ML20113B458

In-Progress Audit of Detailed Control Room Design Review for Omaha Public Power District,Ft Calhoun Station

ML20113B458
Person / Time
Site:	Fort Calhoun
Issue date:	03/08/1985
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20100J726	List: ML20113B458
References
CON-NRC-03-82-096, CON-NRC-3-82-96 NUDOCS 8504110204
Download: ML20113B458 (31)

Text

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.g IN-PROGRESS AUDIT OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR OMAHA PUBLIC POWER DISTRICT'S FT. CALHOUN STATION

' March 8,1985 Prepared by:

Science Applications International Corporation McLean Ytrginia 22102

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Under Contract to:

The United States Nuclear Regulatory Comission Contract NRC-03-82-096 8504110204 PDR 850325 F ADOCK 05000285 .

PDR

l FOREWORD Design Review (DCRDR) being conducted by Om for its Ft. Calhoun Station.

one representative of the U.S. NRC,The audit was conducted by a team compr one representative from Science Comex Corporation (a subcontractor to SAIC). Applications SAIC's participation was provided Reactor under Actions:

Licensing ContractProgram NRC-03-82-096, III. Technical Assistance in Support of the U.S. NRC an evaluation of OPPD's Program Plan.SAIC had previously provided to e

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s TABLE OF CONTENTS 4

Section g

BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . ..... . 1 DISCUSSION . . . . . . . . . . . . . . . . . . . . . . . . . . .... 2 Establishment of qualified multidisciplinary review team

.... 3 Function and task analyses to identify control room operator tasks and operations emergency information and control requirements during 5

., A room comparison inventory of display and control requirements with a control................

9 A human controlfactors roomprincip1cs survey to identify deviations from accepted....................

10 Assessment of HEDs to determine which are significant and...................

" Selection of design improvementss houl d be co rrected 11 . . . . . . . .

Verification that selected improvements will provide the 13 not introduce new HEDsnecessary correction and verification that improveme 1

14 Coordination of control room improvements with changes from....................

other programs such as the safety parameter display system (SPDS),

and up operator training, Reg. Guide 1.97 instrumentation Other . . graded emergisncy operation procedures (EOP's) . . . ., . . 15

. . . . . . . . . . . . . . . . . . . . . . . . . ... . 16 CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . ..... . 17 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . .... . . 20 ATTACHMENT A - FORT CALHOUN IN-PROGRESS . 22 AUDIT ATTACHMENT BATTENDEES BRIEFING - FORT CALHOUN IN-PROGRESS AUDIT ENT

.................. 24 ATTACHMENT C - SURVEY DOCUMENTATION

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IN-PROGRESS AUDIT OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR OMAHA PUBLIC POWER DISTRICT'S FT. CALHOUN STATION BACKGROUND Omah'a Public Power District (OPPD) submitted a Detailed Contr Review (DCRDR) Program Plan for Fort Calhoun Station on October 25, 1983 (References 1&2).

Nuclear Regulatory Commission (NRC) staff comments on that , Program _ Plan were forwarded to OPPD on December 30,1983 (Reference 3) .

Based on review of the Program Plan, the NRC staff planned an in-progre audit of the Fort Calhoun DCROR. That audit was arranged through the NRC Project Manager for Fort Calhoun and was scheduled for February , 1985. 4-8 The purpose of the audit was to compare the organization, process, and results of the Fort Calhoun DCRDR with the DCRDR requirements of Supple I to NUREG-0737 (Reference 4).

The audit included review of DCRDR documen-tation; visits to the control room, remote shutdown panel, and control room mock-up; and discussions of OPPD's plans to complete the DCRDR. Attachment A provides the audit agenda.

The audit team was comprised of the NRC team leader, a consultant from Science Applications ' International Corporation (SAIC), and a consultant from '

COMEX Corporation.

The disciplines of human factors engineering and nuclear operations were represented on the team.

Attachment B provides complete lists of attendees at the entrance and exit briefings.

This report documents the findings of the in-progress audit. It was com-1 piled and integrated by SAIC with input from COMEX Corporation and the NRC staff.

The report represents the consolidated observations, conclusions, and recommendations of the audit team.

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DISCUSSION NUREG-0700 (Reference 5) describes four phases of the DCRDR and provides applicants and licensees with guidelines for their conduct. The phases are:

1. Planning

2. Review

3. Assessment and implementation

4. Reporting The requirements of Supplement 1 to NUREG-0737 indicate the need to include a number of elements in the DCRDR. They are:

,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 opera-tions 3.

A comparison of display and control requirements 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 are significant and should be corrected ~

6. Selection of design improvements s

7 Verification that selected design improvements will provide the necessary correction

8. Verification that improvements will not r troduce new HEDs 9.

Coordination of control room improvements with changes from other programs such as the safety parameter display system (SPDS),

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operator training, Reg. Guide 1.97 instrumentation, and upgraded emergency operating procedures (EOPs)

Licensees are expected to complete Element I during the DCRD phase, Elements 2 through 4 during the DCRDR's review phase, and Ele through 8 during the DCRDR's assessment and implementation .

phase Comple-tion of Element 9 is expected to cut across the planning, review , and assessment and implementation phases.

A Summary Report is to be submitted at the end of the DCRDR.

it shall: As a minimum 1.

, Outline proposed control room changes 2.

Outline proposed schedules for implementation 3.

Provide summary justification for HEDs with safety significance to be left uncorrected or partially corrected The NRC staff evaluates the organization, process and results of the DCR .

The NRC staff evaluation is documented in a Safety Evaluation Report published within two months after receipt of the Summary Report . The Summary Report for the Fort Calhoun DCRDR is scheduled to be submitted NRC staff review by April 1,1985.

The audit team conce,ntrated its review on the organization, process ,and results of the Fort Cal'houn DCRDR. In-progress audit findings, in terms of the DCRDR below, elements identified in Supplement 1 to NUREG-0737, are provid i

Establishment of a qualified multidisciplinary review team. The organiza-tion for conduct of a successful DCRDR can vary widely, but is expected to conform to some general criteria.

be provided by a utility employee. Overall administrative leadership should cient authority to carry out its mission.The DCRDR team should be given suf A core group of specialists in the fleids of human factors engineering, plant operations, instrument and control engineering, and nuclear engineering are expected to participate with assistance as required from otiai disciplines. Staffing for each 3

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technical task should bring appropriate expertise to bear.

Human factors expertise should be included in the staffing for most, if not all, technical tasks.

Finally, the DCRDR team should receive an orientation which contri-butes to the success of the DCRDR.

Section 18.1, Appendix A, of NUREG-0800 (Reference more detail. 6) describes criteria for the multidisciplinary review team The OPPD organization for the DCRDR is two-layered with a five member management team, and a. core working group consisting of five primary me bers. -

The management team consists of three OPPD staff, and two cons from the General Physics Corporation (GPC).

The core working group is chaired by a member of the management te serves, as the DCRDR project manager.

The assumption of the management responsibility of the DCRDR by 0 PPD staff is consistent with NRC guideline .

The core working group consists of four OPPD staff members, with acce other technical specialists as required, and a GPC project manager wit other GPC technical specialists available as needed.

Examination of the resumes of the review team member thee. disciplines described in Section 18.1, Appendix A. NUREG-08DD was a abl -

In addition, OPPD indicated that supplemental expertise was available in the operations and technical fields as required.

Audit results-indicated that a number of disciplines have been brought to bear on each DCRDR activity.

each Participating disciplines generally meet the NRC guidelines for activity. ,

0 PPD described the orientation and training as having been based on p experience gained from normal job assignments and some extra study in the area of the review.

In general, it appears that the reautrement for the establishment of a multidisciplinary review team is being satisfied. However, there is concern that during the initial assessment of HED's and selection of design improvements, human factors specialists were not present.

Rather results of those activities were sent to GPC for review and In addition comment. to the identification of discrepancies in the control room, a legitimate role of the human factors spec'talist is the assessment of HEDs and 'the selection 4

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' and verification of design improvements.

human factors specialists should In the audit team's judgment, be more directly involved in the assessment, selection, and verification activities which are part of the Fort Calhoun DCRDR.

OPPD appears to have recognized this need, and the audit team understands that human factors specialists will particip directly design in future HED assessment as well as selection and verificati improvements. l In addition to the direct participation of human i factors specialists, the audit team recommends participation by the fu DCRDR team, gs well as operators currently on-shift, in the verification' of design improvements. n selectio-Full participation is expected to improve the. effectiveness of the control room interface with opera well as the operators' acceptance of that interface.

A Function and task analyses to identify control room tasks and informa tion and control requirements durino emergency operations.

The purpose of the function aryd task analyses is to identify the control room asks operators during emergency operations and, to determine the information and requirements necessary for the operators to perform thoseAn .

tasks accept-able process for conducting the function and task analyses is:

1.

Analyze the functions performed by systems in responding to tran- ,

sients and accidents in order to identify and describe those tasks operators are expected to perform.

2.

For each task identified in Item 1 above, determine the information (e.g., parameter, value, status) which signals the need to perform the task, the control capabilities needed to ,

perform the task, and the feedback information needed to monitor task performance.

this stage. Displays and controls are not identified at Operator tasks have' been identified and described (in Item 1), and the information and control requirements necessary to perform those tasks are being determined (in Item 2).

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Analyze the information and control requirements identified in Item 2 above to determine those characterics essential to adequate task performance.

dynamic range,Information characteristics include parameter type, setpoints, resolution / accuracy, speed of response, "

units, and the need for trending, alarming, etc.

Control charac- 4 4

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teristics include type (discret$ cr continuous), rate, gain, response requirements, loclling functions, and feedback information associated with control use.

The c'escribed process is prescriptive. It should identify, in detail, what

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operators need to do in order to control the systems which mitigate the'

'Li consequences of transients and accidents.

In addition to its use in the DCRD2, it should be the basis for complete and technically adequate E0Ps.

Idejltification of tasks and necessary information and control capabilities should be based on engineering analyses and be independent of displays and icontrols currently in the control room.

' . Upgraded E0P's for F[rt Calhdun have yet to be developed. The following sched,ule for* development and, implementation of upgraded E0P's was provided '

to the audit team by OPPD:

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1 March 1985 Subnitt Procedures Generation Package (PGP) 7 June 1985 hew E0P's Written 5 August 1985 Commence E0P Training ,

11 October 1985 Upgraded 20P's Implemented j

Since upgraded E0P's were not svallab'e, D r.D u s e d the Combustion

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Enginee.-ing-Emergency Procedures Guidelines (CE ~PGs), number CEN-152, revised 2 ~May 1984, to perform the $'unctiun and task at:alyses. A 7 September .

1984 NRC memorandum ('R'eterence 7) sum:ni.. i;:ing the Pesnits of a 29 August

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1984 meeting between the NRC staff ana the CoeuWor. Enginecring Operations Group subcommittee states': '

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" ...The EPGS (Emergency croceduN Guidelinas) 10 n'ot explicitly identify the information ant

• c.cntrol needs beyond the . safety func-tion' level which are neces.try for prepaing emergency. operating ,

procedures (EOPs) and determitng the cdeqtncy of. existing instru-mentation and centrols, s

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-x Because these information and control needs are not included in the y -

EPGS, further analysis and documentation is re' quired... ."

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OPPD utilized the CE EPGs to establish a base line of emergency ures proced to derive information and control requirements for the Fort rol room. Calhoun cont The EPGs include both Optimal Recovery Guidelines (Volume 1

. for use if the specific accident has already been diagnosed), and Functional Recovery Guidelines (Volume II, for use if a positive diagnoses has not been completed, but a challenge to a critical safety function isAlloccurring) .

possible success paths were considered (approximately 20 r-restoration "Em Section 4.0, " Reactor Trip Recovery Guidelines" in avoid duplication of the task analysis effort. es to The OPPD task analysis for Fort Calhoun used, as a starting , the point operator _ tasks identified by the EPGs.

Since the CE EPGs are not explicit beyond the safety function level, the task analysis worksheet all of with 3 the was EPG sub-tasks " prefilled."required to support the safety function e step of the (" lev l")

$ to seeing the control room.That is plant specific subtasks were identified prior operatic's engineer using existing plant:The source of identifying all sub-tasks e Operating procedures e Operating instructions e

Emergency operating procedures Once all possible sub-tasks wera filled in, operations-oriented subject matter experts filled in the necessary information and control capabilit' Instrument and cont.rol characteristics associated with the nec information and control' capabilities were also identified These pre-fill sary .

activities or mock-up. were performed without reference to the Fort Calhoun control room

- A Walkthrough of the control room mock-up with a full complement rol of cont room operators was conducted.- Each functional recovery success path was wa.lked through, using the tasi analysis worksh eet described above. A human factors spect.alist ary a n6citur eng'ineer stepped the operators

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each through task in deta11, prompting th'e operator for detailed explanation descriptions. s and The!walkth' roughs were videotapad with the human factors I C 3.

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specialist and operators wired for sound so that the characteristics of each instrument and control used to perform a task was recorded. Multiple failures-were postulated to ensure all possible situations were recorded.

GPC personnel with operations and human factors experience are to have completed the first analysis of the videotapes by approrimately 15 February 1985. They will fill in the "B" side of the task analysis worksheet, answering questions about the availability and suitability of required t instruments and controls identified by the pre-filled portion. Instruments and controls found to be not available or not suitable will be address'e comments HEOs. entered on Side B of the worksheet. Those comments will result in The audit team understands that excess instruments and controls (found in the control room, but not " required" by Side "A" of the task analysis worksheet) will be identified for OPPD action as appropriate.

A second tape analysis will have been conducted by a human factors specialist by 1 March 1985, with the objective of preparing link analysis diagrams for each emergency operation. The analysis will consider control room layout and its relation to crew performance of sequential tasks. HEDs 1

will be written, as appropriate.

It was noted by the audit team that crew workload could not be established with the above method since the walkthrough was not in realtime.

As noted, the current task analysis effort was based on CE EPGs. The audit team understands that upon completion of the upgraded E0Ps, another formal .

task analysis, equivalent to that already accomplished, will be conducted by 0 PPD.

Instruments and controls necessary to accomplish upgraded E0Ps, but found to be unavailable or unsuitable, will be identified and , dealt with in the same manner as other HEDs.

( In the audit team's judgment OPPDs organization and process for conducting

.the task analysis will, if implemented as described, s a ti s fy the requirement.

However, results of the comparison of task analysis findings with a control room inventory were not available for audit. In the audit team's judgment, satisfaction of the requirement hinges upon completion of B

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the comparison process and completion of the additionalnalysis task a conducted against upgraded E0Ps.

i probability that the control room supports the upgraderi E0Ps i The audit validating team noted the upgraded E0Ps. that OPPD intends to do real-time nwalkthro i We recommend that those walkthroughs be used i to identify any workload problems that might exist in performing E0Ps.

i A Comparison of display and control i

.t o ry. requirements with a contr,o1 room inven-

, The purpose of comparing display and control requirements with a i

control room inventory is to determine the availability and suitability

! displays and controls required for performance of the E0P's .

Success of this element depends heavily on the quality of the functionask* and t analysgs and the control room inventory.

Display and control requirements should be derived from analyses which are sufficiently detailed to development of complete and technically adequate E0P's.

7 Characteristics I

appropriate to the task shoul,d be described for each display and control need identified by the function and task analyses.

The control room inven-tory should be a complete representation of displays and controls in the control room. y curre The inventory should include appropriate characterts-tics of current displays and controls in order to allow meani ngful compari-

! son with the results of the function and task analyses.

Unavailable or unsuitable displays and controls should be documented as HEDs.

A full-scale photographic mock-up of the Fort Calhoun control room was constructed and is being used extensively throughout the DCRDR. OPPD is using the sock-up as'the control room inventory. ~

l The audit team found the fidelity of the mock-up to be sufficient to permit an adequate comparison characteristics necessary ofanalysis.

from the task available instruments and controls with thos

[ However, the mock-up was constructed in

! October 1983, and .0 PPD is aware of approximately six changes to the con room that were completed after the construction of the mock-up. In the audit team's judgment, differences between the mock-up and control room should be considered by the DCRDR team in determining the availability a suitability of instruments and controls.

Based on discussions with OPPD duris.g the in-progress audit, the audit team understands that OPPD intends to consider modifications to'the control room during the comparison of task ,

analysis results with the control room inventory.

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A control room principles. survey to identify deviations from accepted human fact The key to a successful control room survey is a systematic comparison of the control room against accepted human engineering guid lines. ~

One accepted set of human engineering guidelines is provided b Section 6 of NUREG-0700.

Discrepancies between the control room and accepted human engineering guidelines should be documented as HEDs.

At the time of the in-progress audit, OPPD indicated the control room was complete with the exceptions of annunciators, computers /SPDS , and labeling / demarcation / color coding. The core working group compare control room mock-up, actual control room, and remote shutdown panels against NUREG-0700 guidelines.

Evalua' tion against NUREG-0700 Sections 6.1 througn 6.3 was on a c room-wide basis.

panel-by-panel basis. Evaluation against sections 6.4 through 6.9 was on a HEDs were recorded.

During the survey, both item s,pecific and generic HEDs resulting from the survey, as well as from other DCRDR elements, are being placed into a dBASE III data management .

This programmable system has multi-sort and storage functions to facilitat assessment and evaluation.

The methodology adequate. for conducting the control room survey appeared to be However, several instances where the survey was incomplete were identified during the in-progress audit.

OPPD. This concern was discussed with NUREG-0700 guideline areas against which the survey appeared to be incomplete are listed in Attachment C.

The areas listed in Appendix C were ~

confirmed in discussion with the GPC project manager.

An additional concern of the audit team was the generic HEDs that were recorded withort an accompanying equipment list, e.g., HEDs 152 and 122. This practice does not promote easy identification of all instances of the HED and may not allow for detailed assessment of HEDs and improvements. selection and verification of design Due to the magnitude of the problem and implications for schedule interfer -

ence, the annunciators, labelinggons,iderations, and computer terminals were excluded from the survey.

These areas *are to be addressed by separate studies which will not be completed prior to April 1,1985 when OPPD is scheduled to submit its Summary Report.

The methodology for the annunciator 10 4

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s study has not been finalized at this time.

OPPD anticipates using a consultant to perform a survey of the system possibly using NUREG/CR-

"Near Term improvements for Nuclear Power Plant ControlonRoom An Systems," (Reference 8), to determine how the annunciator system ca upgraded.

The audit team recommends that guidelines in NUREG-07DD be also considered in the annunciator study.

the sof tware, The SPDS/ computer study will examine installed hardware, and location aspects of the SPDS/ computer alre (but not declared operational) in the control room. It is planned develop HEDs that the for the criteria in NUREG-0835 (Reference 9) will be used SPDS.

involve an extensive effort te determine control room needs .

In the until theaudit team's judgment, the Fort Calhoun DCRDR will not be co separate studies (annunciators, SPDS, labels) are complete. A report of the study results which provides the same type of information required in the Summary Report would be useful in close-out of this ele Assessment ed.

HEDs should beof HEDs assessed for to determine which are sionificant a significance.

The potential for operator error and the consequence of that error in terms of plant safety should be systematically considered in the assessment of HEDs.

In addition, both the individual and aggregate effects of HEDs should be considered.

The result of the assessment process should be a determination of which HEDs sho corrected and how quickly based on their potential impact on plant safety Decisions about whether or not HEDs are significant in terms of potenti impact on plant safety should not be compromised by consideration of suc issues as the means and potential cost of correcting those HEDs .

OPPD provided a detailed description of the HED assessment process fo Fort Calhoun Nuclear Station DCRDR. The process assigns two numb HED.

The first number is a criticality rating that considers documented potential for error and safety status evaluations.

Several questions, of the type recommended in Exhibit 2-2, Appendix A SRP Section 181

. , are answered in assigning the criticality index.

The second number is an OPPD priority several rating and deals with the necessity for correction. Once again, questions must be answered (similar to the Exhibit 2-2 considerations) to establish the priority.

The means and cost of correcting 11 .

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an HED were not considered in the assessment process. The process for assignment with NRC guidelines.of criticality and priority ratings appeared to be consistent At the time of the audit, recommendations for improvements assessment of HEDs and formulation of had just started.

Only HEDs resulting from the control room survey had undergone a preliminary assessment.

The audit team reviewed the product of that preliminary HED assessment team's review indicated:

The audit 1.

That the methodology for assignment of the criticality rating was not always followed.

For example, numerous ,HEDs related to

,s labeling on safety related panels / equipment were assigned

• ' criticality related."' IV which means " low potential for error, non-safety 2.

Numerous HEDs were written with inadequate detail.

.. Much investi-gation was required on the part of the review team to clarify the meaning of the HED as written.

In many cases, the core working group had to assume that the deficiency covered " instrument XYZ."

To date no attempt has been made to record this supplementary investigation or assumptions to provide an auditable record.

3.

Human factors specialists were not at the core working group meetings in which preliminary assessments were made. Rather GPC personnel reviewed and commented on OPPD's preliminary assessments at a later ti.me. .

Although the assessment process described by OPPD appeared to be consist with NRC guidelines, that process was not always followed. In order to l

satisfy the requirement, the core working group should adhere to the ~

assessment methodology presented by OPPD.

The audit team recommends that

! clarifying information, obtained during core working group deliberations, be recorded on HED sheets so an auditable record can show exactly what the problem was that produced the HED and why it should be resolved. Inclusion of clarifying information should enhance the assessment of HEDs, as well as selection and verification of design improvements. NRC guidelines recommend 12

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participation of human factor specialists in all DCRDR tasks.

In the audit team's judgment, the Fort Calhoun DCRDR would be enhanced by more d participation of human factors specialists in the assessment of HEDs and th selection and verification of design improvements.

This possibility was discussed with OPPD, and the audit team understands that an effort to increase human factors participat';on will be made.

Selection of design improvements.

The purpose of selecting design improvements is, as a minimum, to correct safety significant HEDs.

Selection of design improvements should include a systematic process f development and comparison of alternative means of resolving . Both HEDs enhancement and design modification may be considered.

At the time of the audit, OPPD had begun the process of selecting des improvemenn.

The process involved OPPD members of the core working group formulating preliminary recommendations for correction on an HED-by-HE basis.

There was no procedure for the integration of the solutions on a control room wide basis.

OPPD recommendations at a later dateHuman factors specialists from G and provided comments. Individual design improvements are to be processed through the standard OPPD administrative channels for design changes.

The preliminary recommendations for resolving HEDs and GPC comments on those recommendations are to be reviewed being made. by OPPD core working group members prior to final recommendation As previously noted, in the audit team's judgment satisfaction of this requirement would be enhanced by more direct participation of a human factors special,ist.

The audit team reviewed the preliminary recommendations for HED correctio and noted that the recorded details concerning some of those recommendations are inadequate.

This was particularly evident where the recommendation was to not fix the condition. No rationale for not fixing the HED was included with the recommendation.

Supplement 1 to -NUREG-0737 requires summary justification for HEDs with safety significance which will be left uncorrected or partially corrected.

The basis for determining an HED is not a

safety significant should be documented as part of the assessment process, 13

In the audit team's judgment OPPD does not currently ha've a process which completely satisfies this requirement. The HED-by-HED approach for selecting design improvements is a reasonable first step. However, an

' effort to assure that a consistent approach to HED correction will be applied control room wide needs to be made. Such an effort typically leads to plant conventions (e.g., labeling conventions, standard abbreviations).

Those conventions can then be subjected to the verification process to assure that they correct HEDs and do not introduce new HEDs. Careful application of plant conventions can, in itself, reduce the probability that new HEDs are introduced. Human factors specialists should be involved in the process.

Verification that selected improvements will provide the necessary correc-tion and verification that improvements will not introduce new HEDs. A key criterion of DCRDR success is a consistent, coherent, and effective inter-

! face between the operator and the control room. One good way to meet that criterion is through iteration of the processes of selection of design improvements, verification that selected design improvements will provide

' the necessary correction, and verification that improvements will not intro-duce new HEDs. Techniques for the verification process might include partial re-surveys on mocked-up panels, applied experiments, engineering analyses, environmental surveys, and operator interviews. Each iteration of the selection and verification processes should reduce inconsistencies in the operator-control room system thereby increasing the coherence and effectiveness of that interface. Since the consistency, coherence, and effectiveness of the, entire operator - control room interface is important ,

to operator performanck, evaluation of both the changed and unchanged por-tions of the control room is necessary during the verification processes.

The NRC staff's Program Plan comments noted that OPPD had no established methodology for accomplishing the verification that selected improvements provide correction and the verification that improvements will no introduce new HEDs. At the time of the audit, there was still not detailed methodology apparent to accomplish these requirements. There was some indication that labels, color codes, and demarcation would be applied to the mock-up prior to implementation in the control room. The audit team understood that, if that activity took place, it would be done after the April ),1985 submission of the Summary Report. The audit team further 14

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understood that verification activities might be reglegated to a " Human Factors Maintenance Program" which is being considered but has not yet been approved by OPPD management. If approved that plan would take effect after the April 1, 1985. In the audit team's judgment, OPPD has developed neither an acceptable method or schedule for satisfying the verification requirements.

An SER based on a Summary Report submitted prior to completion of the verification activities will have to leave these requirements as an open item.

Iteration of selection and verification of design improvements would increase the probability that DCRDR requirements would be satisfied and improva the results of the DCRDR. A very serviceable mock-up of the Fort Calhoun control room has been developed for use in the, DCRDR. The audit team recommends that as many HED corrections as possible be tried out on the sock-up prior to installation.in the control room. The modified mock-up could then be reviewed by personnel from all appropriate disciplines (including human factors specialists and on-shi f t operators). The recommended technique would be valuable because an approach that does not consider integration of control room modifications can itself produce new HEDs.

HEDs identified by a review of the modified mock-up should lead to iteration of the selection and verification of design improvement processes.

The result would be an increased probability that operator's would have a consistent, coherent, and effective interface with the control room. Use of on-shift operators should provide valuable insights about their control room interface, and should a1so improve operator acceptance of that interface. ~

Coordination of er., trol room improvements with changes from other programs such as the safety parameter display system (SPDS), operator training, Reg.,

Guide 1.97 instrumentation, and upgraded emergency operating procedures (EOP's).

OPPD provided the audit team with an Outline of their approach for the integration of all NUREG-0737 programs. The methodology for implement-ing this approach was also presented.

The following observations were made by the audit team concerning the ade -

qJacy of the OPPD integration effort:

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The audit upgraded E0Ps.team understood that a task analysis is eplanned That task analysis should work to assure that the

, control room supports the instrument and control requirements

i. complete and technically adequate E0Ps.

2.

The audit team understood that the training planned for implementing the new E0Ps will also address modifications o the t

control on the upgraded roomE0Ps. resulting from the DCRDR and from the task an i The audit team also understood that HEDs resolved by " additional training" will be tracked and verified to ,

,be suitable corrections to the problems.

3.

i The audit team understood that the SPDS is being subjected separate audit teamhuman engineering review as part of its design. The further understood that the SPDS impact on the operators will be evaluated from a human factors perspective during verification and validation of the upgraded E0Ps .

4.

The audit team understood that proposed modifications and additions to the control room resulting from Reg. Guide 1.97 wou be subjected to human factors review prior to installation .

If OPPD follows t'hrough with the plans as presented to the , it audit team appears that this element of the DCRDR will be satisfied.

Other.

Although not a requirement of Supplemert I to NUREG-0737 , the review of operating experience is valuable and has been accomplished ,

Calhoun. This effort consisted of two parts; one part considered all

" operations incident reports" (an internal report that may cause o an LE be generated), and combustion engineering LER's.

A total of nine LER's were identified (twc plant specific) that may result in HEDs beingTheprepared .

second portion of the effort consisted of preparation of an operator que tionnaire containing questions of the type suggested by NUREG-0700 , distri-bution of the questionnaire for review by plant operations personnel , and then the conduct of an interview in the control room mock-up by contracto personnel to ensure anonymity of the plant personnel.

Approximately 250 potential HEDs have been prepared from the interviews that had not been evaluated at the time of the audit. It was noted by the audit team that a 16 1

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significant contribution to the DCRDR effort may be achieved if the review team, including human factors specialists performs a critical review of the

, interview comments.

On several occasions, OPPD discussed the possibility of an ongoing program of human factors engineering applied to the future modifications and additions to the plant. As proposed, the program includes plans for the use of the checklist that was generated by GPC. The audit team recommends that the program also include documentation of control room conventions or standards resulting from the resolution of HEDs in its data base. The maintenance and application of such a data base would be a positive extension of the DCRDR and would help OPPD protect its investment in an improved operator interface ~ with the control room.

CONCLUSION The DCRDR for Fort Calhoun is underway. The Program Plan has been reviewed and NRC staff comments provided. An in-progress audit was conducted February 4-8, 1985. Based on information available through the end of the in-progress audit, the following concerns exist about the organization, process, and results of the Fort Calhoun DCRDR:

1. Human factors specialists are not as directly involved in assessment of HEDs and in the selection and verification design improvements as they could be. Performance of those activities may suffer.as a result. -

2. The task analysis effort associated with upgraded E0P's is scheduled for completion after submissic a of the Summary Report.

As this effort will work to assure that the control room supports complete and technically adequate E0Ps it is considered part of the coordination element of the DCRDR. The SER following the Summary Report is expected to leave this as an open item.

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3.

Several additions and modifications to the control room are not reflected in the control room mock-up. As the mock-up serves as the Fort Calhoun control' room inventory, additions and modifications should be taken into account in the comparison of the control room inventory with task analysis results.

4 Audit of the control room survey indicated that it was incomplete.

5. Several activities which the NRC considers part of the DCRDR have been relegated to separate studies which will not be complete by the April 1,1985 submission of the Summary Report.

~'

6. Although the organization and process for assessment was

,. acceptable, the process was not always followed.

7. Selection of design improvements was on an HED-by-HED basis

, without consideration, of integrated effects.

8. No methodology for verification that HEDs are corrected and new HEDs are not introduced was apparent.

In the audit team's judgement, resolution of the above concerns would increase the likelihood that requirements for the DCRDR will be met and increase the benefits of the DCRDR.

Several recommendations also resulted from the in-progress audit of the Fort

~

Calhoun DCRDR. The r'ecommendations ~are not intended as additional require-ments. They are intended to encourage the fullest possible berefit from the DCRDR.

They do not appear to require major changes to the current organiza-tion and process of the DCRDR. Those recommendations are:

1.

Direct perticipation of all appropriate disciplines, including -

human factors specialists and on-shift operators, in the selection and verification of design improvements.

2.

Record clarifying information concerning HED's and equipment lists for generic HEDs in the computer data base. ,

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3.

Consider study. guidelines in NUREG-0700 in conduct of the annunciato 4

Provide increased detail of HED resolution recomm data base.

5.

Use the m:ck-up as an aid for integrating and ve.-: fying OPPD's selected design improvements.

i 6.

Establish the planned Human Factors Maintenance Program.

7.

_ Develop plant conventions and standards during the process of HED resolution and provide those conventions and standards to the Human Factors Maintenance Program.

Those conventions and standards would provide a basis for integrating future additions and modifications into the control room.

8.

Provide items. a supplementil Summary Report to aid in close-out of op l

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a

. REFERENCES 1.

Letter from W.C. Jones, Omaha Public Power District to J R NRC, dated October 25, 1983, . . Miller, Program Plan for Fort Calhoun Station. submitting Detailed Control R 2.

" Program October Plan for the Fort Calhoun 14, 1983 Control Room Design Revie Attachment to Reference 1.

3.

" Review of the Fort Calhoun Station Detailed Control v ew Room Des Program Plan," U.S. Nuclear Regulatory Commission. December 30

, 1983 -

4 WUREG-0737 Supplement 1. " Clarification of TMI Action Plan R ments " U.S. Nuclear Regulatory Commission, December 1982.

5.

NUREG-0700, " Guidelines for Control Room Design. .Reviews Nuclear "US Regulatory Commission, Apr'il,1983.

6.

NUREG-0800 (Standard Review Plan), Revision 0, Section 181 dix A to Section 18.1, September 1984. -

7.

" Task Analysis Requirements of Supplement I to NUREG-0737 , August 29, 1984 Meeting with Combustion Engineering Group (CEOG) Operat -

committee," U.S. Nuclear Regulatory Commission, Washington, Transmitted September 7,1984. D.C.,

8. .

NUREG/CR-3217. "Near Term Improvements for Nuclear Power Pla Room Annucistor System,s," U.S. Nuclear Regulatory Commission 1983. , April, 9.

NUREG-0835 (draft), " Human Factors Acceptance Criteria y for the S Parameter Display System," USNRC, Washington, D.C., October 1981 .

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2 10.

" Fort Calhoun Nuclear Power Station DCRDR In-Progress COMEX Corporation. February 11, 1985 ort "

Au f

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)

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i Fort Calhoun TAC Number 51161 SAIC 1-263-07-557-23 21 9

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NRC-03-82-096 ATTAChP.FNT A FORT CALHOUN IN-PROGRESS AUDIT AGENDA Tuesday, February 5 AM e NRC Entry Briefing a Presentation on DCRDR Status e Presentation on DCRDR Mult1 disciplinary Review Team o

Presentation on Coordination of DCRDR with Changes from Other Programs PM e Visit to Control Room Mock-up e Presentation of Computerized Data Base System o Audit of Control Room Survey Documentation e Audit of System Function and Task Analysis Documentation e NRC Caucus e Daily Mini-Exit / Technical Meeting Wednesday, February 6 AM e Comp 1.etion of System Function and Task Analysis .

Documen'tation Audit e Audit of Control Room Survey Documentation e NRC Caucus e Daily Mini-Exit / Technical Meeting e Discuss: Annuciator Study and SPDS/ Computer Study PM e Visit Fort Calhoun Station Control Room and Alternate Shutdown Location e Brief Technical Meeting g ,

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c Thursday, February 7 AM e Audit of HED Assessment Process Documentation e Audit of Process for Selection of Design Improvement and Continuing Role of Review Team o Discuss ~ Label and Demarcation Study PM e Audit of Control Room Survey e

Review of DER Documentation and Recommendations e NRC Caucus s Mini-Exit /, Technical Meeting Friday, February B e

Review of Contro1 Survey Audit With a Representative for OPPD e Discuss: Selection of Design Improvements Coordina-tion of DCRDR Control Room Improvement Programs Such as Regulatory Guide 1.97 e NRC Caucus e Exit Briefing l

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i ATTACHMENT B FT. CALHOUN IN-PROGRESS AUDIT ENTRANCE MEETING February 5, 1985 Name Organization Title Ed Tourigny NRC/ ORB #3 Dennis Serig Project Manager NRC/NRR/DHFS/HFEB M. Joe Moyer Engineering Psychologist SAIC David H. Schultz Research Psychologist COMEX Corp Operating Engineer, R.L. Andrews Consultant to NRC

' OPPD

,. Division Manager R.J. Jaworski Nuclear Production OPPD Section Manager, James J. Fisicaro Technical Services OPPD .

A*

Supervisor, Nuclear Regulatory & Industry K.J. Morris Affairs OPPD Manager Administrative T.J. McIvor Services OPPD Manager, Technical V. Guy Morris Support OPPD Supervisor. Technical J.K. Casper Support OPPD Manager, Reactor &

~

Computer Sudesh K. Gambhir OPPD Manager, GSE Electrical Bill Gartner & Nuclear OPPD Senior Electrical Engineer - GSE Donald C. Burgy General Physics Director, Human Factors Engineering Robert J. Liddle General Physics Manager. Human Factors Power Services 24 D

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FT. CALHOUN IN-PROGRESS AUDIT EXIT BRIEFING ,

February 8, 1985

_Name Organization Title Ed Tourigny NRC D.I. Serig Project Manager NRC Joe Moyer Engineering Psychologist

' SAIC D.H. Shultz Research Psychologist Comex Corp L.A. Yandell Operating Engineer NRC/ Region IV R.L. Jaworski SRI Ft. Calhoun OPPD Section Ma..ager.

James J. Fisicaro Technical Services OPPD Supervisor, Nuclear Regula-K.J. Morris tor & Industry Affairs OPPD Manager, Administrative W. Gary Gates Services OPPD-J.K. Casper Manager Ft. Calhoun OPPD Manager, Reactor & Computer V. Guy Morris Technical Services OPPD Supervisor, Technical Support Sudesh K. Gambhir OPPD

+ Manager, GSE-Electrical

& Nuclear l Mark L. Gutierrez OPPD j

Robert J. Liddle Nuclear Production Engineer General Physics

! Manager Human Factors Power l

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

ATTACHMENT C On the basis of a limited audit of the OPPD tion, concerns typified by the following examples were raised:

control room y documenta-NUREG-0700 Reference NRC Concern ,

6.1.2.2 Annunciator tiles / response buttons appear to be discrep

' with 6.1.2.2e (2) but this was not identified as an HED 6.2.1.8 Communications in emergency gear not surveyed 6.1.5.4 Emergency lighting not surveyed 6.1.5.18 6.1.5.2 Temperature, Shutdown panel

• humidity and ventilation not surveyed at Rem '

6.1.5.1&

6.1.5.2 Concern about temperature humidity and ventilat' n bein .

collected over a single 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period (Feb 83) 6.1.5.3 Was glare addresst),

with neon bulbs particularly as it related to the panel 6.2.1.2b (4) & (5) Phone cords were long & laid on the floor but no HED 6.3 Annunciator survey with the DCRDR was not comprehensive d to annunciator upgrade study which is to be contracted separately. OPPD scope of the DCRDR planned for this to be outside of the 6.4.1.id Did not evaluate compatability with emergency gear

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NUREG-0700

_Re ference NRC Concern 6.5.lf Was control room surveyed for compliance with "displa3 failure" 6.5.2.4b(1)

Condensor A & B absolute pressure meters appear to be discrepant but were not documented as HED

' 6.5.1.5c Condensor graduations of 2.5A & BHG inches vacuum ABS meters have unmarked in

6. 5. 3'. 2 HED is compounded by glare from identified overhead lights not 6.6.3.8 GEMAC controllers-Direction of motion (inersase/ de not identified for continuous motion rotar/ controls 6.6.1.1 HED written spread against panel AI-30 appears to be more wide 6.6.3.3 6.6.3.6 Were all abbreviations reviewed for standardization, avoidance of similarity etc.?

6.6.3.8 Controls under H position labels 2 sampling valves don't appear to have -

6.6.2.9 Some labels (position labels) are obscured by control handles

- no HED identified 6.6.4 Only one HED identified on label lettering, white on black labels 0

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NUREG-0700 e

. Reference NRC Concern 6.5.1.6 6.6.6.3 Question of color use in control room doesn't appear to have been surve,*ed - there appears to be at least several color conventions - were they reviewed for consistency etc?

6.7 No survey of computer - The PRODAC 250 is being phased out and SPDS is on the way in 6.8.2.3 HED against arrangement of switches within annunciator response' group but not against location of group as a whole e

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