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UNITED STATES I
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WASHINGTON, D. C. 20555
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MEMORANDUM FOR: Phillip Qualls, Plant Systems Section, Engineering Programs Branch, Division of Engineering and Technical Programs, Region V THRU:
Olan D. Parr, Chief, Plant, Electrical, Instrumentation and Control Systems Branch, Division of PWR Licensing-B
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FRCM:
Dennis Kubicki, Fire Protection Engineer, Section B, Plant, Electrical, Instrumentation and Control Systems Branch, Division of PWR Licensing-B
SUBJECT:
INSPECTION
SUMMARY
, APPENDIX R COMPLIANCE AUDIT, DIABLO CANYON POWER PLANT UNITS 1 AND 2 - TAC NO. 59803 -
Enclosed are my findings from the Appendix R compliance audit of Diablo Canyon Units 1 and 2, which was conducted between November 18-22, 1985. Based on the results of that audit, I have concluded that the licensee has apparently violated the license for Units 1 and 2 to the extent that it requires PG&E to meet the requirements of Appendix R to 10 CFR 50, except where deviations had been previously approved. Also, an unresolved issue exists pertaining to the adequacy of fire dampers installed throughout the plant.
hm. NA Dennis Ku cki, Fire Protection Engineer Section B Plant, Electrical, Instrumentation and
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Control Systems Branch Division of PWR Licensing-B
Enclosure:
As Stated cc w/ enclosure:
F. Shroeder D. Crutchfield O. Parr J. Wermiel
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j ii. Schierling/
A. Singh S. West l
J. Stang l
D. Kubicki D. Kirsch, Region V
Contact:
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D. Kubicki ci sII5 9 S KA G 3 V[
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ENCLOSURE PLANT, ELECTRICAL, INSTRUMENTATION AND CONTROLS SYSTEMS BRANCH DIVISION OF PWR LICENSING-B INSPECTION
SUMMARY
, APPENDIX R COMPLIANCE AUDIT DIABLO CANYON UNITS 1 AND 2 DOCKET NOS. 50-275/276 Introduction Between November 18-22, 1985, I assisted Region V, during an Appendix R, fire protection coupliance audit at Diablo Canyon Units l'and 2.
I reviewed the adequacy of fire barriers, fire detection systems and fire suppres'sion systems as they pertained to the licensee's commitments to meet the requirements of-Section III.G of Appendix R to 10 CFR 50, except where deviations from these requirements had been previously approved. My findings are as follows:
1.
Fire BarriersSection III.G.2.a. of Appendix R to 10 CFR 50 stipulates that redundant shutdown-related systems should be separated by a fire barrier having a three-hour fire-rating. Structural steel forming a part of or supporting such barriers should be protected to provide fire resistance equivalent to that of the barrier. Contrary to the above, I observed that structural steel in a number of areas in the plant, such as in the 12 KV switchgear room, was not protected. I also observed that unprotected bus ducts penetrate the floor / ceiling assembly between the 12 KV switchgear room and l
the cable spreading rooms above. A bus duct also penetrates the fire-rated enclosure surrounding shutdown-related cables within the 12 KV switchgear room.
I also observed that the insides of conduits which penetrate fire barriers were not sealed against the passage of products of combustion wherever such conduits extend beyond 24 inches of the fire barrier.
Because the Diablo Canyon license contains a condition that the licensee must conform with the provisions of Section III.G of Appendix R, except where deviations have been approved, and because the above conditions are not approved deviations, they represent apparent violations of the Diablo Canyon License.
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1 I observed that in a number of plant locations, fire dampers were not installed per manufacturer's installation requirements or the provisions of National Fire Protection Association (NFPA) Standard 90A. The licensee referenced the results of an internal fire hazards analysis which justifies the adequacy of these dampers. Pending submission of this analysis to NRR and our evaluation of it, this issue is considered unresolved.
2.
Fire Barriers By letter dated July 27, 1977, the licensee committed to install fire detection systems in the plant in accordance with the provisions of NFPA Standard No. 720. Contrary to the above, I observed that fire detectors were not installed throughout a number of plant areas such as in the cable spreading rooms on elevation 104 feet. This represents a deviation from the above-referenced licensee commitment.
3.
Fire Suppression In the licensee's Appendix R compliance report, PG&E stated that the auxiliary feed pump rooms were protected by a sprinkler system which pro-vided area-wide coverage. Contrary to the above, we ob;erved that in the turbine driven auxiliary feed pump room in Unit 2, the sprinkler system was not installed to achieve complete coverage per the requirements of NFPA Standard No. 13. Because the Diablo Canyon license contains a con-dition..that the licensee must conform with the provisions of Section III.L of Appendix R, except where deviations have been approved, and because the above condition is not an approved deviation, it represents an apparent violation of the Diablo Canyon Unit 2 license.
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g NUCLEAR REGULATORY COMMISSION g,
j WASHINGTON, D. C. 20655
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December 9, 1985 Docket Nos.: 50-275 b Io b>Ll and 50-323 LICENSEE: Pacific Gas and Electric Company FACILITY: Diablo Canyon Nuclear Power Plant Units 1 and 2
SUBJECT:
MEETING
SUMMARY
- DETAILED CONTROL ROOM DESIGN REVIEW On November 6,1985 NRC staff for the Diablo Canyon Nuclear Power Plant detailed control room design review (DCRDR) and its consultants from Science Application International Corporation (SAIC) met with Pacific Gas and
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Electric Company (PG&E) and its consultants to discuss certain issues that had been identified by the staff as a result of an audit conducted in February 1985. A notice of the meeting is provided as Enclosure 1.
Although scheduled for two days, the meeting adjourned on November 6, 1985. The attendees at the meeting are listed in Enclosure 2.
Details of the meeting are provided in Enclosure 3, which is a suninary that was prepared by SAIC; it was reviewed by the NRC staff and the staff concurs.
The issues discussed at the meeting pertain to the following 9 elements:
1.
structure and participation of DCRDR teams 2.
function and task analysi-3.
control room inventory 4.
control room survey 5.
assessment of HEDs 6.
selection of design improvements
- 7. and 8. verification and validation 9.
coordination of DCRDR with other programs The elements had been addressed in a report regarding the February 1985 audit which was transmitted to PG&E (letter from G. W. Knighton (NRC) to J.
D. Shiffer (PG&E), dated September 16,1985) and which are identified in NUREG-0737, Supplement 1.
Each of the 9 elements is discussed in detail in, which also includes PG&E handouts from the meeting.
At the conclusion of the meeting the staff provided the following summary:
1.
Based on the infonnation discussed at the meeting is appears that PG&E has perfonned a more intensive DCRDR effort than was apparent 'at the February 1985 audit. However, much of the infomation has yet to be documented in PG&E records or submitted to the NRC.
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A O December 9, 1985 2.
The DCRDR effort does not need to duplicate any effort that already has been perfonned or is in progress. Appropriate reference should be made.
3.
The attendance at the meeting by the major PG8E participants in the DCRDR program, including management, was beneficial and should result in improved communication between staff and licensee.
4 PG&E should address each issue of the 9 elements as discussed at the meeting and as identified in the NRC letter of September 16, 1985. The PG&E response should be by letter in earl particular address item 2 (task analysis)y January 1986 and should in It should include a DCRDR team organization chart with names and positions of individuals.
5.
PG8E should identify to the staff those corrections resulting from the HED assessments that will be made during the first refueling outage.
6.
PG&E will submit a supplement to its Sumary Report, currently scheduled for mid 1987.
The staff comitted to provide this report to PG&E.
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M iT Fans Schierling, Senior Project Manager PWR Project Directorate #3 Division of PWR Licensing-A
Enclosures:
As stated cc: See next page
o Mr. J. D. Shiffer Pacific Gas and Electric Company Diablo Canyon CC*
Philip A. Crane, Jr., Esq.
Resident Inspector /Diablo Canyon NPS Pacific Gas & Electric Company c/o US Nuclear Regulatory Commission Post Office Box 7442 P. O. Box 369 San Francisco, California 94120 Avila Beach, California 93424 Mr. Malcolm H. Furbush Ms. Raye Fleming Vice President - General Counsel 1920 Mattie Road Pacific Gas & Electric Company Shell Beach, California 93440 Post Office Box 7442 San Francisco, California 94120 Joel Reynolds Esq.
John R. Phillips, Esq.
Janice E. Kerr, Esq.
Center for Law in the Public Interest California Public Utilities Commission 10951 West Pico Boulevard 350 McAllister Street Third Floor San Francisco, California 94102 Los Angeles, California 90064 Mr. Frederick Eissler, President Mr. Dick Blankenburg Scenic Shoreline Preservation Editor & Co-Publisher Conference, Inc.
South County Publishing Company 4623 tbre Mesa Drive P. O. Box 460 Santa Barbara, California 93105 Arroyo Grande, California 93420 Ms. Elizabeth Apfelberg Bruce Norton, Esq.
1415 Cozadero Norton, Burke, Berry & French, P.C.
San Luis Obispo, California 93401 202 E. Osborn Road P. O. Box 10569 Mr. Gordon A. Silver Phoenix, Arizona 85064 Ms. Sandra A. Silver 1760 Alisal Street Mr. W. C. Gangloff San Luis Obispo, California 93401 Westinghouse Electric Corporation P. O. Box 355 Harry M. Willis, Esq.
Pittsburgh, Pennsylvania 15230 Seymour & Willis 601 California Street, Suite 2100 David F. Fleischaker, Esq.
San Francisco, California 94108 P. 0. Box 1178 Oklahoma City, Oklahoma 73101 Mr. Richard Hubbard MHB Technical Associates Suite K 1725 Hamilton Avenue San Jose, California 95125 Mr. John Marrs, Managing Editor San Luis Obispo County Telegram Tribune 1321 Johnson Avenue P. O. Box 112 San Luis Obispo, California 93406
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Pacific Gas & Electric Company Diablo Canyon cc:
Arthur C. Gehr, Esq.
Mr. Thomas Devine Snell & Wilmer Government Accountability 3100 Valley Center Project Phoenix, Arizona 85073 Institute for Policy Studies 1901 Que Street, NW Mr. Leland M. Gustafson, Manager Washington, DC 20009 Federal Relations Pacific Gas & Electric Company 1726 M Street, N.W.
Suite 1100 Washington, DC 20036-4502
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Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Michael J. Strumwasser, Esq.
Special Counsel to the Attorney General State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, California 90010 Mr. Tom Harris Sacramento Bee 21st and 0 Streets Sacramento, California 95814 Mr. H. Daniel Nix California Energy Commission 1516 9th Street, MS 18 Sacramento, California 95814 Lewis Shollenberger, Esq.
US Nuclear Regulatory Commission Region V 1450 Maria Lane Suite 210 Walnut Creek, California 94596
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'g UNITED STATES ENCLOSURE 1 8
NUCLEAR REGULATORY COMMISSION g
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wAsmwcTow. o.c. nosss OCT 151985 Docket Nos.: 50-275 l
and '50-323 4
MEMORANDUM FOR: George W. Knighton, Chief 1
Licensing Branch No. 3 1
Division of Licensing I
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FROM:
Hans Schierling, Project Manager '
Licensing Branch No. 3 Division of Licensing
SUBJECT:
DIABLO CANYON - CRDR MEETING WITH PG&E DATE & TIME:
November 6 and 7, 1985 9:00 am - 5:00 pm LOCATION:
Room 5033 Air Rights Building 4550 Montgomery Avenue Bethesda, Maryland PURPOSE:
Discuss status of Licensee's Detailed Control Room Design Review.
PARTICIPANTS:
NRC WPSchierling-N. Thompson L. Beltracht NRC Consultants (SAI)
PG&E B. Lew, et al.
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Hans Schierling, Project Manager Licensing Branch No. 3 Division of Licensing cc: See next page 4F/ pay 9W fiF
Q ENCLOSURE 2 DIABLO CANYON DCRDR MEETING November 6, 1985 Attendance List Name Affiliation Hans Schierling NRC Diablo Canyon Project Manager Peter Beckham PG&E CRDR Phase II Project Manager Joseph Cucco, Jr.
PG8E CRDR Phase II Review Team Leader Bryant Giffin PG&E Joe Seminara PG&E - Consultant John J. Vranicar PG&E Joseph Lisboa Bechtel Rob Fisher PG&E W. Neil Thompson NRC-DHFS-HFEB Team Leader Dom Tondi NRC-DHFS-HFEB Dick Eckenrode NRC-DHFS-HFEB Saba N. Saba NRC-DHFS-HFEB John Stokley SAIC - Consultant to NRC Joel Kramer NRC-DHFS-HFEB Carol Kain SAIC - Consultant to NRC Sig Auer PG&E Tom Libs PG&E
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s ENCLOSURE 3 MINUTES OF MEETING BETWEEN NRC AND PG&E ON THE DCRDR FOR THE DIABLO CANYON GENERATING STATION, UNITS 1 AND 2 The following are minutes of a meeting held on November 6,1985, between the Nuclear Regulatory Commission (NRC) and Pacific Gas and Electric (PG&E).
Also in attendance were a PG&E human factors consultant and NRC consultants from Science Applications International Corporation (SAIC).
Specific attendees and the organizations they represent are shown in.
The purpose of the meeting was to address conceres that resulted from ai. in-progress audit conducted on February 11-15, 1985, at the plant site.
Results of that audit were documented in a report and' forwarded to PG&E on September 16,1985 (Reference 1).
In response to the in-progress audit report PG8E requested a meeting with NRC staff to address the in-progress audit findings and to attempt to overcome any problems found with the DCRDR being conducted. The following are highlights of the meeting. Attachment 2 provides the NRC meeting agenda that had been suggested in the audit report. consists of handouts provided by PG&E during the meeting.
Establishment of a Qualified Multidisciplinary Review Team During PG&E's in-progress audit, several concerns surfaced regarding the core review team composition and the management review team's participa-tion in the DCRDR.
PG8E addressed concerns in the audit report in describing the team composition by discipline and the types of disciplines that are assigned to each DCRDR task. A handout to illustrate DCRDR task assignments was also provided. At the time of the audit, the human factors specialist was not engaged with some important parts of the DCRDR; however, PG&E indicates that this expertise is now available and will take a stronger role in DCRDR tasks.
PG8E also discussed the management team participation in review of i
Human Engineering Discrepancies (HEDs) and approval of proposed design cha n ge s.-
A DCRDR procedure has been established for management sign-off in the assessment and resolution process to increase their involvement.'
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4 Also mentioned during the meeting was the assignment of a new manager to Phase 2 of the DCRDR; this individual is also charged with managing the implementation of the Safety Parameter Display System (SPDS).
PG&E recognizes that an overlap of personnel between the different control room improvement programs will help to coordinate efforts.
Complete documenta-tion of personnel by name DCRDR tasks assigned, level of involvement, and participation in other improvement programs should be included in PG&E's documentation of this requirement.
Function and Task Analysis: Comparison of Display and Control Requirements With a Control Room Inventory The methodology and the composition of the DCRDR Team which were employed in the effort to meet this requirement were ju'dged by NRC to be inadequate.
This mes; age was conveyed to PG&E at the time of the in-progress audit and again in the NRC in-progress audit report (Reference 1).
Since the time of the audit, Diablo Canyon has completed writing all the E0Ps associated with Revision 1 of the Westinghouse Owners Group Emergency Response Guidelines. As of the date of the current meeting, PG&E had not yet turned its attention to satisfying the task analysis concerns resulting from the NRC in-progress audit. However, at the meeting, PG&E agreed to comply with this requirement of NUREG-0737 Supplement 1.
Specifically, PG&E agreed to:
1.
Include a human factors specialist to assist it in the completion of both the analysis itself and the comparison of the display and control needs (product of the task analysis) with the control room inventory. Confirm methodology to be used for completing the task
. analysis.
2.
Ident i fy, independent of the control room, the needed human factors characteristics of the information and control require-ments needed to perform the task.
3.
Create documentation of these required characteristics for use in i
comparison against the control room inventory.
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Complete the comparison and identify HEDs.
5.
Document process for audit purposes.
As an integral part of completing the above steps, PG&E should respond to elements 2 and 3 of the in-progress audit report (Reference 1) in its letter to the NRC Diablo Canyon Project Manager, as well as in its Supplement to the Summary Report.
Additional guidance to PG&E may be found in an NRC memorandum from H.B. Clayton to D.C. Ziemann, dated April 5,1985 (Reference 2).
Items 2 and 4 of this memo are still open items.
PG&E should note that completion of the task analysis was intended to be done to assist in developing effective E0Ps.
Consequently, the results of the new task anslysis effort may result in modifications to those E0Ps already written by PG&E (e.g., instances may be found where the control room does not adequately support the E0Ps).
NRC concluded this item by requesting that PG&E describe their methodology to the NRC before beginning the task analysis. That description should be documented in their response to the NRC Project Manager.
They should feel free to phone NRC for any guidance to develop their methodology.
Control Room Survey During the in-progress audit, PG&E had not completed some of the studies that are part of the survey; namely lighting survey, control environment for heating, ventilation and air, the auditory environment, emergency eouipment, annunciator system and communications.
Review of the remote shutdown panels was also in progress.
Display formats and features on the plant computer and the SPDS are also to be part of the control room survey effort. The audit team had also found the survey identified several i
generic or control room-wide HEDs for which the survey team were to resurvey on a panel-Ly-panel basis.
PG&E addressed this concern by indicating that plans for survey completion were under way and were expected to be finished by February 1986.
Assessment of HEDs t
In response to the in-progress audit, PG&E developed a methodology to reassess HEDs in order to identify the safety significant HEDs.
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methodology was discussed during the meeting, and PG&E provided handouts to illustrate the assessment process and the manner by which it will maintain l
records.
The major item left unresolved during the audit was the specific process to screen safety-significant HEDs.
The assessment of HEDs has been revised and improved from that originally performed; HEDs that impact plant safety will be identified and placed in Priority Groups 1 or 2.
The major delineation between Group 1 and 2 HEDs is defined as the potential for error.
NRC staff are concerned that the potential for error be assessed by the human factors specialist and that HEDs be grouped by either high, medium or low categories. HEDs with no high error potential and no significant safety consequences may be placed in lower priority categories. Group 1 HEDs will be scheduled for the first refueling outage which is planned for July 15,1986; and Group 2 HEDs will be corrected during either the first or the second refueling outage. PG&E was reminded to assess HEDs that have neither high safety consequences nor high potential error for their cumula-tive effects which could raise their significance and priority. Because the Supplement to the Summary Report describing corrections is tentatively scheduled for July 1987 - after the correction phase begins - a conflict exists between implementation of corrections (July 1986) prior to NRC review of those corrections.
In conclusion, the meeting resulted in clarification of PG&E's methodology to satisfy this requirement. With exception of a scheduling conflict, NRC found PG&E has adequately improved its process to identify and schedule corrections for safety-related HEDs. The conflict in scheduling may be resolved by an NRC staff visit prior to the Supplement to the Summary Report to review proposed corrections for safety-significant HEDs.
HEDs and other findings documented during the in-progress audit mini-survey should be addressed in the assessment process and documented in the Supplement to the Summary Report.
Results of the HED assessment process should also be reported to the NRC in their Supplement to the Summary Report.
Selection of Design Improvements This item, which was addressed during the meeting involved the specific procedure PG&E would institute to guide HED correction from design improve-ments through to implementation, including the participation of a human factors specialist.
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During the meeting, PG&E discussed its correction process, provided a flow chart to illustrate the process, and described the role the human factors specialist would provide.
Preliminary HED corrections are formed during core team assessment of HEDs and more formal selection of design changes are to be determined by using a half-scale mock-up. The process will be done by the core review team with the full participation of a human factors specialist.
Documentation of HEDs and proposed corrections are submitted for management team review who then either concur or ask for other alternatives.
Interim compensatory action may also be proposed to reduce the safety significance of potential for error of the HED until a time when full or optimal correction can be made. Justification for no correction may also result during the correction phase.
PG&E also discussed the approach that is taken for modifying procedures when correcting those types of HEDs. The process is largely identical to the one for design corrections; however, the PG&E operations group plays a stronger role in the process to verify that the HED is corrected.
All design changes or procedure changes are fully documented and reviewed by management in a formal plant design change procedure.
The procedure also calls for human factors involvement throughout the process.
It was concluded that this item from the audit has been addressed with a process that should guide HEDs through design correction proposal to implementation.
Verification That Selected Improvements Will Provide the Necessary Correc-tion, and Verification That Improvements Will Not Create New HEDs 3
During the in-progress audit, PG&E had not formalized a procedure for this stage.of the DCRDR, and had not identified the role the human factors specialist would take.
As described above, a more formalized procedure to document HED corrections and to include human factors was established. That process includes review of the corrections on a mock-up and/or in the simu-lator.
Procedural changes are also to be verified by an operations review group who have the following checklists at their disposal to help in verify-ing the correction:
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Westinghouse Owners Group Writer's Guide 2.
2005-EOP Checklist 3.
Human factors review of format consistency with other procedures Coordination of the DCRDR With Other Control Room Improvement Programs The process to accomplish this requirement was briefly described by PG&E. Specifically it indicated that overlap of team members on the dif-ferent programs would afford a mechanism to meet this requirement; however, it did not provide documentation or examples of how this mechanism would
- function, i.e., sign-off sheets, procedures, etc.
PG&E also stated that the E0Ps are complete as of March 1985, Regulatory Guide 1.97 instrumentation is largely installed, and the SPDS has been declared operational.
Training of operators to all changes is not complete, at least for the DCRDR; however, a mechanism exists for the training department to sign-off on all design changes.
PG&E should fully respond to this item during future submittals.
One way to illustrate this item may be to expand the HED Correction Flow Chart to indicate the relatichship and integration of DCRDR corrections with other control room improvement programs.
Conclusions The meeting resulted in clarification of most items found during the NRC in-progress audit at Diablo Canyon, Units 1 and 2.
PG&E concurrence with this meeting summary should be provided along with a specific response to all nine items that were found during the audit, with specific detail describing the process to conduct the function and task analysis.
The NRC staff believe that PG&E has performed a great deal of work to accomplish the DCRDR but has yet to document the specific procedures (particularly for items 2 and 3) and communicate them via submittals to the NRC.
Only through such submittals can the licensee be assured of receiving credit for its e fforts.
At a minimum, information to address all audit items, including the SPDS audit findings, should be submitted in PG&E's Supplement to the i
Summary Report.
An organization chart identifying personnel, task assign-ments, and levels of effort for each of the nine items should be developed and provided, in addition to any quality control aspects for completion of 6
items.
PG8E should also inform the NRC of intentions to implement safety-related corrections during the first refueling outage. A response to all nine items from PG&E should be received by NRC in early January.
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REFERENCES 1.
"In-Progress Audit of the Detailed Control Room Design Review Evalua-tions for' Diablo Canyon Power Plant Units 1 and 2."
Division of Human Factors Safety, NRR, NRC, September 1985.
2.
NRC Memorandum from H.B. Clayton to D.L. Ziemann, " Meeting S.ammary -
Task Analysis Requirements of Supplemenet 1 to NUREG-0737.," April 5, 1985.
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4 ATTACHMENT 1 DIABLO-CANYON DCRDR MEETING November 6, 1985
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Attendance List Name Affiliation Hans Schierling NRC/DL/LB-3 Peter Beckham PG&E CRDR Phase II Project Manager F. Joseph Cucco Jr.
PG&E CRDR Phase II Review Team Leader Bryant Giffin PG&E Joe Seminara PG&E - NF consultant-John J. Vranicar PG&E Joseph Lisboa Bechtel I&C Rob Fisher PG&E - Ops Sr. Engr.
W. Neil Thompson NRC DHFS HFEB Team Leader Dom Tondi NRC DHFS HFEB Dick Eckenrode NRC DHFS HFEB Saba N. Saba NRC DHFS HFEB John Stokley SAIC/ consultant to NRC Joel Kramer NRC DHFS HFEB Carol Kain SAIC/NRC Sig Auer PG&E Co. Eng.
Tom Libs PG&E 9
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ATTACHMENT 2 SUGGESTED AGENDA FOR DIABLO CANYON DCRDR MEETING 1.
Structure and Participation of the DCRDR team A.
Increased participation of human factors consultants B.
Provision for documenting levels of effort or task assignments C.
Increased involvement of PG&E management in HED review and approval process.
2.
Function and Task Analysis A.
Changes to methodology in order to provide a listing of needed instrument and control characteristics associated with operator tasks.
B.
Change in process to include human factors specialists in task optimization of E0Ps.
C.
Completion of all tasks associated with Revision 1 or the EPGs.
3.
Comparison of Display and Control Requirements with a Control Room Inventory A.
Change in methodology to use identified inventory and product from SFTA B.-
Method for documentation.
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Control Room Survey l
A.
Discuss current status and plans for completion of studies / surveys B.
Discuss methods for documenting specific HEDs which are part of a larger generic group.
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s 5.
Assessment of HEDs i
Change of process to screen safety significant HEDs
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Selection 'of Design Improvements Development of a procedure to guide HED correction from design improvement through to implementation, including the participation of the human factors specialists in all phases.
- 7. and 8.
Verification Discuss a formalized procedure for this activity, and include the participation of the human factors specialists.
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Coordination of DCRDR with other programs A.
Discuss a formalized process B.
Provide a procedure with a milestone chart to illustrate product completion, integrator, and iteration with other programs.
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s ATTACHMENT 3 DCRDR TASK ASSIGNMENTS I
REASSESSMENT OF HED'S Develop Methodology:
Review Team Leader Human Factors Specialist Core Review Team members Plant Operations Personnel Reassess HED's:
Human Factors Specialist Review Team Leader Core Review Team members Operators Additional technical support as required Perform Invest / Surveys:
Core Review Team members -
Human Factors Specialist Additional technical support as required Results reviewed by other review team members including Human Factors Specialist l
HED Assessment Concurrence:
Management Team Plant Representative for Priority I NED's Any MT member for non-priority I HED's FORMALIZE ENHANCEMENT METHODOLOGIES Draft Guidelines:
Human Factors Specialist Core Review Team members Plant personnel Convert to Technical Format: Core Review Team members Review Guidelines:
Human Factorr ecialist Review Team La,<.**
Formalize Guidelines:
Core Review Team a abers Design Drafting personnel Management Team HED RESOLUTIONS Develop Resolution Options:
Human Factors Specialist Core Review Team Review Team Leader Plant Operations Personnel
s Implement Changes to Mock-up: Core Review Team members Design Drafting personnel Review Team Leader Verify HED's Corrected:
Core Review Team members Human Factors Specialist Plant Operations personnel Review Team Leader Validate Corrections:
Human Factors Specialist Plant Operations personnel Core Review Team members Review Team Leader General Review of Changes:
Plant Operations personnel Review Operator Comments:
Human Factors Specialist Review Team Leader Core Review Team members Others (DCPP. NOS, DCP) as required SUBMIT MODIFICATION RECOMMENDATIONS Design Change Requests:
Core Review Team members Design Drafting Review Team Leader Project Manager Other Requests / Recommend:
Core Review Team members Review Team Leader Project Manager DEVELOP RESOLUTION IMPLEMENTATION PLAN Establish Milestones:
Review Team Leader Core Review Team members Management Team members (via HED assessment concurrence)
Implementation Schedule:
Project Management Group persomnel Diablo Canyon Project scheduling personnel Review Team Leader PROVIDE MECHANISM FOR HUMAN FACTORS REVIEW OF FUTURE CHANGES Provide HF Training:
Human Factors Specialist (to Eng'g, Operations, etc.) Review Team Leader Core Review Team members
s Perform HF review of DCN's:
Review Team Leader (duration of DCRDR)
Core Review Team members Human Factors Sp.ecialist Perform HF review of DCN's:
Human Factors Group (to be established)
(post-DCRDR)
INTEGRATE WITH OTHER NUREG-0737 ACTIVITIES Peg. Guide 1.97 Review:
Core Review Team members I&C Engineering Human Factors Specialist Review Team Leader SPDS Review:
CRDR Project Manager Human Factors Specialist Core Review Team members Review Team Leader E0P's Review:
Plant procedures group Operating Procedures Review Group Human Factors Specialist Core Review Team members Review Team Leader i
ISSUE FINAL REPORT Draft Report:
Review Team Leader Human Factors Specialist Core Review Team members Review report:
Project Manager Management Team members DCPP. NOS and DCP Manarers Licensing DCRDR contributers Note 1: The order of listing reflects the relative level of involvement.
Note 2: The core Review Team consists of personnel from I&C Engineering, Electrical Engineering, and Operations Engineering.
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9 Ct.5kNIC TO PLANT SPECIFIC (DCPP 1 & 2) TASE ANALYSIS CONVERSION PROCESS DCPP 1 & 2 TASE ANALYStB 4 CENtelC AND DCPP 1 & 2 q
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DOCUMENTAft0E (FS&B. STS...I DCPP 1 & 2 TASK ANALYSIS - EOPe/INSTRUntNTATION & CONTsOL pt0UlstatNTS lguagG-Oe99 y
TASK ANALYSIS ACConPLislutENTS 1.
Systematic Evaluation of generic optiest Recovery S.
Bete >lleh_ed_ Speelfic Step Devletion Documents for Guidelines (ORGo). Critice! Safety Function Status Trees each task onetyens requirement and juottfled (CSFSto). Critice! Safety Functlen Besteretten Guldet!nes differences and/or beste from the generic DCPP 1 & 2 (CSFACs). System Review Took Analyene (SATA) documentotton documents.
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with the plant specific documentatten (es:
STS. etc.),
identified operator's speelfte taske and took/ element 6.
Perferueg_.gt calculations (volues, setpoints, requiremento. Evoluetten of the individual and occuracy. etc.) of instrumentation required for lategrated (sequentiet) teek requiremente !Jentitled emergency trenelente identified in teek analysis.
Instrumentatten & Control cherectoristics, and the Instrumentation and Centrole necessary for proper F.
OrteM sed took enstrale documentatten to support 3
operator response to emergency trenelente, the oyotamatic identificetten and secessment of Control Room / Net shutdown Pene! Muman 2.
Sretematte tweluetton of 14 entitled Boro Instevmentotton Engineering Olocrepancies (Nape).
DCPP 1 & 2 and Controle (Step 1) for a given took(s) for a set of SPECIFIC p
event sequences welldeted e!! essecleted teek requiremonte.
3.
getebilshgg 50P verificetten and volldellen DESICE For esemple, discrete event sequences generate teek Record (Operators' interaction record).
DATA
- requiremente. These in turn estehtleh speelfic l&C chorectern etic o.
Evaluation of the Instrumentation and 9.
Control Rose Welt-Throwah Controle for the fu11 spectrum of event ooquences if for a given erstem (Es: Contelnment Instrumentation) e creeability Analyele Valldete all the associated took requirements of that e Teek Analyste Welk-Through Workoheet DCPP 1 & 2 system.
e Welk-Through Instrument Suttebility Revlow STANDARD o
Walk-Through operator Took Review Y
ftCHNICAL 7
5.
$dested/ Augmented generic documentatten to reflect plant m
&#ECS speelfic conftsuretten and operettenet philosophy for EOPo 10.
The above sequentist enelyste developed Plant (S.T.S.)
and the required Instrumentation and controle. By a direct Specific E0ro and identified Instrumentet1on and correlation between generic Enc-SRTA documentation and Control Characteristico associated with 50Po' Jb plant specific sequentist task enetrole en integrated teoke for ett effected erstems.
CRDR-EOF development wee attelned.
WOG EnGe p
4.
poveloped sacktruund Information (st) for plant specifle (MP SASIC)
E0Pe by sugmenting generic documentetton to plant specific requirements on the following-1r e operator twelfic actione o
Instrumentation and controle swellebility and SRTA multability to allow operators' response to mergency
- THIS INCLUDES P&lDS. SINGLE LiWE 0140. SYSTSit I
WOG v
transiente.
DESCRIP. P.Oe. W PL&S. W SETFORWT STUDf ETC.
o plant Specific Information (Es vertebte values for a given emergency trenelent) 0230T/0003T-1
1 E
e GhekRtc UCCUnaNTS (OACa. CSPSTe, etc.). FSAE. S.T.S., PL48, etc.
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,r BACK Ch3 Ump turonNATION (31)
ENEACENCY PROCEDURE STEl PROCEDUsE DRANCMk3 TO FOR EMER PROC. REACTOR TRIP REACTOS TRIP OR SAFETT IN EP E-0 SEQUENTIAL STEPS ON SAFETT INJ. EP-E-0 GR_gR tuJECT10m EP E-0 y
munsta TITtt IIEE ACHIEVENENTS ACHIEVFJIRWTS ACHIEVEMENTS 1
% FA-S.1 Response to N.P. Gen /ATWS (_
1 e Purpose (a)
Centrol Room Welk-Throuth o Teek seguirements (a) 3 kCA-0.3 Dectore Vital Due e
3 o Beele (*)
e operettlity AnalyeLe o Operator Actions (*)
J BCA-0.0 8.oes of All AC Pur.
4--
3 e Actlene (a) o Task Analyste Welk-Throuth Workoheet e Instr & Centrole (*)
4 8-0.1 Reactor Trip Besponse 6
4 o Instrument (*)
o Watk-theis 1&C Sutteb111ty Revleu I
o NEDo (a) 11 W
E-10 C-1 Sealed Vle Chk!!st ECCSS e
11 o Contret/ Equip (a) o HEDs I
o Operator's Ceemente 13 W
PR-N.1 Seep to Lees Soc. Mt Sink e 13 o Knouledge (*)
o Operator's Ceemente 16 W
J-65 Diese! Generatore 4-16 e Specific Info (a) 10 M
E-1 laas of Re er Sec Coet.
4-18 o Operator's Commmente l
i a As en esemple see Step 11 20 B-2 Peutted S.C. lool 20 21 E-3 3.G. Debe Butture M
21 e As en esseyte see 22 E-1 Lees of Rs or Sec Cool 22 Stop 11
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24 E-1.1 81 Tecuinetton 24 26-27 E-3 S.C. Tube aupture
+
r6-27 20 BCA-1.2 lACA Oute Centelament 4-28 32 AP-9 Loss of instrument Air 4--
32 33 E-1 Lees of Ra er Sec Coo!
ACHIEVEMENTS o Teek Requiremente l
i f If e Operator Actions e Instrument & Controle e Operator's cosamente I
t i f INTEGRATED RESULTS I
o Specific Sintte/Sequentle! Took Requirements e
instrumentatten & Controlo Characterlet!ce e
St Calculations (31-1, -2.
-3.
-9. -10. -13) o ROPE Deelation Document (EP-E-0) o Eor Verification & Valldetton Record (E-0) i IP JP EOF Verification 1&C Requiremente For All Affected Systemen I
SAMPLE OF DCPF 1 & 2 TASE ANALYSIS BSACTOR TRIP SAFETT INJECT 105 l
l 02307/00037-2
REASSESSMENT OF HUMAN ENGINEERING DISCREPANCIES (HED'S)
SCOPE This procedure provides guidance for assessing the safety significance and operability concerns of Human Engineering Discrepancies (HED's).
PROCEDURE Each HED will be assessed in accordance with the flow chart shown on.
This assessment will place each HED in one of five categories which relate to the priority of the HED. The categories are:
High priority; HED shall be corrected or mitigated by the I
1st refueling, or justification must be made-for continuina operation.
Medium prioritv: the HED should be corrected within a II reasonable time period (1st or 2nd refueling).
Operability concern; HED will be corrected as the schedule III permits.
Low priority; cost / benefit analysis will be performed to IV determine fix (if any). No established schedule.
HED need not be considered for correction.
N/A The assessment process will consider the safety significance of the equipment associated with the HED, the potential for error of the HED,
~ and the consequences should an error occur.
PLANT FUNCTION The first step in assessing the HED's as shown on Attachment 1 is determining the function of the equipment involved. HED's affecting equipment which is safety-related, or equipment which is not safety-related but is used in an emergency operating procedure, will be. assessed for safety significance. HED's affecting the balance of plant equipment or which do not directly affect plant equipment will be assessed for plant operability.
POTENTIAL FOR ERROR The HED is next reviewed for potential for error. Attachment 2 includes a series of questions (derived from NUREG-0800. Exhibit 2-2) which will be used as guidance during this part of the assessment.
The human factors specialist will be relied on heavily to determine the actual potential for error occurrence.
~.
s
.o CONSEQUENCE OF ERR 0h The HED's following the safety significance path will next be reviewed for safety consequences of an error resulting from not correcting the HED. The following are examples of errors with significant safety consequences:
An error that would likely result in unsafe operation or the violation of a technical specification, safety limit, or a
~ limiting condition for operation.
An error that would likely result in the unavailability of a safety-related system needed to mitigate transients or systems needed to safely shut down the plant.
An error that would likely result in a challenge to the safety-related systems in shutting down the plant (e.g., a Reactor Trip or a Safety Injection).
HED's judged to not lead to errors of significant safety consequences will also be reviewed for operability concerns. Operability concerns include factors affecting plant availability, plant efficiency, plant reliability, etc.
i d for
,The HED's following the plant operability path will be rev ewe plant operability concerns only.
PRIORITIZATION AND RATIONALE By following the flow chart, each HED will fall into one of the five priorities previously mentioned. If the. priority is not apparent or if there is no clear cut "yes" or "no" answers to some of the assessment factors, the HED will be further analyzed with a view toward improving operator performance and plant safety, and a priority will be selected by the Review Team. The rationale used will be documented on the assessment form. Any significant dissent from the final priority selected will also be documented.
CORRECTION After the HED has been assessed and prioritized, proposed resolutions can be discussed and documented. This step is included here because the subject is clear and it allows input from both Operations and the Human Factors Specialist in determining design requirements. The manner in which HED's are assessed (by function, error potential, and consequence) prevents discussion of resolutions at this time to affect the prioritization of an HED.
For Priority I HED's, an Interim Compensatory Action or summary Justification for Continued Operation (JCO) is included on the Assessment form. The Interim Compensatory Action serves to reduce the safety significance or potential for error of the HED until I
time permits implementation of a final or optimal correction. A JC0 is documented when it is impractical to implement an interim physical modification or when no correction is planned.
I
.g e
The Backfit Feasability is added for information only. It will not be a factor in whether or not a Priority I or II HED will be corrected or mitigated. It may be a factor in the extent of the correction and/or the schedule for implementing the final (optimal) resolution.
The Schedule for Implementation is a goal fer resolving an HED.
M'ilestone dates such as "first refueling." "second refueling,"
" completed," will be used here. Specific dates will be generated later as the extent of the number of changes and Engineering and Construction involvement become known.
CONCURRENCE During the assessment, the Review Team meubers performing the assessment will initial the form in the available space. Any dissents shall also be initialed.
After the assessment form is completely filled out, it shall be sent to a Management Team member for concurrence. Priority I HED's should be signed by the DCPP Management Team member. The non-Priority I HED's may be reviewed by any Management Team member.
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c ATTA W utar E FOTENTIAL 2"CR r.nROR DISCREPANCY HAS CAUSED AN ERROR IN THE PAST (If this can be answered yes, no further review is required).
OPERATORS HAVE ATTEMPTED TO CORRECT THE DISCREPANCY THEMSELVES FACTORS AFFECTING OPERATOR ATTENTIVENESS Discrepancy will cause undue operator fatigue.
Discrepancy will cause operator confusion.
Discrepancy will cause operator discomfort.
Discrepancy presents a risk to control room personnel.
Discrepancy will distract control room personnel from their duties.
FACTORS AFFECTING OPERATOR PHYSICAL ABILITIES Discrepancy will affect the operator's ability to see and read accurately.
Discrepancy will affect the operator's ability hear correctly.
Discrepancy will affect the operator's ability to communicate with others.
FACTORS AFFECTING OPERATOR ACTIONS Discrepancy will cause a delay of necessary feedback to the operator.
Because of the discrepancy, operator will not be provided with positive feedback about control tasks.
Discrepancy will lead to inadvertent activation or deactivatior. of controls.
Discrepancy will otherwise degrade the operator's ability to manipulate controls correctly.
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l FACTORS AFFECTING OPERATOR MENTAL OR PHYSICAL WORKLOAD Tasks in which the discrepancy is involved may be highly stressful.
Discrepancy is involved in a task which is usually performed concurrently with another task.
Discrepancy requires operator to calculate or interpolate data.
Discrepa'ncy violates normal control room or nuclear industry conventions or population stereotypes.
- 4 1
48 CHRON #
CATEGORY HUMAN ENGINEERING DISCREPANCY ASSESSMENT TITLE / SUBJECT (Complete description is on attached HED)
ASSESSMENT:
SAFETY RELATED:
YES NO Reviewers HIGH ERROR POTE!GIAL:
YES NO SIGNIFICANT SAFETY CONSEQUENCE:
YES NO N/A OPERABILITY CONCERN:
YES NO N/A Date PRIORITY:
RATIONALE:
DISSENT:
COPJtECTION PLAN:
A.
Inunediate Capensatory Actions / Justification for Continued Operation:
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Optimal Correction:
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Management Team Representative Date
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UNITED STATES
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8 NUCLEAR REGULATORY COMMISSION o
wasamorow, o. c.aeses December 9, 1985 hC\\/ h Cdi 3 Docket No. 50-275 LICENSEE: Pacific Gas and Electric Company FACILITY: Diablo Canyon Power Plant, Unit 1
SUBJECT:
MEETING
SUMMARY
- IST PROGRAM
' ' - ~ '
The NRC staff met with PG8E representatives on November 4, 1985 in Bethesda, Maryland to discuss the following inservice test _i_ng (IST) issues'that had
~
been identified by the staff with respect to the Ofablo Ci~nyon Power Plant (DCPP) Unit 1 in SSER 31 (April 1985):
1.
Check Valves (SSER 31, Section 5.2.8.1, Item 13) 2.
Pump Flow Measurements (SSER 31, Section 5.2.8.1, Item 4) 3.
Vibration (SSER 31, Section 5.2.8.1, Item 3)
Details of the discussion are presented below, meeting attendees are listed in Enclosure 1, the meeting announcement is Enclosure 2.
The above items were addressed with respect to Unit 1 only.
1.
Check Valves In SSER 31 the staff had identified certain check valves in the safety injection system and residual heat removal system as performing a pressure boundary isolation function and stated that they should be reclassified and listed in accordance with applicable Technical Specifications. PG&E provided additional information to the staff on these valves in Letter No. DCL-85-320, dated October 11, 1985. The staff stated that at least two valves are required at each reactor coolant system high pressure boundary to prevent an inter-system LOCA and both valves must be included in the Technical Specifica-tions and be tested. Since the DCPP Unit I has three valves in each RCS high pressure boundary of the safety injection and residual heat removal systems, PG8E suggested that all three valves be included in the Technical Specifica-tions with the requirement that any two out of the three be successfully leak rate tested. The staff stated that the approach would be acceptable.
PG&E stated that, as a minimum the following valves would be included in the Technical Specifications: 8949 A, B, C and D; 8802 A and B; 8703. The staff suggested that PG&E submit a license amendment request to this effect, including appropriate systehi drawings. The request should be provided no later than Janu;ry 1986.
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. December 9, 1985 2.
Pump Flow Measurements As stated in SSER 31 PG&E had requested specific relief from measuring the flowrate for'the centrifugal charging pumps, auxiliary feed water pumps, diesel fuel oil transfer pumps, boric acid transfer pumps, and make up water transfer pumps in accordance with the requirements of ASME Code Section XI. At the meeting the NRC Staff restated the requirements for flowrate measurements of pumps that are identified in the inservice testing program. The staff also stated that if PG&E could demonstrate that the installation of the necessary instrumentation was impractical the staff would consider requests for relief as appropriate. PG&E and the staff discussed various methods of measuring flow in the ptmps of the above systems. Methods discussed included flow measuring devices and liquid transfer (i.e., tank pumpdown) using changes in tank levels and mathema-tical calculations. PG&E identified a potential difficulty in meeting the Code accuracy requirements for boric acid flow instrumentation and liquid transfer flowrate measurement. The staff indicated that relief requests concerning instrument accuracy, if needed, would be appropriately considered.
PG8E agreed to update the inservice testing in a forthcoming submittal to include the requirements for flow measurement and any necessary relief requests regarding flow measurement accuracy prior to startup after the first refueling outage, in accordance with the schedule outlined in SSER 31.
3.
Vibration Measurements As stated in SSER 31 PG&E had requested relief from the requirement of measuring displacement vibration amplitude for all pumps in the IST program and as an alternate had proposed measuring vibration velocity for those pumps. The staff had identified in Table 5.1 of SSER 31 the acceptance criteria to be applied. At the meeting PG&E presented the basis for the relief request to measure pump vibration in units of velocity.
PG&E dis-cussed the method proposed for vibration limit detemination. The staff took exception to direct conversion of displacement values, as currently described in Section XI, to equivalent velocity values at the pump operating speed. PG&E and the staff discussed the limits proposed in SSER 31. PG&E was concerned with the apparently conservative limits prescribed in relation to that of the Code.
PG&E discussed overall relaxation of the staff proposed limits. The staff was receptive only to relaxation on a case-by-case basis.
PG8E will investigate this option further and respond with a revision to the IST program and a schedule for its implementation.
Conclusion PG8E will evaluate the staff comments and will submit appropriate revisions to the IST program for DCPP Unit 1, including request for relief as necessary.
PG&E will consider to submit a license amendment request regarding the
. ~.
- - -. - ~
J 4
December 9, 1985 i
inclusion of check valves as discussed under Item 1 above.
If necessary, l
PG8E will contact the staff for future clarification prior to future submittals on the IST program. The meeting adjourned in the afternoon, November 4, 1985.
-a._ s LL Hans Schierling, Project Manager PWR Project Directorate #3 Division of PWR Licensing-A
Enclosures:
As stated cc w/ enclosures:
d See next page a 4
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