ML20210G243
| ML20210G243 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 09/15/1986 |
| From: | Stolz J Office of Nuclear Reactor Regulation |
| To: | Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| References | |
| TAC-51126, TAC-56525, TAC-61635, NUDOCS 8609250363 | |
| Download: ML20210G243 (15) | |
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September 15, 1986 Docket No. 50-312
-Mr. John E. Ward Deputy General Manager, Nuclear Sacramento Municipal Utility District Rancho Seco Nuclear Generating Station Post Office Box 15830, Mail Stop No. 291 Sacramento, California 95852-1830
Dear Mr. Ward:
As-per telecons with Mr. R. Ashley and other members of your staff, enclosed please find our outline of a proposed audit which the NRC staff plans to conduct to evaluate your Control Room Design and Safety Parameter Display System. The proposed audit will provide input to the staff evaluation of your action plan for performance improvement. As discussed during the referenced telecons, the audit should be conducted no later than early October 1986, to preclude impact on your projected restart date. Please notify this office when you are ready for the proposed audit.
Sincerely, b
Q John F. Stolz, Director PWR Project Directorate #6 Division of PWR Licensing-B
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. Docket No. 50-312 Mr. John. Ward Sacramento M cipal Utility District Rancho Seco Nuc ar Generating Station Post Office Box 1 0, Mail Stop No. 291 Sacramento, Californ 95852-1830
Dear Mr. Ward:
As per telecons with Mr. R. A ley and other members of your staff, enclosed please find our outline of a pr osed audit which the~NRC staff plans to conduct to evaluate your Control qom Design and Safety Parameter Display System. The proposed audit will prKide input to the staff evaluation of your action plan for performance improvemert. As discussed during the referenced telecons, the audit should be conducted o later than early October 1986, to preclude impact on your projected restart ate.
Please notify this office when you are ready for the proposed audit.
Sincerely, John F. Stolz, Dire'(or c
PWR Project Directorate #6
~
Division of PWR Licensin -B
Enclosure:
As Stated cc w/ enclosure:
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See next page
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Mr. John E. Ward Rancho Seco Nuclear Generating Sacramento Municipal Utility District Station cc:
Mr. David S. Kaplan, Secretary Sacramento County and General Counsel Board of Supervisors Sacramento Municipal Utility 827 7th Street, Room 424 District Sacramento, California 95814 6201 S Street P. O. Box 15830 Ms. Helen Hubbard Sacramento, California 95813 P. O. Box 63 Sunol, California 94586 Thomas Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Mr. Ron Columbo Sacramento Municipal Utility District Rancho Seco Nuclear Generating Station 4440 Twin Cities Road Herald, California 95638-9799 Mr. Robert B. Borsum
~
Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 Resident Inspector / Rancho Seco c/o V. S. N. R. C.
14410 Twin Cities Road i
Herald, California 95638 Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Director Energy Facilities Siting Division Energy Resources Conservation &
Development Commission 1516 - 9th Street Sacramento, California 95814 Mr. Joseph 0. Ward, Chief Radiological Health Branch State Department of Health Services 714 P Street, Office Building #8 Sacramento, California 95814
AUDIT PLAN FOR THE SAFETY EVALUATION OF RANCHO SEC0'S ACTION PLAN FOR PERFORMANCE IMPROVEMENT CONTROL ROOM MODIFICATIONS OBJECTIVE The objective of the plan is to identify and document the scope, depth, and tasks for the subject audit. This audit plan will be forwarded to the licensee prior to the audit as an aid to prepare documents and schedule personnel to support the audit. This audit plan will also be forwarded to the staff's contractors as an aid to schedule personnel and prepare for the audit. The staff's goal in the audit is to collect and~ evaluate data to allow us to prepare a Safety Evaluation Report (SER) on the Action Plan, the Detailed Control Room Design Review, and the upgrade Safety Parameter Disp' lay System.
I DACKGROUND By letter dated July 3, 1986, Sacramento Municipal Utility District submitted for NRC staff review an Action Plan for Performance Improvement (Reference 1) at the Rancho Seco Nuclear Generating Station. The Action Plan was developed in response to the December 26, 1985 overcooling event at Rancho Seco. The licensee describes the Action Plan as a systematic investigation to look far beyond the specific problems associated with the incident, with the goal of
l
. identifying and implementing an array of corrective actions, which will address the root cause of past performance problems.
The licensee describes the objectives of the Action Plan as follows:
1.
Reduce reactor trips; 2.
Reduce challenges to safety systems; 3.
Assure the plant remains in the post-trip window (the allowed ranges of reactor coolant system pressures and temperatures immediately following a a
reactortrip);
4.
Assure compliance with license requirement; i
5.
Minimize the need for operator actions outside the control room; 6.
Improve the reliability and availability of the plant.
The Action Plan is structured to achieve these objectives through the implementation of a number of individual program elements. The program elements are structured to analyze and identify deficiencies in plant design, operations, operating procedures, management, etc; to evaluate and implement actions to correct these deficiencies; and to verify the actions taken.
ll.
In the staff's initial review of the Action Plan and in our discussion of the plan with the licensee's personnel (SMUD-NRC Meeting, August 14,1986),we noted that numerous modifications to the control room were identified by the licensee. Because of the functional scope of these modifications and because of the need to review current products from the Action Plan, the staff concluded a site audit would be the most effective means of performing the safety evaluation.
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AUDIT SCOPE e
Several program elements within the Action Plan have identified modifications to annunciator windows, control board labels, instrumentation and controls.
The licensee is also conducting a Detailed Control Room Design Review (DCRDR) in conformance with the Commission approved requirements presented in j
NUREG-0737, Supplement 1.
The staff's review comments on the licensee's DCRDR Summary Report are presented in Reference 2.
In terms of audit scope, the staff plans to audit the process used by the Action Plan to identify control room modifications and also to evaluate the products of the modifications for compliance to the DCRDR process and guidelines.
Furthernore, we request that the licensee respond to the staff's comments on the DC."Sh.
Specific details on these issues are identified in the enclosed Audit Agenda.
. Also during the audit, the staff will evaluate the licensee's proposed modifications in the Safety Parameter Display System (SPDS), which are to:
1.
Human factor the alphanumeric display formats; 2.
Upgrade the SPDS to' safety grade status.
The staff will utilize the guidance within Regulatory Guide 1.97,
" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess An Accident," to evaluate the upgrade of the SPDS to safety grade status. The a
staff's review will evaluate both hardware and software for the SPDS.
In the review of the software, the staff plans to utilize the guidance within Regulatory Guide 1.152, " Criteria For Programmable Digital Computer System Software In Safety-Related Systems of Nuclear Power Plants," dated November 15, 1985andinANSI/IEEE-ANS-7.4.3.2-1982(Reference 3). Specific details on these audit tasks are identified in the enclosed audit agenda.
1 AUDIT AGENDA Table I contains an agenda of activities for the audit. The agenda is subdivided into tasks for the NRC audit team and for the licensee. These tasks identify the type of documents the licensee should collect to support the audit.
j
AUDIT SCHEDULE Based on the scope of the agenda and our experience with previous DCRDR and SPDS audits, the staff estimates that the technical audit will require three days of effort. We anticipate that two days will be required to perform the Action Plan and DCRDR tasks. We plan to spend one day auditing the upgrade of the SPDS, but we anticipate this will require parallel review sessions, one for hardware and one for software.
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REFERENCES 1.
" Action Plan for Performance Improvement," Sacramento Municipal Utility District, Rancho Seco, July 1986.
2.
Letter from John F. Stolz, NRC, to J. E. Ward, Sacramento Municipal Utility District,
Subject:
Summary Report on the Detailed Control Room Design Review, dated July 17, 1986.
3.
ANSI /IEEE-ANS-7.4.3.2-1982, " Application Criteria for Programmable
~~
Digital Computer Systems in Safety Systems of Nuclear Power Generating Stations," July 6, 1982.
a 4.
Letter from G. Rivenbark, NRC, to R. J. Rodriquez, Sacramento Municipal Utility District,
Subject:
Safety Parameter Display System, dated July 27, 1984.
5.
Letter from J. F. Stolz, NRC, to R. J. Rodriquez, Sacramento Municipal Utility District,
Subject:
Safety Evaluation, Rancho Seco's Safety Parameter Display System, dated April 7, 1986.
I i
TABLE I AUDIT AGENDA I.
ACTI,0N PLAN The following tasks relate to the Action Plan, and are divided in terms of the NRC Audit Team and the Licensee.
NRC AUDIT TEAM LICENSEE
- 1. Conduct Entry Briefing
- 1. No action required.
- Identify scope of audit
- Establish daily schedule for audit.
- 2. Evaluate the process
- 2. Identify and list the functional used to identify and make steps within the Action Plan that changes to the control room.
result in a modification to the control room, then compare these steps to the process used for the i
Detailed Control-Room Design Review.
- 3. Evaluate the role of the
- 3. List all control room modifications human factors discipline in identified by the Action Plan and for the Action Plan modifications.
each modification discuss the role of the human factors discipline in the Action Plan whicn led to the modific-action.
- 4. Evaluate the method used to
- 4. Identify and discuss how the control validate the modified control room will be validated for responses room.
to emergencies and abnormal events subsequent to the design modifica-tions identified by the Action Plan.
- 5. Select and evaluate several
- 5. Conduct a walk through of how control room modifications execution of the Action Plan that originated from the identified control room Action Plan.
(e.g.,
modifications.
Provide and discuss Non-nuclear Instrument System documentation of the system studies Status Report) that identified the control room modifications.
Evaluate documentation Provide and discuss documentation on design for control room modifications, i
l.
2-6.
Evaluate licensee's 6.
Human Factors Issues:
response to human factors issues 6.1.
Address the need for better diagnostics for breaker positior.
indication, e.g.;
simplified electric schematics.
6.2.
Address the need for valve position indication for TBVs, ADVs, and AFW control valves.
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6.3.
Address the need to correct the noise problem associated with the control room's HVAC.
6.4.
Address the desirability of having separate alarms for "ICS" and " Fan Power Failure."
II. DETAILED CONTROL ROOM DESIGN REVIEW i
The following audit tasks relate to the Detailed Control Room Design Review.
In the staff's previous review of these activities, we identified several concerns related to the in-progress audit findings and summary report evaluation that should be addressed by the licensee during this audit. These concerns are:
NRC~ AUDIT TEAM STAFF'S CONCERNS
- 7. Evaluate licensee's response 7.1. The Summary Report did not indicate that E0P Cautions, Notes, and Status Tasks were analyzed follow-ing the NRC in-progress audit.
7.2. The Sumary Report did not indicate that the licensee developed a formal procedure for performing a task analysis of new operator tasks introduced into the control room by E0P revisions.
I
-J
, 7.3. The Summary Report did not include an indication that. procedure A.52
" Hydrogen Purge System Procedure,"
was task analyzed as recommended in the in-progress audit.
2 7.4. Comparison of information and control requirements identified in items 7.1 and 7.3 with control room inventory to verify control and display availability and suitability need to be completed.
7.5. Assessment of new HEOs identified during additional task analyses, i.e., E0P Cautions, Notes, and Status Tasks, need to be completed.
7.6. Given the major extent of the l
proposed control room changes, and a
the fact that some designs such as EFICs were not finalized at the time of the Summary Report, we do not have the information to judge the adequacy of the proposed c
changes.
We recommend that the licensee implement the proposed changes on the DCRDR mockup for i
evaluation by the NRC.
I 7.7. Verification that the proposed solutions resolve the HE0s/HEDs and do not introduce new HEDs
)
needs to be completed for HEOs/
HEDs identified during E0P Cautions, Notes and Status tasks.
]
III. SAFETYPARAMETERDISPLAYSYSTEM(SPDS)ANDRG1.97 The staff's safety evaluation of the licensee's SPDS is presented in j
References 4 and 5.
The safety evaluation is incomplete and the licensee's progress on the open issues that remain will be evaluated during the audit.
These issues are:
NRC AUDIT TEAM LICENSEE 8.1. Evaluate design method and 8.1. Describe the re-design of the design products for compli-alphanumeric display formats.
If ance to human factor available, provide the re-designed t
principles.
display formats for evaluation by the NRC audit team.
i
+.
I 1 8.2. Evaluate the design data for 8.2. Provide SPDS design data for the i
compliance to human factor assessment of the radioactivity pri.nciples.
control function.
8.3. Evaluate the adequacy of 8.3. As the SPDS will be upgraded to the isolation devices.
safety grade status, provide data on the isolation devices used to 1-suitably isolate the SPDS from electrical interference with equipment and sensors that are used in non-safety systems. The
[
specific data required by the staff to evaluate the isolation device
]
are identified in Reference 4.
RG 1.97 For the staff's previous evaluation of the SPDS, the display system was reviewed as a non-safety grade system. The licensee's Action Plan describes a program that will upgrade the SPDS, which will then allow'it to be used to s
comply with RG 1.97 requirements to monitor plant process variables. The staff must now re-evaluate the licensee's SPDS for compliance to RG 1.97 requirements.
1 This review effort will require data on the design of the hardware and of the l
software. The staff's review tasks and data requests from the licensee are:
NRC AUDIT TEAM LICENSEE 9.1. Evaluate schedule for 9.1. Provide a schedule for the i
restart date and completion upgrade of the SPDS to safety l
l of SPDS upgrade.
grade status.
Discuss how compli-ance with RG 1.97 requirements i
will be achieved if the completion of'the upgrade is after the plant's l
restart date.
I 1
9.2. Evaluate the boundary of the 9.2. Identify and discuss the scope of i
- upgrade, the upgrade in terms of hardware involved and interfaces with other systems, including safety and non-safety systems.
9.3. Evaluate conformance of the 9.3. Address the conformance of the software to RG 1.152.
software to Regulatory Guide 1.152, " Criteria for Programable Digital Computer Software for Safety-Related Systems of Nuclear j
Power Plants." This Regulatory Guide Endorses ANSI /IEEE-ANS-7-4.3.2-1982(Ref-erence 3). Also, provide documen-l tation, such as test reports,
. verification reports etc, that are the products of the verification and validation effort.
9.4. Select a minimum of two 9.4. Conduct a walk through of the process sensors whose hardware and the software for the signals are used by the SPDS.
selected signals.
Discuss and illustrate how the signals are processed.
Identify points in the walk through where verification and validation activities occurred.
Evaluate walk through.
9.5. Evaluate guards against 9.5. Describe the features of the design common mode failures / errors.
process and of the display system that serve as guards against common mode failures / errors.
9.6. Evaluate the maintenance and 9.6. Describe the maintenance and con-configuration control figuration control program for the a
- program, display system.
Provide the procedures that will be used to modify the software.
i 9.7. Evaluate reliability 9.7. Describe the results of a
- analysis, reliability analysis that compares the reliability of the upgraded computer based SPDS and a hypothetical implementation of the same display 1
i function using analog hardware.
9.8. Evaluate compliance of the 9.8. Provide the documents and data that systems's hardware to illustrate the upgraded SPDS complies industry and regulatory with industry and regulatory criteria and standards for criteria and standards for safety-safety related systems.
relatedsystems(ie,IEEEStd323, 1974, Standard for Qualification of Class IE Equipment for Nuclear Power Generating Stations.
IEEE Std 344-1975 Recomended Practices for Seismic Qualification of Class IE Equipment for Nuclear Power, etc per RG 1.97.
9.9. Evaluate the restart pro-9.9. Describe the steps needed to cedure and the design of restart an upgraded SPDS upon a the display system.
total loss of power to the system.
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. 9.10. Evaluate the technical 9.10. Provide and discuss the technical specification proposed for specification that is to be used the system.
for the operational system.
Discuss the scope and depth of the tests used to evaluate operability of the system. Also discuss the technical basis used to select the test period.
- 10. Exit Briefing
- Preliminary observations and results from audit.
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