ML20107L925

Comments on Detailed Control Room Design Review Program Plan,Surry Power Station Units 1 & 2 & North Anna Power Station Units 1 & 2

ML20107L925
Person / Time
Site:	Surry, North Anna, 05000000
Issue date:	06/11/1984
From:	LAWRENCE LIVERMORE NATIONAL LABORATORY
To:
Shared Package
ML20107L900	List: ML20107L925
References
FOIA-84-933, RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8503010109
Download: ML20107L925 (27)

Text

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1 COMMENTS ON THE DETAILED CONTROL ROOM DESIGN REVIEW PROGRAM PLAN FOR VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS NO. 1 AND 2 NORTH ANNA POWER STATION UNITS NO. 1 AND 2 LAWRENCE LIVERMORE NATIONAL LABORATORY JUNE 11, 1984 g 30 g 9 050109 PEDROB4~933 PDR L

CCMMENTS ON THE OETAILEO CONTROL ROOM DESIGN REVIEW PROGRAM PLAN FOR l'

VIRGINIA ELECTRIC AND POWER CCMPANY SURRY POWER STATION UNITS NO. 1 ANO 3 NORTH ANNA POWER STATION UNITS NO.1 AND 2 l

t BACXGROUND l

Licensees and applicants for operating licenses shall conduct a Detailed The objective is to " improve the acility Control Room Cesign Review (OCROR).

l l of nuclear power plant control room operators to prevent accicents or cooe with accidents if they occur by improving the information provided to them" (NUREG-0660, Item I.D. ) . The need to conduct a OCROR was confirmed in OCROR requirements in Supplement 1 to NUREG-0737 and Supplement I to NUREG-0737.

Supplement I to NUREG-0737 NUREG-0737 replaced those in earlier documents.

recuires each applicant or licensee to conduct a OCROR on a schedule negotiated with the Nuclear Regulatory Commission (NRC).

NUREG-0700 describes four phases of the DCROR and provides apolicants and licensees with guidelines for its conduct.

The phases are: .

"1. Planning

2. Review

3. Assessment and Imolementation 4 Reporting.

Criteria for evaluating each phase are contained in draft NUREG-0801.

CRC:.

A Program Plan is to be sucmitted within two months of the start of the Consistent with the recuirements of Succlement 1 to NUREG-0727, tne 1

Program Plan shall describe how the following elements of the OCROR will be accomplished:

1. Establishment of a qualified multidisciplinary review team

2. Function and task analyses to identify control room operator tasks and information and control requirements during emergency operations

3. A comparison of display and control requir'ements with a control room inventory 4 A control room survey to identify deviations from accepted human factors principles

5. Assessment of human engineering discrepancies (HEDs) to determine which HEDs are significant and should be corr.ected

6. Selection of design improvements

7. Verification that selected design improvement's will prov'ide the necessary correction

8. Verification that improvements will not introduce new HEDs

9. Coordination of control room improvements with changes from other programs such as SPOS, operator training, Reg. Guide 1.97 instrumentation, and upgraded emergency operating procedures.

As a minimum it A Sumary Report is to be submitted at the end of the DCROR.

shall-

1. Outline proposed control room changes

2. Outline proposed schedules for implementation

3. Provide sumary justification for HEDs with safety significance to be lef t uncorrected or partially corrected.

The NRC will evaluate the organization, process and results of the DCROR.

Evaluation will include review of reouired documentation (Program Plan and Summary Report), and may also include reviews of additional documentation, In'orogress audits may be briefings, discussions, and on-site audits.

conducted after submission of the Program Plan, but prior to submission of the Summary Report. Evaluation will be in accordance with the reoufrements of Supplement I to NUREG-0737.

Additional guidance for the evaluation is provided by NUREG-0700 and draft NUitEG-0801. Results of the NRC evaluation of a DCROR

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will be documented in a Safety Evaluation Report (SER) or SER Supplement.

Improvements which can be accomplished Significant HEDs should be corrected.

with an enhancement program should be done promptly. Other control room improvements should be done on a schedule acceptable to the NRC.

Discussion The Virginia Electric and Power Company (VEPCO) submitted a Detailed Control

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Room Design Review (OCROR) Program Plan for its Surry and North Anna Power We have Stations to the Nuclear Regulatory Commission on March 1,1984 reviewed the plan against the requirements of Supplement 1 to NUREG-0737.

The Program Plan states, on page 1-3, that it is intended that the plan be a baseline for any audit of VEPCO's CROR. The licensee should be advised that the NRC will use the reouirements of Supplement I to NUREG-0737 and the guide-lines of NUREG-0700 and NUREG-0801 in their audit.

A human factors evaluation of the design of the remote shutdown capability provided to meet 10 CFR Part 50, Aopendix A GOC-19, and 10 CFR Part 50, Appendix R is not specifically identified as a requirement in Supplement I to In the interim, NUREG-0737.

NRC staff review of this issue is not complete.

we recommend that the scope of the DCROR include a human f actors evaluation of To the extent practicable, the design of the remote shutdown capability.

without delaying completion of the DCROR, it should also address any control room modificatons and additions (such as controls and displays for inadeauate 0 1 1

core cooling and reactor system vents) made or planned as a result of other post-TMI actions and the lessons learned from operating reactor events s Generic implications of the Salem ATWS events are discussed Salem ATWS events.

in NUREG-1000 and required actions are described in Secton 1.2, " Post-Trip Review - Data and Information Capability," of the enclosure to Generic Letter I

83-28.

The following comments apply to specific elements of the Surry/ North Anna .

DCRDR Program Plan.

Qualifications and Structure of the DCRDR Team Supplement I to NUREG-0737 recuires that the licensee establish a cualifie multidisciplinary review team. The VEPC0 DCRDR team will consist of a 10-member core review team, which will be supplemented by up to 17 add The availability of these members supporting members on an as-recuired basis.

has been assured by a VEPC0 management directive and has been pre'-p

The disciplines available in the support group are the degree possible.

Nuclear, Mechanical, Electrical, Industrial, Operations, Training, Human Six individuals within Factors, and an Architect and Engineer representative.

the c5re team will be members of the Human Engineering Discrepancy Asse The HEDAT will review and assess all HED reports, develop Team (NEDAT). fit recommended resolutions, and establish preliminary schedules for all back activities.

Figure 2.2 of the licensee's Program Plan shows that the primary man structure of the team is comprised of the HEDAT members, and that huma project management and expertise is provided by a consultant, the Esse

' Corporation.

The VEPCO Lead Discipline Engineer (LDE) has overall responsibility for following the planned schedule, reviewing progress, resolving problems, He chairing project meetings, and reporting project status to his managemen EDAT review will also act as HEDAT team leader and ensure strict adherenc procedures.

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Liaison with corporate management will be provided by the Nuclear Operations Department (N00) Corporate Project Coordinator, who will also act with other coordinators in staff capacity to the LDE.

The Station Coordinators for Surry and North Anna are responsible for determining station facility, personnel availability and activity coordination as appropriate, and for providing operational expertise.

The two lead Essex human factors (HF) specialists are responsible to the LDE for, and will ensure the technical quality of, human factors work and the availability of other appropriate HF specialists as appropriate throughout the project. They will coordinate all HF activities and will contribute to the HEDAT functions. The HF specialists are committed to collect, reduce, and The major DCROR analyze data, and to locate, analyze, and resolve HEDs.

planned activities and approval cycles are illustrated in Figure 2.4 of the plan. Figure 2.3 of the plan describes in matrix format the 15 OCROR task assigments of the support staff personnel and each category of team member, t

oith coded identification of prima ~ry responsibility, support responsibili y, and approval authority. .

Appendix A of the Program Plan contains the resumes of HED assessment team members.

We conclude that the VEPCO management and staffing effort has been adequately

. planned, and that the DCROR team will have access to a suitable diversity of expertise. To enhance the qualifications and structure of the OCRDR team, we recommend that a formal program of HF orientation and training for non-HF specialists be instituted and. executed to provide a common basis of under-standing for review team members.

B'ased on our review of the qualifications, organization, and management structure of the Surry/ North Anna review team, it is expected that the licensee will satisfy the reauirement of Supplement I to NUREG-0737 to establish a qualified multidisciplinary review team to conduct a DCROR.

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two comments While not required by Supplement I to NUREG-0737, the f thefollowing tasks are intended to provide the NRC with a more comolete description o included in the Plan.

Documentation and Document Control l

The VEPCO OCROR plan states that the project team includes a l project experienced in document and office management, '

documentation and reports. ibil-corporate and station document control systems and willthat It is recommended ensure t ity and auditability of review project data and files. fficient detail to the OCROR Summary Report describe the document system i in su allow the NRC to fully understand and review it, especially the aud capability.

Operating Excerience Review ibed The Operating Experience Review (OER) recommended by NURE in Section 4.2 of the plan, and consists of two tasks:

Review of plant and industry documents 1) 2)

Survey of plant operations personnel .

ien These tasks will identify CR design attributes and procedural ac Proolems identified in both tasks will te may affect operator performance.

documented in HE0 reports for analysis and assessment by the Seven sources of documents will be reviewed by HF special icentify human errors, equipment f ailures, prececure preolems, Occument sources to be sources of potential human perfor-ance problems.

reviewed are:

1) Licensee Event Recorts (LE4s) 2)

Significant Cceratine Excerience :ecorts (50ERs) 6

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3) Engineering Work Requests (EWRs)

4) INP0 Significant Event Reports (SERs)

INPO Operations and Maintenance Remainders (0&MRs) 5)

Westinghouse Data Letters (WOLs) 6)

Westinghouse Technical Bulletins (WTBs).

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Appendix B of the VEPC0 plan illustrates an Historical Report Suma h

data for review by the Lead Human Factors

' form to be used to collect t e The HRS will be attached to its related HED report.

Specialist (LHFS).

The operations personnel survey will consist of these subtasks:

Use of self-administered questionnaires 1)

2) Conduct of structured interviews

3) Analysis of all questionnaire and interview responses.

The questionnaires will be issued to all licensed SR0s and R0s, STAS and training staff, and to selected administrative personnel to solicit '

information in the following areas: .

1)

Availability and usability of CR information

2) Design and location of controls and displays

3) Annunciator warning system effectiveness 4)

Adecuacy of workspace layout and anthropometry

5) Operation of process computer *

6) Adequacy of panel labeling

7) CR comunications

8) CR environment

9) Maintenance in the CR 10)

Units 1 and 2 operator interfaces

11) Personnel Human Error

12) Respondent biographical data.

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l Structured interviews will be conducted eith a minimum of

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R0s and SR0s, and will address 14 areas identified from Chapter 6 of i

NUREG-0700.

Operators will be encouraged to provide any other comments or concerns they may have regarding CR design or operation.

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i Response analyses and tabulations will be aided by checklists constr i

1 Chapter 6 of NUREG-0700.

2 We conclude that the OER, as planned, is complete and well-structured, an I

aill meet the intent of the guidelines described in NUREG-0700.

Function and Task Analysis _

l Supplement I to NUREG-0737 requires the licensee to perform systems i

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1 and task analyses to identify control room operator tasks and informatio Furthermore, Supplement 1 l

control requirements during emergency operations.

l to NUREG-0737 recommends the use of function and task analyses that ha ,

used as the basis for developing immergency operating procedures tech guidelines and plant-specific emergency operating procedures to defin P r equirements.

t The licensee's program plan (Section 1.3.3.3) states that the System Fun ,

I and Task Analysis (SFTA) will be done in 4 steps: J

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1. Identification of systems and subsystems by review of plant documentation and the Westinghouse Owner's Group Emergency Resp!

Guidelines and Task Analysis.

2. Identification of normal and emergency operating procedures to i

undergo task analysis. s t

i 3.

Identification of system / subsystem functions through document r and operator interviews.

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4. Identification and analysis of CR operational tasks.

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It is requested that the licensee explain more fully and differentiate the tasks to be performed in accomplishing steps 1 and 3 above.

(a) a tabular listing of The two basic products of this analysis will be:

major operating systems and subsystems, and (b) tables and/or functional-flow block diagrams showing the specific operator functions required to complete the procedures selected for analysis.

Item (b), above, will record the actual task analyses of the required operator This functions in terms of operator input-output and decision requirements.

record will establish the information and control requirements and the performance criteria for the tasks to be performed by the operators under emergency conditions.

The SFTA method described in the plan (4.4.2) states that emergency event sequ'ences which challenge safety-related functions will be considered from the following list of scenarios: ,

o Small loss of coolant accident o Inadequate core cooling o Anticipated transient without reactor trip following a loss of off-site power o

Multiple failure of tubes in a steam generator and tube ruptures in more than one steam generater.

Other scenarios may be considered as may be necessary.

Functions, such as the following, are stated to be challenged by the event sequences chosen:

o Suberiticality o Containment integrity o Heat sink o Reactor coolant system inventory .

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r o Core cooling o

Reactor coolant system integrity. ,

It is assumed that all scenarios and functions listed above will undergo SF If, in by the licensee and will be reported in the DCROR summary report.

fact, not all of the above will be analyzed, any omissions should be justif Additional scenarios and functions which may be analyzed should be descrio It is recommended that a large break LOCA be considered.

The selection of event scenarios and system functions will form the basis for The WOG generic task analysis data will the selection of appropriate ERGS.

provide the initial input for the development of unit-specific task. analys information.

The above process will develop an inventory of tasks, and, for each task, identify the following:

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the operating event o

o the title of the task .

o the task objective o

the cue or signal that initiates the task o the number of the task o

the behavioral or subtask elements that identify which ooerator performs the element, where it is performed, the action that is taken, and other data necessary to describe components, parameters, and parameter states.

It is stated that the unit-specific task analysis information will identify the required instruments and controls for each task, but a description of ho It is not stated this identification will be accomplished is not included.

either how or in what format the instrument and control ch be determined (e.g., control type and characteristics, instrument range, It is accuracy, scale details, tolerances, rate of data change, etc.).

requested that these items be explained in the summary report.

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r-The NRC memorandum of April 5,1984, from H. Brent Clayton to Dennis L.

Ziemann, " Meeting Summary--Task Analysis Reouirements of Supplement I t meeting with Westinghouse Owner's Group (WOG)

NUREG-0737, March 29, 1984 Procedures Subcommittee and Other Interested Persons" states that it appears that Revision 1 of the ERG and background documen,ts do provide an adecua basis for generically identifying information and control needs.

The licensee should describe specifically how it is intended to accomplish Items 2, 3, and 4 of the April 5,1984 Memorandum, which is reproduced in Appendix A to this report.

Examples of the pre-printed forms that VEPC0 will use to record the data are illustrated in the plan in Fig.1, Task Sequence Chart, and Fig. 2, Task Data Form.

Terminology to be used on the forms will be selected from the Standard Data Base Entries of Fig. 3, and Standardized Behavior Verbs in hierarch order, Fig. 4. The forms appear to be functional and well designed for easy The format provides easy computer entry.

recording and subsequent use.

The licensee should be aware that operator information and control needs should be determined from the system function and task It is recuirements important to such a those specified in the generic and plant-specific ERGS.

recognize that information and control reouirements should be derived fr analysis of system function and task recuirements; not from existing instruments and controls that are installed in the control room.

It is not clear from the VEPC0 Program Plan what process will be used to identify the operator information and control needs that are associated wit each task.

An objective, independent determination of the operator information and control needs for each operator task should be done before instrumen Review of the sample forms provided in control specifications are developed.

the Program Plan does not indicate that an objective identification of ope informaton and control needs will be accomplished or adeouately document 11

r The licensee should closely review the task analysis methodology to ensure that operator information and control requirements to perform operator tasks are determined and documented to support the specification of instruments and controls. The Program Plan does not as yet describe this process in sufficient detail to determine that the VEPC0 DCRDRs for Surry and North Anna will meet the requirement of NUREG-0737, Supplement 1, to perform function and task analyses to identify operator tasks and information and control recuirements during emergency operations.

Control Room Inventory Supplement I to NUREG-0737 requires the applicant to make a control. room inventory and to compare the operator information and control needs determined from the task analyses with the control room inventory to determine missing controls and displays.

Section 4.5 of the DCRDR describes a very complete and systematically organized plan to develop a comprehensive listing of instruments, controls and ecuipment contained in the Surry and North Anna CRs. Data collected will be placed in the VEPC0 data base.. management system in five files:

o System instrumentation a System manual controls o System automatic controls o Annunciator system o

Miscellaneous CR instrumentation and controls and operator equipment.

In each category, a complete collection of equipment locations, types, parameters, and other characteristics are described and planned to be filed Where appropriate, the following will also be included:

for later retrieval.

o Component photograph or drawing, if available o Photomosaic location code o Surveys and checklists applied to component o identification of HEDs written' for component, if any.

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The inventory will be made plant-specific throuch photomosaics and visits to The licensee should be made aware that simulators, the CR and/or simulators.

if used for inventory purposes, must be exact duplicates of the CRs, and this should be confirmed in the Summary Report.

The licensee should ensure that the DCRDR objectively compares information and control needs throughout the control roomw 'ith a control room inventory to identify missing controls and displays. An objective comparison is needed to fulfill the requirement of Supplement 1 to NUREG-0737 for comparison of operator information and control needs with the control room inventory.

When conducted and documented as described, we conclude that the licensee will meet the requirement in Supplement 1 of NUREG-0737 to compare acceptably determined operator information and control needs with a CR inventory.

Control Room Survey Supolement 1 to NUREG-0737 requires that a control room survey be conducted to NUREG-0700 identify deviations from accepted human factors principles.

The provides guidelines and criteria for conducting a control room survey.

objective of the control room survey is to identify for assessment and possible correction, the characteristics of displays, controls, equipment, panel layout, annunciators and alarms, control room layout, and control room a e ient conditions that do not conform to good human engineering practices.

Section 4.3 of the DCRDR plan states that NUREG-0700 will provide the specific and detailed criteria to which all survey data will be compared. .

The licensee CR survey plan will be executed using 14 individual specific task plans. Each task plan covers an individual area which parallels the structure Each task plan uses an appropriate mix of one or more of Ch. 6 of NUREG-0700.

a) measurements, b) obser-of four types of basic data collection procedures:

The data vations, c) ouestionnaires/ interviews, and d) document reviews.

types are determined by the NUREG-0700 criteria and are described in 13

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The texts of the task plans are not included in the plan , Section 4.3.2.f.

the DCROR clan, but are stated to follcw the following format:

1.0 - 03jectives 2.0 - Review Team 3.0. - Criteria Summary 4.0 - Procedures 5.0 - Equipment / Facility Requirements

• 6.0 - Inputs and Data Forms Listing 7.0 - Required Outputs / Expected Results 8.0 Figures and Tables (if recuired) 9.0 - Procedure Exceptions (if any)

Appendix A - Detailed Criteria Appendix B - Data Collection and Analysis Forms Appendix C - Criteria-to-Procedure Matrix Appendix 0 - Task Plan Criticue Sections 1.0 through 8.0 above are summaries of the task requir For each task plan:

-task conductor .

o Aopendix A centains detailed criteria and procecural infermation referenced to NUREG-0700, Chapter 6, o

Appendix B contain subaccendices which describe the data and analysis procedures, each of which is ccmolete for each tas plan.

o Section 9.0 and Appendix 0 are ecmoleted byforthe task cond ccmmer:

necessary, and submitted to the VEPCO tecnnical reviewer and feeoback.

It is reccmmencec tnat tne acclicant o Accendix C is not described. in the be recuested to include a description and sarole matrix Summary Recert for NRC review.

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Examples of a two page HED report form, a 3 page HED Potential Significance form; and a HED Cost Estimate form are included in Appendix 8 of the DCRDR Program Plan (which is different from Appendix B of the task plan described The forms appear to be well designed and to contain adeouate infor-abov e) . Copies of all completed task plans mation for efficient review and. analysis.

will be filed in the Review Data File.

Section 4.1.2.2 of the Program Plan states that "any deviation from the In addition, the licensee should justify such guidelines will be noted."

deviations.

Based on our review we conclude that the licensee has submitte It is expected that the licensee will meet the intent DCRDR CR Survey Plan.

of NUREG-0700 and satisfy the requirement of Supplement 1 to NUREG-0737 to conduct a CR survey to identify deviations from accepted HF principles.

Assessment of HEDs _

Supplement 1 to NUREG-0737 requires that HEDs be assessed to determine HEDs are significant and should be corrected.

The basic procedure to be employed in selecting HED corrective actions described by the plan is based on Exhibit 4-2 of NUREG-0700 and NUREG-08 The process is as, follows:

draf t of October 1981.

o Assess extent of deviation from NUREG-0700 guidelines o

Estimate increase in human error for the discrepancy o

Determine if discrepant component is safety function related o

Determine if errors in using discrepant component (s) could lead to violation of tech specs or unsafe operation o Assign category and priority, based on the above.

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They HEDs identified during the review period will be assessed by those the HEDAT.

will separate those HEDs that are unlikely to degrade performance from that may degrade performance.

The assessment factors used will be estimations of: a) the potential for operator error, b) the consequences of the errors and c) the probability of error recovery.

The estimates of the potential for error will be based on the expert judgm of the lead HF specialist, and will consider o

Component design factors (e.g., extent of deviation from guideline, conformance to plant design conventions),

o Task factors (e.g., difficulty, frequency, time demands), and o

Human factors (physical performance; sensory and perceptual performance; cognitive performance).

Figure 5-1 of the plan Error consequences will be estimated by the HEDAT. l ting provides nine classes of HEDs to aid the HEDAT in analyzing HEDS a appropriate corrective actions.

Documented errors or HEDs that are identified as being safety related or which increase the probability of an error tha could result in unsafe operation or violation of a technical specification will receive the highest rating.

HEDs will be selected to be corrected by enhancements, operator trainin Cost benefit procedural revisions, and/or design improvement alternatives. The analyses will be made to limit the number of changes which must be licensee should objectively explain and justify the rationale used to lea safety significant fiEDs partially corrected or uncorrected.

l We expect that an acceptably executed and documented I toassessme enable the licensee to demonstrate that this requirementldofbeSuppleme NUREG-0737 to assess HEDs to determine which are significant and sh corrected has been met.

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Selection of Desian Imorovements Supplement 1 to NUREG-0737 requires selection of control room design improvements that will correct significant HEDs.

It also states that improvements that can be accomplished with an enhancement program should be done promptly. An unacceptable schedule of implementation is defined in the "Near term corrective Glossary on page 1-17 of the Plan, where it is stated:

actions . . . will be completed by the end of the second refueling outage after submittal of the final Summary Report and after NRC acceptance."

The plan states that the selection of HED corrective actions involves the following:

o Analysis for correction by enhancements o Analysis for correction by design alternatives o Assessment of the extent of correction.

It is planned that the HEDAT will -identify potential corrective actions for all HEDs, regardless of their priority.

Those HEDs selected for correction by enhancement will be reassessed for effects on operator performance and, if appropriate, will be re-evaluated via checklisting and task analysis to verify HF suitability.

If not suitable for correction by enhancement, HEDs will be corrected by design alternative.

Factors used to identify HED design alternatives will include reference to task analysis data, constraints due to equipment availability, scheduling, coordination requ'irements, cost, impact on operator training, plant main-Alternatives will be verified by functional and tenance and documentation.

task analyses and reapplication of NUREG-0700 guidelines.

It is recommended that the licensee use cost with objective restraint and discretion in the determination of corrective actions so as to ensure that HEDs will not be inadequately ~ corrected.

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It Th'e extent to which HEDs will be corrected will be reviewed by the HEDAT.

is stated that, ideally, all discrepancies should be fully corrected, but any that are not fully corrected will be identified, documented, and justified.

The corrective action implementation schedule will consider the following:

o Prioritization and categorization guidelines of Paragraph 5.2 of the Plan ..

o Safety consecuences of operator errors that could be caused by the discrepancy o Integration with other NUREG-0737 Supplement 1 programs o Plant operation constraints o Operator training / retraining requirements o Outage schedules o Equipment procurement schedules.

We conclude that when the plan is executed and reported as described the licensee will meet the recuirement of Supplement 1 to NUREG-0737 to select However, the design improvements that will correct significant HEDs.  ;

i'mplementation will not be acceptable unless all corrective actions are completed on a schedule acceptable to the NRC.

Verification that Desicn Improvements Provide Necessary Correction and Do Not Introduce New HEDs Supplement I to NUREG-0737 recuires that the licensee verify that selected design improvements will provide the necessary correction and will not introduce new HEDs.

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The Program Plan does not specifically address these issues as separato However, certain sections of the plan include statements relative elements. Some examples follow:

to satifying these requirements.

"Where appropriate, the control room simulator will be P g. 5-8 5.3.5 utilized to test corrections required on various panels," and "this... effort affords an opportunity to look for possible violation of other HF criteria resulting from the original correction."

P g. 1 -14 1.3.4.3 "The acceptability of design alternatives will be verified by reapplication of 0700 guidelines and task analysis . "

P g. 1 -14 1.3.4.4 "In addition the correction will be reviewed to ensu that no new HEDs are introduced into the control room as a result of the change."

P g. 1 -15 1.3.5 "...all HED resolutions will be evaluated to .

each resolution is complete and adequate."

We conclude that the execution of the licensee's plan as described will m We recommend that the licensee be reouested to provide this requirement. f sufficient detail in his Summary Report to describe the steps taken these requirements of Supplement 1 to NUREG-0737.

Coordination of Control Room Improvements With Other Procrams_

Supplement 1 to NUREG-0737 requires that control room improvemen coordinated with changes from other programs; e.g, Safety Parame System (SPOS), operator training, Regulatory Guide 1.97 (R. G Emergency Operating Procedures (EOPs).

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The plan states in section 1.2.1 that VEPC0 recognizes interfaces between the CROR and other related activities (e.g. SPOS, E0P, operation training, and instrumentation ) and that the plan is organized to consider CROR coordinatio VEPC0 further states that it has used all alth these related efforts.

relevant NRC NUREGs and Reg. Guides in developing the Program Plan and ha dedicated the necessary resources to ensure the success of the CRDR projec However, except for a few brief nonspecific statements in other parts d of the plan, there is no description of how the coordination effort will proceed, an who is responsible'for executing and recording it.

Because the specific methods and procedures planned to be used for the coordination effort are not discussed, we recortrnend that the licensee be requested to provide descriptions which will ensure that design improvements introduced as the result of other control room improvements are reviewed to meet the same standards of good human factors engineering as improvemen The licensee will need to provide evidence of these result from the DCROR.

coordination efforts and details of their accomplishment in their Summary Report to verify that the design ifnprovement coordination requirement of Supplement 1 to NUREG-0737 is met.

Conclusions .

Based on our review of the VEPC0 Surry/ North Anna DCROR Program Plan, w conclude that VEPCO plans to conduct a DCROR that generally meets the However, there are several areas in the plan of Supplement 1 to NUREG-0737. They are:

which should be described in mere detail in the Summary Report.

o A detailed description of how the detailed information and control needs will be determined is needed because it is not clear th objective and independent processes will be used to identify and document the information and control needs that are as If operator information and control needs are not each task.

objectively identified during the task analysis, a key ingredient o the OCROR will be missing, and the comparison of these needs with the inventory will not be valid.

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A detailed description of the steps that will be taken to verify o

that the HED design improvements will provide the necessary correction without introducing new HEDs.

o A detailed description of how the coordination effort will be accomplished.

o An acceptable schedule for implementation of all corrective actions should be submitted to the NRC.

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References

1. " Requirements for Emergency Capability," NUREG-0737, Supplement 1, USNRC, Washington, DC, December 1982, transmitted to reactor licensees via Generic Letter 82-33, December 17, 1982.

2. Letter to Dennis L. Ziemann, NRC, from H. Brent Clayton, NRC, Meeting Sumary--Task Analysis Recuirements of Supplement I to NUREG-0737, March 29, 1984 Meeting with Westinghouse Owners' Group (WOG) Procedures Subcomittee and other interested persons, April 5,1984

3. Letter from W. L. Stewart, Virginia Electric and Power Company, to Harold R. Denton, NRC, forwarding Control Room Design Review Program Plan, March 1,1984. ,

4.

Control Room Design Review Program Plan for North Anna and Surry Power Stations, Virginia Electric and Power Company, ( Attachment to Reference 2).

5. NUREG-0700, " Guidelines for Control Room Design Reviews," September 1981, USNRC.

6. NUREG-0801, " Evaluation Criteria for Detailed Control Room Design Reviews," Draft, April 1983, USNRC.

7. NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," May 1980, Revision 1, August 1980.

8. NUREG-1000, " Generic Implications of ATWS Events at the Salem Nuclear \

Power Plant," April 1983.

9. Generic Letter 83-28, "Reouired Actions Based on Generic Implications of Salem ATWS Events," July 8,1983.

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Appendix A Text of Memorandum of April 5,1984 MEMORANDUM FOR:

Dennis L. Ziemann, Chief Procedures and Systems Review Branch Division of Human Factors Safety FROM:

H. Brent Clayton, Section Leader Section A - Procedures Procedures and Systems Review Branch Division of Human Factors Safety

SUBJECT:

MEETING

SUMMARY

- TASK ANALYSIS REOUIREMENTS OF SUPPLEMENT 1 TO NUREG-0737 MARCH 29,1984 MEETING WITH WESTINGHOUSE OWNERS GROUP (WOG) PROCEDURES SUBCOMMITTEE AND OTHER INTERESTED PERSONS Staff representatives met with representatives of the WOG Procedures Subcommittee and others on March 29, 1984, to discuss the task analysis requirements of Supplement 1 to NUREG-0737 (Generic Letter 82-33). The purposes of the meeting were (1) for the Subcommittee to discuss how operator information and control needs have been addressed by the Emergency Response Guideline (ERG) development effort, and (2) for the staff to identify any additional analysis or documentation needed for review.

Mr. Doug McKinney, Subcommittee . Chairman, made a brief presentation. on the background of the ERG development program as it relates to the issue of task analysis. His presentation included a description of the ERG background documents, development of Revision 1 to the ERG, interactions with NRC, Supplement 1 to NUREG-0737 requirements, and an overview of how the WOG had responded to the reouirements. A copy of Mr. McKinney's transparencies is enclosed (Enclosure' l).

Mr. Ralph Surman of Westinghouse made a presentation which described in some detail the development of the ERG and the accompanying background He emphasized that documentation for both the Basic version and Revision 1.

one of the main objectives of the ERG is to identify the operator tasks necessary to perform functions which are identified in the background documentation. A copy of Mr. Surman 's transparencies is enclosed as Enclosure 2.

After a caucus, the staff made the following comments to the meeting attendees:

(1) Based on the presentations by Mr. McKinney and PE. Surman, it appears that Revision 1 of the ERG and background documents do provide an adequate basis for generically identifying information and control needs.

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• (2) Each licensee and applicant, on a plant-spgcific basis, must describe the process for using the generic guidelines and background documen-tation to identify the characteristics of needed instrumentation and controls. For the information of this type that is not available from the ERG and backround documentation, licensees and applicants must describe the process to be used to generate this informaton (e.g., from transient and accident analyses) to derive instrumentation and control characteristics. This process can be described in either the PGP or DCRDR Program Plan with appropriate cross-referencing.

(3) For potentially safety-significant plant-specific deviations from the ERG instrumentation and controls, each licensee and applicant must provide in the PGP a list of the deviations and their justification.

These should be submitted in the plant-specific technical guideline portion of the PGP, along with other technical deviations.

(4) For each instrument and control used to implement the emergency operating procedures, there should be an auditable record of- how the needed characteristics of the instruments and controls were determined. These needed characteristics should be derived,from the information and control needs identified in the' background documentation of Revision 1 of the ERG or from plant-specific information.

(5) It appears that the Basic version of the ERG and background documentation erovide an adequate basis for generically deriving information and control needs. However, because of the differences in the organization of the material in the background documents between Basic and Revision 1, it is apparent that it would be easier to extract the needed information from the Revision 1 background documents.

At the conclusion of the meeting, there was general agreement with the staff's coments among the owners' representatives present.

Enclosure 3 is a list of attendees.

Original signed by H. Brent Clayton, Section Leader Section A - Procedures Procedures and Systems Review Branch Division of Human Factors Safety NOTE: The enclosures mentioned in the text above are not included in this appendix.

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Mr. W. L. Stewart Surry Power Station Virginia Electric and Power Company Units 1 and 2 cc: Mr. Michael W. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virginia 23213 Mr. J. L. Wilson, Manager Post Office Box 315 Surry, Virginia 23883 Donald 'J. Burke, Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission Post Office Box 166, Route 1 Surry, Virginia 23883 Mr. Sherlock Holmes, Chairman Board of Supervisors of Surry County Surry County Courthouse .

Surry, Virginia 23683 W. T. Lough Virginia Corporation Commissfon Division of Energy Regulation Post Office Box 1197 ,

Richmond, Virginia 23209 Regional Radiation Representative EPA Region III Curtis Building - 6th Floor 6th and Walnut Streets Philadelphia, Pennsylvania 19106 Mr. J. H. Ferguson Executive Vice President - Power Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261 James P. O'Reilly Regional Administrator - Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Virginia Electric and Power Company cc: Mr. J. H. Ferguson Richard M. Foster, Esquire Musick, Williamson, Schwartz, Executive Vice President - Power Leavenworth & Cope, P.C. Virginia Electric and Power Co.

P. O. Box 4579 Post Office Box 26666 Boulder, Colorado 80306 Richmond, Virginia 23261 Michael W. Maupin, Esquire Mrs. Margaret Dietrich Hunton, Williams, Gay and Gibson Route 2, Box 568 Gordonsville, Virginia 22042 P. O. Box 1535 Richmond, Virginia 23212 Mr. W. T. Lough Virginia Corporation Commission Mr. Faul W. Purdom Division of Energy Regulation Environmental Studies Institute P. O. Box 1197 Drexel University Richmond, Virginia 23209 32nd and Chestnut Streets Philadelphia, Pennsylvania 19104 U.S. Environmental Protection Agency Atomic Safety and Licensing Appeal Region III Office ATTN: Regional Radiation Board Panel Representative U.S. Nuclear Regulatory Commission Curtis Building .

Washington, DC 20555 6th and Walnut Streets Philadelphia, Pennsyl,vania 19106 Ellyn R. Weiss, Esquire Sheldon, Harman, Roisman and Weiss 1725 I Street, N.W., Suite 506 Regional Administrator Nuclear Regulatory Conmission Washington, DC 20006 Region II Mr. E. W. Harrell Office of Executive Director for Operations P. O. Box 402 101 Marietta Street N.W. Suite '900 Mineral, Virginia 23117 Atlanta, Georgia 30323 l

l Mr. Anthony Gambardella Old Dominion Electric Cooperative Office of the Attorney General l

11 South 12th Street - Room 308 c/o Executive Vice Presider!

Innsbrook Corporate Center Richmond, Virginia 23219 4222 Cox Road, Suite 102 l Resident inspector /Nortn Anna Glen Allen, Virginia 23060 c/o U.S. NRC Mr. Richard C. Klepper Senior Resident Inspector Board of Supervisors Route 2, Box 78 Louisa County Courthouse Mineral, Virginia 23117

. P. O. Box 27 Louisa, Virginia 23093