ML20127D890
| ML20127D890 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/16/1985 |
| From: | Johari Moore, Savage J LAWRENCE LIVERMORE NATIONAL LABORATORY |
| To: | |
| Shared Package | |
| ML17054B767 | List: |
| References | |
| NUDOCS 8506240368 | |
| Download: ML20127D890 (37) | |
Text
- * ^ -
e *'8 Enclosure t
IN-PROGRESS AUDIT REPORT G7 THE
,. NINE MILE POINT, UNIT 2 DETAILED CONTROL ROOM DESIGN REVIEW I
i BEING CONDUCTED BY NIAGARA MOHAWK POWER CORPORATION l
James W. Moore Jack W. Savage Lawrence Livermore National Laboratory May 16, 1985 i
- . -.- . =_ ~ :- . , = - z . .- - . .__. L - ~-
e t IN-PROGRESS AUDIT REPORT OF THE -
NINE MILE POINT, UNIT 2 DETAILED CONTROL ROOM DESIGN REVIEW BEING CONDUCTED BY
. NIAGARA MOHAWK POWER CORPORATION
- 1. BACKGROUND Licensees and applicants for operating licenses shall conduct a Detailed Control Room Design Review (DCRDR). The objective is to " improve the ability of nuclear power plant control room operators to prevent accidents or cope with accidents if they occur by improving the information provided to them,"
NUREG-0660, Item I.D. (Ref. 1). The need to conduct a DCRDR was confirmed,in NUREG-0737 (Ref. 2) and Supplement 1 to NUREG-0737 (Ref. 3). DCRDR requirements in Supplement 1 to NUREG-0737 replaced those in earlier documents. Supplement 1 to NUREG-0737 requires each applicant or licensee to
_ conduct a DCRDR on a schedule negotiated with the Nuclear Regulatory Commission (NRC).
NUREG-0700 (Ref. 4) describes four phases of the DCRDR and provides applicants and licensees with guidelines for its conduct.
The phases are:
- 1. Planning
- 2. Review 3 Assessment and Implementation 4 Reporting Criteria for evaluating DCRDRs are contained in Appendix A to Standard Review Plan (SRP), Section 18.1 of NUREG-0800 (Ref. 5).
A Program Plan is to be submitted withing two months of the start of the DCRDR. Consistent with the requirements of Supplement 1 to NUREG-0737, the
e t Program Plan shall describe how the following elements of the DCRDR will be accomplished:
- 1. Establishment of a qualified multidisciplinary review team
- 2. Function and task analyses to identify control room operator tasks and information and control requirements during emergency operations 3 A comparison of display and control requirements with a control room inventory
- 4. A control room survey to identify deviations from accepted human factors principles
- 5. Assessment of human engineering diecrepancies (HEDs) to determine which HEDs are significant and should be corrected
- 6. Selection of design improvements
- 7. Verification that selected design improvements will provide the necessary correction
- 8. Verification that improvements will not introduce new HEDs
- 9. Coordination of control room improvements with changes from other programs such as SPDS, operator training, Reg. Guide 1.97 instrumentation, and upgraded emergency operating procedures.
A Summary Report is to submitted at the end of the DCRDR. As a minimum, it shall:
- 1. Outline proposed control room changes L
2
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- 2. Outline proposed schedules for implementation '
3 Provide summary justification toe HEDs with safety significance to be left uncorrected or partially corrected.
The NRC will evaluate the organization, process, and results of the DCRDR.
Evaluation will include review of required documentation (Program Plan and Summary Report), and may also include reviews of additonal documentatilon, briefings, discussions, and on-site audits. In progress audits may be conducted after submission of the Program Plan, but prior to submission of the Summary Report. Evaluation will be in accordance with the requirements of Supplement 1 to NUREG-0737. Additional guidance for the evaluation is provided by NUREG-0700 and NUREG-0800 Appendix A to SRP, Section 18.1.
Results of the NRC evaluation of a DCRDR will be documented in a Safety Evaluation Report (SER) or SER Supplement.
Significant HEDs should be corrected. Improvements which can be accomplished 1
with an enhancement program should be done promptly. Other control room
.. improvements should be done on a schedule acceptable to the NRC.
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. t
- 2. DISCUSSION The Niagara Mohawk Power Corporation (NMPC) submitted a Detailed Control Room Design Review (DCRDR) Program Plan for its Nine Mile Point, Unit 2 Plant (NMP-2) to the Nuclear Regulatory Commission by letter dated June 29, 1984 The DCRDR Program Plan was reviewed against the requirements of Supplement 1 to NUREG-0737 by the NRC Division of Human Factors Safety (DHFS) and consultants from Lawrence Livermore National Laboratory (LLNL). Their comments were submitted to the NRC Division of Licensing in a memorandum dated November 11, 1984 (Ref. 6).
The NRC Human Factors Engineering Branch (HFEB) and consultants from LLNL conducted a DCRDR In-Progress Audit at NMP-2 on March 19 - 22, 1985. This audit report documents the NRC audit team's observations, findings, and conclusions resulting from this on-site audit.
2.1 DCRDR REVIEW TEAM 2.1.1 Requirement Supplement 1 to NUREG-0737 requires the establishment of a qualified multidisciplinary review team. Guidelines for review team selection are found in NUREG-0700 and NUREG-0800, Appendix A to SRP Section 18.1. NUREG-0700 guidelines state that support of the applicant's management is needed to provide to the DCRDR team all of the information, equipment, and categories of manpower needed to conduct a control room design review.
2.1.2 Findings The NMP-2 Review Team is directed and coordinated by Niagara Mohawk Power Company (NMPC) Team Leader, Art Vierling, and includes the following personnel, o Project Engineering / Team Leader (NMPC) o Advisory Operations Engineer, Stone and Webster Engineering Corp.
(SWEC) o Station Shif t Supervisor (NMPC) o 2 Start-up and Test Engineers, General Electric Co. (GE)
^ '
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. t o Training Representative (NMPC) o Human Factors Lead Engineer, Advanced Resource Development Corp.
(ARD) .
o 4 Human Factors Engineers (ARD)
The resumes and DCRDR team responsibilities of the DCRDR Team Leader and the Lead Human Factors specialist are generally acceptable. The resumes of other review team members that were examined during the audit do not contain sufficient information to enable a suitable comparison with the guidelines in NUREG-0800 (Ref. 5). In some cases core skills are reasonably well described, but supplementary capabilities are not included. We recommend that additional information be appended to the resumes of the HF specialists and additional resumes be supplied for the Station Shift Supervisor and Training Representative. A description of the experience and capabilities of all support personnel. involved in the review should be included in the Summary Report.
NMP-2 indicated that team members had attended an orientation program conducted by ARD. We recommend that a formal description of the overall orientation program be supplied in the Summary Report. This description should include:
- 1. Titles of subject matter and DCRDR phases presented (e.g.
assessment, verification, function and task analysis, NUREG-0700, NUREG-0800, NMP-2 design, etc).
i 2. Session hours for each subject.
3 Who participated in the subject matter presentations.
- 4. Who attended the sessions (e.g., mangement, team members, others).
Team member task assignments to assure suitable HF expertise and a suitable 1
match of team member capabilities to DCRDR task requirements were not described in detail. We recommend that the Summary Report include an explanation of:
o Team member assignments vs. DCRDR tasks,
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. i o Levels of effort expended in accomplishing the tasks, o Participation of experts other than team members.
2.1.3 Conclusions Based on NRC audit team observations during the NRC in progress audit, the NRC audit team concluded that NMPC mangement has made a firm committment to support the DCRDR. To help assure that the NMP-2 DCRDR meets the requirement to establish a mult1 disciplinary audit team, the NRC audit team recommends that NMPC take the following actions:
o Improve the documentation of the experience and capabilities of all DCRDR team members and support personnel.
o Describe the orientation provided to DCRDR team members and support personnel.
o Document the participation of individual personnel in the performance of DCRDR tasks.
These comments and recommendations are intended to guide NMPC in providing information that will enable the NRC to determine whether this requirement of Supplement 1 to NUREG-0737 has been met.
2.2 FUNCTION AND TASK ANALYSES 2.2.1 Requirement Supplement 1 to NUREG-0737 requires the applicant to perform systems function and task analyses (SFTA) to identify control room operator tasks and to identify control room operator information 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 procedures technical guidelines and plant-specific emergency operating procedures to define these needs.
.- . . . . _ . . -.. ... ~ . - - - - . - - .
e s 2.2.2 Findings The steps recommended for a top-down systems function and task analysis that are 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 the existing control room design. The analysis 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.
For the NRC to determine that NMPC has met the SFTA requirement of Supplement.1 to NUREG-0737, the SFTA processes should be described in terms of:
o What was done, o Who performed the analyses.
o How the function and task analyses were done.
In order, to be acceptably accomplished for all emergency conditions, the systems function and task analyses should:
o Be independent of existing equipment.
o Identify and analyze the appropriate operating events, plant safety-related systems, and functions which must be exercised and analyzed.
o Identify the E0Ps and tasks which must be executed and analyzed.
o Identify plant variables and parameters associated with each task.
o Identify the values and characteristics of identified plant variables at functional or task decision points.
~--
O I o Name the independent reference sources used, and describe who will use them and how they will be used to specify and document the transition from Boiling Water Reactors Owners Group (BWROG) EPGs to the plant-specific characteristics of information and controls needed by the operator to mitigate the effects of the emergency conditions.
o Completely cover all emergency operations included in the EPGs.
To enhance the acceptability of the description of the methodology, the 4
applicant's documentation should include the folicwing:
o Discussions of the approaches and information sources used (e.g.,
documents, guidelines, operations personnel, multiple approaches, plant-specific calculations, etc.).
o The rationale and methodology used in the selection of event sequences, along with a description of how it was verified that the selected sequences adequately cover the complete range of systems needed to mitigate abnormal plant conditions.
o The process used to identify the functions, systems, subsystems, and events selected for analysis.
An essential part of the task analysis is the use of independent reference sources to ensure that characteristics of the operator information and control needs are identified independently from observation of the characteristics of existing equipment in the control room.
j The NMPC task analysis team consists of:
o Human Factors Engineer, o NMP-2 subject matter experts, o NMP-2 E0P coordinator, o GE system expert.
e :
The development of the E0Ps at NMP-2 is nnt ' ased on the SFTA defined operator tasks and instrument and control neede as recommended by guidelines. Instead the Task Analysis being executed by .he NMP-2 DCRDR team is based on and dependent on the existence of final and complete EOPs.
NMP-2 is using BWROG Emergency Procedure Guidelines (EPG), Revision 3, to prepare the NMP-2 plant specific EOPs, which will be used as a basis for their task analyses and the determination of information and control needs. NMP-2 submitted to the NRC Procedures Branch in October, 1984, a plant-specific technical guideline to translate from the generic EPGs to NMP-2 plant specific E0Ps. This guideline is understood to identify all items which must be made plant specific (e.g., fluid level reference). NMPC stated that the NRC Procedures Branch has approved all but the Containment Pressure Limit. The plant-specific technical guideline was nots examined by the NRC audit team.
NMP-2 explained that equipment items listed in the generic EPGs that did not exist at NMP-2 were dropped, and that equipment items which existed at NMP-2 but were not mentioned in the generic EPGs were added to the NMP-2 technical guideline.
Examples are:
o Items dropped, Isolation Condenser HPCI (NMP-2 has HP core spray) o Items added, ARI (Alternate Rod Insertion).
It appears that NMP-2 recognizes that the E0Ps chosen as a basis for their task analyses must be complete and technically adequate in order to meet the requirements of Supplement 1 to NUREG-0737. It is not clear how and when the iterative meshing among the EPGs, the NMP-2 plant-specirc technical guidelines being reviewed by the NRC Procedures Branch, and the interim, but changing, draft plant-specific E0Ps will result in final, complete plant-specific EOPs. Changes in any of the above factors could result in altered E0Ps, invalid task analyses, and an invalid statement of information and control needs.
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The Summary Report should state how NMP-2 will ensure that the task analyses of the EOPs will encompass branching into normal ops from the EPGs/EOPs. An example might be " Hot Shut-Down" and " Cool Down" functions that could include task sequences within which the E0Ps may branch to lower levels of procedures that would still involve the use of emergency systems and equipment.
Questions related to this concern are:
o Does NMP-2 categorize procedures into Emergency, Normal, Abnormal?
o Do NMP-2 Emergency procedures direct the operator to "go to" any of the Normal or Abnormal procedures?
o Were E0P "go-to" branchings to Abnormal or Normal Operating Procedures included in the task analyses?
NMPC committed to review their ops and to include operation of emergency equipment which might be operated after branching from E0Ps into lower levels of procedures. The details of how this was/will be done is of concern and should be reported to the NRC for evaluation.
The mechanics of recording the E0P tasks and corresponding information and control needs seems to be well organized as exemplified by the Task Analysis Worksheet, page 11 of this report, and the Task Analysis Data Collection form, page 12 of this report. These forms are used by the task analysis team to identify step-by-step operator actions for each task, to describe " Control" and " Indicator" characteristics needed, and to later identify the corresponding ID number of matching control board equipment.
It was explained to the NRC audit team that the "needed" information and control characteristics determined from the task analysis are recorded on the task analysis forms in generic terms to avoid the possibility of reference to existing equipment.
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Examples of the type of characteristics recorded are:
o Control mode: discrete or continuous, o Control operating characteristics: spring return, pull to lock, key lock, etc.
o Control Feedback: status lights, flag or target, backlit message, etc.
o Information level: state, value, trend.
o Information presentation characteristics: status lights legend, continous parameter (e.g. units, range, divisions).
The Task Analysis Data Collection form will be used as the reference against which the CR Inventory form (page 18 of this report) will be compared to d'etermine HEOs. Both sets of information will be coded into the computer, and the comparison will be done in the computer.
NMPC contended that the determination of information and control needs was accomplished independently of the existing control room because of the following conditions:
o Many systems were not in place on the control boards.
o The task analysis was done at the training center, not at the control boards.
o Participants were told not to base answers to questions on their recollection of the control board contents.
NMPC stated that the Remote Shutdown Panels (RSP) will be surveyed per NUREG-0700 but will not be task-analysed.
2.2 3 Conclusions Based upon the NRC audit team's observations and discussions during the In-Progress Audit, it appeared that NMPC has a workable and adequate process developed for conducting a SFTA. While the methodology deviates from recommended guidelines, the NRC audit team concluded that it appears to be basically acceptable.
The SFTA process does need further explaination in the Summary Report.
Specifically, the NRC audit team recommends the following improvements:
o NMPC should explain in detail how the transition from the generic E0Ps to the plant specific EPGs was accomplishec.
o NMPC should provide a description of their methodology for incorporating changes in the EOPs into their SFTA and for revising operator information and control needs.
o NMPC should better explain and document the steps taken to ensure that the operator information and control needs determined from the task analyses were determined independently from identification of the characteristics of controls and instruments in the present control room design, o NMPC should clarify that the task analyses include analyses of operator needs when EOPs branch into lower levels of procedures as part of the plant specific response to emergency conditions. NMPC should ensure that the task analyses include all operator actions that must be taken to respond to emergencies.
When the the SFTA is complete and explanations have been provided on matters which need clarification, final appraisal of the NMP-2 SFTA process and results will be possible.
The NRC audit team believes that the interchange of-information which occurred during the audit has clarified for NMPC what the NRC expects and how the SFTA should be conducted and auditably reported to satisfy the task analysis requirement of Supplement I to NUREG-0737.
23 COMPARISON OF CONTROL AND DISPLAY REQUIREMENTS WITH A CONTROL ROOM INVENTORY 2 3.1 hequirement Supplement 1 to NUREG-0737 requires the applicant to make a control room inventory and to compare the operator display and control requirements
- 1. _ .. __ ._ . ._
determined from the task analyses with the control room inventory to determine missing controls and displays. Guidance in NUREG-0700 also calls for a review of the human factors suitability of instruments and controls used to satisfy operator information and control requirements.
2.3.2 Findings The NMP-2 inventory was collected by using the most recent blueprints of control panel layouts as a reference for a CR walk-through to identify all components. NMPC stated these blueprints were ahead of-the actual control boards. The inventory will be entered into the data base management system computer. The final "as-built" condition will be reached in September, 1985. Both Stone and Webster and General Electric will perform quality control checks to verify that the inventory is an exact match with the as-built control panels and drawings.
A computerized comparison of the inventory with the information and control needs listed on the Task Analysis Data Collection forms will verify the availability and support the verification of suitability of CR equipment. Any mismatches will create Human Engineering Observations (HEOs). All HEOs will be assessed. NMPC should make clear that NUREG-0700 provided the guidelines used to evaluate the human factors suitability of components.
The computerized inventory methodology appears to be complete and capable of sorting and making some analytical discriminations, such as confirming the consistent use of terms and abbreviations, and serving as a reference during assessment and corrective actions.
The goals of the inventory were described as:
i o Encode complete description of safety related control room equipment as it appears from the front of the control panels with enough information about function to compare to requirements defined by the task analysis, o Break down components by function.
o Cross reference with NMP numbers (tag numbers).
., o For displays, controls, recorders, and annunciators, a comprehensive collection of information was coded, such as:
o Panel number o X-Y grid position on panel o Label type o NMP-2 tag number o Pertinent color o Type of component o What is controlled / measured o Units, ranges, actions, positions, indicator lights, scales, etc.,
as appropriate o Vendor panel components o Multi-function recorders o Labels (exactly as on prints)
Additional coding refinements identified nearly 250 specific individual component characteristics. (e.g., label, meter, and switch types; scale detail; parameters and units measured; colors).
An example of the inventory, data sheet is on page 18 of this report. The inventory print-out enabled NMP-2 to check and correct existing files and drawings so that the data-base accurately describes the control boards.
SFTA needs were recorded on the Task Analysis Data Collection form using a different, more generic terminology than that described aoove for the inventory. A computer algorithm was devised to translate the "needs" and
" inventory" language so that an item-by-item comparison of availability and suitability could be made and HEOs identified for resolution.
- 1 6 --
t 0 LIST OF NMP-2 PANELS INVENT 0RIED P601 -- Reactor Core Cooling control board .
P602 -- RWCU and Recirculation control board P603 -- Reactor control board P851 -- Steam and Water Systems & Turbine / Generator control board P852 -- Electrical control board P870 -- HVAC Division I control panel P871 -- HVAC Division 2 control panel P873 -- Drywell Cooling and Primary Containment Purge Division I control panel P875 -- Primary Containment Purge Division 2 control panel l
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Some examples of how the "needs" and " inventory" comparison algorithm works are as follows:
Category Question Answer o Availability check Is component ID in Available or not
. . inventory available 6
o Control Mode Check Is switch type Suitable or consistent? unsuitable o Valve Action Check Is valve action Suitable or consistent with mode? unsuitable o Control Feedback Check Is flag specified? Suitable or Is backlit specified? unsuitable o Level of Information Check Does inventory type Suitable or match level need? unsuitable o Scale specified Do units of indicator Suitable or match the need? unsuitable o Divisions Check Does lower / upper range Suitable or match the need unsuitable o Annunciator Check Print legend This will be a 4
visual comparison 6
Some uncertainties and refinements were identified to be resolved (see examples below).
An example of an HE0 identification based on the RPV pressure E0P is:
Entry Level Top of Scale Scale Division Need 1037 psi 1200 psi 10 Inventory 1037 psi 1200 psi 20 This results in an HE0 based on the discrepancy of scale divisions.
Another example based on Containment /Drywell E0P is:
Entry Level Top of Scale Scale Divisions i
Need 1.68 60 0.5 Inventory 0 150 2 i
NMP-2 stated that an HE0 would be written based on the scale division discrepancy. The difference in top-of-scale numbers was not considered to be an HE0 because the needed top-of-scale value of 60 is within the 0-150 range of the inventoried instrument. However, this approach does not address the human factors suitability question of whether an instrument with 0 to 150 units scale range is suitable to display a variable that ranges from 1.68 to 60 units.
The NRC audit team objected to this decision on the basis that the discrepant i top-of-scale numbers should also result in an HEO. The audit team recommends that additional HEOs be written if other entry levels, top-of-scale numbers, or scale division numbers for the same meter appeared during the comparison.
Each case should become an HE0 to be assessed. NMP-2 will address this refinement of analysis during the completion of the comparison process.
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2.3 3 Conclusions The NRC audit team concluded that NNPCs methodology for a comparison of control room inventory and control and display requirements appears to be adequate and that use of this methodology should meet the intent of Supplement 1 of NUREG-0737. The NRC audit team recommends that: i o NMPC provide a description of the cross check process Stone and Webster and General Electric will use to verify the prints used for .
the control room inventory are an accurate representation of the control panels, o NMPC should make a statement in the Summary Report indicating that NUREG-0700 guidelines were used as the criteria to determine the RF suitability of components, o NMPC should ensure that the comparisons of operator information and control needs with the characteristics of control room instruments and controls adequately evaluate the human factors suitability of the control room equipment.
The NRC audit team concluded that the comparison systems and processes are adequately designed and when refined should result in an acceptable comparison and identification of HE0's.
2.4 CONTROL ROOM SURVEY 2.4.1 Requirement 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 correcti a. characteristics of displays, controls, equipment, panel layout, annunciators and alarms, control room layout, and control room ambient conditions that do not conform to good human engineering practices.
2.4.2 Findings The present DCRDR CR survey has been in process since October 1984, beginning with a control room that had undergone a previous human factors review in 1982. Some control room modifications from that review are still in progress. Details of the previous review were not extensively discussed by the NRC audit team. The present review follows NUREG-0700 guidelines. It is understood to be independent of BWROG check lists.
- The check lists now being used by the NMP-2 survey team appear to have been derived directly from NUREG-0700. Examples and descriptions of the format and content of all forms used to collect DCRDR data should be included in the DCRDR Summary Report.
NMPC stated that each HE0 identified by the Survey Team in the Control Room Survey is a deviation from HF criteria which will be examined to determine which are significant. Significant HEOs will be identified as Human Engineering Discrepances (HEDs) for which enhancements or corrective actions will be selected.
The NRC audit team observed that the incomplete state of the control room, the existence of unfinshed and open survey items (e.g., RSP, P-601, Fire Panel systems not operational (SNO), environmental measurements, emergency lighting, operator survey observations plus clean-up and resurvey work) contribute to the total amount of DCRDR work yet to be done. It was understood that most of the survey work already finished was done by consultant personnel. During the audit there was no specific discussion of how and when additional personnel would be, assigned to complete the survey. Any additional HEOs will add to t,he total of all identified HEOs which NMPC has committed to assess.
The Audit Team performed a mini-survey of selected parts of the control room and compared the 17 HEOs identified with those already listed among the NMP-2 HEOs. Nine (9) of the 17 had been identified by the NMP-2 survey. The eight (8) that had not been identified are paraphased below. Appendix A of this report contains a list of photos taken during the mini-survey.
Audit Team HE0 NMPC Comment o J-Handles are less than 3" These were not enecked in NMP-2 survey, from edge of P-852 but will be reviewed later
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o There is excessive use of A written NMP-2 record identified these key switches as a "to be investigated" non-compliance item -
o There is a possibility of These will be reviewed later inadvertent activation when changing light bulbs of '
back lit legend push-buttons o Some controls on P-601 are NMP-2 contends that these controls are more than 25" from the acceptably within the 29" extended edge of the panel reach guideline
. o On P-601 two meters have P-601 will be surveyed later unmarked scales and two meters are missing from the panel o On P-601 mimics do not P-601 will be surveyed later indicate end points o A KW load-set meter scale NMP-2 will survey this later on one panel had calibrations below zero o One panel contains Main These items will be picked up later Steam Pressure meters A and on task analysis or walk-throughs B, and Pressure Set Point indications A and B. Label character sizes and scale markings were not consistent between the A and B meters Due to the relatively high ratio of HE0's found by the NRC audit team and not identified by NMPC, the NRC audit team believes that a more comprehensive and thorough control room survey is needed at NMP-2.
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A specific item of concern is the lighting survey, both the emergency and normal lighting. The report chould include a description of the RSP lighting and the pathways which the operators must follow between the CR and the RSP.
The Summary Report should also include a description of how the control room survey will identify HEOs related to CR equipment compliance with NMP-2 conventions and standards (e.g. abbreviations, acronyms, colors, types of controls vs functions) and the HF suitability of these conventions.
2.4 3 Conclusions The NRC audit team concluded that NMPC appears to intend to meet the control room survey requirement of Supplement 1 to NUREG-0737. Due to the number of open survey items, the incomplete state of the control room, and the large number of apparently unfinished survey items, the NRC audit team could not make a final determination that the NFP-2 control room survey will be satisfactory. NNPC will need to provide the results of their completed survey to the NRC for review.
In completing the control room survey NMPC should ensure that the control room survey is comprehensive and thorough.
o NMPC should complete all unfinished and open survey topics and document all HEOs resulting from the surveys, o NMPC should address the specific HE0's listed in Section 2.4.2.
o NMPC should critically review the control room survey that has been conducted to date to evaluate whether there are areas of weakness in the current survey and to determine whether additional surveys are needed.
o NMPC should ensure that a description and evaluation of the emergency lighting is provided for review by the NRC.
l o NMPC should evaluate the suitability of standards and conventions used at NMP-2 and evaluate conformance to these standards and conventions ,
o NMPC needs to maintain an auditable trail for all survey
, documentation.
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2.5 HED ASSESSMENT 2.5.1 Requirement .
Supplement 1 to NUREG-0737 requires that HEDs be assessed to determine which HEDs are significant and should be corrected.
2.5.2 Findings The assessment process for NMP-2 was developed by their consultants, Stone and Webster. The process consisted of taking HEOs identified d.uring the DCRDR and placing them into one of four following categories.
Category 1 - HEOs associated with documented errors in similar plants included in the operating experience review Category 2 - HEOs associated with potential errors Category 3 - HEOs associated with low probability errors of serious consequence.
Category 4 - HEOs not associated with errors.
Then within each one of these four individual categories the HEOs were assigned one of five category levels.
Level A - Includes those HEOs for which the related documented (in similar plants) error was associated with a safety-related function, and
, resulted in unsafe plant operation.
Level B - Includes those HEOs for which the related documented (in similar plants) error was associated with a safety-related function, and resulted in violation of a technical specification.
Level C - Includes those HEOs for which the related potential error is associated with a safety-related function, and could result in unsafe operation or the violation of technical specification.
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Level D - Includes those HEOs for which the related potential error is associated with a nonsafety-related function, but could result in a plant outage or significant financial loss. -
Level E - Includes those HEOs for which the related potential error is associated with either a safety-related function or a nonsafety-related function, but could not result in unsafe operation, tre violation of technical specification, a plant outage, or a significant financial loss.
NMPC stated that the HEOs are assessed and assigned by category and level.
The HEOs assigned to categories 1 A,1B,1D, 2C, and 2D are considered to be significant HEOs and immediately become HEDs under the NMP-2 classification system. At this stage in the assessment process, NMPC stated that all category 1E, 2E, and 4 HEOs will be classified as non-significant HEOs and no further evaluation of these HEOs will be performed.
Based upon NRC staff comments concerning the Program Plan, NMPC stated during discussions at the in progress audit that HE0 category 1C has been eliminated. The NRC audit team is concerned that HEOs that would fall into category 1C may have been omitted from consideration and classification as HEDs just because they have not resulted in unsafe plant operation at another plant. Potential safety related errors that have been documented in similar plants and that have the potential to cause unsafe operation should be taken seriously.
At this point in the assessment process there are only two categories of HEOs left to be further assessed. These are categories 3C and 3D. In the program plan there are four assessment techniques discussed. The following is a list of the four techniques:
4 Technique 1 - Assessment by HE0 category and level.
Technique 2 - Assessment by HE0 significance rating.
4 Technique 3 - Assessment by HE0 mockup mapping and computer sorting of HEOs.
Technique 4 - Assessment by review team judgement.
According to NMPC all category 3C and 3D HEOs will be evaluated by two or more of the above techniques. At the present time NMPC states the assessment processes which will be applied to category 3C and 3D HEOs will be determined by the DCRDR review team leader. During the time of the audit NMPC was not sure of the methodologies to be used by the review team leader in the selection of the varicus assessment techniques to be used for th category 3C and 3D HEOs. NMPC has committed to provide the NRC, prior to the Summary Report, a description of the methodology used to select which techniques will be used in the assessment process.
There appears to be a great deal of uncetainty between NMPC and ARD as to who is responsible for particular steps of the assessment process. A formal description of these responsiblities will be provided in the Summary Report.
2.5.3 Conclusions NMPC appears to intend to meet the requirements of Supplement I to NUREG-0737. The NRC audit team recommends that the following actions be taken to improve the NMP-2 assessment process:
o NMPC should clarify the elimination of HE0 category IC and the disposition of discrepancies that are associated with that category, o NMPC should provide a detailed explaination of the four assessment techniques to be used to review category 3C and 3D HEOs to determine if they should become HEDs. This explaination should include the rationale the review leader will use in selecting which techniques will be used.
o NMPC should clarify and document who is responsible for performing all steps of the assessment process.
Until the above concerns are clarified, we cannot conclude that the HED assessment requirement will be met.
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2.6 SELECTION OF DESIGN IMPROVEMENTS 2.6.1 Requirement .
Supplement 1 to NUREG-0737 requires the selection of control room improvements that will correct significant HEDs. It also states that improvements that can be accomplished with an enhancement program should be done promptly.
2.6.2 Findings After all HEDs have been identified by the assessment process. NMPC stated that the following sequence will occur in the order indicated:
o Stone and Webster (S&W) will propose all initial engineering solu tions, o The DCRD.R review team will identify potential solutions for all valid HEDs, using a HF manual being developed by ARD for corrective action design and implementation.
o The entire Review Team w'ill meet and discuss alternative solutions for HEDs. The most appropriate solution will be decided based on team consensus.
o The Management Team will review and accept or reject the proposed solutions.
o S&W will review the Management Team decisions and prepare detailed recommendations.
o The DCRDR Team Leader will review the S&W recommendations, o The Team Human Factors Specialist will evaluate the S&W recommendations, w
o The Management Team will once again review the proposed solutions / corrective actions before implementation.
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b O An examination of typical HEDs reported indicated that the predominant HED source was the checklist, followed by the operator interview survey. Other sources mentioned were task analyses, verification of availabiliby, and validation of capability. There was some uncertainty about the total number of HEDs in each category, since it is expected that the completed survey will show overlapping and duplication among sources.
The HED forms contain space for the following information.
o Various identification and reference numbers o HED description o Comments o Source of discrepancy
- o Explanatory Information (including reference to NUREG-0700 guideline numbers) o Panel and equipment ids o Equipmont name It was understood by the 'NRC audit team that justifications for not implementing corrective actions would be written on the HED form. It was not stated whether or where a description of proposed or selected corrective actions or enhancements would be written on the HED form. This information should be included in the Summary Report, along with other pertinent information that will completely and unambiguously describe the intended uses of the forms.
2.6.3 Conclusions The NRC audit team concluded that a detailed explanation of NMPC's design improvement selection process and the results of that process east be provided in the NMP-2 DCRDR Summary Report in order to demonstrate that this requirement of Supplement 1 to NUREG-0737 is met. Design improvements to correct HEDs should be implemented on a schedule acceptable to the NRC.
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2.7.2 Findings, NMPC discussed the verification process in very cursory terms. There are many unanswered questions concerning the responsibilities of team members, reference materials to used, sid the overall methodology. It is not clear whether the simulator will be used, or how differences between the simulator and the Control Room will be' accounted for.
2.7.3 Conclusions The NRC audit team concluded that NMPC should formally document the design improvement verification process in detail in the NMP-2 DCRDR Summary Report.
2.8 COORDINATION OF CONTROL ROOM IMPROVEMENTS WITH OTHER PROGRAMS 2.8.1 Requirement dupplement 1 to NUREG-0737 requires that control room improvements be coordinated with changes from other programs: e.g., Safety Parameter Display System (SPDS); Operator training, Regulatory Guide 1.97 (R.G.1.97) instrumentation, and upgraded emergency operating procedures (EOPs).
2.8.1 Findings NMPC states that they conducted a mini-review of the control room in 1982. At this time NMPC states that R.G.1.97 was considered and therefore they feel they ha'ra met the portion of the coordination requirement which deals with R.G. 1.97. The NRC audit team is concerned whether a thorough HF evaluation of RG 1.97 instrumentation was performed.
It was stated during the in progress audit discussions that the NMP-2 review
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team leader is responsible for the coordination effort and all related activities. During discussions with NMPC it became that clear there is not presently any coordination effort among the DCRDR team, and the SPDS people and the E0P people. Neither was there mention of any effort in effect to coordinate the appropriate DCRDR activities with the NMP-2 training personnel. For NMPC to demonstrate a level of compliance with this NUREG-0737
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requirement they will need to provide a description of how training will be involved in this activity. A description of how the NMPC procedures and training people will be informed of design changes being implemented in the control room should also be provided.
2.8.3 conclusions The NRC audit team concluded that to demonstrate this requirement of Supplement 1 to NUREG-0737 is met, NMPC should formalize and document their methodology for the coordination effort.
The NRC audit team recommends that the DCRDR coordination effort include a review of the human factors suitability of control room modifications from other control room improvement programs. NMPC should confirm that revisions to procedures and operator training will be coordinated with implementation of control room improvements and modifications.
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3 CONCLUSIONS The NRC audit team believes that NMPC is willing to respond to the concerns and comments expressed in the body of this report. The NRC in-progress audit
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clarif1ed for NMPC the NRC DCRDR policy to require auditable compliance with Supplement 1 to NUREG-0737 and that compliance includes considering the guidelines of NUREG-0700 and the DCRDR evaluation criteria of the Standard Review Plan, NUREG-0800, Section 18.1, Appendix A.
Some specific major concerns are:
o The scheduled completion date of July,1985, for the Summary Report will be difficult to achieve cortsidering the status of the significant amount of work which still must be completed.
o More comprehensive resumes of team member and support personnel are needed. Specific DCRDR team member and support personnel task assignments should be provided.
o Details of the NMPC DCRDR orientation program are needed.
o NMPC needs to explain in detail in the Summary Report how the transition from the generic E0Ps to plant specific EPGs was accomplished and how the results were included in the task analyses.
o A description of NMP-2's methodology for incorporating changes in the EOPs into the SFTA.
o NKPC needs to provide a description of the cross check process to be used by Stone and Webster and General Electric to verify the prints used for the control room inventory are a accurate representation of the
! control panels.
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.t o A more complete and comprehensive description of the CR Survey process is needed in the following areas:
"HF manual references, format and content.
"How HEOs related to the HF suitability of NMP-2 equipment standards and conventions will be identified.
- Emergency lighting of CR, RSP, and passage ways between.
" Selection and justification of HE0's not to be fixed.
o Due to the number of open survey items, the incomplete state of the control room, and the number of unfinished survey items, NMPC will need to provide the final survey results to the NRC for their review.
o The completeness of the NMPC survey process can be questioned based on the NRC audit team mini-survey which identified 17 HEOs, only nine of which had previously been identified by the NMFC survey.
.. o A detailed explanation is needed of the four assessment techniques that are used in the HE0 assessment process. This explanation should also include the rationale that the Review Team Leader will use in selecting which techniques will be used. The elimination of HE0 category 1C should also be explained.
o A complete and comprehensive description of the processes and personnel assignments is needed for the selection of design improvements, o The verification process for control room design improvements needs to be formalized and reported in detail in the Summary Report.
o NMPC needs to provide a complete explanation of their formalized methodology and process for the control room improvement coordination effort in the Summary Report.
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There is some concern that insufficient time remains to ensure the completeness and high qua'.ity of 'the DCRDR effort and (the NMP-2 DCRDR)
Summary Report. The NRC audit team recommends that this situatio.n be addressed by NMP-2 to demonstrate to the NRC that all of the requirements of Supplement 1 to NUREG-0737 will be met on a schedule acceptable to the NRC.
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REFERENCES
- 1. NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident, "May 1980; Revision 1, August 1980.
- 2. NUREG-0737, " Clarification of the TMI Action Plan Requirements,"
. November 1980.
3 NUREG-0737, " Clarification of TMI Action Plan Requirements," Supplement 1, December 1982.
4 NUREG-0700, " Guidelines for Control Room Design Reviews", September 1981.
- 5. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants", Section 18.1, Appendix A. " Evaluation Criteria for Detailed Control Roca Design Reviews", September 1984
" Staff Comments on the Nine Mile Point Nuclear Station Unit 2 Detailed 6.
Control Room Design Review Program," memorandum from William T. Russell to Thomas M. Novak November 11, 1984.
- 7. Memorandum for Voss A. Moore, from S.H. Weiss, " Meeting Summary - Task Analysis Requirements of Supplement 1 to NUREG-0737 - May 4,1984 Meeting with BWR Owner's Group Emergency Procedure Guidelines and Control Room Design Review Committees," May 1984.
- 8. Program Plan Report, Detailed Control Room Design Review Nine Mile Point Nuclear Power Station - Unit 2 Niagara Mohawk Power Corporation, June, 1984.
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Appendix A Photo Log This photo log contains a list of the photos taken during the NRC audit team mini-review of the control room.
Photo Number Title
- 1. General Control Room Shots (wide angle lens)
- 2. General Control Room Shots 3 General Control Room Shots
- 4. General Control Rdom Shots
- 5. J-Handle switch less than 3" from edge
- 6. Panel 601, Excessive use of key switches
- 7. Key switches-Inconsistent direction of operation
- 8. Panel-603, Inconsistent mounting of key switches.
Some teeth up, some teeth down
- 9. Panel-603. Potential to inadvertently interchange lens of indicator light when changing bulbs.
- 10. Panel-603 contains a longer than recommended string of displays
- 11. Steam / water turbine panel (Saba Request)
- 12. Panel-601, controls more than 25" from edge of panel 13 Panel-601 Annunciator axes not labeled
- 14. Panel-601 Mimics have no end point markings