ML20214L988

Evaluation of Dcrdr for Arkansas Power & Light Co Arkansas Nuclear One,Unit 2, Technical Evaluation Rept

ML20214L988
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/25/1986
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20214L289	List: ML20214L287 ML20214L988 ML20214W648 ML20215L608
References
CON-NRC-03-82-096, CON-NRC-3-82-96 SAIC-86-3067, NUDOCS 8609100491
Download: ML20214L988 (26)

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SAIC-86/3067 EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR ARKANSAS POWER AND LIGHT COMPANY'S ARKANSAS NUCLEAR ONE, UNIT 2

- TECHNICAL EVALUATION REPORT August 25, 1986 t

Prepared for:

l U.S. Nuclear Regulatory Comission Washington, D.C. 20555 i

Prepared by:

Science Applications International Corporation 1710 Goodridge Drive McLean, VA 22102 Contract NRC-03-82-096

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FOREWORD This Technical Evaluation Report (TER) documents findings from a review of Arkansas Power and Light Company's (AP&L) Detailed Control Room Design Review (DCRDR) for its Arkansas Nuclear One, Unit 2 (ANO-2). Science Appli-cations International Corporation's (SAIC) evaluation was performed in support of the NRC under Contract NRC-03-82-096, Technical Assistance in Support of Reactor Licensing Actions: Program III. SAIC previously parti-cipated in the review of AP&L's generic Program Plan for conducting a DCRDR at ANO, Units 1 and 2. Because insufficient details were provided, the NRC staff met with AP&L on May 2, 1984. A summary of this meeting, along with NRC comments, was prepared and transmitted to the licensee on June 7, 1984.

AP&L submitted the DCRDR Final Summary Report for ANO, Unit I on August 14, 1985. Based on a preliminary review of this Final Summary Report, and on the fact that both ANO Units I and 2 used the same DCRDR process, the NRC decided to conduct an on-site, pre-implementation audit of the DCRDR for ANO-1 and an in-progress audit for ANO-2 between September 16-20, 1985.

Results of the in-progress audit at ANO-2 were prepared and transmitted to the licensee. The Final Summary Report for ANO-2 was submitted to the NRC on May 5, 1986.

This report includes the SAIC evaluation of the DCRDR for AP&L's Arkansas Nuclear One, Unit 2 and is based on the information provided by the licensee

• in the Summary Report and Program Plan, and information provided during the in-progress audit, as well as additional information obtained from a ' meeting held between the NRC staff and the licensee on August 7, 1986.

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i TABLE OF CONTENTS EA21 Section

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I BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . .

3 DISCUSSION.. . . . . . . . . . . . . . . . . . . . . . . . . . . i

1. Establishment of a Qualified Multidisciplinary Review 3

e Team . . . . . . . . . . . . . . . . . . . . . . . . . 4

2. System Function and Task Analysis. . . . . . . . . . .

3. Comparison of Display and Control Requirements With a 6

Control Room Inventory . . . . . . . . . . . . . . . .

4. A Control Room Survey to Identify Deviations From 7

' Accepted Human Factors Principles. . . . . . . . . . .

5. Assessment of HEDs to Determine Which Are Significant 9

s and Should Be Corrected. . . . . . . . . . . . . . . . 10

6. Selection of Design Improvements . . . . . . . . . . .

7. Verification That Selected Improvements Will Provide the Necessary Correction and Verification That 11 Improvements Will Not Introduce New HEDs . . . . . . .

8. Coordinatiiii of Control Room Improvements With Changes From Other Programs Such as the Safety Parameter Display System, Operator Training, Reg. Guide 1.97 Instrumenta-12 tion,'and Upgraded Emergency Operating Procedures. . .

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9. Other. . . . . . . . . . . . . . . . . . . . ... . . .

13 CONCLUSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . .

16 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . .

APPENDIX A - Evaluation of HEDs Listed in Volume 2 of the ANO-2 Final Summary Report for Which Corrective 18 Actions Are Proposed or Being Evaluated . . . . .

APPENDIX B - Evaluation of HEDs Listed in Volume 2 of the ANO-2 Final Summary Report for Which No Corrective 21 Actions Are Proposed. ..............

23 APPENDIX C -

Attendance at DCRDR Meeting on August 7, 1986. . .

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, TECHNICAL EVALUATION REPORT OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR ARKANSAS POWER AND LIGHT COMPANY'S ARKANSAS NUCLEAR ONE, UNIT 2 BACKGROUND Licensees and applicants for operating licenses shall conduct a Detailed Control Room Design Review (DCRDR). The objective is to " improve

- the ability of nuclear power plant control room operators to prevent accidents or cope with accidents if they occur by improving the information ,

provided to them" (NUREG-0660, Item ID - Reference 1). The need to conduct a DCRDR was confirmed in NUREG-0737 (Reference 2) and Supplement I to NUREG-0737 (Reference 3,) . DCRDR requirements in Supplement I to NUREG-0737 require each applicant or licensee to conduct a DCRDR: on a schedule negotiated with the Nuclear Regulatory Commission (NRC).

NUREG-0700 (Reference 4) describes four phases of the DCRDR and provides applicants and licansees with guidelines for their conduct. The phases are:

1. ' Planning

2. Review

3. Assessment and implementation

4. Reporting.

The requirements of Supplement I to NUREG-0737 indicate the need to include a number of elements in the DCRDR. They are:

1. Establishment of a qualified multidisciplinary review team.

2. Function and task analyses to identify control room operator tasks and information and control requirements during emergency opera-tions.

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3. A comparison of display and control requirements with a control room inventory.

4. A control room survey to identify deviations from accepted human factors principles.

5. Assessment of human engineering discrepancies (HEDs) to determine which are significant and should be corrected.

6. Selection of design improvements.

7. Verification that selected design improvements will provide the necessary correction.

8. Verification that improvements will not introduce new HEDs.

9. Coordination of control room improvements with changes from other programs such as the safety parameter display system (SPDS),

operator training, Reg. Guide 1.97 instrumentation, and upgraded emergency operating procedures (EOPs).

Licensees are expected to complete Element 1 during the DCRDR's planning phase, Elements 2 through 4 during the DCRDR's review phase, and Elements 5 through 8 during the assessment and implementation phase.

Element 9 is expected to run concurrently through all phases.

A Summary Report is to be submitted at the end of the DCRDR. At a minimum it shall:

1. Outline p.oposed control room changes.

2. Outline proposed schedules for implementation.

3. Provide summary justification for HEDs with safety significance to be left uncorrected or partially corrected.

The NRC staff evaluates the organization, process, and results of the DCRDR. Results of the evaluation are documented in a ' Safety Evaluation Report (SER) published within two months after receipt of the Summary 2

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- Report. Guidance cor.tained in NUREG-0800, Section 18.1 (Reference 5) is provided to evaluate the acceptability of this Sumary Report.

DISCUSSION -

Arkansas Power and Light Company (AP&L) submitted to the NRC a DCRDR Program Plan for the Arkansas Nuclear One, Units 1 and 2, on November 25, 1983 (Reference 6). NRC staff coments on that Program Plan were forwarded to AP&L on February 2, 1984 (Reference 7). The NRC staff met with AP&L on May 2, 1984, to gain additional information on the ANO DCRDR process to supplement the Program Plan submittal. In addition, an in-progress audit was conducted at the ANO-2 plant site between September 16 and 20, 1985.

Results of the audit were forwarded to AP&L on February 12, 1986 (Reference 8).

AP&L submitted a Summary Report for ANO-2 on May 5, 1986 (Reference 9).

In response to additional questions that the NRC staff had, AP&L presented informaticn at a meeting in Bethesda, Maryland, on August 7, 1986. The objective of the meeting was to resolve as many open items as possible for the DCRDR program. Also, any items which could not be resolved at the meeting were to be identified. Furthermore, a decision was reached at the meeting that the NRC staff would issue an SER on the DCRDR program following receipt of the TER from SAIC. Any open items identified in the TER will be treated as separate action items.

This TER is based on all information transmitted to the NRC to date.

The comments which follow contain specific review results which address the nine DCRDR elements identified in Supplement I to NUREG-0737.

1. Establishment of a Oualified Multidisciolinary Review Team The NRC team concluded from the in-progress audit that the organiza-tion, structure, and management of the DCRDR team appeared to be flexible enough to permit a multidisciplinary effort. Specifically, the reviewers found that the team had the proper mix of disciplines and the necessary freedom of operation and access to facilities recommended in NUREG-0800 to accomplish the DCRDR. Team members were familiarized with the general design and operation of the plant, relevant NRC documentation, and general 3

human factors engineering principles and methodology prior to beginning the review. During the course of the review, input and support from specific AP&L support organizations were solicited as appropriate.

A concern remaining from the in-progress audit regarded greater involvement of the training department in the DCRDR process because of the potential impact control roem changes would have on operations. As described on page 3-5 of the Summary Report, input was solicited from the training department during the assessment process. In addition, the training department will be involved in the corrective action process to ensure coordination of design changes. One of the methods suggested by AP&L for involving its training department in the DCRDR process was to use the, simulator to help evaluate corrective actions, "as appropriate."

Based on all information provided, it is the judgment of the reviewers that the licensee meets this Supplement I to NUREG-0737 requirement.

2. System Function and Task Analysis The purpose of the system function and task analysis is to identify control room operator tasks during emergency operations and to determine the information and control capabilities the operators need in the control room to perform these tasks. To accomplish this, AP&L conducted a system function review which consisted of analyzing and documenting the functions associated with the systems and subsystems exercised for each emergency operating event. Subsequently, an operator task identification analysis was conducted which entailed the identification and documentation of operator functions and tasks for emergency events. Information and control requirements necessary for task performance also were identified. Both the system function and task analysis review processes were examined at the in-progress audit. These are also described in detail in the audit report and the DCRDR Summary Report, and are summarized below.

The system function review conducted at ANO-2 was performed in conjunction with the AP&L emergency operating procedures,(EOPs) development program. The basis for both was generic information developed for the Combustion Engineering (CE) Owners' Group. Information developed for the Owners' Group was- based on Sequence of Event Analysis which provided a 4

systematic examination of each of the safety functions which may be affected by initiating events. These events represented the major event categories or event types analyzed in Safety Analysis Reports, and included the effects of multiple equipment failures and failures of the operator to respond.

Results of analysis included:

o Safety function elements which identified major plant operating systems and subsystems to the level of major components.

o Event trees which identified appropriate event sequences for analysis with emphasis on abnormal and emergency conditions.

o Sequence of event diagrams (SEDs) which identified and documented, on functional block diagrams, the functions associated with the systems and subsystems involved in each selected event; and which provided codes indicating allocation of functions to man or machine.

As the CE Owners' Group information was generic in nature, each SED then was reviewed to determine its applicability to ANO-2. Where design differences affected the event diagram, the diagram was marked in a manner to conform to the current ANO-2 design. Once plant-specific, the informa-tion yielded by the event trees and SEDs provided the necessary input for the review of system functions and permitted plant-specific E0Ps to be developed.

Subsequently, these E0Ps were used as a starting point to identify tasks to be conducted by operators during emergency situations. For each section of an E0P, a task description form was completed which identified operator functions to be accomplished and operatcr tasks associated with ,

operator functions. For each task, a task analysis data collection form was completed in an iterative fashion by a human factors specialist (HFS) work-ing with an ANO-2 subject matter expert (SME). Display information and con-trol requirements for performing the task were identified. Examples of I information collected to describe control requirements for operator tasks included position of control (off/on, etc.); mode (continuous / discrete);

functional requirement (pull-to-lock, etc.); control status lights; flag requirements; legend indicator tile; and feedback requirement. Examples of 5

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. display information requirements which were collected for operator tasks included level (state, value, trend); status light; units of measure required; range; divisions required; precision; etc. This information was entered into a data base.

Finally, nine events were walked through in a control room validation exercise. As described in the Summary Report, this exercise was conducted to determine whether th,e functions allocated to the control room operating crew could be accomplished effectively within both the structure of the established emergency procedures and the design of the control room as it now exists. During the walk-throughs, which were arranged, supervised, and videotaped by an HFS with the assistance of the DCRDR SME, operators were

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instructed to call out relevant actions, directions of mcvement, and the displays and indicators used, as well as their responses. Where the HFS observed instances in which equipment availability, suitability, or location could be enhanced, or in which operator uncertainty existed due to proce-dural ambiguity, HEDs were written to improve operator actions and to provide for corrective actions when operator deviations were safety-signifi-cant. Although it is unclear whether the nine events walked through included all emergency operating procedures, the licensee implemented a validation approach consistent.with the guidelines of NUREG-0700. Events chosen were consistent with those suggested in NUREG-0700 and exercised all control room workstations.

It is the judgment of the reviewers that the ANO-2 system function and task analysis was conducted in a comprehensive and systematic fashion and meets the requirement of Supplement I to NUREG-0737.

l Comoarison of Disolav and Control Recuirements With a Control Room 3.

' Inventory Existing control room display and control requirements were compiled in a comprehensive inventory. All displays, controls, controllers, annuncia-tors, and other equipment with which the operators interact were included in this inventory. To compile the inventory, a current set of as-built draw-ings was marked up to reflect the present configuration of the ANO-2 control room. Panel by panel, existing instruments were assigned a coded sequence number, inventoried, and checked off on the as-built drawing. Each piece of 6

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equipment on the control boards and its characteristics were identified by the same codes that had been used to characterize the information and con-trol requirements identified in the task analysis. The inventory data then was stored in the computerized data base.

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The comparison of the display and control requirements identified during the task analysis with the control room inventory was not reviewed during the in-progress audit, and it was suggested that the licensee document this process in the Summary Report. As described in the AP&L submittal, the ANO-2 DCRDR team verified the information and control requirements established during the task analysis with existing control room

. display and controls compiled in the inventory. Verification first deter-mined whether appropriate equipment was available in the control room to perform each functional task required by emergency operations. Then, for equipment that was identified as available, it was determined whether the characteristics of each piece of equipment made it suitable for the task.

Equipment that was ' confirmed to be unavailable or unsuitable was documented as an HED.

In the judgment of the reviewers, AP&L provided a detailed description of a well-planned and executed control room inventory for ANO-2. The documentation process, utilizing the data base management system, permitted an effective comparison of control and display requirements to be made. The ANO-2 inventory and comparison analysis meet the requirement of Supplement I to NUREG-0737.

4. A Control Room Survey to Identify Deviations From Acceoted Human Factors Princioles A comparison of instrument and control features in the ANO-2 control room with AP&L's human factors guidelines was conducted. These guidelines were derived from those given in Section 6 of NUREG-0700 and closely followed them in format and content, with some modification. The survey effort covered the nine content areas suggested in NUREG-0700 (e.g., work-space, panel design, annunciator warning system, etc.). ,Environmental con-ditions, including sound, lighting, and the HVAC system, also were surveyed.

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The licensee's survey effort was reviewed in detail during the in-progress audit. At that time, tne team indicated that the survey effort was fairly complete and thorough. However, as documented in the audit report, the following issues had to be addressed before the effort would meet the requirement of Supplement I to NUREG-0737.

First, the NRC team did not agree with the licensee's use of six guidelines which had been modified from those in NUREG-0700, and indicated that the control room should be rechecked for these six items and responses provided. Second, it was suggested that all sections of the checklist, including color-coding conventions, be reviewed for completeness. Third,

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although a survey of a utility's remote shutdown capability is not required by Supplement I to NUREG-0737, the NRC staff strongly recommended that ANO-2's remote shutdown capability be evaluated as part of the DCRDR survey activities, particularly in light of problems which had surfaced during the audit of the ANO-1 remote shutdown capability (Reference 10).

Although a review of information provided in the . licensee's Summary Report did not indicate whether AP&L had accepted the six NUREG-0700 guide-lines which previously had been modified and found unacceptable by the NRC staff, a telephone conference held between the NRC staff and AP&L DCRDR team members on July 1, 1986, indicated that AP&L did, in fact, agree to use the NUREG-0700 guidance for checklist items 6.1.2.3.b, 6.1.2.3.d(2),

6.1.2.3.f(2), 6.3.2.1.c, 6.5.1.6.c(2), 6.6.5.1.g, and 6.9.2.2.e. However, the licensee has not provided any documentation to indicate whether all sections of the survey, including color-coding, have been rechecked for completeness, or whether the control room was resurveyed using the six guidelines referred to above. It is our understanding, based on the tele-phone conference, that these items have also been done by AP&L.

In summary, the ANO-2 control room survey was conducted in what appears to be a fairly comprehensive and thorough manner. The methodology and objectives of the effort were essentially in accordance with the guidance provided in NUREG-0700. In conclusion, the survey effort is found complete in terms of meeting the intent of the requirement of NURIG-0737, Supplement 1.

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5. Assessment of HEDs to Determine Which Are Sianificant and Should Be Corrected ,

The DCRDR assessment team (composed of the DCRDR team and supplemented by personnel who provided expertise in specialties such as computers and training) reviewed and assessed each HED based on its impact on plant safety, personnel safety, and plant operability.

Each team member was provided with a book containing all of the  !

identified HEDs. Each team member was also provided an evaluation sheet for each HED. The evaluation sheets were designed to measure the impact of the  !

HED on physical performance, sensory / perceptual performance, cognitive performance, task variables, operating crew error, and plant safety.

Foll'owing the review of the six factors, the assessment team member assigned each HED to one of three significance categories: high, medium, I and low. The evaluation sheets also provided for assessment of the possible cumulative impact of Category 3 (low significance) HEDs to ensure that the interactive or cumulative effects were considered. The results of each team member's HED assessments were combined into one volume, a copy of which was then provided to the individual team members.

A series of assessment team meetings followed which resulted in team consensus regarding the category rating of each HED. As consensus was reached, the category was recorded for each numbered HED and a list maintained. The assessment effort produced a listing of 616 categorized HEDs and four nonrated HEDs.

The NRC staff reviewed all of the HEDs submitted by ANO-2 in its Summary Report, Volume 2. The purpose of this review was to validate the licensee's assessment process as well as to evaluate the appropriateness of the design solution and implementation schedule. In spite of the fact that the staff judged a small number of HEDs to be incorrectly categorized, the staff concludes that the HED assessment process as used by AP&L is satisfac- ,

tory and meets the requirements of Supplement I to NUREG-0737. The few problems uncovered during this review are discussed in App'endix A.

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. 6. Selection of Desian Imorovements i

During the in-progress audit conducted at ANO-2, the audit team was given an informal explanation of the procedure used in the selection of design improvements to resolve HEDs. The NRC staff was also able to review the AP&L Design Change Procedure (DCP, Procedure No. 202). This review revealed that there was no formal incorporation of human- factors considerations in the DCP. AP&L provided verbal assurance that more than a checklist was used in the evaluation of HED solutions and that there was detailed involvement of the DCRDR team members in the selection of design improvements. The methodology, which was not described in Procedure No.

202, was requested to be fully documented in the ANO Unit 2 Summary Report.

A single-page form identified as " Detailed Human Factors Review Checklist" has been included as Appendix D to the Summary Report. This form is merely a checklist of the nine survey sections of Chapter 6 of NUREG-0700. There was no written discussion of the process for selection of design improve-ments. However, at the meeting held on August 7, 1986, the utility presented additional documentation regarding the use of this checklist for design selection and verification purposes.

Despite the lack of formal documentation that AP&L has, in fact, a procedure to involve the DCRDR team members in the selection of design improvements, the staff concludes, based on verbal explanations given during the audit, and the August 7 meeting, that the human factors specialists did participate in the process.

The NRC staff has several concerns with regard to AP&L's use of color in the resolution of HEDs. Many of these same concerns were documented more fully in the TER for ANO-1. However, because all the surface enhancements for ANO-2 have not been finalized, there would appear to be ample opportunity for AP&L to reexamine this more carefully. Below are some of the major concerns.

At the meeting on August 7, 1986, AP&L stated that they intended to use the same color matrix for ANO-1. The NRC reviewers found the color-coding scheme, as shown on the ANO-1 matrix, could have been acceptable but for an inconsistency on integral switch plates (pumps). In all cases but this one, the color red indicates equipment activity and black indicates equipment 10 i

inactivity. Here the meaning of the colors red and black are exactly opposite. This concern was rectified before applying the scheme in ANO-2.

Additionally, the staff has concerns about: (1) the number of colors used in the control room; (2) the contrast between colors; and (3) the overuse of colors on any single panel such as may be the case for Unit 1 Engineered Safety Features Panel. In order to avoid potential color prob-lems, SAIC encourages AP&L to seek guidance from NUREG-0700 as well as experience with Unit 1.

As described above, there are four major problems associated with

_ AP&L's use of colors to solve various HEDs. These concerns are: (1) too many colors (19 instead of the recommended maximum of 11); (2) colors not easily distinguishable; (3) rainbow effect on the ESFP; and (4) an incon-sistent color matrix for integral switch plates. SAIC's position is that the issue of color coding is complex and the possibility of operator error is significant should the utility implement their plans, to correct HEDs using their current color coding solutions. In principle, SAIC is in agree-ment that all these concerns need further inspection by the NRC staff.

The NRC staff should review the proposed use of color to resolve HEDs in the Unit 2 control room. A method for executing this review would be to request that the NRC resident inspector fpilow up on this concern. Such a possibili'ty would be similar to that agreed to for Unit 1.

The 'NRC staff finds that AP&L has a selection process which, if followed, should fulfill this requirement of Supplement I to NUREG-0737.

However, this is an open item until the utility submits to the NRC the resolutions developed for their annunciator upgrade and surface enhancement programs.

7. Verification That Selected Desian Imorovements Will Provide the Necessary Imorovements and Verification That Imorovements Will Not Introduce New HEDs This element of the DCRDR was discussed at some length with the utility during the audit. The NRC staff requested that AP&L describe the process in writing or include 'a copy of the procedure to assure the staff that a formal

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procedure for verification of effectiveness of corrective actions is in place and is used by AP&L. . The AP&L " Procedure No. 202," which was reviewed by the NRC staff audit team, was not satisfactory because it did not refer-ence any human factors participation or reference any actual AP&L DCRDR team participation in the process. It is, in fact, not a procedure for design verification of HED solutions, per se. Rather, it is an engineering design process procedure.

A review of this particular step of AP&L's Unit 2 (Reference 9), as well as of Unit 1 (Reference 11), reveals that this process is still loosely defined by AP&L. Although loosely defined in the Summary Report, the verification process as used by AP&L was presented at the meeting of August ,

7, 1986. The utility brought documentation and examples of the verification procedure. The NRC staff concurred that the verification process will satisfy the requirement of 1 to NUREG-0737.

8. Coordination of Control Room Imorovements With Chances From Other Proarams Such as the Safety Parameter Disolav System. Doerator Trainina. Rea. Guide 1.97 Instrumentation and Uoaraded Emeraency Ooeratina Procedures The Summary Report states that AP&L has a coordinated program for the implementation of NUREG-0737, Supplement 1 initiatives which is intended to optimize the interface between the various initiatives. During the audit, the audit team was formally briefed on the coordination program. In addi-tion, the relationships between the various initiatives (i.e., DCRDR, SPDS, Reg. Guide 1.97, symptom-oriented E0Ps, operator training) and the dates for completion of the various program milestones are shown on Figure 5-1 in the Summary Report.

Based on information provided at the audit and in the Summary Report, the reviewers conclude that this DCRDR element is being satisfactorily performed and meets the requirements of Supplement I to NUREG-0737.

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_ . . - - . . - - - , , . _ _ _ - _ _ . _ 7,,_ . . -. , - , . - . , ,

9. Other Proposed Schedules for Implementing Corrective Actions The NRC staff position regarding implementation schedules for HED resolutions is that all corrections should be completed within two refueling outages following submission of the Summary Report. AP&L's Summary Report indicates that all but four of the Category 1 HEDs will be corrected within the next two refueling outages.

Additionally, there are numerous Category 2 and 3 HEDs for which specific resolutions and implementation schedules have not been provided.

Even though AP&L and the NRC staff agreed at the audit that the utility did not have to provide an implementation schedule or solutions for these HEDs, AP&L is encouraged to resolve them.

Survey of the Remote Shutdown Panel During the audit, the NRC staff recommended that a human engineering evaluation of the remote shutdown capability be included within the scope of AP&L's DCRDR. The Summary Report for Unit 2 provides no documentation that indicates that AP&L has acted on this recommendation. The staff maintains that this evaluation is important to the overall success of the DCRDR.

CONCLUSIONS Arkansas Power and Light Company's Summary Report for the DCRDR conducted at Arkansas Nuclear One, Unit 2 demonstrates a strong commitment toward meeting most of the requirements of NUREG-0737, Supplement 1. The submitted documentation and audit findings indicate that most requirements have been met. However, additional information concerning HED solutions is required from the licensee to provide assurances that all requirements as stated in NUREG-0737, Supplement I are satisfied.

The following is a summary of the technical evaluation of Arkansas Power and Light Company's ANO-2 Summary Report and DCRDR.

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l. The ANO-2 DCRDR team meets the requirements of a qualified multi-disciplinary review team.

2. The system function and task analysis meets the requirement of Supplement I to NUREG-0737.

3. The inventory, as well as the comparison of requirements established in the task analysis, meets the requirement of Supplement I to NUREG-0737.

4. Based on a review of the documentation, as well as on a telephone conference, it was determined that the control room survey meets the intent of Supplement I to NUREG-0737.

5. The HED assessment process is consistent with the requirements outlined in Supplement I to NUREG-0737.

6. The process for selection of design improvements meets the Supplement I to NUREG-0737 requirements; however, not all HEDs have solutions. In order to meet the DCRDR requirements for this item, AP&L needs to formally submit the solutions and implementation schedules for all Category I HEDs. (This includes all annunciator upgrade and surface enhancement program HEDs.)

7. The' verification process that control room improvements correct HEDs and do not introduce additional HEDs in the control room was not adequately formalized in docketed submittals. However, additional information presented at the August 7, 1986 meet'ing resolved this issue. SAIC concludes that the AP&L process does meet the requiremer:ts of Supplement I to NUREG-0737.

8. The coordination of control room improvements with changes from other programs satisfies the requirement of NUREG-0737, Supplement 1.

9. The Summary Report does not outline proposed schedules for implementa-tion of all corrective actions as required by Supplement I to NUREG-0737. The utility is encouraged to finalize solutions for all HED categories and to implement those solutions within two refueling outages. -

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Appendices A and B present SAIC evaluations of all the HEDs listed in Volume 2 of the ANO-2 Final Summary Report. In general, SAIC concludes that the assessment process was acceptable, based on the facts that only eight Category 3 HEDs were judged by SAIC to require AP&L to consider upgrading to Category 2. With regard to the justification for "no-action," SAIC concurred with the AP&L assessment in all but 12 cases. However, there were many HEDs for which resolutions were not finalized or for which no evaluation could be made by SAIC due to inadequate documentation.

In compliance with the objective of the August 7, 1986 meeting, SAIC

- has identified the items which were not resolved at that meeting. In order to satisfactorily complete all requirements to Supplement I to NUREG-0737, AP&L needs to submit docketed solutiens and implementation schedules to all Category I HEDs (see Appendix A-2.1 and A-2.2). Implicit in this requirement is the need for the NRC staff to review AP&L's use of color for HED solutions. SAIC does not concur with all of ANO-l's HED solutions using color.

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REFERENCES

1. NUREG-0660, Vol.1, "NRC Action Plan Developed as a Result of the TMI-2 Accident," U.S. Nuclear Regulatory Commission, May 1980; Revision 1, August 1980.

2. NUREG-0737, " Requirements for Emergency Response Capability, "U.S.

Nuclear Regulatory Commission, Washington, D.C., November 1980.

3. Supplement I to NUREG-0737, " Requirements for Emergency Response Capa-bility" (Generic Letter No. 82-33), U.S. Nuclear Regulatory Commission, December 1982.

4. NUREG-0700, " Guidelines for Control Room Design Reviews," U.S. Nuclear Regulatory Commission, September 1981.

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5. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 18.1, September 1984.

6. Arkansas Power and Light Company, Arkansas Nuclear One, Units 1 and 2, Control Room Design Review Program Plan, dated November 25, 1983.

7. "NRC Response to Arkansas Nuclear One Program Plan Submittal," U.S.

Nuclear Regulatory Commission, Washington, D.C., February 2,1984.

8. "In-Progress Audit Report of the Detailed Control Room Design Review for Arkansas Nuclear One, Unit 2," U.S. Nuclear Regulatory Commission, Washington, D.C., February 12, 1986.

9. Arkansas Power & Light Company, /,rkansas Nuclear One, Unit 2, " Control Room Design Review Final Summary Report," Volumes 1 & 2, May 5,1986.

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10. Audit Report of the Detailed Control Design Review for Nuclear One, Unit 1, U.S. Nuclear Regulatory Commission, November 7, 1985.

I 11. Arkansas Power and Light Company, Arkansas Nuclear One, Unit 1,

" Response to CRDR Audit Findings," April 29, 1986.

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- 12. Arkansas Power and Light Company, Arkansas Nuclear One, Unit 1, "CRDR Corrective Action Supplemental Information," October 18, 1985.

13. Arkansas Power and Light Company, Arkansas Nuclear One, Units 1 and 2, "NUREG-0737 Supplement 1 Update," October 30, 1985.

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APPENDIX A EVALUATION OF HEDS LISTED IN VOLUME 2 0F THE ANO-2 FINAL SUMARY REPORT FOR WHICHCORRECTIVEACTIONSAREPROPOSEDORBEINGEVAL0ATED A-1. HEDs for which proposed corrective actions and implementation dates are satisfactory.

All the solutions for Category 1, 2, and 3 HEDs that have already been corrected have been found to be satisfactory. All solutions of the HEDs currently being corrected have been found to be satisfactory. The solutions

. for the nine HEDs scheduled for correction by refueling outage 2R5 (the current outage) have been judged satisfactory. The solutions for all but one HED scheduled for implementation by 2R6 have been judged satisfactory.

The one exception is noted in Section A-2.1 of this appendix.

A-2. HEDs for which the proposed corrective actions and/or implementation dates are not satisfactory A-2.1 Insufficient __information_was provided by AP&L for the following HED.

We have indicated the reason for not being able to evaluate these HED. Until sufficient information is available for the NRC staff review, this HED is still an open item.

The list of components involved with HED 403 was not provided.

Absence of that information and the lack of description of any definitive corrective action rendered this HED impossible to evaluate regarding categorization or resolution.

A-2.2 Unsatisfactory implementation schedule Ntaeteen HEDs, including four Category I and four Category 2 HEDs, are to be corrected by the annunciator upgrade program. This program was originally undertaken by AP&L in 1982, but the implementation was subsequently postponed until after the results from the DCRDR were complete. Implementation of HED corrections resulting from this program is not scheduled to start until the 2R7 refueling outage and 18

. is not scheduled for completion until prior to startup after refuel-ing outage 2R9, approximately six years in the future. At the time ,

this evaluation was written, ANO-2 was in 2R5. Other than HED cate-gorization, no information is provided to indicate when HED correc-tions will be implemented. Below are HEDs and their respective  ;

assessment categories associated with the annunciator upgrade pro- l gram. The implementation schedule should be negotiated with'the NRC ei staff with the goal being to achieve full resolution by the end of 2R7. -l J

Cateaory 1 Cateaory 2 Cateaory 3 56 57 85 121 60 59 106 122 107 61 112 123 111 114 118 124 120 355 356 The resolutions for a large group of Category 2 HEDs are currently under evaluation; however, no corrective actions or implementation schedules have been proposed. Even though AP&L and the NRC staff agreed at the audit that the utility did not have to provide an implementation schedule or solutions for Category 2 or 3 HEDs, AP&L is encouraged to resolve the following HEDs in a timely fashion.

Cateaory 2 i

11 32 81 384 540 12 33 82 406 574 22 34 83 451 609 25 41 129 480 611 26 48 376 512 614 The SAIC reviewers determined that eight Category 3 HEDs for which resolutions are under evaluation are of sufficient importance to be upgraded to Category 2. They are HEDs 62, 108, 109 and 134; 432, 443, 447 and 528. The latter four resulted from task analysis for E0Ps. .

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, Below is a listing of Category 3 HEDs which have been scheduled for various corrective actions but with no indication when such actions will be implemented.

Cateaory 3 016 241 126 247 178 248 239 264 I

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. APPENDIX B ,

1 EVALUATION OF CATEGORY 3 HEDS LISTED IN VOLUME 2 0F THE ANO-2 FINAL

SUMMARY

REPORT FOR WHICH NO CORRECTIVE ACTIONS ARE PROPOSED B-1 HEDs for which inadequate justification is given for "no action."

Task analysis, based on Emergency Operating Procedures, defines required instrument / display characteristics, e.g., range, accuracy, units, etc. The justification for "no action" for HEDs 438, 441, 444, 454, and 524 simply disputes the defined requirements. Close examination of these HEDs reveals that there is a mismatch between E0P requirements and the capability

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of the existing instrumentation in the control room. These should be resolved.

HEDs 221, 163, 166, and 201 dealt with various control room color schemes; when taken together, their justifications for "no action" are anibiguous and do not constitute adequate justification for taking no action regarding the overall control room color scheme standardization.

The following HED gives an example of inadequate justification for the "no-action" disposition.

HED 259 - Category 3 "The refresh rate is too low, generating a chronic and visually disturbing flicker with certain displays." (SPDS)

Resoonse:

"The flicker is not disturbing to the plant operators since the displays are used for trend information, etc. and do not involve significant time " studying" or reading the displays. This flicker is due to SPDS hardware limitations that cannot be addressed without replacing the hardware. Therefore, due to the adequacy of the exist-ing system and the lack of justification for an extensive change, no further action is plannei to address this HED."

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, Flicker has been established as a fatiguing factor even though the exposed personnel are not particularly conscious of its presence.

Therefore, until definite evidence can be provided to demonstrate that in I the ANO-2 control room flicker is not, in fact, a disturbing factor, a "no action" disposition cannot be accepted. .

Similar to the example given above, SAIC judged HED numbers 71 and 72 to be inadequately justified for "no action."

B-2 The HEDs listed below were too vague regarding HED description and/or response for an evaluation to be made concerning the discrepancies or the justifications for the proposed "no action" dispositions.

132 226 232 281 463 498 159 228 235 282 465 500 211 230 246 283 474 600 221 231 265 462 492 608 0

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• APPENDIX C ATTENDANCE AT DCRDR MEETING ON AUGUST 7, 1986 UAmg Oraanization Joe Moyer SAIC John Stokley SAIC Charles Morris PWR-B Guy S. Vissing PWR-B .

Dan Williams AP&L Dale E. James AP&L

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Garry G.. Young Young Engr. Serv./AP&L J. Calvo (Jose) NRC L. Beltracchi (Leo) NRC Jack Ramsay NRC Robert Lee NRC e

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