear Plant CHECKLIST / SURVEY WORKSHEET COMPLIANCE-
- G-51 PANEL NUMBER:
YES NO N/A Emergency controls are readily accessible.
J List ir.strument numbers not in compliance:
Comments:
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Figure 3 Farley Nuclear Plant j
CONTROL ROOM DESIGN REVIEW HED CATEGORIZATION RECORD HED #
LIKELIHOOD THAT HED WILI. CAUSE ERROR Cat.4 CAT. 1 OR 3 CAT. '1 OR 2 I
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RESULT OF ERROR (IF UNCORRECTED)
Cat.3 CAT.1 or 2 I
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I NO REQUIRES REDUCTION LOSS OF LOS5 0F EXTENDED EXTENDED EFFECT ADDITIONAL IN OPER.
COMPONENT SYSTEM LOD OF LOSS OF STEPS PERFORMANCE FUNCTION FUNCTION SYSTEM PLANT FUNCTION FUNCTION g
EFFECT ON MAINTENANCE AND/0R RESTORATION OF A CSF CAT. 1 OR 3 CAT. 1 I
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LOSS OF EXTENDED PREVENT EFFECT REDUCTION SAFETf SAFETY CSF LOSS OF CSF RES".0 RATION TO SAFETY MARGIN MARGIN MARGIN REMARKS i
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TEAM ACTION CATEGORIZATION 1
2 3
4 NOTE: DISSENTIt'G TEAM MEMBER (5) OPINION NOTED AB0VE TEAM MEMBER TEAM MEMBER SIGNATURE CONCURRENCE DATE Team Leader (T)
YES NO Administrative Asst.
(A)
YES NO Human Factors Spec.
(H)
YES NO Operations Specialist (0)
YES NO Procedures Specialist (P)
YES N0 l
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Summary of APC0 Program Plan Items Differing from NUTAC Guidance l
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S ction APCo Proposal NUTAC Guidance Justificatien/Correcticn 3.
Management, Staffing Planning "hase says that More detail should be Development of detailed and Scheduling CRDR procedures will be provided about the overall procedures for every CRDR developed if required.
organization and focus of activity may not be the DCRDR project.
An necessary since the review-implementation plan should team will perform these be developed which describes activities.
Some activities the purpose of the CRDR.
are sufficiently detailed in This plan shoulo be provided the program plan.
to the review team as part of the orientation.
3.2 Review Team Structure APCo has added an APCo feels these additional Administrative Assistant and members will enhance Review an Emergency Procedures Team capability.
Specialist to the NUTAC guidance Review Team.
3.4 Review Team APCo does not propose to Line organizations should APCo believes the review Organizational utilize line organizations perform control room reviews team has the necessary Interfaces as an integral part of the as often as possible.
expertise to perform all DCRDR; only when certain control room reviews without tasks require their involving line assistance.
organizations.
If additional expertise is required, then line organizations will be utilized.
4.1.1 Historical APCo states that the The review team leader must The review team leader will Documentation Review Administrative Assistant review all documents which review the Administrative will screen all significa tt may relate to control room Assistant's list of possible documents for possible discrepancies before control room discrepancies discrepancies relating to presenting thea to the before presenting it-to the the control room.
review team for evaluation.
review team for evaluation.
Page 1 of 3
Section APCo Proposal NUTAC Guidance Justification /C:rrecticn 4.1.4 Structured Interviews Follow-up interviews will be Follow-up interviews are APCo believes that performed after the operator included as a required interviews should only be
- questionnaires are reviewed portion of the DCRDR conducted if they can add.
only if it appears there are project.
significantly to the some discrepancies or information gained from the ambiguities to the answers.
questionnaire:.
Cor.tracted personnel should These interviews will be
- conduct foll ow-up Since.the purpose for the performed by the DCRDR team intceviews.
follow-up interviews is to leader's de ignee.
clarify, it would eliminate confusion if the DCRDR team members performed the interviews themselves.
4.2 CN: trol Room Survey APCo will not re-evaluate Earlier survey _ resolved surveys which were addressed disc repancies.
in the 1980 Control Room Survey (e.g., noise survey) 4.2.2 Personnel Assignments Survey Teams will consist of The surveys will be In order to avoid confusion members of the DCRDR team if conducted by members of during the review of Control possi bl e, various line organizations.
Room surveys, members of the DCROR team will perform the surveys themselves.
Page 2 of 3
Section APCo Prop 3 sal NUTAC Guidance Justi fication/Carrecti:n 5.2 Evaluation Criteria HED categories are revised.
Based on other utilities' experience in HED assessment, the revised APCo method should be more effective.
5.3 Resolution of HEDs All proposed resolutiens All resolutions should be Some resolutions may be more will be evaluated for reviewed for good human adequately verified by means ef fectiveness. Designers factors engineering with a other than a mock-up.
will be instructed to mock-up of all modifications include human factnrs utilized before engineering in all proposed impl ementa tion.
control room modifications.
APCo will utilize a physical or visual verification for those HED resolutions deemed appropriate to ensure ' bat new HED's are not introduced as a part of the initial !ED resol ution.
5.5 Methods of All modifications will be Validation of modifications Existing plant procedures Impl ementation performed in accordance with will be performed 60 days and policies will provide plant procedures.
Any af ter operation by the effective feedback.
negative feedback from review team. A report will operatien personnel will be provided to the prompt a post-modification vice-president categorizing review.
the effectiveness of the modification. Operator feedback will be continually received regarding all rontrol room modifications.
D-38 Page 3 of 3
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