ML20116B102
| ML20116B102 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/20/1985 |
| From: | Johari Moore LAWRENCE LIVERMORE NATIONAL LABORATORY |
| To: | |
| Shared Package | |
| ML20116B105 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 ', NUDOCS 8504240710 | |
| Download: ML20116B102 (15) | |
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COMMENTS ON THE .
DETAILED CONTROL ROOM DESIGN REVIEW PROGRAM PLAN FOR .
MISSISSIPPI POWER AND LIGHT COMPANY GRAND GULF NUCLEAR STATION-UNIT 1 James W. Moore Lawrence Livermore National Laboratory March 20, 1995 O
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, 1. INTRODUCTION l
l Lawrence Livermore National Laboratory (LLNL) has evaluated the program plan subnitted by Mississippi Power & Light Company (MP&L) for conduct of a detailed centrol design review (DCRDR) at Grand Gulf Nuclear Station-Unit 1 l (GGNS-1).
The purpose of the evaluation wast l
1 To determine the planned program would result in a successful DCRDR.
- 2. To determine whether an in progress audit is necessary.
l 3 To provide an audit agenda when necessary.
4 To provide constructive feedback to Mississippi Power and Light Company, t
l Evaluation was against the requirements of Supplement I to NUREG-0737.
l Additional guidance was provided by NUREG-0700 and Appendix A to Section 18.1
( of NUREG-0800, Standard Review Plan (SRP). This report provides the results -
of this evaluation.
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- 2. DISCUSSION 2.1 DCRDR Review Team Supplement 1 to NUREG-0737 requires the establishment of a multidisciplinary review team to conduct a DCRDR. Guidelines for review team selection are
! found in NUREG-0700 and the criteria for evaluating DCRDRs are contained in '
Appendix A to SRP Section 18.1 of NUREG-0800.
Mississippi Power & Light Company plans to establish a multidisciplinary review team consisting of a core group of specialists and a small number of supporting team members. General Physics Corporation is the Human Factors Consultant to MP4L for the Grand Gulf Nuclear Station Unit 1 DCRDR.
MP&L states in their program plan that all levels of their management recongnize the importance of the DCRDR and will provide all necessary support to the DCRDR team leader to complete a multidisciplined Control Room review.
The following is a list of team members for the DCRDR review tecm.
o The MP&L DCRDR Team Leadef is responsible for planning, scheduling, coordinating, and intergrating all DCRDR activities.
o The MP&L DCRDR Team Member for Operations, Engineering, and Licensing will provide operations, engineering, licensing input to the DCRDR Team, and is responsible for DCRDR liaison with MP&L's licensing organization.
o The MP&L DCRDR Member for Engineering will provide engineering input to the DCRDR, and is responsible for DCRDR liaison with Nuclear Plant Engineering (NPE) -
Systems o The DCRDR Team Member for Human Engineering is the Project ManaEer for General Physics Corperation. He will provide human factoas engineering input te the DORDR team and is respor.sible for DCRDR liaison with other supporting Human Factor
. Co r.s ul t a r.t s .
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t Three other areas are listed as DCRDR Team Support. They are the fellowing:
- 5 Human Factors Support to be provided by General Physics Corporation.
Administrative and Technical Background Support for the DCRDR will be provided by an MP&L engineer.
Tecnnical Support by MP&L engineers will provide technical and DCRDR
. liasion with Nuclear Plant Engineering-Mechanical-I&C, under the direction of the DCRDR Team Leader. Additional technical support will be available on site from the Architect Engineer and/or the NSSS supplier. .
The description of the qualifications for review team core members was complete. If the review team is allocated tasks appropriately we conclude the review team is capable of conducting an effective review.
We do have some concern about the level of involvement of the Human Factors Consultants in all phases of the DCRDR. MP&L states that Human Factors Consultants will participate in the review when appropriate. The planned level of committment or involvement of human factors specialists is not clear from this statement. We recommend that further clarification be provided on specific involvement of the review team core members, including the human factors specialists, in the DCRDR.
2.2 Function and Task Analysis Supplement 1 to NUREG-0737 requires the licensee / applicant to perform systems function and task analyses (SFTA) to identify control room operator information and control needs during emergency operations. Supplement 1 to NUREG-0737 recommends the use of function and task analyses that have been used as the basis for developing emergency operating proceduaes technical goldelines and plant-specific emergency operating procedures to define these needs.
MP&L intends to use a top down approach to perform their SFTA. The Emergency
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Procedures Guidelines (EPGs) developed by the BWR Owners Grcup (BWORG), the Plant Specific Technical Guidelines (PSTGs), and Emergency Operating Procedures will be used as the base documents for the SFTA.
The steps for top-down systems function and task analysis identified in the NUREG-0700 guidelines are:
- 1. Identification of systems and subsystems
- 2. Identification of operating events for analysis 3 Function identification
- 4. Operator task identification and analysis Operator information and control needs should be determined independently from existing control room design. The analy' sis should include the appropriate functions of plant safety-related systems and the emergency operating procedures (EOPs) that must be used to ensure that the plant can be efficiently and reliably operated by available personnel during emergency conditions.
The GCNS-1 Program Plan is quite specific in detailing that the display and control needs identified during task analysis are based on independent sources of data other than actual instruments and controls present in the control room.
The methodology for conducting an SFTA as explained in the GGNS-1 Program Plan appears to be sound and comprehensive. If MP&L conducts the SFTA as outlined in the Program Plan it shculd meet the intent of the requirements of Supplement 1 tc.NUREG-0737.
We do, however, have some concern about the manner in which the various documents for the SFTA will be completed. Due to the numerous forms which are used in the SFTA process, it is essential that all forms be completed in an accurate and comprehensive manner. Failure to do this will simply result in a degradation of the validity of the SFTA results. There forms will be used as the input media for the DCRDR database management system (DBMS). The DBMS is an intergal part of the DCRDR in providing an auditable trail for all information that is recorded and gathered during the SFTA. We recommend further explanation of the documentation process and the features of the DBMS that will provide tracking and auditability of data entered into the DBMS.
2.3 Comparison of Display and Control Requirements With Control Roor Inventory Supplement 1 to NUREG-0737 requires the licensee / applicant to make a control room inventory and compare the information and control requirements determined from task analyses with the control room inventory to determine the ,
suitability of exisiting controls and displays and identify those that are missing.
The GGNS-1 Program Plan states a control room inventory will be conducted using panel layout drawings which reflect an "as-built" configuration of the control room. The data will be recorded on a form (fig. C-3 in Appendix C of the GGNS-1 Program Plan) . Then a data summary of the control room inventory will be entered in the DBMS. .
The Program Plan discusses a two step verification process to provide a
. comparison of information and contr'ol requirements determined from the SFTA to the results of the control room inventory. During the first step of the process MP&L will verify the availability of display and controls identified in the actual control room inventory. The second part of the process will address the suitability of available displays and controls.
The methodology explained in the Program Plan should provide for an adequate control room inventory. However, we are concerned that usage of the panel layout drawings may not provide all the necessary descriptive information of instrument and control characteristics for a complete and accurate inventory and for the comparison with display and control characteristic requirements.
We recom end further clarification be provided on the usage and content of the panel layout drawings and the possible use of cther sources of information to b
describe the characteristics of instruments and controls presently in the control room.
2.4 Control Room Survey Supplement 1 to NUREG-0737 requires that a control room survey be conducted to identify deviations from accepted human factors principles. NUREG-0700 provides guidelines and criteria for conducting a control room survey. The objective of the control room survey is to identify for assessment and possible correction, the characteristics of displays, controls, equipment, panel layout, annunicators and alarms, control room layout, and control roosn ambient conditions that do not conform to good human engineering practices.
MP&L states that the control room survey will be conducted using checklists based upon NUREG-0700 (Section 6). The Program Plan indicates the survey will be conducted on a panel by panel basis on the main control room panels and the remote shutdown panels.
The Program Plan states that any deviations from the checklists will documented as HEDs. All HEDs will entered in the DBMS. The Program Plan states all HEDs from the Preliminary Design Assessment (PDA) not previously resolved will be identified as new HEDs.
The process as explained in the Program Plan appears to be, acceptable. We
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recommend further explanation concerning identification of which team members will actually perform the survey. This will allow a better understanding of the completeness and accuracy of the survey.
2.5 Assessment of Human Engineering Discrepancies Supplement 1 to NUREG-0737 requires that HEDs be assessed.to determine which HEDs are sigr.ificant and should be corrected. NUREG-0700 contains guidelines for the assessment process.
MP&L plans to assess all HEDs based upon two primary criteria :(1) whether or not the HED has resulted in a documented error or provides the potential for
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operator error, and (2) what impact the HED has on plant safety. HEDs will be grouped in four . categories which are listed below.
The categories are:
o Category I - HEDs associated with documented error that resulted in unsafe conditions or Technical Specification violations.
o Category II - HEDs associated with high potential for errors that may result in unsafe ' conditions or Technical Specifications violations.
o Category III - HEDs associated with low potential errors that
. result in unsafe conditions or Technical Specification violations.
o Category IV - HEDs not important to safety.
The Program Plan states that prior to assessment, all HEDs will be reviewed by a human factor specialist who will make intial resolution recommendations.
The methodology used for assessment of HEDs appears to be acceptable in its ability to provide a sound and comprehensive process for analyzing HEDs.
We are concerned that having HED resolution recommendations made prior to the assessment of HED significance may bias the assessment process against HEDs that are difficult or expensive to correct. We also are concerned as to how the cumulative and interactive effects of HEDs will be assessed. We recommend that further explanation be provided to allow a better understanding of the entire assessment process.
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2.6 Selection of Design Improvements 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.
The GGNS-1 Program Plan states that the DCRDR Team will provide recommendations to resolve each HED documented during the DCRDR. MP&L states the resolution of Category IV HEDs will be optional, and will depend on the nature and complexity of the discrepancy. The Program Plan gods on to state that for all HEDs which will not be resolved, or only partially resolved, justification will be provided.
The process for selecting design improvements as explained in the GGNS-1
. Program Plan we find to be comprehensive and acceptable. However, we feel the cumulative and interactive effects of Category IV HEDs should also be considered when selecting design improvements. MP&L should also provide an implementation schedule acceptable to the NRC.
2.7 Verification That Design Improvements Provide the Necessary Correction and Do Not Introduce New HEDs Supplement 1 to NUREG-0737 requires that the licensee / applicant verify that
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selected design improvements will provide the necessary correction and will not introduce new HEDs.
The GGNS-1 Program Plan stat'es consideration will be g'iven to the effectiveness of the improvements and to assure 'that no new deviations from human factors criteria will result from the improvement. MP&L goes on to explain that resolutions to HEDs will be compared against human factors criteria, and examined for effects on task performance, and/or reviewed by operations personnel. The Program Plan indicates the intent to perform a verification that design improvements provide the necessary correction ar.d not to introduce new HEDs. We recommend explanation of the methodology that will 9
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b'e used so we can gain a more complete understanding of the verification
- process.
2.8 Coordination of Control Room Improvements with Other Programs Supplement 1 to NUREG-0737 requires that control room improvements be coordinated with changes from other programs; e.g.. Safety Parameter Display-Systems'(SPDS), Operator Training, Regulatory Guide 1.97 (1~97) and Emergency .
Operating Procedur.es (EOPs).
The Program Plan indicates the MP&L's intent to integrate the SPDS, E0Ps, R.G.
1.97 and operator training activities with the DCRDR. The plan discusses how the SPDS will be designed to incorporate accepted human factors principles and will be consistent with other computer conventions in the control room. The l E0P upgrade program will be completed in conjunction with the validation process of the DCRDR. The GGNS-1 Program Plan discusses R.G. 1.97 and '
Operator training coordination as well.
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.These efforts to some extent fulfill the control room coordination requirement of. Supplement I to NUREG-0737. We recommend'that MP&L provide further explanation as to who is responsible for these activities, their level of -
involvement, and more detail on specifics of how activities will accomplished.
2.9 other Topies 2.9.1 Documentation and Document Control The GGNS-1 Program Plan describes a database management system (DBMS) which uses an IBM XT computer as its focal point. The Program Plan indicates all information from forms and standard documents in the DCRDR will be entered into the database. MP&L also states the DCRDR Team Leader is responsicle for all-document control.
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l The system and method for document managemer.t and control as explained in the l i
Program Plan should provide an easy access and an auditable trail for recordec ;
! information and documentation in the DCRDR process. !
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h However, we would have to see a demonstration of the actual DBMS features or have a detailed explanation of its features and capabilities to comment on it in detail. We do recommend the MP&L maintain hardcopy files of all orignal working documents throughout the DCRDR process.
2.9.2 Operating Experience Review Tne GGNS-1 Program Plan states the Operating Experience Review (OER) will consist of two steps:
- 1) Historical Documentation Review
- 2) Operator Interviews MP&L indicates that as part of the historical documentation review process Licensee Event Reports (LERs) from GGNS-1 and two other similar plants (Lasalle and Susquehanna) will be reviewed. The Program Plan states problems uncovered will be documented and reviewed for applicability. All applicable control room problems will be documented as HEDs.
The Operator Interviews will consist of confidental questionnaires distributed to operations personel and training instructors. The Human Factors Consultant (HFC) will distribute and evaluate the questionaires to ensure uninhibited responses. The HFC will assimilate *the questionnaire responses and develop an interview format. He will then conduct follow-up interviews with the operators and instructors. The HFC will the document concerns and generate HEDs as appropriate.
The methodology for the OER appears to be adequate. However, the content and subject areas of the survey questionnaires are not discussed in any detail in the Program Plan. We cannot comment on the comprehensiveness or accuracy of the OER as explained in the Program Plan.
O 3 c0NCLUSIONS Based upon our review of the MP&L GGNS-1 DCRDR Program Plan, we conclude the MP&L plans to conduct a DCRDR that generally meets the intent of Supplement 1 to NUREG-0737. Our review, however, identified several concerns which are listed below. In most instances, our concerns are that the GGNS-1 Program Plan generally describes what is planned, but does not iclude sufficient detail of how the DCRDR will be accomplished: e.g.:
o Who is involved.
o What disciplines are utilized.
o Who is responsible for which tasks. ,
The following items summarize the comments and concerns already expressed in the body of this report. Numbers in parentheses refer to the sections of this report.
A. Review Team' (2.1)
We have some concerns about level of involvement of the Human Factors Consultants in all phases of the DRDR. We recommend further clarification be provided on Human Factors involvement in the DCRDR.
B. Function and Task Analysis (2.2)
We are concerned about the large number of different documents
- used in the SFTA to record data. There is some question as to e
how accurately and comprehensively that these forms and documents will completed. We also recommend further explanatt or.
of the documentation process and the features of the DBMS th.at will provide tracking and auditability of data entered int: the DBMS, e
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Comparison of Display and Control Requirements with Control Room Inventory (2 3)
We have concerns with the usage of panel layout drawings to perform the Control Room Inventory. It is not clear to us that these drawings will provide all the necessary descriptive information of instrument and control characteristics for an accurate Control Room Inventory. We recommend further clarification as to the informational content of these drawings and the possible use of other sources of information to describe the charactendstics of instruments and controls presently in the
. control room.
D. Control Room Survey (2.4)
We recommend further explanation and identification of which DCRDR team members will perform the Control Room Survey.
E. Assessment of Human Engineering Discrepancies (2.5)
We are concerned the HED resolution recommendations made prior to the assessment of HED significance may bias the assessment process against HEDs that are difficult or expensive to -
correct.
We are also" concerned as to how the cumulative and interactive effects of HEDs will be assessed. We recommend MP&L provide clarification on this matter.
F. Selection of Design Improvements (2.6)
We feel as mentioned in previous comments that the cumulative and interactive effects of Category IV HEDs should also be considered when selecting design improvements.
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G. Verification that Design Improvements Provide the Necessary i
Correction and Do Not Introduce New HEDs (2.7)
We recommend explanation of the methodology used for the verification and validation process to enable us to gain a more complete understanding of the processes.
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Coordination of Control Room Improvements with Other Programs (2.8)
We recommend MP&L provide further explanation of who is responsible and their level of involvement for the various programs incorporated in this task. More specifics of how activities will be accomplished should also be provided.
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REFERENCES
- 1. Detailed Control Room Design Review Program Plan for Grand Gulf Nuclear Station-Unit 1 December 1984
- 2. - Supplement'1 to NUREG-0737 (Generic Letter 82-33), " Requirements for Emergency Response Capability," NRC, December 17, 1982.
3 NUREG-0700, " Guidelines for Control ROOM Design Reviews", NRC, September 1981.
4 NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants", Section 18.1, Appendix A, Revision 0, NRC, September 1984. l b
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