ML20116C453

Evaluation of Detailed Control Room Design Review Program Plan for Hb Robinson Steam Electric Plant,Unit 2

ML20116C453
Person / Time
Site:	Robinson
Issue date:	04/15/1985
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML14192A630	List: ML20116C453
References
CON-NRC-03-82-096, CON-NRC-3-82-96 NUDOCS 8504290007
Download: ML20116C453 (16)

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EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW PROGRAM PLAN FOR CAROLINA POWER AND LIGHT COMPANY'S H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 April 15, 1985 Prepared by Science Applications Internation'al Corporation Under Contract to The U.S. Nuclear Regulatory Commission Contract NRC-03-82-096 -

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TABLE OF CONTENTS l

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Section P_a age l INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 EVALUATION OF PROGRAM PLAN . . . . . . . . . . . . . . . . . . . . . 2

1. Establishment of a Qualified Multidikciplinary Review Team 2

2. Use of Function and Task Analysis ............ 4 3 Comparison of Dtsplay and Control Requirements With Control Room Inventory. ............... 5

4. Control Room Survey. ................... 7

5. As s e s sme n t o f HE Ds . . . . . . . . . . . . . . . . . . . . 8

6. Selection of Design Improvements . . . . . . . . . . . . . 9

7. Verification That Design Improvements Provide the Necessary Correction and Do Not Introduce New HEDs. . 9

8. Coordination of the Control Room Improvements With Other -

Programs. . . . . . . . . . . . . . . . . . . . . . 10

9. Other. . . . . . . . . . . . . . . . . . . . . . . . . . 11

SUMMARY

OF CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . 11 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 e

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EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW PROGRAM PLAN FOR CAROLINA POWER & LIGHT COMPANY'S H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2

. INTRODUCTION' The Nuclear Regulatory Commission (NRC) Division of Human Factors Safety and their consultants Science Applications International Corporation (SAIC), have, as a team, evaluated the Program Plan (Reference 1) submitted by Carolina Power & Light Company (CP&L) for conduct of a Detailed Control Room Design Review (DCRDR) at the H. B. Robinson Steam Electric Plant, Unit

. No.2. The disciplines of human factors engineering, instrumentation and control engineering, nuclear engineering, and reactor operations were repre- -

sented during this evaluation. All evaluation team members were familiar -

with' nuclear power plant control rooms and experienced in evaluating DCRDRs.

The purpose of the evaluation was:

1. .To determine whether the planned program would result in a successful DCRDR.

,- 2. To determine whether an in-progress audit was necessary.

3. To provide an audit agenda where appropriate.

4. To provide constructive feedback to CP&L.

'The evaluation was conducted relative to the requirements of Supplement 1 to NUREG-0737 (Reference 2). Additional guidance was provided by NUREG-1 0700 (Reference 3) and Section 18.1, Revision 0, of NUREG-0800 (Reference 4). This report provides the results of the evaluation. Comments.of the Nuclear Regulatory Commission (NRC) staff member responsible for evaluation of the (CP&L) DCRDR have been integrated into the report in order to repre-sent the consolidated observations, conclusions, and recommendations of the NRC staff and its consultants (SAIC).

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EVALUATION OF PROGRAM PLAN l

1. Establishment of a Qualified Multidisciplinary Review Team In Section 2 of the Program Plan, CP&L has provided a description of the DCRDR review team organizational structure and the responsibilities of the team members.

1 CP&L introduces a management structure for the DCRDR program at H. B. l Robinson which can be summarized as follows: The establishment of the CP&L  !

review team and the DCRDR program was initiated by the Manager - H. B.

Robinson Nuclear Project, and the General Manager. The overall responsi-bility for the review team and its on-going support, and coordination between DCRDR and other programs, lies with the Principal Engineer - Opera-tions (also designated as the Lead Discipline Engineer of the core review team) who reports to the Manager - Operations. And finally, at the end of the chain of command, the Site Operations Coordinator, who reports to the -

Lead Discipline Engineer, i s responsible for the day-to-day DCRDR -

activities.

In addition to the Lead Discipline Engineer and the Site Operations

Coordinator, the core review team is comprised of

System Integration Team Leader Lead Human Factors Specialist Operations Support Human Factors Specialists.

Responsibilities for each of the team members are described in Section 2.3.2.

Support to the core review team will be provided by the review team support members who represent disciplines such as operations, nuclear, mechanical, electrical, industrial, and human factors engineering.. These support personnel are not assigned full time to the DCRDR effort; however, their availability is assured by the CP&L upper level management.

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' Within the core review team structure, a special group called the

" Human Engineering Discrepancy Assessment Team (HEDAT)" is formed to handle the review and assessment of HEDS, to recommend HED resolutions, and to prepare a preliminary implementation schedule. Members of the HEDAT include the Lead Discipline Engineer, the Site Operations Coordinator, the System Integration Team Leader, the Lead Human Factors Specialist, and the Human Factors Manager.

Responsibilities for all HEDAT members were provided in the Program Plan except for the Human Factors Manager; in fact, there exists no information related to this HEDAT member elsewhere in the Program Plan.

This ' lack of .information prevents us from getting a full understanding of the interaction between this person and the DCRDR program.

i In general, CP&L has presented a well-defined structure for the DCRDR

-review team that should ensure the freedom of operation and support from the management of the plant. However, a number of concerns about certain -

5 aspects' of the core review team still exist.

• i The Program Plan does not contain detailed documentation of the 2

qualifications of the DCRDR team members as recommended in Subsection 2.1.2 of NUREG-0800. Also, the proposed level of effort of each review team member was not included in the Program Plan. This prevented us from being 1-able to evaluate the appropriateness of the proposed assignments and responsibilities of each of the DCRDR team members based on team member's qualifications.

However, the Program Plan did state that the licensee will provide the core team resumes in the Summary Report in order to document the proven track record of the DCRDR managers, administrators, supervisors, and technical experts.

The Program Plan did not indicate that the licensee had a formal 3

oriente. tion program for the personnel selected for the DCRDR team.

Subsection 2.1.4 of NUREG-0800 recommends that the licensee should develop an orientation program for the personnel selected for the DCRDR team.- This

! orientation is intended to ensure that team members share a basic understanding of the DCRDR before they begin review activities.

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Since the Program Plan did not provide adequate information with regard to DCRDR team qualifications, level of effort, and team orientation, we recommend that a meeting or phone conference with the licensee be held in order to discuss these issues. The outcome of that meeting will uetermine the need for additional meetings or an in-progress audit.

Without information concerning the above aspects of the review team composition and qualifications, we cannot fully evaluate the licensee's response to this requirement of NUREG-0737, Supplement 1.

2. Use of Function and Task Analysis 4

The Program Plan states that the objective of the system function and task analysis activity is to establish the information and control requirements and the performance criteria for the tasks which operators are required to accomplish under emergency conditions. These requirements and criteria will serve as benchmarks for the examination of the adequacy of the '

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control room instrumentation and other equipment. This objective conforms ~

to the function and task analysis objective as presented in Subsection 3.4.1

' of NUREG-0700.

The CP&L task analysis methods and procedures are based on the Westing-house Owners Group (WOG) Emergency Response Guidelines (ERGS), Revision 1, and the WOG High Pressure Basic Systems Review and Task Analysis (SRTA).

Based on the results of NRC-WOG meeting of March 29,1984 (Reference 9), the i NRC accepted that Revision 1 of the ERG and background documents do provide an adequate basis for generically identifying information and control needs.

. Therefore, the CP&L methodology meets the Supplement 1 to NUREG-0737 DCRDR requirement for "the use of function and task analysis (that had been used as a basis for developing emergency operating procedures technical guide- s lines and plant-specific emergency operating procedures) to identify control room operator tasks and information and control requirements during i

emergency operations."

The WOG SRTA documentation was developed for Westinghouse high pressure nuclear power plants rather than low pressure plants such as H.B. Robinson Unit 2. Item 3 in the NRC-WOG meeting of March 29,1984 (Reference 9) 4 states that for potentially safety-significant plant-specific deviations i

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. . from the ERG instrumentation and controls, each licensee and applicant must provide a list of deviations and their justification. CP&L plans to create an E0P/ ERG Transition Document which tracks the differences between the WOG

ERGS and the plant-specific E0Ps. The Transition Document will consist of the following sections

4 o List of differences between the ERG low pressure reference plant and H.B.-Robinson.

o Step deviation forms which explain any variance between an H.B.

Robinson step and a WOG step.

o Deviations for the instrument values used in H.B. Robinson E0Ps.

The Element Tables used in the H.B. Robinson task analysis will contain plant-specific tasks, plant-specific knowledge requirements, plant-specific instrumentation and control requirements, and the plant-specific task -

actions. This methodology should result in a comprehensive identification -

) of operator tasks, information and control requirements, and instrumentation

, control characteristics.

In summary, the CP&L function and task analysis methodology uses the Westinghouse High Pressure Basic Westinghouse System Review and Task Analysis, and plant-specific emergency' operating procedures which are based on the WOG Revision 1 Emergency Response Guidelines, to establish the input

and output requirements for control room operator tasks. The CP&L method-ology is designed to identify operator information and control requirements along with instrumentation and control characteristics for each operator task performed during emergency operations. It is our judgment that the CP&L methodology should result in system function and task analysis which meets the Supplement 1 to NUREG-0737 requirement.

3. Comparison of Display and Control Requirements With Control Room Inventory

• The Program Plan states that project personnel will conduct a systematic review of relevant control room documentation (e.g., instrument lists, engraving lists, FSAR, etc.) to develop the control room inventory.

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1 The instrument data collected in the inventory will be compared with the requirements identified in the task analysis. Discrepancies will be recorded as human engineering discrepancies. This should produce inventory '

4 results which conform to the requirement in Supplement 1 to NUREG-0737, by identifying missing displays and controls.

e In addition, CP&L plans to evaluate the availability and adequacy of the existing controls and displays to meet the needs identified in the task analysis. This will be done in the verification and validation processes as outlined in the Program Plan.

The verification wi14 be conducted to determine the availability and suitability of the instruments and controls'. The verification of availa-bility is designed to compare operator information and control requirements identified in the task analysis with the results of the control room inven-tory in order to verify the presence or absence of instruments and controls.

The CP&L methodology for verification of suitability is designed to use

] selected guidelines from NUREG-0700 and criteria derived from the task ~

l- analysis to determine the suitability of control room components. Human l engineering discrepancies identified during the verification process will be

recorded and assessed in the assessment and implementation phase. It is our judgment that the CP&L methodology for verification of availability and suitability conforms to the guidance provided to Subsection 3.7 of NUREG-0700.

The validation will be conducted to determine if the functions ailocated to the control room operating crew can be accomplished within the structure of the established emergency operating procedures and the design of the control room as it exists. In order to accompitsh the validation, i CP&L has outlined a methodology which will involve observation of operators walking through selected event sequences. The system function and task analysis data will be used to ensure that the sequences chosen represent all emergency interface requirements. The purpose of the validation activity will be to identify problems with control room layout, location of related components, operator workload, or ot'her human engineering concerns. Human engineering discrepancies identified in the validation activity will be recorded and assessed in the assessment and implementation phase. The i

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l l validation process outlined by CP&L follows the validation guidance provided in Subsection 3.8 of NOREG-0700.

1 In summary, the CP&L control room inventory methodology consists of a control room inventory, verification of instrumentation availability 4

and suitability, and validation of control room functions. It is our deter-mination that the CP&L methodology should result in a control room inventory which will satisfy this Supplement 1 to NUREG-0737 requirement.

4. Control Room Survey i

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The DCRDR is specifically directed toward evaluating the control room and ' remote shutdown panels. The Program Plan states that the CP&L control room surveys are planned to follow the guidance of NUREG-0700. The surveys

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1. Workspace -

2. Anthropometrics

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3. Emergency Equipment 4 HVAC

5. Illumination

6. Ambient Noise

7. Maintainability

8. Communications

9. Annunciator Systems

10. Controls

11. Displays

12. Labels and Location Aids

13. Computer System

14. Conventions.

l Two NUREG-0700 subsections (6.8 Panel Layout and 6.9 Control-Display Integration) are not included in the survey activity because they are used j

as criteria for the system function and task analysis activity and the verification and validation activity. The methodology for the evaluation of panel layout and control display integration is included in Sections 3.6 and 3.7 of the Program Plan.

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In summary, the CP&L control room survey methodology will address seven of the nine topic areas in Section 6.0 of NUREG-0700. The remaining two NUREG-0700 topic areas (panel layout and control display integration) will be addressed in the function and task analysis activity and the verification and validation activity. If carried out following this methodology, the CP&L Survey will satisfy the survey requirement in Supplement 1 to NUREG-0737.

5. Assessment of HEDs The licensee describes the methodologies for the assessment and

categorization of human engineering discrepancies (NEDs) in Sections 4.1 and 4.2 of the Program Plan. The assessment of HEDs will be performed by members of the HEDAT team which was described previously in Section 1.0 of

, this review.

As stated by CP&L, the HED assessment process involves a prioritization -

of HEDs based on their potential for error and the consequence of error ~

resulting from the HEDs. Each HED will be evaluated for its potential for

] error before the consequence of the error can be assessed. The criteria used to assess the potential for error include: (1) component design factors (i.e., deviations from guidelines, plant design conventions);

(2) task factors (i.e., difficulty, frequency ...); and (3) human factors i

(i.e., physical sensory and perceptual performance). Error consequence is r defined in terms of the " potential impact to plant safety."

, Based on the extent of the potential for error and error consequence assessed for each HED, HEDAT members will classify the HED in one of the following categories: (1) Category I - HED that may lead to an error which has safety consequences or may lead to a technical specification violation; one that causes a recurring error is also classified in this category; (2)

Category II - HED that has been determined to be of valid concern, but i without documented cases of the error occurring; (3) Category III - HED that has a low potential for error and no documented occurrence of error; and (4) l Category IV - HED that has no impact on operator performance and no poten-tial for error. l

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The plan goes on .to say that all Category I, II and III HEDs will be .l analyzed for disposition. Although Category IV HEDs are considered as l optional for correction, they will 1,e reviewed by the HEDAT members for their cumulative and interactive effects on all other HEDs. If any of l

- Category IV HEDs was found to contribute to cumulative or interactive effects. it will be reclassified to the appropriate category.

In summary, the HED assessment process described by CP&L is consistant with guidance provided in NUREG-0800, Section 18.1, and shculd lead to satisfactory compliance with the requirement of SJpplement 1 to NUREG-0737.

I 6. Selection of Design Improvements The CP&L methodology for HED correction states potential corrective action will be identifled by the HEDAT members for all HEDs, regardless of priority ranking. The methodology includes an analysis for correction of HEDs by enhancements or design alternatives followed by an assessment of the -

extent of correction. Where it is determined that correction by enhancement

• is not possible, the discrepancy will be analyzed for correction by design alternatives. Multiple design alternatives will be considered, as appro-

-priate. Cost and schedule estimates will be considered for each proposed change. _ The impact of design change on operator training, plant mainte-nance, and documentation will alsc be considered. For all HEDs selected for correction, the extent to which each discrepancy will be corrected (by enhancement or redesign) will undergo evaluation by the HEDAT members, t- Discrepancies which are not fully corrected will be identified and docu-mented by the review team, and a justification will be prepared for each

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It is our judgment that the selection of design improvement process described by CP&L conforms to the guidance provided in Subsection 4.2.2 of NUREG-0700 and should satisfy this Supplement 1 to NUREG-0737 requirement.

7. Verification That the Design Improvements Provide the Necessary Correc-tions and Do Not Introduce New HEDs I

The CP&L Program Plan describes a methodology for assessing the design 4 improvements. Each HED correction considered will be reassessed by the

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4 HEDAT in order to evaluate the effect of the improvement on operator performance. The HEDAT members will also ensure that no new HEDs are created by the correction, other corrections are not invalidated, and the correction is in compliance with human engineering guidelines.

However, the techniques for conducting these proposed verification  !

steps should have been provided in the Program Plan. For example, the j licensee could consider using mock-up techniques to ensure that the total  :

correction package provides a consistent, coherent, and integrated interface between operator and the control room. This should help reduce the possi-bility of piecemeal correction of HEDs. Furthermore, the mock-up provides a l

valuable tool to assist the HEDAT in differentiating the effectiveness of alternative design improvements for any individual HED. These mock-up tech-niques should then be followed by walk-through/ talk-throughs with operators to verify the solutions' suitability in regard to actual control room opera-tions.

It is our judgment that the methodology outlined by CP&L should lead '

toward meeting this requirement of NUREG-0737 Supplement 1; however, the approach could be enhanced by providing well-developed verification plans and techniques which would ensure verification of HED corrections.

8. Coordination of Control Room Improvements With Other Programs CP&L has shown intention of coordinatin'g the DCRDR effort with other related activities such as E0P, SPDS, implementation of Reg. Guide 1.97 requirements, and implementation of the Emergency Response Fccilities. The Program Plan also contains an overview discussion of H-B. Robinson Unit 2 .

integrated Emergency Response Capabilities Level 1 activities. In addition, the licensee has demonstrated the integration of E0P in the DCRDR activities through the use of the upgraded plant-specific emergency operating procedures for the system function and task analysis activity.

However, the process for coordinating DCRDR activities wi'th the remaining post-TMI programs such as SPDS, Reg. Guide 1.97 and Training, has not been described in detail in the Program Plan. Without this information, a complete evaluation of the degree to which the licensee's program will 10

4 satisfy the requirement of Supplement 1 to NUREG-0737 cannot be accomplished.

9. Other CP&L plans to conduct an operating experience review to identify any characteristics in the control room layout or operation of the control room that may contribute to operator performance problems. This activity will be conducted by interviews with licensed operators. HEDs identified during the

operating experience review process described by CP&L conforms to the guidance provided in Subsection 3.3 of NUREG-0700, and should serve to identify human performance problems which could be alleviated by improving

human engineering.

Upon completion of the DCRDR, a summary of the results will be prepared

.and submitted to the NRC for review. The Final Summary Report will describe the results of the DCRDR and will be submitted within six months after -

startup from cycle 10. The report will summarize the DCRDR process and

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provide summary descriptions of the identified human engineering discrepan-cies and their proposed corrective actions. It will provide implementation schedules for each corrective action and describe -the process that will be used to assess changes to ensure additional HEDs aren't created by the changes. It will also describe any modifications or revisions made to this l Program Plan and will include the project team resumes and report any changes in review team personnel. Samples of the procedures used in the DCRDR and sample data forms will be provided. This should satisfy the Supplement 1 to NUREG-0737 requirements for the DCRDR Summary. Report.

SUMMARY

OF CONCLUSIONS f CP&L H.B. Robinson Program Plan addressed all of the DCRDR requirements stated in Supplement I to NUREG-0737. Information in the Program Plan indicated a thorough understanding of and an intent to satisfy most of the '

requirements. However, our review of the Program Plan did identify several concerns with regard to 'the establis'hment of a qualified multidisciplinary team.

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The Program Plan does not contain detailed documentation of the qualifications of the DCRDR team members as recommended in Subsection 2.1.2 of NUREG-0800. Also, the proposed level of effort of each review team member was not included in the Program Plan. This prevented us from being able to evaluate the appropriateness of the proposed assignments and responsibilities of each of the DCRDR team members based on team member's qualifications. However, the Program Plan did state that the licensee will provide the core team resumes in the Summary Report in order to document the proven track record of the DCRDR managers, administrators, supervisors, and technical experts.

The Program Plan did not indicate that the licensee had a formal orientation program for the personnel selected for the DCRDR team.

Subsection 2.1.4 of NUREG-0800 recommends that the licensee should develop an orientation program for the personnel selected for the DCRDR team. This orientation is intended to ensure that team members share a basic understanding of the DCRDR before they begin review activities.

Since the Program Plan did not provide adequate information with regard to DCRDR team qualifications, level of effort, and team orientation, we recommend that a meeting or phone conference, with the licensee be held in order to discuss these issues. An agenda for the meeting is presented below.

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Proposed Agenda for 18eeting Between CP&L and the NRC The following topics are proposed for the meeting:

o Qualifications and Structure of the DCRDR Team.

1. Identity, qualifications and level of effort of the review team members and the HEDAT members.

2. Provision for a team orientation on basic understanding of the DCRDR prior to the start of the control room review program.

o Verification of Design Improvement

1. Techniques to test proposed changes. -

o Coordination of the DCRDR with other programs

1. Detailed description of the process for coordinating DCRDR activities with other programs such as SPDS, Reg. Guide 1.97, and Training.

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REFERENCES

1. Control Room Design Review Detailed Program Plan and Implementation Guidelines for H.B. Robinson Steam Electric Generating Plant Unit 2 Carolina Power and Light Company, December 1984.

2. Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability (Generic Letter No. 82-33), U.S. Nuclear Regul atory Commission, December 17, 1982.

3. NUREG-0700, Guidelines for Control Room Design Reviews, U.S. Nuclear Regulatory Commissiorr, September 1981.

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

Section 18.1 and

5. NUREG-0660 Vol.1. "NRC Action Plan Developed as a Result of the TMI-2 Accident," U.S. Nuclear Regulatory Commission, May 1980; Revision 1 August 1980.

6. NUREG-0737, " Clarification of TMI Action Plan Requirements," U.S.

Nuclear Regulatory Commission, November 1980.

7. NUREG-1000, Generic Implications of ATWS Events at the Salem Nuclear Power Plant, April 1983.

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

9.

Letter from H. Brent Clayton to Dennis L. Ziemann,

Subject:

Meeting Summary - Task Analysis Requirements of Supplement 1 to NUREG-0737, March 29, 1984 Meeting with Westinghouse Owners Group (WOG) Procedures Subcommittee and Other Interested Persons U.S. Nuclear Regulatory Commission, April 5, 1984.

H. B. Robinson Steam Electric Plant. Unit 2 TAC No. 51197 SAIC/1-263-07-351-60 Contract NRC-03-82-096 14

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