ML20212R183

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Forwards Response to Issues Raised in Encl 2 of Util Re Crdr,Per NRC 861113 Request
ML20212R183
Person / Time
Site: Yankee Rowe
Issue date: 01/22/1987
From: Papanic G
YANKEE ATOMIC ELECTRIC CO.
To: Mckenna E
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
FYR-87-08, FYR-87-8, NUDOCS 8702020530
Download: ML20212R183 (5)


Text

Telephone (617) 872 8100 TWX 710 386 7619 YANKEE ATOMIC ELECTRIC COMPANY 2.c2.1

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1671 Worcester Road, Framingham, Massachusetts 01701 1

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s January 22, 1987 FYR 87-08 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Attention:

Ms. Eileen M. McKenna, Project Manager Project Directorate No. 1 Division of PWR Licensing - A

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) YAEC Letter to USNRC, dated March 28, 1984 (c) USNRC Letter to YAEC, dated June 12, 1984 (d) YAEC Letter to USNRC, dated January 1, 1985 (e) YAEC Letter to USNRC, dated August 1, 1985 (f) USNRC Letter to YAEC, dated January 13, 1986 (g) YAEC Letter to USNRC, dated March 14, 1986 (h) USNRC Letter to YAEC, dated November 13, 1986

Subject:

Control Room Design Review

Dear Ms. McKenna:

In Reference (h), you identified that Yankee would respond to the issues raised in Enclosure 2 by January 23, 1987. Attached to this letter is our response.

We trust that you will find this information satisfactory; however, should you have any questions, please contact us.

Very truly yours, YANKEE ATOMIC ELE RIC COMPANY Coorge apanic, J Senior Project Engineer Licensing GP/RR/bam Attachment

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ATTACHMENT Response to Enclosure 2 of NYR 86-258. Dated November 20, 1986 ITEM 1 This concerned the qualifications, structure, and responsibilities of the DCRDR team and was found to be acceptable and to satisfy the corresponding requirements of Supplement 1 to NUREC-0737.

ITEM 2 This item concerned the function and task analysis performed and reviewed during an in-progress audit by the NRC and a review of the " Standard Requirements for Control Needs" submitted to the NRC.

Each area of concern is addressed below.

During the meeting of May 15, 1986, the NRC stated that the control requirements were determined not to be in adequate detail. YAEC committed to develop new control requirements and to repeat the controls portion of the task analysis. The new controls requirements " Standard Requirements for Control Needs," was developed and forwarded to the NRC subsequent to the meeting.

The " controls requirements" were derived from industry conventions for controls based on Yankee Nuclear Power Station (YNPS) itself and a generic-type analysis of tasks. The controls requirements were jointly developed by the Lead Instrumentation and Control (I&C) Engineer in conjunction with the experienced plant operators.

The need for positive feedback of control actuation and in what form (e.g.,

via indication of flow, level, pressure, or temperature) has been determined by the original plant systems engineers and all subsequent systems engineers.

The controls requirements were developed for not only the second task analysis (controls only), but also as part of our human engineering guidelines specification. Some concern was expressed over the use of the word

" generally" and the use of stop pushbuttons for a Motor-Operated Valve (MOV) serving as a pump discharge valve. Again, the controls requirements were developed to be generic for use at the YNPS plant.

Numerous drawings, specifications, calculations, purchase orders, and design packages would have to be reviewed to determine if, idealistically, a particular pump, valve, or breaker control switch would need an " AUTO" position.

This type of determination can only be made during a task analysis on an operating plant.

A second controls task analysis was performed in late October 1986. The analysis was performed by an experienced senior operator / instructor, a human factors consultant, and the same I&C engineer who developed the new controls requirements.

ATTACHMENT Response to Enclosure 2 of NYR 86-258. Dated November 20. 1986 (Continued)

During the task analysis, the controls requirements were found to be inadequate in only one area, that being the specific handle shape for a given control function. The controls requirements for an Electrical Distribution System Breaker states that the " control switch to be Westinghouse Type W switch with heavy duty pistol grip handle, or equivalent." The existing handles are, in fact, a heavy duty oval ("T"-type) handle.

It was determined by the review team that the existing handles should not be changed to meet the controls requirements since this may introduce operator unfamiliarity.

The closing of electrical breakers to connect generating sources together at YNPS is done entirely manually, i.e.,

no synch-check relays exist, so that a touch (shape) familiar to the operators is extremely important.

In this case, controls requirements will be changed to match the existing equipment.

ITEM 3 This concerned the comparison of display and control requirements with the Control Room inventory. As agreed to in the meeting and discussed in Item 2 above, a second controls task analysis has been performed. Any HEDs identified will be included in the assessment, selection, verification, and correction processes of the DCRDR.

ITEM 4 This concerned the Control Room survey. The NRC concerns regarding the survey have been satisfied and YAEC has satisfactorily met the requirement of Supplement 1 of NUREG-0737.

ITEM S This concerned the assessment of HEDs for scheduling the implementation of control board changes. YAEC's approach to categorization of HEDs and its impact upon the design change implementation schedule has been found to be acceptable to the NRC.

Any new HEDs identified from the comparison of control task analysis will undergo the same assessment process as the original HEDs and, therefore, YAEC will have met the requirements of Supplement 1 of NUREG-0737.

ITEMS 6 AND 7 These items concerned the selection of design improvements and the verification that the improvements will provide the necessary corrections without introducing new HEDs.

The methodology described by YAEC for selecting and verifying design improvecents has been found to be acceptable by the NRC.

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I ITEM 8 This concerned the coordination of the DCRDR with other improvement programs. l l

ATTACHMENT Response to Enclosure 2 of NYR 86-258. Dated November 20. 1986 (Continued)

Based on a review of the means available to YAEC to coordinate improvement programs as described in the supplement to the summary report and the integration of DCRDR efforts and products with other improvement programs, the coordination efforts performed so far and those planned have been found to be acceptable to the NRC.

YAEC intends to carry out its plans for coordinating the DCRDR with training, as discussed in the meetings, and with any other areas as necessary; and it therefore will have met the requirement of Supplement 1 to NUREG-0737.

ITEN 9 This concerned the proposed corrective action to HEDs.

During the meeting held in November 1986, YAEC presented to the NRC two specification manuals, one concerning abbreviations and the second concerning design guidelines for human factors engineering.

The specifications generally follow NUREG-0700 and MIL Standard 1472B, with some exceptions dictated by plant design.

YAEC also presented "before" and "after" views of the diesel generator / safety injection panels. The "after" view is a half-scale mock-up showing the labels, mimics, relocated components, and other improvements that are planned to resolve tha HRDs, These improvements will ha implemented during the May 1987 refueling outage.

The NRC noted that YAEC's approach, using inputs from human factors consultants, engineering, and plant operators was good, and that the resulting improvements for these panels were excellent.

ITEM 10 This concerned the justification for HEDs lef t uncorrected.

As discussed in Item 9, the "after" view of the diesel generator / safety injection panels was presented to the NRC.

During this meeting, YAEC

- explained the HEDs that are to be corrected and provided justification for several HED findings that will not be corrected.

A typical HED finding was l

that a device was outside of the anthropometric limits used by the original i

DCRDR team. The team's limit guidelines were a result of the BWR owners' group and were more restrictive for controls and indication than the NUREG-0700 limits.

When NUREG-0700 limits are applied to the controls and indicators on the diesel generator / safety injection panel, the margin by which the limits are exceeded is reduced. This typically occurs if the MOV controls are part of a mimic, when the control is infrequently operated such as the safety injection actuation lockout relays, or when the indicators cannot be moved because of panel physical restraints and electrical separation considerations such as the I

diesel generator synchroscope and voltmeters. The NRC staff concurred with the reasoning for not correcting those particular HEDs.

I ATTACHMENT Response to Enclosure 2 of NYR 86-258. Dated November 20, 1986 (Continued)

CONCLUSION As presented during the November meeting with the NRC, in the Resolution Program handout, all HEDs currently identified will be corrected during the 1987 or 1988 refueling.

It is currently planned that the results of the six

. studies to be conducted will be implemented during the 1988 refueling outage.

However, the implementation of any annunciator improvements may extend beyond 1988 because of the potential scope of work.

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