ML20202B505

Summary of 860515 Meeting W/Util in Bethesda,Md Re NRC Comments on Licensee Dcrdr Summary Rept & Suppl.Comments, List of Attendees & Worksheet for Reassessing Util Procedure for Defining Controls Encl

ML20202B505
Person / Time
Site:	Yankee Rowe
Issue date:	06/13/1986
From:	Mckenna E Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8607100315
Download: ML20202B505 (19)

Text

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.D JUN 131986 Docket No.50-029 LICENSEE: Yankee Atomic Electric Company FACILITY: Yankee Nuclear Power Station

SUBJECT:

MEETING

SUMMARY

Re: Detailed Control Room Design Review (DCRDR) Summary Report

- Staff Comments A meeting was held on May 15, 1986 in Bethesda, Maryland between members of the NRC staff, personnel from Yankee Atomic Electric Company (YAEC), and their respective consultants. The purpose of the meeting _was to discuss the staff's comments on the licensee's DCRDR Summary Report and supplement (see Enclosure 1). A list of attendees is provided in Enclosure 2.

During the nceting, each of the eleven sections from the comments (TER) were discussed. For those areas that are open, the licensee discussed how they proposed to resolve the concerns or provided clarification of their previous responses.

ITEM 1 - QUALIFICATION AND STRUCTURE OF THE DCRDR TEAM This item was considered resolved by the NRC review team in the TER. At the meeting, the licensee noted that they had retained a human factors consultant to enhance the expertise of their DCRDR team.

ITEM 2 - FUNCTION AND TASK ANALYSIS ITEM 3 - COMPARISON OF DISPLAY AND CONTROL REQUIREMENTS WITH A CONTROL ROOM INVENTORY Items 2 and 3 were discussed together at the meeting. The TER had raised some concerns regarding the instrumentation and control requirements. The licensee stated that their analysis for identification of instrumentation needs was ,

acceptable but acknowledged that additional review of control requirements was warranteu. The staff agreed. The licensee proposed to reassess their pro- ,

cedure for defining controls and send a copy of the proposed worksheet for this ,

purpose; a copy is attached as Enclosure 3 to this meeting summary. This item j remains open pending staff review of the worksheet. l 1

8607100315 860613 PDR ADOCK 05000029 P PDR

ITEM 4 - CONTROL ROOM SURVEY The only open issue for this section was a human engineering discrepancy (HED) which is now being tracked along with the other individual HED's. Thus this section of the sumary report is considered resolved.

ITEM 5 - ASSESSMENT OF HEDS This issue concerned the licensee's consideration of safety significance in prioritizing resolution of HEDs. The licensee stated that all the HEDs had been reviewed for safety significance and that none were identified as requiring immediate action. As discussed further below, safety significance will be a major consideration in the resolution of the HEDs.

ITEM 6 - SELECTION OF DESIGN IMPROVEMENTS ITEM 7 - VERIFICATION THAT IMPROVEMENTS WILL PROVIDE THE NECESSARY CORRECTIONS WITHOUT INTRODUCING NEW HEDS

' The licensee described the approach they intend to pursue for resolving HEDs. The licensee will take half-size photographs of the present control room layouts to construct a photo mockup. Proposed changes can then be evaluated by seeing the "before" and "after" configuration. This review would be done on a panel-by-panel basis, with the first one being the safety injection / diesel generator panel. This panel was selected for its potential safety significance and because examples of each type of HED are present.

All HEDs affecting that panel will be evaluated on an integrated basis to establish any necessary improvements.

The licensee sorted the HED's into 12 categories (procedure, environment, training, annuniciator, labels, color, demarcation, engineering, zone code, SPDS, mimic, discard). For each category, a specification for evaluation and resolution will be developed. The licensee will verify that these specifications meet the guidelines of NUREG-0700, or will identify any differences.

To satisfy item 7, the licensee stated that the final design will be checked against the original HED to verify it has been fixed. Use of the specifications will ensure that the modifications are developed considering human factors criteria such that new HEDs are not generated.

ITEM 8 - C0 ORDINATION OF THE DCRDR WITH OTHER IMPROVEMENT PROGRAMS The licensee discussed how the DCRDR effort was coordinated with other programs such as Safety Parameter Display System (SPDS), Emergency Operating Procedures (E0Ps) and Regulatory Guide 1.97. The clarification provided at the meeting was sufficient to satisfy the staff's question.

ITEM 9 - PROPOSED CORRECTIVE ACTIONS ITEM 10 - JUSTIFICATIONS FOR HEDS LEFT UNCORRECTED Items 9 and 10 were discussed together at the meeting. As discussed under item 6, an integrated review of all HEDs on a panel-by-panel basis is being performed. The licensee stated that following these reviews each HED will be resolved either by being corrected in accordance with the specifications or an adequate justification will be provided.

ITEM 11 - 0THER This section presented other factors that might enhance the DCRDR but that were not required. No specific licensee response was, therefore, needed.

SUMMARY

The results of the review of the first panel is expected in August. The staff will review at that time the effectiveness of the evaluation process (including the specifications for the various HED types) and the resolution of individual HEDs associated with that panel. If the licensee's process is satisfactory, subsequent staff review will be limited to evaluating the justifications for uncorrected HEDs.

Based on the information presented at the meeting and in Enclosure 2, the staff will finalize its report on the licensee's DCRDR Summary Report.

h Eileen i. McKenna, Project Manager Project Directorate #1 Division of PWR Licensing-A

Enclosures:

1. Staff Comments on DCRDR Summary Report and Supplement

2. List of Attendees

3. Worksheet Reassessment cc's next page Office: LA/ PAD #1 PM/h PD/ PAD #1 Surname: PShuttled .- EMcKenna/tg Glear Date: 08//2/86 / 86 Qf//[/86

Mr. George Papanic, Jr.

Yankee Atomic Electric Company Yankee Nuclear Power Station cc:

Mr. James E. Tribble, President Yankee Atomic Electric Company 1671 Worcester Road Framingham, Massachusetts 01701 Thomas Dignan, Esquire Ropes and Gray 225 Franklin Street Boston, Massachusetts 02110 Mr. N. N. St. Laurent Plant Superintendent Yankee Atomic Electric Company Star Route Rowe, Massachusetts 01367 Chairman Board of Selectmen

. Town of Rowe Rowe, Massachusetts 01367 Resident Inspector Yankee Nuclear Power Station c/o U.S. NRC Post Office Box 28 Monroe Bridge, Massachusetts 01350 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 150 Tremont Street, 7th Floor Boston, Massachusetts 02111

>3 Distribution Copies: ;ct 1313U DocketNo(s) '

NRC PDR Local PDR PAD #1 r/f PAD #1 s/f Glear E. McKenna OELD EJordan BGrimes ,

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', Enclosure 1 STAFF C0!EEliTS Of; DCRDR SUWARY REPORT Ai;D SUPPLEf EfiT

1. Qualifications and Structure of the DCRDR Team Review of the Summary Report left the NRC in doubt regarding the degree of involvement of the review team in the selection of deHgn improvements and verification that improvements would not introduce new HEDs. In the Supplement to the Summary Report, YAEC responds to this concern by indicat-ing that the review team including the human factors specialist, will remain in existence until the completion of the HED corrections. The team will regularly review the work being done with respect to the selection of design improvements, and will review both the conceptual and final HED correction to ensure that the design improvement corrects the HED without introducing new HEDs. Given this level of involvement of the review team personnel in the selection and verification of design improvements, the reviewers conclude that task assignments are adequate to satisfy the requirements of this DCRDR element.

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2. Function and Task Analysis A concern remaining from the evaluation of the Summary Report regards the comprehensiveness of the E0Ps and task analysis in covering all tasks involved in emergency operations. YAEC responds to this concern by provid-ing documentation demonstrating the comprehensiveness of E0Ps and task analysis. The Supplement to the Summary Report states that a " mini" probabilistic risk assessment (PRA) as well as a broader scope PRA were conducted in 1980 and 1981-82, respectively, to assist in evaluating man-dated design changes to the station. YAEC combined the plant-specific PRA with the procedure effort the NRC and owners' groups were working on to develop higher level procedtres for the operator to use during emergencies.

YAEC concluded that the critical function to be ensured under all conditions is Fuel Cladding Integrity (FCI). From this task analysis goal, the func-

tions for the operator to control and the function-based procedures and instruments were derived. Thus, the E0Ps used in the DCRDR were those func-tion-oriented procedures which were designed to ensure maintenance of the tasks that ensure fuel cladding integrity. From a review of this documenta-tion, the reviewers conclude that the comprehensiveness of the E0Ps and task analysis in covering all tasks involved in emergency operations is satis-fa c tory.

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In the Summary Report, YAEC indicated that the detail with which it derived needed characteristics of instruments and controls was kept to a minimum. This was not at a level acceptable to the NRC. Consequently, the

NRC requested documentation either (1) describing the performance and results of an analysis of tasks which have "I&C requirements" of a vague or general nature to provide the necessary detail, or (2) demonstrating that

! the level of analysis suggested in the NRC's example was not necessary. ,

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i In response to this concern, YAEC describes in the Supplement to the Summary Report the methodology used to develop specific information and control requirements to implement the E0Ps. This description includes four assumptions made in order to conduct the DCRDR task analysis (page 4 of Supplement 1 to the Summary Report). The reviewers find the first assumption to be satisfactory. The second assumption indicates that mechanical design characteristics (e.g., intermittent or maintained contact switches, discrete vs. continuous controls, etc.) is not a concern of human factors and, therefore, need not be specified when defining the information and control requirements. The reviewers cannot concur with this position.

Human factors is concerned with mechanical design specifications, and pre-scribing mechanical design characteristics is necessary in the task analysis.

The third assumption states that since the reviewer should be unawdre of plant-specific knowledge of the information and control channels, the control position should not be specified. Again, the reviewers find this assumption to be unacceptable. Prescribing control positions is necessary in determining control requirements in the task analysis. The fourth assumption addresses the selection of design improvements and, thus, is not relevant to the system function and task analysis.

YAEC included in the Supplement to the Summary Report four examples to illustrate the methodology (based on the above-mentioned assumptions) used to develop information and control requirements. The third example lists control requirements for the task, " initiate manual reactor scram by de-energizing control rod drives." The " detailed" requirements of the switch are as follows:

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i e It should be easily accessible.

e It should be reliable, e It should be quick acting.

e It should be easily operated.

Specific information characteristics are not provided. This lack of neces-sary specificity in defining information and control requirements is probably due to YAEC's questionable assumptions.

The assumptions YAEC presents in the Supplement to the Summary Report were not presented previously and, thus, not reviewed by the NRC. The reviewers find most of these assumptions to be inappropriate. Since the assumptions pervade the entire definition of information and control requirements and the assumptions are inappropriate, the reviewers must question the validity of the derivation of all needed characteristics of instruments and controls.

In summary, until the licensee provides documentation demonstrating that all tasks have been reanalyzed to derive the necessary detailed charac-teristics of instruments and controls, this requirement of Supplement 1 to NUREG-0737 will remain open.

3. Comparison of Display and Control Requirements With a Control Room Inventory The NRC had two concerns with the comparison of display and control requirements with a control room inventory described in the Summary Report.

Fi rs t, it appeared that the approach YAEC took to compare the requirements with the control room was not as thorough as required to meet Supplement 1 to NUREG-0737. Second, the validity of the comparison was questionable since control room inventory consisted of general rather than specific requirements. In response to these concerns with the comparison of require-ments with the control room. YAEC referred to information provided in the SFTA. As previously discussed in the Function and Task Analysis section of this report, the characteristics of instruments and controls derived in the task analysis are vague or general and not specific enough to permit a valid comparison with the existing control room. Until the licensee provides documentation describing the performance and results of a comparison of the 3

I control room with the characteristics for instruments and controls at the necessary level of detail, this requirement of Supplement I to NUREG-0737 will remain open.

4. Control Room Survey The NRC in-progress audit team's review of the survey documentation revealed numerous instances where criteria or results were ambiguous, incom-plete and inconsistent, and where sections of the checksheets were omitted.

In the Supplemeat to the Summary Report, YAEC stated that the survey team has completed all of the generic questions and two nongeneric questions.

YAEC noted that no additional findings resulted from this effort. Subse- l quently, the entire package of survey checksheets was independently audited l to verify that each question was answered. This documentation satisfies the NRC's concern regarding the completion of the survey checksheets.

Another concern remaining from the Summary Report regards a safety-

, significant human engineering discrepancy (HED) the NRC discovered during the in-progress audit but which had not been reported as an HED. In l response to this example presented in the in-progress audit report, YAEC stated that "while not adhering to the strictest human factors standard...

no operator has ever been confused by this layout and the reviewers thought it unworthy of comment." The NRC indicated that this response was not an adequate justification for omitting an HED from the assessment, resolution and implementation processes, and that YAEC should provide evidence that it l has included this HED in these processes. In the Supplement to the Summary Report, YAEC states that this discrepancy was de:mented as Finding No. 563.

No further information regarding this Findih3 vis provided. In order to close out the control room survey require 1e- M .pplement I to NUREG-0737, the licensee must provide information spec sfying tf.e assessment, disposition and implementaion schedule of Finding No. 563.

5. Assessment of HEDs The NRC has indicated that YAEC does not clearly indicate to what extent it is considering the safety significance of HEDs in its prioritiza-tion for implemening HED corrections. While the licensee has provided an explanation of how the HED categorization will impact the implementation 4

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l process, it does not address the safety significance of the HEDs. The -

licensee should indicate how YAEC intends to consider the impact of HED l safety significance on the implementation process.

6. Selection of Design Improvements The NRC has a number of concerns / questions regarding this DCRDR element which were documented in the October 10,1985 TER. The YAEC response to the NRC concerns indicates that it has not yet completed the associated work, resolved the problems, or developed the information required. Such a response is not satisfactory; therefore, this DCRDR element must remain an open item. The information requested by the NRC should be submitted for review before the NRC is able to evaluate the adequacy of this element.

7. Verification That Improvements Will Provide the Necessary Corrections l Without Introducing New HEDs The NRC previously indicated that descriptions of the methodology, guidelines, and criteria to be used for determining that a modification would correct a particular problem without introducing another HED are too vague and general to permit an evaluation of the verification process.

The YAEC response states that the DCRDR team will remain intact to determine that the proposed modifications will correct the problems without introducing other HEDs. The guidelines and criteria to be used to make such determinations will be those previously used to identify HEDs.

In addition, the licensee indicates that YAEC will perform a verifica-tion that corrective actions will resolve the HEDs and will not introduce new HEDs. However, the details of the verification process were not provided in sufficient detail. A detailed description of the verification and vali-dation process should be provided to the NRC for review.

8. Coordination of the DCRDR With Other Improvement Programs The NRC has not received sufficient details regarding YAEC's procedures or methodologies for coordinating the various improvement programs specified 5

by Supplement I to NUREG-0737 to allow them to evaluate the effectiveness of YAEC activities in meeting the requirements of this DCRDR element.

The YAEC response states that its probalistic safety studies led it to the conclusion that ensuring fuel cladding integrity was a unifying goal for dll Yankee personnel and, therefore, became the unifying goal of the five NRC requirements for' emergency response capability stipulated in Supplement I to NUREG-0737. Further, Yankee project management took responsibility for ensuring that emergency procedure improvements meshed with safety parameter displays, that procedures written to restore critical safety functions used the same critical safety function deliniation as depicted on SPDS displays, and that Yankee emergency response facilities deliniated critical safety functions in the same manner.

The response lists the " tools" for achieving this control as budgeting of programs, scheduling, allocation of manpower, technical reviews of work

products, informal meetings and discussions, and top-down direction of personnel. The response seems to indicate the belief that the use of the foregoing " tools" has resulted in control of all five requirements of Supplement I to NUREG-0737 to ensure an integral final compliance to the goal of maintaining fuel cladding integrity.

Despite the foregoing, reviewers of the supplemental response cannot see how the NRC needs can thus be satisfied.

YAEC needs to describe how, what, and when each of the improvement programs will be integrated into each of the other programs.

9. Proposed Corrective Actions Appendix B of the TER listed HEDs for which corrective actions had been proposed but were found inadequate, and the reasons therefore. The NRC concern is its inability to complete evaluation of the proposed actions until the noted inadequacies are addressed by YAEC.

YAEC's response to this NRC concern states the inadequacies noted have not yet been resolved. Until each inadequacy is addressed and resolved, this item will remain open.

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10. Justifications for HEDs left Uncorrected Those HEDs for which a justification for not taking corrective action was provided but found to be inadequate were discussed in Appendix D of the TER. The TER indicated that for each HED listed in Appendix D, YAEC should provide information which responds to the inadequacy described. The YAEC response states that the subject inadequacies have not been resolved. Until each inadequccy is addressed and resolved, this item will remain open.

11. Other The NRC feels that while the recommended actions are not intended as additional requirements, the benefits from the DCRDR would be increased if YAEC would pursue the following:

o Perform systematic and rigorous analysis of operator traffic

- patterns and workload.

e Expand the scope of the LER review to include a larger, more repre-sentative sample of documented events.

e Perform a follow-up investigation of all operator concerns identi-fied.

• Survey additional operators.

YAEC's response states that while they it agrees with the NRC recommen-dations, it does not now have the time to perform any additional work.

Its present time constraints are appreciated. If, however, the SF&TA element of the DCRDR is repeated, time should be available to conduct the above recommended activities.

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ENCLOSURE 2 DCRDR

SUMMARY

REPORT COMMENTS MEETING YANKEE 5/15/86 NAME POSITION / AFFILIATION Ji.n Clifford Project Manager / PAD #1 George Papanic YAEC Licensing Eng.

E. A. Sawyer YAEC Manager, Eng. Services A. C. Macris H. F. (A.C. Macris Proj. Consult)

R. J. Rossman YAEC Lead I&C Engr.

J. D. Candon YAEC Principal Engineer J. D. Hazeltine YAEC Project Manager

! E. M. McKenna NRC/ PAD #1 R. J. Eckenrode NRC/DPA/EICSB T. K. O'Donohue SAIC M. J. Mayer SAIC Human Factors

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o Enclosure 3 ATTACHMENT A I&C NEEDS WORKSHEET Standard Requirements for Control Needs l

Standard A l

Control Switch for Electrical Distribution System Breakers f

1. Readily accessible.

2. Open/CJused positions clearly marked (open/left and close/right).

3. Breaker indication provided (green /left and red /right indicating lights).

4. Identified by function.

5. Control switch to be Westinghouse Type W switch with heavy duty pistol grip handle, or equivalent.

6. Amber light will exist between green and red lights to indicate an automatic trip of the breaker. The switch should be three position, spring return to normal (center).

7. Control switch (spring return to normal) shall have a mechanical (red / green) target to show the last activated position of switch action taken.

O Standard B MOV Control Switch

1. Readily accessible.

2. Open/ Closed positions clearly marked (close/left and open/right).

3. Valve position indication provided (green /left and red /right indicating lights).

4. Both lights on when valve in mid-travel (valve not fully open or not fully closed).

5. Identified by function.

6. For MOV throttling service, switches shall be spring return to center from open or close position, generally. If MOV is used as a pump discharge valve, a stop pushbutton switch may be utilized to stop valve travel for system pressure surge considerations.

7. Control switch to be Westinghouse Type W with heavy duty oval handle, or Westinghouse Type OT2 with lever handle, or equivalent. In special applications, some MOV control switches may utilize removable switch handles as a method of restricting operation.

8. When positive feedback via process variable indication (flow, level, pressure, etc.) exists, it shall be identified by instrument tag number on the review form.

9. " Auto" (automatic) position, if required by system design, shall be the center switch position.

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4 Standard C Pump Controls and Indication

1. Readily accessible.

2. Start /Stop positions clearly marked (stop/left and start /right).

3. Identified by function.

4. Pump breaker position indication (green /left and red /right indicating lights).

5. Control switch to be Westinghouse Type W switch with heavy duty pistol grip handle, or equivalent.

6. Amber indicating light may exist between green and red lights to indicate automatic trip of pump breaker. If so, switch should be three position, spring return to normal (center).

8. Control switch (if spring return to center) shall have a mechanical (red / green) target to show the last activated position of switch action

- taken.

l 9. If the control switch has an automatic start position ("AUT0"), the AUTO position shall be the center position.

10. When positive feedback via process variable indication (flow, level, pressure, etc.) exists, it shall be identified by instrument tag number l on the review focm.

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a Standard D Trio Valves (SOV or Air-Operated Valves)

1. Readily accessible.

2. Open/Close positions clearly marked.

3. Identified by function.

4. Valve position indication (green /left and red /right indicating lights).

5. Switch to be Westinghouse Type OT2 control or pushbutton type, States Co.

push-pull actuated, or equivalent.

6. If the control switch has an automatic open or close position, the AUTO position shall be the center position.

7. When positive feedback via process variable indication (flow, level, pressure, etc.) exists, it shall be identified by instrument tag number on the review form.

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e Standard E Function Actuation Switches (To be used for reactor trip, turbine trip, volt meter selection, and other special functions as required.)

1. Readily accessible.

2. Identified by function.

3. Positive feedback of switch actuation shall be provided by; indicating lights, alarms, meter readings, etc.

4. Switches shall be Westinghouse Type W or OT2 pushbutton, or equivalent.

In special applications, some function actuation switches may utilize removable handles as a method of restricting operation.

5. Switches shall be located or designed to minimize inadvertent operation.

6. Switches may be maintain or momentary control action.

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Standard F Process Controllers

1. Readily accessible.

2. Auto / Manual clearly marked.

3. Identified by function.

4. Demand si5nal clearly shown.

5. Positive feedback via process variable indication (flow, level, pressure, etc.) shall be provided and identified by instrument tag number on the review form.

6. Controllers shall increase by forward, up, clockwise, or right motion, generally.

Exceptions to Standards

1. Any use of a maintained position control switch (unless identified in the

_ applicable standard) shall be fully documented on the review form for easy understanding of switch function.

2. Any deviation from the individual requirements within each standard shall be documented in detail on the review form.

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