ML20137C111
| ML20137C111 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/13/1985 |
| From: | Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19269B587 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 A02959, A04818, A2959, A4818, NUDOCS 8508220206 | |
| Download: ML20137C111 (7) | |
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(203) 665-5000 August 13,1985 Docket No. 50-423 A02959 A04818 Director of Nuclear Reactor Regulation Mr. B. 3. Youngblood, Chief Licensing Branch No.1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Reference:
(1)
B. 3. Youngblood letter to W. G. Counsil, dated April 11, 1985, transmitting Supplement No. I to the Safety Evaluation Report for Millstone Nuclear Power Station, Unit No. 3.
Dear Mr. Youngblood:
Millstone Nuclear Power Station, Unit No. 3 Supplement I to NUREG-0737 Control Room Design Review in Section 18.0 of Reference (1), the NRC Staff identified four (4) items related to the Control Room Design Review (CRDR) for Millstone Unit No. 3 as being either incomplete, not addressed or not meeting the criteria of Supplement I to NUREG-0737. A meeting was held on July 18, 1985 with the NRC Staff to discuss these four (4) items. The purpose of this submittal is to docement those discussions and to assist in removing the CRDR as an outstanding item in Reference (1). Accordingly, a summary of the information provided to the NRC Staff on July 18, 1985 for each of the four (4) items is included in Attachment No.1. Additional information related to these four (4) items will be included in our CRDR Addendum Report, which is scheduled to be submitted on or about September 3,1985.
Most of the information contained in Attachment No. 2 is of the type which the Westinghouse Electric Corporation customarily maintains in confidence and withholds from public disclosure.
This information has been handled and classified proprietary by the Westinghouse Electric Corporation, and we hereby make application for withholding Attachment No. 2 from public disclosure pursuant to 10CFR2.790.
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l If any additionalinformation is needed, please do not hesitate to contact us.
t Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY et al.
BY NORTHEAST NUCLEAR ENERGY COMPANY Their Agent h b bNr
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Senior Vice President cc:
Dr. S. N. Saba (NRC Human Factors Engineering Branch)
STATE OF CONNECTICUT
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Then personally appeared before me J. F. Opeka, who being duly sworn, did state that he is Senior Vice President -of Northeast Nuclear Energy Company, an Applicant herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Applicants herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.
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Docket No. 50-423 l
Attachment No.1 Millstone Nuclear Power Station, Unit No. 3 Supplement I to NUREG-0737 Control Room Design Review t
August,1985
Docket No. 50-423 1
Attachment No.1 Millstone Nuclear Power Station, Unit No. 3 Supplement I to NUREG-0737 Control Room Design Review August,1985 4
Item No.1:
The sys.'cm function and task analysis process is presently incomplete. Some Emergency Operating Procedures (EOPs) prepared from the Westinghouse Owners' Group (WOG) Emergency Response Guidelines (ERGS) are.not fully developed and specific information characteristics required for the procedures are still under development. The NRC audit team determined that the applicant did not describe the processes to be used to identify the characteristics of needed instruments and controls.
Summary of Discussions:
l Revision I to the WOG ERGS provides the basis for generically identifying information and control needs. Information and control needs related to the plant-specific EOPs and deviations from the WOG ERGS have been identified by i
l the NUSCO Reactor Engineering Branch. The information and control needs were then compared against our control room inventory and the appropriate instruments and controls were selected for use with the EOPs.
The' remaining item was the determination of the specific characteristics of these instruments and controls. Westinghouse was retained to determine these characteristics (i.e., setpoints, units, range, resolution, accuracy, response time, l
and type of display). The details of this Instrumentation Characteristics Review i
Program (ICRP) and its associated methodology are included in Attachment No.
2.
Deliverable documentation from the ICRP included completed I&C Characteristic Requirements Forms and the supporting Characteristics Justification Tables. Examples of the I&C Characteristic Requirements Form and the Characteristics Justification Table are also included in Attachment No.
i 2.
l l
System function and task analysis is now completed for Millstone Unit No. 3.
Item No. 2:
l The comparison of the display and control requirements with a control room l
inventory is only partially completed.because the system function and task l
analysis is not complete. The results, when completed, should be submitted to l
the NRC for review and comments.
l l
Summary of Discussions:
As indicated in Item No.1, the information and control requirements were compared against the control room inventory to determine the appropriate instruments and controls for use with the EOPs. In addition, a comparison of the characteristics of the installed instruments and controls against the information provided by the ICRP described in item No. I has been performed. The actual characteristics were recorded on the I&C Characteristic Requirements Forms in the column marked VALID. (See Attachment No. 2.) Those characteristics which did not satisfy the specified~ characteristics were noted as Human Engineering Discrepancies (HEDs), prioritized, and are currently being evaluated to determine any necessary corrective action. The final resolution of these HEDs will be identified in the Addendum Report.
. Item No. 3:
The assessment of HEDs did not meet the requirements.
The assessment methodology should ensure that the assessment of safety significance and priority is not adversely influenced by problems in resolution or scheduling. All HEDs should be prioritized including those resolved by "no change".
Prioritization has been discussed in the NRC program plan comments and in the results of the in-progress audit report.
Summary of Discussions:
The purpose of assessment is to determine HED significance and "suggest the priorities according to which the HEDs are considered for corrective action".
(See N UREG-0700, Section 4.3.)
This section indicates that early implementation is desireable whenever possible. NNECO has recognized the importance of early implementation and has proceeded to correct, where possible, all HEDs prior to fuel load. Consequently, during the assessment phase, those HEDs which were scheduled to be corrected prior to fuel load were not prioritized.
In order to be conservative, HEDs were written for all cases so they could be assessed by the full core team to insure a problem was not overlooked. Also, HEDs were written for any item that was questionable by the reviewer and in some cases was caused by an unclear understanding of the system / process involved.
It is important to understand that the triage methodology was a screening of all HEDs for practical workability of the assessment process.
Therefore, outstanding HEDs listed in Figure 19 'of the Summary Report were deferred not because the " team cannot decide on relatively simple solutions" but rather since further study and assessment was required. For example, HED CC-010 states that the "use and meaning of a white light is not consistent". This HED was deferred for further review to determine the use of each white light identified in the HED as it was not immediately obvious to the team.
Although the criteria of safety significance is not listed in the Assessment Triage Methodology Flowchart (Figure 14a in the Summary Report), this criteria was uppermost in the core team's evaluation of all HEDs. Although not included in the chart,it is stated in the methodology discussion of assessment on page 13, Section 1.4, of the Summary Report.
The Assessment Triage Methodology Flowchart will be revised in the Addendum Report to more accurately reflect the decision-making process that took place.
Safety significance was also included as a criterion in the " tie-breaker" methodology shown in Figure 15 in the Summary Report. However, we intend to delete the " tie-breaker" concept in the Addendum Report because it was never needed.
As shown in Figure 19 of the Summary Report and as will be documented in the Addendum Report, all HEDs which will not be corrected by fuel load or justified as "no change" have been prioritized and include a disposition code as stated in the Program Plan. The forty-nine (49) HEDs which are to be corrected by enhancements to the control boards but were not prioritized or scheduled for
l,
correction in the Summary Report, are scheduled to be corrected prior to fuel load. On a related matter, we intend to revise the definition of a Priority ~ 3 HED to delete any reference to safety significance since Priority 3 HEDs only relate to minor consequences to the reliability of operations.
In conclusion, we believe that the safety significance of each HED was adequately addressed during the assessment phase by the core team, it is recognized that scheduling did have an influence on the assessment phase of the review, however, this influence was one of a constructive nature (i.e., to promptly correct deficiencies found) rather than an adverse one.
Item No. 4:
The' verification program leaves some gaps and does not fully meet the requirement.
The methodology used and the additional information given verbally to the NRC audit team is adequate and should be confirmed in a supplement to the Summary Report.
Summary of Discussions:
As the class and individual improvements were being selected, they were first implemented, whenever possible, on the full scale control room mock-up for review and approval by the core team. An integral part of this approval was to verify that each corrective action resolved the HED in question.
These improvements were then added to the control board arrangement enhancement drawings for inclusion into the enhancement design. Those of a nature unsuitable for implementation on the mock-up (e.g., computer sof tware, ESF panel circuit modifications, etc.) are being reviewed on the control boards as they are -
implemented.
The enhancement design was an iterative process of review and approval. The first step was the initial design by the 1/2 scale Computer Aided Draf ting System to enable the core team to review the entire hierachical labelling that was recommended. This iteration was then reviewed by the core team and the operations and training departments for their comments and suggestions.
The second iteration was a revised issue of these drawings incorporating the comments of the first. This version of the enhancement design was implemented on the mock-up. The core team then reviewed this design for further corrections and/or improvements. In addition, the operators undergoing training in the same building were queried for comments and suggestions which were then incorporated into a third and last iteration.
The mock-up was then updated to the last iteration for review and approval by the core team. Walk and talk throughs were then performed to verify that the HED concerns were indeed addressed.
- ne various iterations discussed above assured that the HEDs were corrected by the enhancements and that no new HEDs were introduced. The validation of the review was performed in accordance with the methodology in the Summary Report and the findings will be addressed in the Addendum Report.