ML20128G736
| ML20128G736 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/21/1985 |
| From: | Britt R WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton, John Miller Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, TAC-57793, TAC-57794, NUDOCS 8505300291 | |
| Download: ML20128G736 (12) | |
Text
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s,
L Wisconsin Electnc ma cown 231 W. MICHIGAN, P.O. BOX 2046. MILWAUKEE, WI 53201 May 21, 1985 Mr.
H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D.
C.
20555 Attention:
Mr. J.
R. Miller, Chief Operating Reactors, Branch 3 Gentlemen:
DOCKET NOS. 50-266 AND 50-301 RESOLUTION OF NRC CONCERNS REGARDING THE CONTROL ROOM DESIGN REVIEW PROGRAM PLAN POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 On July 31, 1984, we submitted a program plan describ-ing our methodology for conducting a detailed control room design review (CRDR) of the Point Beach Nuclear Plant control room.
This plan was prepared to comply with the requirements of Supplement 1 to NUREG-0737, as contained in NRC Generic Letter 82-33.
In your letter to us dated January 22, 1985, the Staff transmitted the results of their evaluation of our CRDR program plan.
Although the plan generally meets NRC requirements, the Staff identified ten concerns which they believed "if resolved, would increase the benefits of the CRDR and the likelihood that the Supplement 1 requirements would be met."
A meeting was held with Messrs. Colburn and Serig of your staff on April 3, 1985 to resolve these concerns and to discuss the status and schedule for conduct of the CRDR at Point Beach.
A subsequent telephone conversation was held with Messrs. Colburn and Serig on April 16, 1985 to further clarify our responses to the staff concerns.
The purpose of this letter is to confirm our responses to the staff concerns and to provide an updated schedule regarding the conduct of the CRDR at Point Beach.
Our responses to the concerns are provided in to this letter.
Most of the responses involve clarifications or minor modifications of our program plan.
Two significant areas of concern involved our proposed use of a control room survey checklist, which was significantly different from the NRC's NUREG-0700 Section 6 checklist, and the use of a 8505300291 850521 PDR ADOCK 05000266 3
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-Mr.fH.~R. Denton. Maj 21, 1985 teost/ benefit analysis in the assessment of human engineering deficiencies (HEDs).. Based on a detailed comparison of.the control room survey checklists contained in'both our program plan and NUREG-0700, Wisconsin Electric has decided to use the reformatted NUREG-0700 control room survey checklist-and to add.several items from ourl program plan checklist not found in NUREG-0700.
Regardingsthe use-of a. cost / benefit analysis in evaluating HED
~
resolutions,iWisconsin-Electric. believes that this is an appropriate technique to.use_in comparingLand assigning priorities.to proposed
-HED resolutions.
However,.we are committed'to. correcting all accident-related HEDs regardless of the results of a cost /be'nefit analysis.- We trust that our responses address each of the
' concerns.
In'a Commission Order dated July 2,.1984 (revised February 5, 1985) Wisconsin Electric was requested to submit a Laummary report of the results of our CRDR at Point Beach no later than October 31, 1985. -We are presently conducting the CRDR and have reevaluated the schedule which was included in-the program plan submitted to the NRC on July 31, 1984.
As.
- discussedLat the. April'3 meeting, we now believe that the Octoberf31, 1985 dategis not feasible'if.a thorough and effective CRDR is to
.be conducted. lA revised schedule for the conduct of the CRDR at_ Point Beach is provided in Attachment 2 to this letter.. We
-request that~the required submission date for the sunnary report be revised to March 31, 1986.
Additionally, since our schedule has been shifted, we
. request that the in-process _ audit, tentatively scheduled for May.1985,,be changed to November 1985.
This will allow the NRC
'to audit'the-CRDR at the.same relative point as requested in your LJanuary 22, 1985~ comment letter.
There are three reasons which we believe justify requesting.these delays. ;First, the completion of planning phase tasks,:specifically the fabrication of aJfull-scale photographic mockup of the Point' Beach control room and the selection of a human factors consultant'to assist us in the conduct.of the CRDR, was delayed by unanticipated problems during the f all 1984' refueling outage of Unit 2.
Resolution of the. outage problems tied up the personnel evaluating bids on those projects.
The photography-i work.for the mockup was delayed-until December 1984 due to unanticipated delays in the installation of the new auxiliary
-safety instrumentation panels (ASIPs) in the Point Beach control room.
We wanted the mockup to include the latest configuration of the ASIPs which contain readouts for several new post-accident monitoring instruments installed in response to NUREG-0737.
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2 Mr. H. R.;Denton May 21, -1985 The' mockup was completed in late March 1985, approximately five months.later than originally-anticipated.
The selection of General Physics-Corporation _as our' human factors consultant was completed in~ December 1984..- Following several1 planning meetings with General. Physics, the human factors orientation of the CRDR team was conducted-in March-1985, approximately two months later than1 originally _ anticipated.:
Second, the CRDR is very closely linked to the Emergency' Operating Procedure (EOP) -upgrade effort.
We are requiring that
'the; upgraded EOPs-be used as_ a basis for the system function review
.and' task analysi~s (SFRTA) portion _ of ; the detailed CRDR.
The final' drafts of-the upgraded EOPs will not'be available'to start the-SFRTA untilithe.end of May 1985.
,The delays in'the EOPs,were
- discussed in our. letters to you dated October 26 and December 6, 1984.- -Thisiis'a significant delay'from~the" original schedule for
'the:SFRTA and causes a' corresponding delay in two other execution phase tasks;<namely,. verification of required instrumentation and-
' validation-of control room functions.
These two tasks are-now
-scheduled.to be completed in November 1985, approximately six months
'later than originally anticipated.
Third,.the concerns identified in your January 22, 1985
-letter required us to review and modify our CRDR progran plan.
We'did not launch fully ~into the execution phase tasks until'we had developed proposed resolutions to-the~ staff concerns, thus avoiding potential duplicate or wasted effort.
Experience at other
-power-plants indicates that a comprehensive and effective CRDR
~
typically takes a minimum of one year.to complete.
Work on CRDR
. execution phase tasks.for Point Beach began in March 1985 and is now proceeding at'a strong pace.
Therefore, we:believe that the requested March _ 31, 1986 deadline for submittal of a summary report is.both1 reasonable and realistically attainable.
If you have any questions regarding this matter, please contact us.
Very truly yours, 12/b
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resident
'R. W.'Britt' Attachments
' Copy to.NRC Resident Inspector
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'1 May 21,.1985
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A i Attachment 1-
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3 RESPONSE TO NRC CONCERNS-REGARDING THE POINT-BEACH: NUCLEAR ~ PLANTS CONTROL' ROOM DESIGN REVIEW PROGRAM PLAN y
El~.~. [Many o'f the - tasks. of the control room design ! review. (CRDR) appearito:.be - assigned solely nto, the' human ; factors ' consultant (HFC) rather than to1some appropriate combination of Point'
.. Beach and4HFC'per onnel.
RESPONSE
gy Theidistribution:of work in Table'5.1 of the program plan does not'accuratelyireflectithe actual participation. in. the
- 3 :
- work. _It-is planned andmexpected"that Wisconsin Electric (mainlyflicensed Point Beach. personnel) will. be involved in
- the system function review and-task analysis (SFRTA)'and
' validation of control room function? tasks.
The control room-
' inventory and verification,of-instrumentation are simply data
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compilation 3and' comparison work"that can be done by General' Physics Corporation (GPC)1and will. receive normal supervisory.
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'and review participation by Wisconsin Electric personnel.
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Thefassessment. phase will~ require considerable Wisconsin ~
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< Electric involvement by the C.RDR' team and others.
.A better Jdefined levelof-participation summary table is attached.
2.
'A plant < orientation for'HFC members unfamiliar with Point Beach did'notnappear'to be part cfLthe proposed orientation gW program.
' RESPONSE' The plant orientation of HFC members unfamiliar with-Point n,
Beach was= inadvertently left out of'thelprogram plan.
As part'of the CRDR team orientation on March.8,.1985, an intro-
. duction ~to and tour of Point' Beach was provided to HFC personnel.
Any HFC personnel notiat the orientation will receive theRsane' basic plant orientation,.if necessary to perform their-
' assigned functions.
In addition, an. introduction and overview uof-human factors' engineering,1 systems analysis techniques, and related CRDR review ~and assessment processes were presented
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by the HFC:to the Wisconsin Electric personnel as'part of'the orientation.- This orientation'will be added to a revision
- of the CRDR program plan.
o L3..
The program plan does not address CRDR team validation of Emergency Operating l Procedures (EOPs)that are revised as'a result of-the validation activity.
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- ' Attachment J1-May 21, 1985
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- RESPONSE ~.
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'Thelproposed revisions to EOPs'as'a result'of CRDR effort-lwillErequireithat the normal. process;for review and' approval c
of changes to' procedures be followed.; -Note that Figure 2-1 of the. program plan ' requires. human. engineering deficiency. (HED)
. resolutions to be.. verified for correction of a problem without-s;-
l introducing other.HEDs.,It:is intended;to use the. photographic mockup for:this' verification activity. LAlso, all solutions 70
'are' validated in the effectiveness: phase of the program plan,-
.?
Jwhich would include.any revised EOPs.. No -specific procedures.
- for'HED; resolution,. verification, or_ validation are discussed
.inithe program plan; since it is.notLknown exactly.what form
-those resolutions may take at thisftime.
As-this becomes apparent-during the execution' phase, validation methods.will
'be defined.and procedures' described in a revision of the CRDR'
' program-plan.
4..
Uselof'the control: room survey checklists will probably.not result in~a successful control room; survey.
RESPONSE
-Wisconsin Electric has decided.to use the reformatted NUREG-0700 Section 6 control room survey checklist rather.
thanithe program plan checklist..However, fifteen items from
~
the Wisconsin Electric program plan checklist will be-added
?to the-NUREG-0700 checklist.
In addition, the specific.
anthropomet'ric limits from the program plan checklist will~
7 be substituted into the NUREG-0700-checklist in place of.the-
' references to195% male'and'5% female.
5.
The Point Beach program plan assessment methodology does not describe what. criteria will be used to determine-the-" accident -
related-potential" of an'HED.
RESPONSE
If a TED affects the performance of a task identified in the accident response-based SFRTA, it'is considered'to have
" accident-related potential".
Similarly, if a HED could result'in' violation of'a Technical Specification, it is
" Tech Spec-related" (see revised Figure 4-1).
These criteria 1will im included in a revision of CRDR the program plan.
-6..
The; assessment process does not appear to consider the aggregate effects of HEDs.
RESPONSE
s All HEDs are1to be screened for resolution.
By. reviewing y*
HEDs against design conventions and' cross listing HEDs on.a computerized data base -(IBM AT using Ashton-Tate's dBase
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-Attachment 1 May 21, 1985 III data base handling software)'lar guideline or checklist item, control room area, panel, system, equipment, and component (as applicable) to check for patterns, aggregate effects of.HEDs should be recognizable and will be handled accordingly.
General Physics will document this process as part of their normal HED review.
The revised HED record form (attached) will be used to document all HEDs so that an integrated assessment and resolution of these related HEDs can be performed.
7.
It appears that several of the criteria for determining the validity of a HED could remove HEDs from consideration for correction without adequate assessment.
RESPONSE
The methodology for screening of HEDs has been revised to eliminate the flow-path item which allows dismissal of a HED before it is adequately assessed for safety significance.
All HEDs will be assessed for safety significance, i.e.,
accident-related and Tech Spec-related, per the attached
-revised flow chart (Figure 4-1).
This assessment will be documented on the attached revised HED record form.
- 8.. It appears that a cost / benefit analysis may be used as the sole basis for determining whether some HEDs should be corrected.
RESPONSE
As noted above, the methodology for HED assessment has been revised.-
While in some cases the NRC concern is accurate, it should be noted that a cost / benefit; analysis alone does not result in non-implementation for a number of HED evaluations.
Assignment.of dollar values to " benefits" is very subjective.
Hence, while a higher cost than benefit situation may
-occur,)the HED may still.be corrected.
For example, all accident-related HEDs have a resolution priority of 1, 2, or 3 and should be corrected.
This will occur as a result of the "HED priority" screening to be'done under the revised methodology.
See attached HED assessment flowchart (Figure 4-1) and attached revised HED record form.
9.
A HED-by-HED approach to selection of design improvements may result in piecemeal improvement of the control room.
RESPONSE
By utilizing the design conventions established in the control room inventory and through common supervision of improvement design work, we'can minimize or eliminate'this problem.
With the intended use of the photo mockup for both i
. May 21, 1985 design and verification, interactions will be recognized and any. piecemeal work will be prevented, as much as.possible, resulting in an integrated solution.
In addition, as discussed
'in our response to Item.6, all HEDs will be cross-listed and sorted by design review attribute, as appropriate, so that.they can:be assessed and resolved in an integrated manner.
10.
Mechanisms for verifying that selected design improvements
.will provide for.necessary corrections and will not introduce new HEDs were not described.
RESPONSE
The program plan.does not spell out a specific procedure for verifying the impact or effectiveness of resolutions.
A~ procedure which documents this methodology is committed to be developed during the execution phase.and put in place to evaluate proposed resolutions.
It is our intention, however, to use the control room photo mockup to test resolutions-and-then:to verify and validate HED resolutions.
The methodology developed will be incorporated into a revision of the CRDR program plan.
This process will be
-documented on the attached revised HED record form.
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4 LEVEL OF PARTICIPATION SIM4ARY rt re i
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O 1.0 PLANNING PHASE 1.1 Select HFC C/RC W
RC RA
.2 Procure CR Mockup C/RC W
RC RA et
.3 Conduct HF Orientation C/W W
W W
W W
2.0 EXECUTION PHASE 2.1 Historical Document Review C/RA W
RC RC C/RC RC RA 2.2 Ooeratino Personnel Survev RA 2.2.1 Operator Questionnaire C/RA W
RC RC RC C/RC W
2.2.2 Operator Interview C/RA W
RC RC RC C/RC W
?.3 CR Survey C/RA W
W/RC W/RC RC W/RC W
RA 2.4 SFRTA C/RA W
W/RC W/RC W/RC W/RC T
T W/RC RA 2.5 CR Inventory C/RA W
RC RC W
RC RC RC RA 2.6 Verify Instruments C/RA W
RC RC RC 2.7 Validate CR Functions C/RA W
W/RC W/RC W/RC W/RC T
W W/RC RA 2.8 Compile HEDs C/RA W
RC RC RC RC
3.0 ASSESSMENT
PHASE 3.1 HED Evaluation C/RA W
W W
W W
T T
T T
3.2 Resolution of HEDs C/RA W
W W
W W
T T
T RA T
T T
T/RA 3.3 Definition of Relative Costs
- /W/RA W.
W W
W W
T T
T T
T T/RA 3.e Verifv HED Resolutions
- /W/RA W W/RC W/RC W/RC W/RC T
T T
T T
T RA 3.5 Schedulino HED Correction
- /W/RA RC W/RC RC W/RC W/RC T
T T
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T RA 4.0 DOCUMENTATION PHASE 4.1 Task Reports C/RA W
RC RC RC RC RA 4.2 Sumary Report C/RA W
RC RC RC RC RC RA RA Key _:
4.3 General Documentation
- /W/RA W RC RC RC RC RA 5.0 CORRECTION PHASE W,
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y Participation 6.0 EFFECTIVENESS PHASE 6.1 Prepare HF Procedure C/RA W-RC RC RC RC RC RA RC Review & Coment RA Review & Approva,l 7.0 SPECIAL STUDIES T Technical Suppor0 7.1 SAS Location Study C/RA W
W/RC W/RC W/RC W/RC RC RA RA 7.2 Ooerator Staffina C/RA W
RC W/RC RC W/RC T/RC HC/T RA RA
" Enclosure NEO v#
Resolution Pr_io ity I
2 3
4 NEN0 40 xFERiENCEO-vEs HED BEFORE Priority OEFIIIENEllIFY Yh~
ACCIDENT RELATE 0 REs0LUTION NO yg x
OEFINENERIFY AVORABL TECIL PEC. Vu.
RELATEn REs0LUn0N isENEF
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N0 1
8 DEFillENERIFY FAVORASLE c0sTMNEFIT
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DEFisiEuERiFv 8
REscum0N (7
ACCIDENT ERROR RELATED E
yg "3 DEFiNEuERin ayan,at REOLUTION 18 0 m
FAVORASLE 11 0 pE50
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COBT/SENEF
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ERROR CN. sFEc.
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/OENEF NO 8
VEs x
NO 7
DEFiNEutRiFv 11 0 -
ABOLUTION FAVORA8LE COST /DENEFIT ERROR NO 5
KEY:
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DEFINEhWW U
ENNANCEISENT EIIetc e
REC / REC - ERROR REC 0emm0N M NO 8
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riouME 4-t HEo=======asesY Flow Priority Key:
- 1. Correct ASAP.
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- 2. Correct as soon as 4
I practicable.
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- 3. No specific completion date.
- 4. Correction not recommended
Attcchmsnt 1 Enclosure HUMAN EN61NEERIN6 DISCREPANCY RECORD POINT BEACH NUCLEAR PLANT INo.
==================================================================
I.
IDENTIFICATION Origin:
Guideline / Checklist Location:
Control Roos Area Panels Systems Equipment:
Components Description of Discrepancy:
4 Proposed Resolutions Prepared By:
Dates
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==================================================================
II.
EVALUATION l
HED Experienced Before?
YES NO !
Accident Related?
YES ! !
NO l,
Technical Specification Related?
YES ! !
NO : !
Error Recognition / Recovery Expected?
YES I i NO N/A t
Cossents:
i l -
t l
i HED PRIORITY:
Reviewed and Approved - CRDR Team:
Dater
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/
==================================================================
Notes t
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1 of 2 HED FORM REV. 1 - 5/7/85 I
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HUNAN ENGINEERING DISCREPANCY RECORD POINT BEACH NUCLEAR PLANT lNo.
==================================================================
I!!. RESOLUTION / VERIFICATION Definitions Verified?
YES : !
NO I
' Description / Documentation:
Relatg.d_ Effects:
- ! Procedures
-l Training
! ! Task Analysis
! :- Crew Interaction
! : Related HEDs Favorable Cost / Benefit?
YES NO Description / Documentations i
Resolution Priority:
1 2
3 :
4 Schedules i
Reviewed and Approved - CRDR Team:
Dates
/
/
Approved - PBNP Nanager:
. Dates
/
/
==================================================================
IV.
CORRECTION / VALIDATION:
Correction Completed:
Dates
/
/
Documentation:
Attachment Effective?
YES : :
NO New HEDs Created?
YES : :
NO Comments:
i i.
Reviewed and Approved - CRDR Team:
Dates
/
/
I HED FORN REV.1 - 5/7/85 2 of 2
_.. _,., _.. ~ _. _. _.. ~. _ _. _. - _ _ _
05/21/85 Attachm nt 2 1
POINT BEACH NUCLEAR PLANT CONTROL ROOM DESIGN REVIEW SCHEDULE c
CADA ACTivlTY MONiltB E
I888 3888 SCT NOW SEC JA81 FEB MAR APR MAY JUN JUL AUS SEP OCT It0V OEC JAN FEB MAR APR MAY j
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15 SCHEDULING HE0 CORRECTIONS 4.0 00CUGIENTAfl04 PIIASE 2l hf 2 f q
41 TASK REPenit 4.2 SussIAAAY REPORT
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.7 EO CORREstl001 PIIAGE TO SE SCNEOULEO l
l Le EFFICTIVENESS PNASE f tl BE SCHEDULEO 79 SPECIAL STU0eE3 f.I SAE LOCAT10N BTUOY F.3 OPERATOR STAFFING STUOY CRDR SCHEDtJLE