ML20140B661
| ML20140B661 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/14/1986 |
| From: | Papanic G YANKEE ATOMIC ELECTRIC CO. |
| To: | Lear G Office of Nuclear Reactor Regulation |
| References | |
| FYR-86-032, FYR-86-32, NUDOCS 8603240262 | |
| Download: ML20140B661 (19) | |
Text
'
t Tzt phons (617)872-8100 TWX 710380 7619 YANKEE ATOMIC ELECTRIC COMPANY FYR 86-032 2.C2.1 W
1671 Worcester Road, Framingham, Massachusetts 01701
,Yauxes
~
March 14, 1986 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Mr. George Lear, Director PWR Project Directorate No.1 Division PWR Licensing - A
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b) YAEC letter to USNRC, dated March 28, 1984 (c) USNRC letter to YAEC, dated June 12, 1984 (d) YAEC letter to USNRC, dated January 7, 1985 (e) YAEC letter to USNRC, dated August 1, 1985 (f) USNRC letter to USNRC, dated January 13, 1986
Subject:
Detailed Control Room Design Review Summary Report, Supplement 1
Dear Sir:
A meeting with the NRC staff was held on January 23, 1986 to discuss the Detailed Control Room Design Review (DCRDR) Technical Evaluation Report (TER) for the Yankee Nuclear Power Station [ Reference (f)]. As a result of the meeting, Yankee committed to supplying various programmatic and specific information to action items identified in the TER.
The attachment to this letter provides the programmatic information requested. Based on the meeting results, we believe that the enclosed information will be responsive to the TER action items. Therefore, we have initiated additional action to.espond to the specific information relative to the evaluation of Human Engineering Deficiencies (HEDs) using the methodology in the attachment. We expect to complete all currently identified corrections within the next two refuelings and will have a tentative schedule for implementation by the end of April 1986. Once the schedule has been developed, we suggest that another meeting be held to go over individual HED evaluations and the schedule for their corrections. The schedule could be
)
effected by the resolutions selected and we believe that a-meeting is the best format to reach agreement on individual HED corrections.
!f you have any questions on the information attached, please contact us.
Very truly yours, 8603240262 660314 PDR ADOCK 05000029 P
^
Georg
- apanic, Senior Project Engineer Licensing
)
CP/dsm Enclosure
]
s RESPONSE TO NRC REVIEW OF
SUMMARY
REPORT 1.
QUALIFICATIONS AND STRUCTURet OF THE DCRDR TEAM a.
Provide docunentation of the level of involvement of each of the review tean personnel in each of the following activities:
(1) Selection of design improvements.
(2) Verification that the improvements provide the necessary corrections without introducing new HEDs.
Response
HED corrections for Yankee can be broken down into three categories
- HEDs for which specific corrections have been recommended and accepted, HEDs for which a general correction has been recommended, and HEDs which require further study before a final correction can be developed. For all three categories, the level of involvement.
for each of the review team personnel-will be essentially the'same.
The review team, including the human factors specialist, will stay in existence until the HED corrections are finished. They will regularly review the work being done with respect to the selection of design improvements. The team, including the human factors specialist, will review the conceptual and the final design related to the correction of each HED to insure that the design change corrects the HED.
They will review the results of each study-to insure that the resulting design corrects the HED.
The review will include a verification that the improvements provide the necessary corrections without introducing new HEDs.
2.
FUNCTION AND TASK ANALYSIS a.
Provide documentation demonstrating the comprehensiveness of EOPs and task analysis in covering tasks performed and interfaces involved in emergency operations.
Response
In 1980, Yankee Atomic performed a " mini" Probabilistic Risk Assessment (PRA) to assist in evaluating mandated design changes to the Yankee station. This was followed by a broader scope PRA during 1981 and 1982. Figure 2-5 (enclosed) is a' synopsis of the effort.
Over one hundred thousand scenarios were considered. In parallel, the NRC was working with various owners ~ group emergency procedure committees to analyze and proceduralize multiple failure scenarios.
Because of the many possible scenarios, the industry faced the prospect of adding hundreds of event-based procedures to the operator's burden which was obviously impractical. Therefore, a broader approach to recovery from emergencies, especially multiple failure scenarios, had to be developed. Yankee's approach was to combine the plant-specific PRA with the procedure effort to develop a practical set of higher level procedures for the operator to use during an emergency.
7 Yankee first examined the risk profile from the PRAs and made several conclusions:
1.
The systems at Yankee that. prevented core melt were the Fuel Cladding System, the Main Coolant System.-the Secondary Coolant System, and the Vapor Container System.
l 2.
The only two criter'la (system functions) for these systems was that they remain intact for postulated scenarios (system-integrity function) while scram, makeup, steaming and letdown-remain operable (system operability function).
3.
The system that always prevented core melt, if intact, was the Fuel Cladding System. Thus, from an operator's perspective, the critical function to be assured under all conditions is Fuel Cladding Integrity (FCI). This is shown as the Yankee task analysis goal on Figure 1 (enclosed).
In human factors, there is event-space where everything is known about system integrity and operability and the only unknown is time, or there is function space where nothing is known about the system configuration but one has plenty of time to diagnose what is intact and what is operable.
In operations analysis, events are mechanistic activities while functions are nonmechanistic activities to be assured independent of the initiating event. An examination s
of Level 6 and Level 7 of Figure 2-5 plus examinations of the pre-TMI Yankee startup, scram, and shutdown procedure gave the following functions for the operator to control:
a.
Reactivity Control J
b.
Main Coolant System Inventory Control c.
Main Coolant System Cooling Control i
d.
Secondary Coolant-System Inventory Control e.
Secondary Coolant System Cooling Control f
f.
Vapor Container Integrity Control Function-Based Procedures and Instruments 4
i For function-based procedures, Yankee created a small' set of nonncchanistic procedures that an operator could use in a structured manner to ascertain the plant system configuration, and then recover from the condition, independent of initiating event. Some logical i
arbitrary decisions had to be made:
1.
Reactivity control would address only too much reactivity, too little reactivity was too trivial.to pursue procedurally.,
t
2.
Main Coolant inventory's two procedures would pursue icw inventory due to losses to the secondary system and low inventory due to losses everywhere else, high inventory being trivial to pursue.
3.
Main Coolant cooling control would be renamed Core Heat Removal with one procedure to encompass pressurized thermal shock (high pressure, Icw temperature operations) and another procedure to deal with inadequate core cooling (high temperature, low pressure operations).
4.
Secondary Coolant inventory control and Secondary Coolant cooling control were consolidated into one task (Secondary Cooling / Inventory Control) but with four procedures to deal with too little cooling (high SG pressure), too much cooling (low SG pressure), too little inventory (low SG water level),
and too much inventory (high SG water level).
5.
Vapor Container Integrity control would have one procedure dealing with containment overpressurization. It was decided that the under pressure case could be dismissed since no feasible lineup could be created to draw a vacuum in the vapor container.
At this point in the development of the procedures. EPRI and Yankee management decided to install a prototype Safety Parameter Display System (SPDS) at Yankee. Because of our previous efforts on nonmechanistic procedures, we were able to immediately decide upon the seven leading symptoms for the SPDS design and they were:
1.
Neutron Flux 2.
Secondary Pressure 3.
Secondary Level 4.
Secondary Radiation 5.
Main Coolant Pressure 6.
Main Coolant Temperature 7.
Vapor Container Pressure In addition to these " leading symptoms," more instruments were added to round out the operators assurance that the function (task) was being maintained for all events. Figure 1 contains the instruments that the operator's use to assure maintenance of the tasks.
Horizontally, a quick scan of the seven leading symptoms by the managing operator serves to take the station's pulse. Vertically, l
j should a primary side or secondary side operator decide to operate to restore a function, the related instruments for each task are columnized on Figure 1.
Horizontally, a slow scan of the five 1 -
t groups of task maintenance variables provides the managing operator with an in-depth assessment of how well the primary or secondary operators are operating or maintaining the five tasks.
In summary, the task analysis was a comprehensive probabilistic safety study which identified the corporation's risks as well as the goals for an operator to assure fuel cladding integrity. The EOPs used in the CRDR were those function-oriented procedures which were designed to assure maintenance of the tasks that assure fuel i
cladding integrity.
b.
Provide documentation either (1) describing the performance and results of an analysis of those tasks which have "I&C requirements" of a vague or general nature (as represented by the examples provided in the NRC in-progress audit report) to provide the necessary details or (2) demonstrating that for each instance where the level of detail was too vague or general, the level of analysis suggested in the NRC's example was not necessary.
Response
To meet the requirement of NUREG-0737, Supplement 1, Section 5.1.b(ii), a DCRDR task analysis of the Emergency Operating j
Procedures (EOPs) was undertaken to derive information and control needs for emergency operation of Yankee. It also allowed adherence to the guidance of other NRC documents that the DCRDR task analysis be independent of the existing Control Room equipment.
Certain assumptions had to be made for the DCRDR task analysis:
f 1.
The EOPs cover the emergencies of interest.
2.
The I&C needs and requirements derived are only those concerned with human factors, the man-machine interface. Unless specifically needed to implement the procedures, no electrical, electronic, or mechanical specification were assumed. Voltage levels, intermittent or maintained contact switches, discrete versus continuous controls, etc., were not assumed unless that 1
was the only method that would enable the task specified in the EOP step to be accomplished.
3.
If the derivation of I&C needs is to be truly independent, the reviewer or consultant in Yankee's case must be unaware of plant-specific knowledge of the I&C channels.
Consequently, since the number and sequence of relays in a control channel is i
not known, he should not attempt to specify whether the switch should close or open a circuit. His concern is only the availability of control and information in the form most useful j
in implementing the EOP.
4.
The level of detail for I&C requirements suggested in the Audit Report and the response to the Summary Report, will appear in the detailed engineering design change implemented to correct the Human Engineering Deficiencies (HRDs), and will reflect a detailed knowledge of the existing plant circuitry and l.
4 equipment. The corrections do not attempt to maintain independence, and require knowledge of the existing equipment.
Engineering design changes will be reviewed for human factors and for their capability to address the concern raised in the HED.
In the process of meeting the requirement of Section 5.1.b(ii) for j
the Yankee Detailed Control Room Design Review (DCRDR), the Yankee 1.
Review Team developed a method which met the criteria above. The EOPs and certain plant parameters were provided to a consultant, knowledgable in human factors and in nuclear plant operation, but not in Yankee-specific I&C equipment.
1 From these EOPs, the consultant developed worksheets containing a list of information and control needs to implement the EOPs. If the EOP task was to determine the steam generator level, an obvious "need" would be a level indicator.
If no specific level was defined by the EOP, the level indicator would have a " requirement" that the indicator range cover the full to empty capacity of the steam generator. If the EOP directed that a certain valve be opened, the "need" was a valve control, the " requirement" that it be readily available, easily identified with the open direction clearly specified, and with a valve position indicator showing that the valve was indeed performing as directed. It became apparent that the requirements for most valve controls were similar and a standard set of requirements was developed to avoid the need of restating these general requirements for each valve needed. Pump control requirements also lent themselves to similar standardization.
The following examples illustrate the methodology used to develop l
specific needs and requirements to implement the EOPs. The examples show instances where the consultant and the Review Team decided that an instrument needed a lengthy list of requirements and one where a brief list was sufficient. Two other examples show a control with a lengthy list of requirements and one that is very brief.
]
Example No. 1 One entry condition to EOP No. 1, Reactivity Anomaly is " abnormal or uncontrollable or unknown neutron flux or reactor power following a reactor scram." Since no specific power level is defined, j
instrumentation covering all power ranges and a positive indication I
of reactor scram must be provided. In addition, since some scrams are bypassed above and below 15 MWe, indication of plant power level relative to that point is needed and, if no power level information was available, that condition must be identified as well, i
The I&C needs to cover all of this were defined as:
i 1.
A neutron flux monitor.
2.
A reactor power monitor.
3.
Scram indication, j
4.
Loss of indication alarm.
5.
Indication of 15 MWe turbine power.
i
'\\
i 1
The detailed requirements of these needs is listed below. Those listed under No. 1,-refer to the No. 1 item in the list of needs; a neutron flux monitor. That convention is followed throughout.
1.
Neutron Flux Monitors Source Range Indicator Units: Counts /Sec Range:
1 to 100,000 Scale: Logarithmic Scale Major Division: Decades Scale Minor Division: Half Decades Intermediate Range Indicator Units: Detector Amps Range: Adequate Overlap of Source and Power Range Indicators Scale: Logarithmic (Power of 10)
Scale Major Division: Decades Scale Minor Division: Half Decades 2.
Power Range Indicator Units: % Power Range:
0-120 Scale: Linear Scale Major Division: 10 Units Scale Minor Division: 5 and 1.0 Recording and Trending Capability on All Ranges 3.
Any of the Following:
Annunciator Alarms Indicating Lights Control Rod Position Indication 4.
Annunciator 5.
Indicating Lights Above 15 MWe This example illustrates that, where necessary, the consultant and the Review Team specified a lengthy and detailed set of requirements to enable the implementation of'the EOP task. It is apparent, upon examination, that the detailed requirements are specific where necessary and less so if not required, e.g.,
the "any of the following" for scram indication, No. 3.
Example No. 2 1
Step 3 in EOP No. 1 Reactivity Anomaly, states " verify turbine trip." The need is identified as: '
_ _ ~ _ _ _ _ _ _ _
lL.
Turbine trip indicator.
The requirements stated two options, either indicating lights showing all turbine stop valves closed, or a stop valve position j
indication.
If all stop valves are closed, no steam is admitted to the turbine and it is considered tripped.
i The walk-through revealed the existence of indicating lights and a recorder showing stop valve position, both located on the turbine area of the main control board. The human factors. requirements were satisfied. This is an example of how a minimum set of requirements can adequately define suitable equipment.
Example No. 3 The task described by Step No. 1 of EOP No. 1, Reactivity Anomaly is
" initiate manual reactor scram by de-energizing control rod drives." The need is described as " switch." The consultant decided, and the Review Team concurred, that for human factors i
consideration, and with no knowledge of the details of the Control Rod Drive System except that it was an electromagnetic drive, the need was satisfied with " switch."
For describing the detailed requirements of the switch, it was decided that certain things were needed.
1.
It needed to be easily accessible. Manual scrams are frequently used to back-up automatic scrams and the operator should not incur delay while going to where the switch is located.
It was found that three switches were provided on the Main Control Board and that they were spaced at intervals to make them easily accessible to the operators.
2.
It needed to be reliable. This is interpreted to mean.that the operator should have no doubt when he has operated the switch and'should know that the function is occurring. It implies a crisp action. The scram switches require only a simple push on the switch to operate them. The switches have been in operation for many years and the operators have expressed satisfaction with them as a reliable means of scramming the plant.'
3.
The switch should be quick acting. The reasons stated in requirement No. 1 apply here. The scram switches are very quick acting and simple to use.
4.
The switch should be easily operated. Again, the' explanation for requirement No. 1 applies. The three scram switches were found to be mushroom headed switches which could be quickly and easily operated by pushing downward with the palm of either hand.
No additional electrical or mechanical details were needed to describe the requirements of this switch to suit the operators needs. While these requirements would perhaps appear vague and ambiguous to a design engineer attempting to purchase a switch to be used in a circuit, they are explicit in human factors terms when assessing the needs and requirements of switches in operation for over 25 years.
Example No. 4 EdP No. 2, Secondary Pressure High, Step 4.1 states " restore vacuum." The consultant and the Review Team determined the operators needs as information concerning the. parameters which control or contribute to the maintenance of proper vacuum in the main condenser. These would be the existing level of vacuum, the circulating water status, the air removal equipment status, the gland seal status, and the condensate removal status. Control of these systems, as well as indication, would be required. Those systems which traditionally are controlled from outside the Control Room required two-way communication with an auxiliary operator.
Evaluation of this task resulted in eleven needs, some with detailed requirements where necessary, and others with more general requirements where that was suitable. Needs and requirements are listed below in columnar form:
1.
Vacuum Indication Units:
Inches of Mercury Range: 0 to 30 Scale: Linear Major Division:
1 Minor Division:
0.1, 0.05 Location: Readily Available to Operator 2.
Circulating Water Pump Ammeter Range: 0 to 200 3.
Air Ejector Steam Pressure Indication Range: 0 to 400 Units: psig Divisions:
5, 1 1
4.
Condensate Flow Indicator Flow or No Flow
'5.
Gland Steam Pressure Indicator Range: 0 to 25 Units: psig Divisions:
5, 1 j
1 i
i 6.
Circulating Water Pump Control Readily Accessible Start /Stop Clearly Marked Identified by Function Breaker Position Indication 7.
Circulating Water Pump Discharge Valve Control Readily Accessible Open/ Closed Clearly Marked Valve Position Indication Provided Both Lights on in Mid-Travel Identified by Function 8.
Communication With Auxiliary Operator Two-Way With Page Capability 9.
Condensate Pump Controls Standard C, as in Item 6 10.
Hot Well Level Indicator Units: Inches Range: 15 to 30 11.
Hot Well Level Control Control Level Within 15 Inches This example provides a detailed listing of requirements to perform-the task (s) identified by the EOP step. They are requirements which can be readily evaluated when compared with the actual Control Room Inventory. There is no attempt to determine how the signal is transmitted, whether electrically or by hydraulic or pneumatic method, the accuracy of the transmission or the response time.
These are determined by engineering design requirements.
The examples shown above are typical of the entire list of information and control needs.
It was felt that a trained human factors engineer, with nuclear experience, can evaluate these needs and requirements against the existing Control Room information and i
control capabilities and make HED evaluations.
3.
COMPARISON OF DISPLAY AND CONTROL REQUIREMENTS WITH A CONTROL ROOM INVENTORY a.
Provide documentation describing the performance and results of a comparison of the Control Room with the needed characteristics for instruments and controls identified in the analysis of those tasks previously found to be of a vague or general nature.
_g_
r:
Response
See above Response 2(b).
4.
CONTROL ROOM SURVEY a.
Provide documentation describing how the omitted sections of the survey were completed and ambiguities and inconsistencies clarified.
Response
During the in-progress audit by the NRC, it was determined that some of the status survey checksheets were incomplete, i.e.,
all the questions had not been answered, the static surveys were performed by the three teams of two men each, an operator and an engineer. A set of survey checksheets were completed for each panel, or well-defined group of panels. The response to each survey sheet question was numerical from one to four.
If the answer was valued at two or more, a written comment was required. A review of the sheets revealed the following:
1.
All of the completed checksheets had been done by one of the three teams.
2.
The questions which had not been completed were generic, e.g.,
is there a plant color code? Discussion with the survey team revealed that in their opinion, if this type of question is answered once, for one panel, it is answered for all.
3.
In two instances, nonsenerle questions were overlooked.
The incomplete survey sheets were returned to the survey team leader for completion. The team completed all of the generic questions and the two nonseneric questions.
No additional findings resulted from this effort.
To guarantee that no other such omissions existed, the survey checksheets were reviewed, and the finding number resulting from each comment was entered on the survey sheet in the left-hand column next to the question's numerical value.
Following this, the entire package of survey sheets was independently audited to verify that:
1.
Each question was answered, and 2.
Each question with a numerical value of two or greater contained a written comment and a finding number.
This audit is documented in our files, b.
provide documentation describing the assessment, resolution, and implementation schedule for the HED concerning the circulating water pump switches and indicator lights.
_Respon se_
During the in-progress audit of the Yankee Detailed Cont Design Review (DCRDR),
rol Room they felt violated human factors principles and had not bthe NRC tea reported as a iluman Engineering Defleiency (llED).
een in question concerned the circulating water pump c The arrangement and the pump discharge valve position indicating lights ontrol switches control switch is located directly above the control switch for P Pump No. I No. 2.
Two red and green CW pump discharge valvo position ump indicating lights are located between the pump control swit h No. I valve indicating lights are on the left, No c es.
. 2 is on the right.
At a recent meeting of the DCRDR review team, this situatio System for evaluation. evaluated and Finding No. 0563 entered into the Data M n was 5.
ASSESSMENT OF llEDs_
a.
Provide documentation describing how the implementati Room improvements will be integrated and considerate of HED on of Control classification.
Response
based on breaking the liEDs down into various categorie c ons is Initially, the llEDs were classified as Level Adeveloping a log and egories.
finding of the IIED is similarly classified.
, B, or C and each additionally classified under the following categories:The findings have been 1.
Panel Number (1-19) 2.
Estimated Engineering Man-liours to Correct 3.
Grouping (by panel, type, or as independent) 4.
Schedule (87, 88, or 89 refueling or independent of r f e ueling) 5.
Estimated Installation Time The first determination is to put the llEDa or findings i t groupings.
panel, those findings which cover more than one panel and a no types (color, etc.), and, finally, those findings which re called independent of panels or types and can be corrected with are to any other findings.
out regard l
I type, or as an independent.Thus, the HEDs are integrated by panel, Once the 1(EDs are categorized into groupings and classifi highest classification will be determined consistent witho cation, an and by engineering man-hours to design the correction, available man h available to install the corrections, and interference of the corr
- ours with other Control Room work.
ection work _ _ _ _ - - - - - - - - - - - - - - - - - - - -
- Response During the in-progress audit of the Yankse Detailed Control Room Design Review (DCRDR), the NRC team disco'.ered an arrangement which they felt violated human factors principles and had not been reported as a Human Engineering Deficiency (NED). The arrangement in question concerned the circulating water pump control switches and the pump discharge valve position indicating lights. Pump No. I control switch is located directly above the control switch for Pump No. 2.
Two red and green CW pump discharge valve position indicating lights are located between the pump control-switches.
No. I valve indicating lights are on the left, No. 2 is on the right.
At a recent meeting of the DCRDR review team, this situation was evaluated and Finding No. 0563 entered into the Data Management System for evaluation.
5.
ASSESSMENT OF HEDs a.
Provide documentation describing how the implementation of Control Room improvements will be integrated and considerate of HED classification.
Response
i The integration and implementation schedule of HED corrections is based on breaking the HEDs down into various categories and developing a logical sequence of actions based on the categories.
Initially, the HEDs were classified as Level A, B, or C and each i
finding of the HED is similarly classified. The findings have been additionally classified under the following categories:
i i
1.
Panel Number (1-19) i 2.
Estimated Engineering Man-Hours to Correct 3.
Grouping (by panel, type, or as independent) 4.
Schedule- (87, 88, oc 89 refueling or independent. of refueling)
{
5.
Estimated Installation Time The first determination is to put the HEDs or findings into groupings. The groupings are defined by those findings grouped by panel, those findings which cover more than one panel and are called types (color, etc.), and, finally, those findings which are independent of panels or types and can be corrected without regard to any other' findings. Thus, the HEDs are integrated by panel,-
type, or as an independent.
Once the HEDs are categorized into groupinEs and classification, an orderly progression of HED implementation by individual panel and by highest classification will be determined consistent with available engineering man-hours to design the correction, available man-hours to install the corrections, and interference of the correction work with other Control Room work.,
j
6.
SELECTION OF DESIGN IMPROVEMENTS a.
Provide documentation describing the review process taken to evaluate what potential reduction in operator error and commensurate increase in plant safety could be achieved by correcting the 19 HEDs it noted " benefit cannot be supported by cost."
Response
The review process taken to evaluate HEDs will be forwarded at a later date when the individual HED resolution schedule is established.
b.
Provide documentation describing the approach and guidelines or criteria the engineering staff have used or will use to develop detailed solutions.
Response
Once the integration and implementation schedule of HED corrections is finalized (see Response to Item Sa), the engineering staff will develop the detailed HED findings corrections using the Summary Report recommendations as a " starting point." Project human engineering guidelines currently under development will be used as design input to the HED corrections for such things as color, labels, and abbreviations, etc. These guidelines are being developed using input from NUREG-0700; EPRI NP-309, NP-2411, NP-3659; MIL-STD-1472B; " Human Factors in Engineering Design" by McCormick and the Army / Navy / Air Force text
" Human Engineering Guide to Equipment Design," edited by Van Colt and Kincado.
Once the guidelines have been reviewed and approved by the consultant and Review Team, they will be implemented into the overall HED Correction Effort.
The engineering details of the HED corrections will also be reviewed by the consultant and Review Team to ensure that the HED has been corrected and that no new HEDs have been introduced by the new designs.
The engineers designing the corrections have been trained by the consultant who assisted in the DCRDR for Yankee and, therefore, have a human factors perspective upon initiation of their engineering, c.
Provide representative HED forms demonstrating the adequacy of the HED forms for supplying the information necessary for the engineering staff to proceed with the development of detailed solutions.
Response
The attached sample, " Findings File Report," page is typical of the information available to the e1gineering staff in order for them to proceed with the development of detailed solutions to the HEDs.
- L2-
1 1
The information contained in the " Findings File Report" originated se the comments made by the members of the CRDR Team on the survey review forms.
It is bains expanded, as discussed in Response Sa, to aid in the integratien and correction effort for the HEDs.
d.
Provide a response to the concern that the resolutions for all HED corrections do not appear to be final.
Response
The final resolutions of all HEDs will be determined after the studies are complete and the resolutions have been discussed with the NRC.
A meeting is proposed to discuss the final HED corrections with the NRC.
e.
Prior to the initiation of HED corrections or to the end of 1985, provide an implementation schedule for every HED to be corrected.
Response
A final implementation schedule will be established when the staff and Yankee have agreed upon the resolutions to be made.
7.
VERIFICATION THAT IMPROVEMENTS WILL PROVIDE THE NECESSARY CORRECTIONS WITHOUT INTRODUCING NEW HEDs a.
Provide documentation describing the methodology, including guidelines and criteria used, for determining that a modification would correct the problem without introducing another HED.
Response
The method used will be that described in Response 1(a). The review team, including the human factors specialist, will remain active until the HED corrections are finished. They will determine that the modification will correct a problem without introducing another HED.
The guidelines and criteria used for the determination will be the same ones used to determine the existence of an HED in the first place and are listed in our preliminary report and summary report, b.
Clarify the relationship of the verification and validation process referred to in the summary report to the review team's review of the detailed solutions developed by the engineering staff.
Response
Using the same guidelines and criteria that were used during the 1
development of an HED, the review team will perform a verification and validation of the detailed solutions developed by the engineering staff. The process will ensure that the detailed solution corrects this HED and does not introduce new HEDs.,
8.
COORDINATION OF THE DCRDR WITH OTHER IMPROVEMENT PROGRANS a.
Provide documentation describing the development of procedures or methodologies for int 3 grating the changes among. improvement programs.
Response
With the completion of the Yankee Probabilistic Safety Study in 1982, the Yankee Project Management Team had a tool to evaluate the i
risk of changes.to Yankee. It became obvious that minimizing off-site releases by continuously assuring fuel cladding integrity was a unifying goal, not just for operators, but also Project Management.
It therefore became the unifying goal of the five NRC requirements for emergency response capability in Supplement 1 to NUREG-0737.
From inception, the Yankee Project Management took responsibility for assuring that the emergency procedure improvements meshed with the safety parameter displays;.that the procedures written to-restore critical safety functions used the same critical safety function delineation as depicted on SPDS displays.
Furthermore, Yankee Project Management took responsibility for assuring that the Yankee emergency response facilities, in particular, the Technical Support Center, delineated critical safety functions in the same manner as the operator's procedures and the operator's SPDS displays. In this way, it assured that a common goal, prevention of core melt, permeated the entire emergency response capability for Yankee. Tools for achieving this control included budgeting of programs, sche,duling, allocation of manpower, technical reviews of work products, informal progress meetings and discussions, and top-down direction of personnel.
When published in late 1982, two of the items in Supplement 1 to NUREG-0737 created schedular problems. Both the control Room review and the Regulatory Guide ~1.97 review created large' uncertainty on the part of Yankee Project Management. This was because the success of our Control Room review would hinge on the acceptability of our i
emergency procedures, at that time unknown. Also, the success of a Regulatory Guide 1.97 program hinged upon an appropriate integration with environmental qualification requirements. As time has progressed, we have been able to reach agreement with the NRC on most of these issues and have proceeded to implement them.
As of 1986, all five requirements of Supplement I to NUREG-0737 are 1
controlled to assure an integral final compliance to the goal of maintaining fuel cladding integrity, b.
Provide documentation describing the mechanism which ensures that the DCRDR will be coordinated with other improvement programs.
Response
See the response to 8a.
. 4
I 0
9.
PROPOSED CORRECTIVE ACTIONS a.
For each HED listed in Appendix B of this report, provide information which responds to the inadequacy described.
Response
The inadequacies described in the report will be resolved at a proposed meeting between the NRC and Yankee.
l 10.
JUSTIFICATIONS FOR HEDs LEFT UNCORRECTED s.
For each HED listed in Appendix D of this report, provide information Which responds to the inadequacy described.
j
Response
The inadequacies described in the report will be resolved at a proposed meeting between the NRC and Yankee.
J 11.
RECOMMENDATION a.
In addition to these actions, we recommend that YAEC improve upon its analysis of operator traffic patterns and workload and the review of operating experience. The following recommended actions are not intended as additional requirements but are to encourage I
increased benefit from the DCRDR:
o Perform a systematic and rigorous analysis of operator traffic patterns and workload.
o Expand the scope of the LER review to include a larger, more 1
representative sample of documented events, o
Perform a follow-up investigation of all operator concerns identified.
t o
Survey additional operators.
j
Response
Rach of the above actions was addressed in our DCRDR Summary Report. Although we agree with the recommendations to go further into these areas, if we are to meet our schedules for 1
implementation, we cannot perform any further work at this time. If our implementation schedule does allow it at some time, we will try to take the further actions recommended.
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