ML20197B392

Forwards Addl Info Re Suppl 1 to NUREG-0737 Concerning SPDS, Per NRC 860625 Request.Rev 1 to SAR Also Encl

ML20197B392
Person / Time
Site:	Millstone
Issue date:	10/08/1986
From:	Opeka J, Sears C NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Thadani A Office of Nuclear Reactor Regulation
Shared Package
ML20197B397	List: ML20197B392 ML20197B749
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.2, TASK-TM A02959, A2959, TAC-51257, NUDOCS 8610300227
Download: ML20197B392 (15)

Text

o tO NORTHEAST UTILITIES o.nor.i Omc.. . see.n stre 8.rnn conn.cucut 1 . sI w Ns c cwww P.O. BOX 270 m e*t ** " w* :"" HARTFORD, CONNECTIUJT 06141-0270 L L J [.Z C['g" "" (203) 665-5000 October 8,1986 Docket No. 50-336 A02959 Office of Nuclear Reactor Regulation Attn: Mr. Ashok C. Thadani, Director PWR Project Directorate #8 Division of PWR Licensing - B U. S. Nuclear Regulatory Commission Washington, D. C. 20555

References:

(1) W. G. Counsil letter to 3. R. Miller, " Supplement I to NUREG-0737, Safety Parameter Display System, Safety Analysis Report," dated March 25,1985.

(2) 3. F. Opeka letter to A. C. Thadani, " Safety Parameter Display System," dated July 31,1986.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Supplement I to NUREG-0737 Safety Parameter Display System On June 25, 1986, the NRC Staff informally requested that Northeast Nuclear Energy Company (NNECO) provide additional information on the Safety Parameter Display System (SPDS) beyond that forwarded in References (1) and (2). In response to that request, NNECO hereby provides the attached information.

We wish to bring to your attention that in our view some of the NRC Staff questions infer that regulatory criteria exist which are more restrictive than the fundamental regulatory positions contained in Supplement I to NUREG-0737.

Although we do not believe that such regulatory criteria can be construed as requirements of Supplement I to NUREG-0737, we are voluntarily providing additional information to allow the NRC Staff to better understand our SPDS design philosophy and to be as supportive of the NRC Staff's review as possible.

Additionally, we have attached Revision 1 to the Millstone Unit No. 2 SPDS Safety Analysis Report (SAR) for your use. This revision supersedes in its entirety the SAR submitted in Reference (1).

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We trust that this submittal adequately addresses the NRC Staff concerns.

i Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY l

. .D i 3. F. Opeka '

l Senior Vice President By: C. F. Sears Vice President l

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e a Docket No. 50-336 Attachment 1 Millstone Nuclear Power Station, Unit No. 2 Supplement I to NUREG-0737 Safety Parameter Display System Additional Information l

l October,1986 l

i

e 5 MILLSTONE MUCLEAR POWER STATION, UNIT NO. 2 SAFETY PARAMETER DISPLAY SYSTEM (SPDS)

RESPONSE TO INFORMAL REQUEST FOR ADDITIONAL INFORMATION 2.1 Scope of Application The licensee's safety analysis states that the SPDS algorithms are monitored for both pre-trip and post-trip conditions of plant operation.

Those parameters inappropriate for pre-trip conditions are not monitored prior to reactor trip. Our review of the safety function algorithms noted that severity one limits for Reactivity Control are not monitored prior to reactor trip. To complete our review, we request the licensee to define the characteristics cf the SPDS that allow a user of the system to monitor the Reactivity Control Critical Safety Function (CSF) prior to reactor trip.

Also, the licensee should define the characteristics of the SPDS that allows a user of the system to evaluate - prior to reactor trip - each critical safety function defined in NUREG-0737, Supplement 1.

Response

Many algorithms would show unacceptable conditions if monitored prior to reactor trip because the Safety Function Status Checks (SFSCs) in the Emergency Operating Procedures (EOPs) are tailored to post-trip conditions, not power operation. Therefore, only those criteria which are meaningful prior to reactor trip are monitored by the SPDS algorithms.

Some safety functions (e.g., vital auxillsries and containment integrity) are applicable to all power levels and hence are monitored in their entirety prior to reactor trip. Some safety functions have parameters which would cause the algorithms to show an unacceptable condition at power operation. These parameters are, therefore, bypassed at power operation.

In the case of Reactivity Control, all of the parameters for the Reactor Trip Recovery algorithms are inconsisten t with power operation.

Therefore, the algorithm is bypassed prior to reactor trip.

Although some parameters are not monitored at power operation, the SPDS is "on" at all times during operating modes 1, 2 and 3. During normal operation, all SAFETY FUNCTIONS are green and are displayed at all times.

2.2 Operator Interaction The licensee's SPDS design appears to contain features that allow a user to interact with the system. The safety analysis states that if the operator informs the SPDS an event-specific procedure has been selected for use, the SPDS will compare the existing plant conditions with the event-specific safety function status check limits to determine !f any of the limits are violated. We request the licensee to define the nature of the operator interaction, the type of data displayed to the operator, and the means taken to validate the data to ensure that the operator is not misicad. Also, define if any control actions are displayed on the CRT for operator use.

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Response

The operator interacts with the SPDS primarily through the use of a membrane keyboard. Both specific procedure and specific safety function displays are called with a single keystroke. A sketch of the keyboard layout is shown in Figure 1. (This keyboard layout is subject to change prior to final implementation.) The type of data displayed is primarily alphanumeric. The name of each SPDS parameter, its value and quality, and its acceptance criteria are displayed on colorgraphic CRTs. Magenta alpha characters and Blank (no character), U, or N are dispir immediately to the lef t of parameter values to indicate quality. ';

operator control actions are displayed on the CRT screens.

2.3 Display Hierarchy ar.d Clutter The licensee's "SPDS displays will be implemented with a hierarchy or structure that facilitates and systematizes passage between displays." We request the licensee to define this structure and describe the human factors guidelines used to implement this feature of the display system.

In the discussion on primary displays (Section 4.2 of the safety analysis),

the licensee states that other information may be displayed simultaneously along with the status of the safety functions. Too much information on a

_ display format will result in clutter, rendering the displayed data useless to operators during emergencies. To complete our review, we need the human factor guidelines used to design the display formats. Furthermore, the licensee should define how the designer determines the amount of information that will fit on one CRT screen.

Response

The SPDS displays are arranged in a three-level hierarchy as generally shown in Figure 2. (Specific details of this hierarchy are subject to change prior to final implementation.) Level I consists of the Overview display for each of the seven Emeigency Operating Procedures (EOPs). Level Il consists of the six Safety Function (SF) displays for each of the seven recovery EOPs. Level III consists of a Sensor Data display for each of the six safety functions. The six safety function status boxes are integral with every display page.

Each EOP has one Overview display, six Safety Function displays, and six Sensor Data displays associated with it. The human factors guidelines contained in NUREG-0835 were used in developing this display hierarchy.

To reduce the potential for clutter and other human engineering discrepancies, all SPDS displays were built (designed) on colorgraphic display terminals. Each display was reviewed by a design team which included a senior licensed operator, a human factors expert, and other operations-oriented personnel. The team would identify the need for change and the displays would be revised accordingly. This process was repeated until all team members agreed that each display met the needs of the operating crew.

1 I 2.4 Data Validation Provide a description of how validated data, unvalidated data, and invalid data will be coded and displayed for operators use in rapidly and reliably assessing the safety status of the plant.

Response

See Section 5.0 of the attached revised SAR.

2.5 SPDS Location The primary users of the SPDS are the shift supervisor and the supervising control operator. To complete our review, we need the human factor guidelines used to locate the SPDS within the control room; also provide a description of the shift supervisor's and supervising control operator's workstations during emergencies.

Response

The SPDS information can be displayed on any of the colorgraphic CRTs connected to the Integrated Computer System. This arrangement permits the operating crew to move freely around the control room and still have access to SPDS information. Figure 3 shows the location of the shif t supervisor's and supervising control operator's work stations. The shif t supervisor needs access to SPDS information while he is positioned to support the coordination of offsite efforts. In addition, SPDS access must be available from the operator console. SPDS/ Computer workstations are provided at both locations.

2.6 Oscillation of Process Variables and Displayed Data Our review of the safety function algorithms noted that data on the trend of variables were needed to execute the algorithms. To complete our review, we need information on how the trend data is determined by the SPDS. Furthermore, the licensee should describe the features of the SPDS design used to transmit and display oscillating process variables, which may be symptoms of a severe accident.

Response

Trend information for each variable used in the execution of the safety function algorithms is determined using least squares techniques.

Simplistically, a sequence of values x(0), x (1), ..., x(NT) is supplied to define the time-dependent behavior of the variable x over the time from (tp-NT*TS) to tp. In these expressions, tp is the present time, TS is the time interval for data collection, and NT is a specified number of time intervals. The variable x(0) refers to the present time, x(l) to one time interval before the present time, etc. A sequence of corresponding quality labels y(0), y(l), ...,y(NT) is also provided as input.

f I

-q-The input variables having good quality are used to define a least-squares linear fit of x versus time interval number. This straight line increases by a calculated amount, delta, between (tp - NT*TS) and tp. The output from the sof tware (increasing, decreasing, or steady) is determined by comparing delta to a specified deadband (DB).

The use of a least-squares fit permits a determination of trend during a time when one or more of the input labels are "no good". It also gives low sensitivity to a noisy signal.

Trend arrows and colorgraphic trend displays are used to display trend information. Trend arrows are used to indicate qualitative trend information. Trend arrows point up when a variable is increasing, to the right when a variable is stable, and down when a variable is decreasing.

Eighteen (nominal) predefined SPDS trend displays are available for use by the operating crew to obtain longer term trend information. Furthermore, the operating crew can create additional graphic trend displays or modify existing graphic trend displays using the trend definition features of the Integrated Computer System.

The update rate for the SPDS parameters being trended is consistent with the operator's information ar.d control requirements derived from the control room design review. That is, the trend information provided by the SPDS will be consistent with that information provided by the control board instruments.

2.7 Design Validation In Section 4.0, SPDS Displays of the safety analysis, the performance requirements for the system are defined. However, our review of Section 6.2.2, SPDS Validation, was unable to detect a commitment to validate the performance of the system. To complete our review, we need information on how the performance requirements are validated from the test of the display system. Furthermore, the licensee should define how the developed displayed concepts (Section 7.3.5, Develop Display Concept) will be validated.

Response

Validation is cornprised of the testing and evaluation of the integrated SPDS hardware and sof tware to determine the compliance with functional, performance and interface requirements. SPDS validation will be conducted at three levels and will ensure that the system meets functional requirements and will aid control room use of function-oriented EOPs.

LEVEL 1: FACTORY ACCEPTANCE TEST SPDS sof tware and hardware will be integrated for functional testing prior to site installation. Testing will be conducted for all appropriate hardware, sof tware and system functions.

LEVEL 2: SITE ACCEPTANCE TEST Af ter SPDS installation in the plant has been completed, a site acceptance test will be performed to demonstrate correct operation of the installed SPDS hardware and sof tware. Furthermore, an inservice test will be conducted during plant startup to provide further assurance that the SPDS is functioning properly.

LEVEL 3. MAN-IN-THE-LOOP EVALUATION Operations personnel, trained in function-based EOPs, will review SPDS displays and the man-machine interface. This review will utilize SPDS displays that will function statically. The objective of this evaluation is to review the SPDS design as an aid to emergency response by the operating crew.

To make the SPDS validation program more effective, NNECO prepared the acceptance test cases and acceptance criteria. Thus, NNECO designed the SPDS, the vendor implemented the design, NNECO prepared the test cases and acceptance criteria, and both organizations witnessed the actual testing.

2.8 Design Verification Ou: review of the verification activities proposed by the licensee noted that design verification was a formal activity. We also noted that verification consisted of independent technical review and evaluation, which is an acceptable approach. However, our review of Section 7.0, Human Factors Engineering, noted that several design reviews are conducted within the design process. The licensee should define the relationship between the design reviews discussed in Section 7.0 and the

' design verification activities in Section 6.0 of the safety analysis and discuss how each will be performed.

Response

The SPDS was designed using a team approach. Teams were assigned responsibility for designing specific features. One team designed the safety function algorithms, another the signal validation algorithms, another the displays and man-machine interface, and another the base system design. Each group conducted its own design reviews as the design of its specific feature progressed. When a team considered the design of its specific feature to be complete, the design specification was sent to members of the overall SPDS design team for review. Comments were returned to the team responsible for the specific design, resolved, and necessary changes incorporated. The revised design specification was then sent to a team member who had not directly participated in the design of the specific feature (independent reviewer) for a detailed technical review.

Comments were returned to the team responsible for the specific design, resolved, necessary changes incorporated, and the specification then issued.

i 3.1 Functions and Parameters NUREG-0737, Supplement 1, requires that data displayed by the SPDS shall be sufficient to provide information to plant operators about:

1. Reactivity Control

2. Reactor Core Cooling and Heat Removal from the Primary System

3. Reactor Coolant System Integrity

4. Radioactivity Control

5. Containment Conditions For review purposes, these five items have been designated as Critical Safety Functions (CSFs).

Our review of the licensee's Safety Analysis identified the following Emergency Operation Procedure Safety Functions, which the licensee states correspond to the SPDS Safety Functions:

1. Reactivity Control

2. RCS Inventory Control

3. RCS Pressure Control

4. RCS Heat Removal

5. Containment Integrity

6. Vital Auxiliaries in our review of these functions, we were unable to make a o rect correspondence to the NUREG-0737, Supplement 1, required functions for all of the above identified functions. To continue our review, the staff requests the licensee to identify the correspondence between the above functions and the Critical Safety Functions. Furthermore, the staff requests the licensee to: 1) identify the minimum set of parameters required by operators to evaluate each of the Critical Safety Functions,2) provide the basis for each parameter selection, and 3) identify where in the SPDS cach parameter is displayed.

Response

The following table compares the Millstone Unit No. 2 Safety Functions

t I (SFs) with the Critical Safety Functions (CSFs) defined in NUREG-0737, Supplement 1:

Millstone Unit No. 2 SF NUREG-0737, Supplement I CSF

1) Reactivity Control Reactivity Control

2) RCS Inventory Control Reactor Core Cooling

3) RCS Pressure Control Reactor Coolant System Integrity

4) RCS Heat Removal Heat Removal from the Primary System

5) Containment Integrity Containment Conditions and 1

Radioactivity Control

6) Vital Auxiliaries (no comparable CSF)

The parameters used to monitor each of the safety functions were given in Appendix C of Reference (1) and are again included in Appendix A in the attached revised SAR. The parameters are selected to be consistent with the SFSCs of the Millstone Unit No. 2 EOPs. They are displayed on the 4 data pages described in the response to question 2.3.

3.2 Neutron Flux Neutron flux is a fundamental variable for monitoring the status of plant reactivity control and should be monitored and displayed for all power ranges (source range to beyond design power). Our review of the safety analysis noted that. reactor power (wide range) is monitored, but we found no evidence to indicate that it is displayed. We request that the licensee provide information on the displayed range for neutron flux.

Response

Neutron flux is displayed on all data pages which correspond to an algorithm which uses reactor power as an input. The validated range of this parameter is 10-6 -100% power.

1 3.3 Hot Leg Temperature Hot leg temperature and cold leg temperature are key indicators to determine the viability of natural circulation as a mode of heat removal i

during specific accident scenarios. Our review of the safety analysis noted

! that THOT and TCOLD were measured and that TCOLD was displayed in

! the SPDS. We were unable to determine if THOT was displayed. We request that the licensee provide information to clarify the display status of THOT.

1 1

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Response

Hot leg temperature is displayed on all data pages which correspond to an algorithm which uses it as an input.

3.4 Shutdown Cooling Flow Shutdown cooling flow is a key indicator to determine the viability of the heat removal system used when the secondary system is not the principal heat removal system (i.e., large LOCA, ECCS, normal shutdown flow). Our review of the licensee's safety analysis was unable to identify shutdown cooling flow as a displayed variable. We request the licensee to define how the SPDS is used to make a rapid and reliable functional assessment of heat removal for the conditions described above.

Response

Shutdown cooling flow is injected via the LPSI header and hence is monitored as LPSI flow. Note that the SPDS is not intended to monitor plant accidents which are initiated from shutdown cooling conditions. This is consistent with the EOPs which form the basis of the SPDS. The SPDS can, however, follow transients which are initiated from Modes 1, 2 and 3 down to shutdown cooling or other long-term heat removal method. For example, following a large break LOCA, the SPDS is capable of monitoring sump recirculation flow to assure adequate long-term cooling.

3.5 Steam Generator Radiation Prior to isolation, steam generator radiation in conjunction with containment radiation and plant vent stack radiation, provides a rapid assessment of radiation status for the most likely radioactive release paths. Upon isolation of a steam generator, radiation in the generator should be monitored as the generator's safety valve is a potential release path to the environment. Our review of the licensee's safety analysis was unable to identify the monitoring and display of radiation within an isolated steam generator. We request the licensee to define how radiation in the secondary system (steam generator and steamline) is monitored by the SPDS when the steam generator and/or the steamline are isolated.

Response

Steam generator radiation is not currently monitored at the plant and, therefore, was not included in the original SPDS design as delineated in Reference (1). However, since plant modifications will be implemented by December 31, 1986 or prior to startup from the current refueling outage, whichever is later, to allow for the monitoring of steam generator radiation (Regulatory Guide 1.97 variable E-3b), this information will also be included in the SPDS.

_9 3.6 Containment Isolation '

Containment isolation is an important parameter for use in making rapid assessment of " Containment Conditions." In particular, a determination that known process pathways through containment have been secured i provides significant additional assurance of containment integrity. Our '

review of the licensee's safety analysis was unable to identify information on containment isolation within the SPDS. We request the licensee to define how containment isolation is monitored by the SPDS or to provide i justification for its exclusion.

Response

The status of containment isolation equipment is monitored as indicated in Appendix C in Reference (1). When this equipment is in a satisfactory state following a containment isolation signal, then the SPDS indicates that the signal has been acceptably processed.

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