ML20126E720
| ML20126E720 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/23/1992 |
| From: | Long R GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C-92-1956, C000-92-1956, C321-92-2344, NUDOCS 9212290283 | |
| Download: ML20126E720 (8) | |
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Uh a i pa Jers y07054 201 316-7000 TELEX 136-482 Writer's Direct Dial Number.
December 23, 1992 C000-92-1956 C321-92-2344 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Oyster Creek Nuclear Generating Statior (OCNGS)
Docket No. 50-219; Operating License No. DPR 16 Integrated Schedule - Cancellation of B/A 402808 Conversion of SIGMA Computer Room to GSS Office
References:
1.
GPUN Letter No. C321-92-2152, dated June 5, 1992 Integrated Schedule Semi-Annual Update 2.
NRC Letter from A.W. Dromerick to R.L. Long(GPUN),
dated June 16, 1992 Re: OCNGS - Integrated Schedule ABC List Update This letter provides justification for cancellation of B/A 402808, Conversion of the SIGMA computer room to a GSS office, as requested by NRC Staff in Reference 2 above. This project was an outcome of the Detailed Control Room Design Review (DCRDR) performed in the period 1982 1984 and the resolution of Human Engineering Deficiencies (HEDs) in the 1985 - 1987 time frame. However, it is not considered to have any safety significance in that its implementation would have no bearing on nuclear plant safety, safe plant operations, nor any impact upon the health and safety or welfare of the public, in light of the current resolutions effectuated since that time.
Introduction and Backaround In accordance with NUREG-0737 Supplement 1, GPU Nuclear Corporation submitted the Oyster Creek Detailed Control Room Design Review (DCRDR) Summary Report on April 30,1984.
Additional information was provided in a supplement to the Summary Report on April 8,1985.
There are five HEDs contained in Group 6,
" Control Room Environment," that are related to relocation of the GSS office.
[See Table 1.] Items 6-8, 6-9, 6-12 and 6-13 directly address relocation of the GSS office.
The deficiencies addressed include: the lack of an efficient overview function; potential jarring of controls; traffic / noise in the control room; and, entry into the control area by unnecessary personnel, item 6-7 is a related deficiency that describes operations and maintenance personnel equipment tagging-that could interfere with operator's vision of the control board.
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- C000-92-1956 C321 92-2344 Page 2
-In the period of time which has ensued since the original DCRDR,. Oyster Cree'k operators have been challenged many times to respond to plant transients as well as to external events.
in such situations the NRC has found that Operations performance has been good, as evidenced by Systematic Assessment of Licensee Performance (SALP) Reports during that time period.
For example, see the following two citations:
SALP Report No. 50-219/91-99 (for the Period 4/16/91 to 7/18/92)
Section Ill.A Plant Operations... "The control room operators responded well to plant challenges including three automatic scrams, the loss of a main feedwater pump, several recirculation pump trips, and the inadvertent opening of an electromatic relief valve."
SALP Report No. 50-219/90-99 (for the Period 3/16/90 to 4/15/91)
Section Ill.A Plant Operations... "The operators responded extremely well to plant challenges and exhibitad good safety perspectives."... And, "The operators performed well under challenges posed by the unplanned shutdowns and automatic scrams." Lastly, "Overall, during the assessment period the control room operators exhibited proficiency and performed well "
GPUN believes that Oyster Creek operators do perform well as supported by these SALP comments and other NRC inspection reports.
The originally proposed corrective action to HEDs is not well founded, with respect to the relocation of the GSS office.
Resolution of CRDR Deficiencies Table 1 identifies the specific deficiencies, proposed corrective actions and current resolutions that relate to the GSS office modification. The GSS office relocation project (See Table 2] was originally undertaken to resolve-the HEDs identified in the Oyster Creek Control-Room Design Review.
In the DCRDR Summary Report, the HEDs on Table 1 were designated as _"Importance Category C" items, i.e., deficiencies which are unlikely to affect operator performance irreversibly under any condition or for which solutions are not.
clear cut.
In addition,.the report. states that "... in no' case is a Category C deficiency likely to lead to an -irreversible operator error or to affect plant safety."
Listed below are the HEDs and a description of ' specific operating procedures or improvements that have been instituted to eliminate the deficiency.
ITEM 6-7 Irterference -With 00erator's Vision-of Panels -
w This deficiency indicated that personnel who request equipment tagging may interfere with operator's vision of the control board.
This concern has been eliminated.by controlling tagging using a computer console behind the Control-Room Operator (CRO) desk near the emergency communication panel. CR04s vision of the panels is presently not obstructed by technicians or equipment operators that need to tag equipment / systems out of service.
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C000-92-1956 C321-92-2344 Page 3 ITEM 6-8 Efficient Overv ew Function i
The concern is that the existing GSS office tends to isolate him from current plant status and may affect response to a plant transient event.
The present office location does not' allow the GSS to directly view control room front panels.
However, the operators are trained to respond to all alarms and off-normal indications, monitor plant parameters and equipment, and periodically record plant operating data to determine if adverse trends are emerging.
If abnormal conditions are observed by a CRO, he will immediately notify the GSS, who will respond.
In addition, the GSS does have direct auditory contact with the control room alarm annunciations.
There is no significant increase in ability of the GSS to responJ to unusual events or to monitor the performance of l
systems and components by relocating his office to the SIGMA computer room. The relocation would be approximately the same distance from the panels as the existing office.
Access to the " Exclusion Area" is direct and unimpeded at present, and if relocated to the SIGMA computer room access could potentially be slowed.
The scope of the original corrective action proposed included removing the SIGMA computer, ret outing conduit from the southwest wall, installing a bulletproof window in the southwest wall, upgrading existing door to meet security access requirements, installing flooring, providing lighting and electrical power, and relocating existing GSS office equipment (see attached control room drawing).
This proposal would result in the GSS office being outside the control room HVAC and security boundaries.
This will not satisfactorily resolve all the deficiencies identified in the Control Room Design Review. The GSS's ability to monitor current plant status visually will be improved, but access to the control room will tend to be impeded by the security door. Also, auditory communications could be impaired because of the new wall.
There is no apparent improvement L
over the existing location which affords direct auditory contact and unimpeded access in the event of an emergency. To resolve all the identified deficiencies would require the expanded project scope described-in Table!2.
ITEMS 6-9. 6-12, 6-13 Traffic Noise and Casual Entry These~ three deficiencies are related in that the present office location does not permit the GSS to adequately control the number of people in the control room at
-any one time, and does not allow him-to prevent casual entry into "the Control Area" by personnel 'who have no reason for being there'.
- H6 wever, current-procedures and practices at Oyster Creek address these deficiencies.
L Vital Access Control There is limited access to the control room, especially during.the operating cycle.
Control - room access is granted for. one calendar month to certain individuals and is tightly managed.by Plant Operations. All others are granted access for only the days access is required.
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C000-92-1955 C321-92-2344 Page 4 Station Procedure 106 - Conduct of Operatical The purpose of this procedure is to provide general rules and guidance to the overall operation of 0yder Creek.
Section 4.9 discusses
" Personnel Conduct, Practice, and Policies." Distractions that have the potential of interfering with shift personnel duties will be eliminated, which includes the unnecessary congregation of personnel in the control room for no operational reason.
All personnel conducting business in the control room do so in a manner as not to interfere with the control room operator's ability to monitor the plant.
Personnel who wish to check charts, plant parameters, or conduct business in the control room will request permission of the Group Shift Supervisor or Group Operating Supervisor upon entering the control room.
Loitering is not permitted in the control room.
Outaae Coordination Center (OCC)
Traffic problems have occurred during past refueling / maintenance outages when people walk into the control room to obtain GSS signature on various documents.
Several improvements have been implemented or are being planned to reduce outage traffic.
During the 13R outage, switching and tagging was done in the Outage Coordination Center (OCC), and will continue to be the practice during all refueling outages.
Work packages were assembled in the OCC and sent into the GSS for final sign off.
An Operations engineer is assigned as a
" Control Room Coordinator" during refueling outages to reduce control room loading by more effective utilization of the OCC.
Additional Shift Senior Reactor Operator (SRO)
Oyster Creek also has an additional day shift SR0 who performs administrative duties in support of the GSS.
Hi', office is located outside the control room in the OCC, which results in less traffic into the control room area. The day shift SR0 cotrdinates maintenance and contractor work, assists in switching and tagging, and keeps the GSS informed of changing schedules and plant conditions.
Conclusions The response by Operations personnel to plant transients and external events has been good during the time period which has ensued since the DCRDR was performed.
Procedures and work practices have been upgraded, and there is no need for additional corrective measures to the control room HEDs.
Providing additional SR0 office space and to create a permanent GSS office in the old SIGMA computer room (facing the Control Room front panels) would be a significant manpower and hence financial burden on GPUN with little or no safety benefit to the plant or the health and safety-of the public.
As the safety significance is minimal, this project is not cost justified from a Control Room Design Review benefits viewpoint, i
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r C000'-92-1956
~C321-92-2344 Page-S Also,_ changes to procedures and practices have been implemented-to resolve the other DCRDR ' deficiencies, Restrictions over Control Room - access and the
" Exclusion Area" within the control _ room, Operations Standards (procedures), and-day-shift SR0 support'of the GSS enables the GSS to have more freedom to. monitor plant status and control traffic,_if and when needed.
Lastly, the functions performed in the Outage Coordination Center (switching and tagging, document preparation for signoff) and 'the-functions performed by the Control Room Coordinator _ benefit _the GSS during outages.
Based on the reasons cited above, as well as the' history _of Oyster - Creek operations, the project to relocate the GSS office is 'being removed from the integrated schedule.
~ Very truly yours, f
W Robert L. Long d
Vice President and Director Corporate Services and THI-2
'I Attachments cc: ' Administrator, Region 1 NRC Oyster Creek Project Manrmt NRC Oyster Creek-Resident Ins,t v
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TABLE 1 - B/A 402808, SIGMA COMPUTER ROOM
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CONVERSION TO GSS OFFfCE ITEM CORRECTIVE NO.
DEFICIENCY ACTION RESOLUTION 6-7 Equipment operators and maint.
A rearrangement of the desks -
Tagging behind the CR0 desk technicians sometimes interfere
'in the. control area is under eliminates the potential for with the operator's vision of
. consideration.
Relocation of blocking the operator's vision.
control board.
Switching (Blocking).and Tagging to reduce this problem will be considered.
6-8 Location of GSS office inhibits Relocate GSS office to room Present location provides direct an efficient overview function.
currently occupied by SIGMA auditory contact via alarm computer.
annunciation and rapid unimpeded access in the event of an emergency,-
and is within the HVAC and current Security envelope of the Control Room.
6-9 Some controls can be jarred by Rearrange traffic pattern by Vital Access, Procedure walking by.
relocation of GSS office, 106, Tagging behind CR0 Blocking and Tagging desk.
desk.
6-12 Hard to control traffic, noise, Relocate tagging operator';
Vital Access, Procedure and confusion in control room.
station.
Relocate shift 106, Outage Control Center, supervisor's office to SR0s.
contral access.
6-13 Present location of GSS/GOS office Relocate GSS office to room Vital Access, Procedure is unable to prevent casual entry currently occupied by SIGMA 106, Outage Control Center, to control area by personnel who computer.
shift SR0s.
,have no reason for being there.
1 TABLE 2-B/A 402808 SIGMA COMPUTER ROOM CONVERSION TO GS$ OFFICE PROJECT SCOPE i
In the December 9,1991 Integrated Schedule submittal (CPUN Letter C321-91-2316), this Category B project was scheduled to be completed in two phases.
Phase 1 in Cycle 13 would remove the SIGMA computer and provide office space for Operations personnel. Phase 2 in the 15R outage (October 1994) would convert this area into a permanent GSS office.
GPU Nuclear had planned to complete the two phases, as follows:
- Phase I would have provided space for an SR0 office in the SIGMA computer room, af ter removal of the computer equipment.
- Phase 2 would have converted the SR0 office into a new GSS office. The following work scope was included:
Install three windows in the walls adjoining the control room. (One window in each wall to enable the GSS to view the same panels the operators view from their desks.)
Reroute approximately 21 fire protection conduits to facilitate window-installation (includes firewatch).
Install noe door in new GSS Office south wall for personnel entry via the Control Room.
- Block off the doorway between the SIGMA computer room and RAGEMS computer room so that the control room boundary (security, fire protection, HVAC) will include the new GSS office.
- Tie-in Control Room HVAC to new GSS Office.
Provide sufficient lighting (normal and emergency) for new 6SS Office, l
- Relocate emergency phones and cabinets.
Install new countertop opening in east wall of existing GSS Office for control of personnel entry into Control Room.
Convert the existing door into a security access door with keycard reader,-i.e.,
door that separates the control room from the RAGEMS computer room.
l The work scope described above is clearly quite extensive; and, therefore the implementation of a new GSS. office, in the SIGMA computer room location, would be extremely bcrdensome to l
GPUN without the realization of any significant gains in nuclear safety or safe plant operation.
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