ML20214S874
| ML20214S874 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/21/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20214S864 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 TAC-64721, NUDOCS 8706100021 | |
| Download: ML20214S874 (15) | |
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SUPPLEMENTAL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATI RELATING TO DETAILED CONTROL ROOM DESIGN REVIEW NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION
Nebraska Public Power District (NPPD) submitted a Detailed Control Room Design Review (DCROR) Program Plan for Cooper Nuclear Pcwer Plant on March 1, 1984. The NRC staff coments on that Program Plan were forwarded to NPPD on June 4, 1984. An in-progress audit report was forwarded to NPPD on March 20, 1985.
NPPD submitted a DCRDR Sumary Report (SR) for Cooper on February 4, 1985. Staff review of that report identified a rumber of concerns.
Those concerns were discussed in the staff's September 5, 1985 Safety EvaluationReport(SER). That SER also requested submittal of additional information describing how staff concerns were to be resolved. NPPD responded to the staff's recuest in a February 27, 1986 Supplement I to the DCRDP SR. Based on a review of that supplement, the NRC staff planned a preimplementation audit of the Cooper DCRDR. The j audit was conducted from May 13-16, 19P6.
Most of the staff's concerns were resolved by the preimplementation !
i audit. Remaining concerns were identified in a November 4,1986 Supplement I to the SER. NPPD responded to those remaining concerns in a February ?,1987 Supplement 2 to the DCRDR SP. That supplement indicated that NPPD had completed activities related to some of those concerns. Per comitment, NPPD provided schedules for activities to address the other concerns. NPPD also comitted to report results of ;
those activities in a third supplement to the DCRDR SR. That supplement is scheduled for submittal 60 days af ter the 1988 refueling outage. All 0706100021 070602 PDR ADOCK 0D000298 -
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Cooper DCRDR activities, except final verification of control room improvements implemented during the 1989 refueling outage, should be complete by that time.
2.0 EVALUATION A synopsis of the staff's current position on the Cooper DCRDR is provided below. The position is based on all information available to date and is arranged in order of the DCRDR elements identified in Supplement I to NUREG-0737.
2.1 Establishment of a Qualified Multidisciplinary Review Team The staff's November 4,1986 Supplement 1 to the SER noted that the previous review found the multidisciplinary review team to be acceptable, and that subsequent modification strengthened capabilities in the areas nf human factors engineering and instrument and control engineering. The staff further noted that participation of the modified team through the remainder of the DCRDR would lead to full satisfaction of the element. NPPD responded in its February 2,1987 Supplement 2 to the DCRDR SR by stating that the same personnel structure had been maintained.
This element continues to be satisfied. It should be fully satisfied by participation of the modified team through the remainder of the DCRDR. NPPD should assure that human factors specialists are actively involved in the ongoing DCRDR.
2.2 Function and Task Analyses to Identify Control Room Operator Tasks and Information and Control Requirements During Emergency Operations The staff's November 4, 1986 Supplement 1 to the SER indicated that NPPD's process for conducting the function and task analyses was acceptable. However, the scope of the analyses was not adequate.
I' NPPD comitted to expand that scope in the February 27, 1986 Supplement 2 to the DCRDR SR. Staff review of that supplement and of information provided during the May 13-16, 1986 preimple-mentation audit indicated that the proposed expansion would be acceptable. However, results of the expanded function and task analyses were not available for review during the preimple-mentation audit.
A second concern with the function and task anlayses was that NPPD's documentation was difficult to audit. The staff did not require improved documentation but concurred with its contractor's conclusion that such improvement would enhance the usability of information from the function and task anlayses.
NPPD's February 2, 1987 Supplement 2 to the SR responded to staff concern about the scope of the function and task analyses by indicating that analysis of "...other procedures referenced in the Emergency Operating Procedures..." was currently being performed.
Completion was expected by June 1987. In addition, NPPD comitted to complete function and task analyses of alternate shutdown panel procedures by September 1987 and of station blackout procedures within 60 days of the approval of such procedures. NPPD also comitted to provide final results of the expanded function and task analysis in Supplement 3 to the DCRDR SR.
i Appendix H to NPPD's February ?, 1987 Supplement 2 to the SR responded to concerns about function and task analyses documentation. That document indicated that improved forms had been adopted as a means to improve access to information from the function and task analyses. ,
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This element should be satisfied upon completion of the expanded function and task analyses.
2.3 Comparison of Display and Control Requirements with a Control Room Inventory The staff's November 4,1986 Supplement I to the SER indicated that NPPD's method for comparison of display and control requirements with a control room inventory was producing acceptable results.
However, NPPD's commitment to expand the function and task analyses (see 2.2 above) was expected to result in the need to compare t additional display and control requirements with the control room inventory.
In its February 2,1987 Supplement 2 to the SR, NPPD committed to l compare display and control requirements identified by expansion of the function and task analyses with the control room inventory.
NPPD further conmitted to provide the results of this comparison in Supplement 3 to the DCRDR SR. l This element should be satisfied upon comparison of display and control requirements, identified by the expanded function and task analyses with the control roem irwentory. The carparison should determine availability and human factors suitability of displays and controls. Required displays and controls which are unavailable or unsuitable sbeuld be documented as Human Engineering Discrepancies (HEDs) and included in the assessment, selection of design improvements, and verification elements of the DCRDR described in 2.5, 2.6, and 2.7 below.
2.4 A Control. Room Survey to Identify Deviations from Accepted Human Factors Principles The staff's November 4, 1986 Supplement 1 to the SER indicated that, with two exceptions, the Cooper control room survey was complete. Those exceptions were survey of operator communi-cations in Self Contained Breathing Apparatus (SCBA) and respirators and survey of the Plant Management Information System / Safety Parameter Display System (PMIS/SPDS).
NPPD's February 2, 1987 Supplement 2 to the SR indicated that the survey of operator communication in SCBA and respirators was complete. An HED noting "... difficulty in voice communication among operators wearing protective gear..." was documented.
NPPD's February 2, 1987 Supplement 2 to the SR also indicated completion of an SPDS survey. That survey included review of the consistency of the SPDS displays with Cooper standards, control board information, and the E0Ps. Inconsistencies identified by the SPDS survey were recorded as HEDs. NRC staff review of those HEDs indicates that the SPDS survey was acceptable. Survey of PMIS displays has been delayed pending addition of new software and displays related to class "A" dose assessment. NPPD committed to report results of the PMIS survey in Supplement 3 to the DCRDR SR.
This element should be satisfied when the survey of PMIS displays is completed. HEDs identified as a result of that survey should be l 4
included in the assessment, selection of design improvements, and i 1
verification elements described in 2.5, 2.6, and 2.7 below. ;
Results of the PMIS/SPDS survey should guide efforts to assure reasonable consistency in operator interfaces with the control room and the PMIS/SPDS.
. I 2.5 Assessment of HEDs to Determine which are Significant and Should be Corrected 4
The staff's November 4,1986 Supplement 1 to the SER indicated that NPPD's process for assessing Human Engineering Observations (HE0s) was acceptable. All potential operator control room interface problems identified by the Cooper DCRDR were initially termed HEOs.
< HEOs determined to be significant were redesignated HEDs. Although -
the assessment process was acceptable, it was not complete at the :
time of the May 13-16, 1986 preimplementation audit.
The February 2,1987 Supplement 2 to the SR indicated that HEOs identified by review phase activities completed since the May 13-16, 1987 preimplementation audit had been assessed. Included were HE0s identified by the communication and SPDS surveys. Also included were annunicator warning system (AWS) problems identified by an NPPD contractor. Staff review of assessment results indicates that the process continues to produce acceptable results.
NPPD committed to report assessment results for HEDs identified by ongoing DCRDR activities in Supplement 3 to the SR.
This element should be satisfied upon assessment of any HEDs identified by ongoing activities described in 2.3 and 2.4 above.
2.6 Selection of Design Improvements The staff's November 4,1986 Supplement 1 to the SER indicated that NPPD's selection of design improvements process was producing acceptable plans for design modifications and panel enhancements.
However, design improvements for the AWS were not available for j review during the May 13-16, 1986 preimplementation audit. The !
November 4, 1986 Supplement 1 to the SER.also noted that NPPD's development of Control Room Human Factors Engineering Standards and i
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Implementation Guidelines should help to assure a consistent interface between the control room and the operator. The staff did, however, identify specific concerns indicating that development of the standards and guidelines should continue.
Since the preimplementation audit, AWS HEDs have been grouped into nine problem areas. NPPD's February 2,1987 Supplement 2 to the DCRDR SR indicated that design improvements for most of those areas were selected and scheduled for implementation. Design improvements for two problem areas, multi-irput windows and lack of reflash, were only partially determined. Multi-input windows were assessed against a set of prioritization criteria. Priority One multi-input windows (i.e., the most important) are to be split into single-input windows during the 1988 refueling outage. That schedule and general approach is acceptable. However, the staff is concerned about the proposed addition of "...second level alarm boxes..." In the staff's judgment, resolution of that concern will require active participation of buman facters specialists in the selection and preimplementation verification of AWS modifi-cations. Priority Two and Three multi-input windows are still being evaluated. NPPD committed to report results of that evaluation in Supplement 3 to the DCRDR SR. The schedule for resolving prcblems with the Priority Two and Three multi-input windows and for reporting the results is acceptable.
Appendix B to NPPD's February 2,1987 Supplement 2 to the SR was an addendum to the Cooper Control Room Human Factors Engineering Standards and Implementation Guidelines. Staff review of that addendum indicates that NPPD is responding acceptably to concerns resulting from the May 13-16, 1986 preimplementation audit.
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However, item one in the Attachment to this SER Supplement 2 identifies one remaining concern. NPPD has also committed to add enhancement guidelines for cathode ray tube (CRT) displays following completion of the human factors evaluation of the PMIS.
Those guidelines should be provided for staff review in Supple- ,
ment 3 to the DCRDR SR.
NPPD has developed an acceptable process for selecting design 4 improvements to correct HEDs. This element should be satisfied upon selection of design improvements for AWS HEDs, inclusion of CRT display guidelines in the control room standards and guidelines, and selection of design improvements for HEDs identified by onooing DCRDR activities described in 2.3 and 2.4 above.
2.7 Verification-that Selected Improvements Will Provide the Necessary Correction and Will Not Introduce New HEDs The staff's November 4,1986 Supplement 1 to the' SER indicated that f NPPD had an acceptable process for verifying that selected design 4
improvements provide the necessary correction without introducing ,
l j new HEDs. The bulk of the verification activities were complete at the time of the preimplementation audit. However,~ some activities were planned to extend beyond implementation of changes in the control room. As a result of discussions' during the f
i preimplementation audit, the staff understood that NPPD would maintain a record of verification activities directly on the sheets on which each HED and design improvement were recorded. That record would permit confirmation that this element had been satisfied. 1 l
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NPPD's February 2, 1987 Supplement 2 to the SR indicated that postimplementation verification of HED corrections made during the-1986 refueling outage was complete. NPPD also indicated that verification was documented on individual HED sheets and that problems identified by the postimplementation verification are being corrected.
l This element should be satisfied upon completion of postimplementation verification of HED corrections implemented during the 1988 and 1989 refueling outages. Region IV has accepted responsibility for an audit of documents confirming completion of the postimplementation verification.
2.8 Coordination of Control Room Improvements with Changes from Other Programs Such as the Safety Parameter Display System, Operator Training, Reg. Guide 1.97 Instrumentation, and Upgraded Emergency Operating Procedures The staff's November 4,1986 Supplement 1 to the SER indicated that the required coordination of control room improvements was following a formal plan. One concern with that plan involved coordination with training. NPPD was required to assure that training resolutions for HEDs were verified to provide the
' necessary correction without introducing new HEDs. NPPD was also required to assure appropriate initial and requalification schedules for training resolutions of HEDs. Finally, NPPD was required to improve its plan for training operators on control room modifications resulting from the DCRDR. Control room modifications which might result in temporary degradation of operator performance were to be specifically addressed by that plan.
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NPPD's February,2, 1987 Supplement 2 to the SF provided the lesson plan used for training all Cooper operators about control room changes. Staff review of that plan indicated that it was acceptable. The February 2, 1987 Supplement 2 to the SR also contained commitments to verify training resolutions of HEDs and to-develop appropriate initial and requalification schedules for that training. Those commitments are also acceptable.
NPPD's ccordination process is acceptable. Concerns about coordination with training have been resolved. This element will be satisfied upon verification of training resolutions of HEDs and development of schedules for the initial and requalification training.
2.9 Other DCRDR Activities Although it is not a DCRDR requirement, NPPD conducted a review of Licensee Event Reports (LERs) and scram reports. The technical evaluation report attached to the staff's September 5, 1985 SER 1 recommended that the review be expanded to include experience at plants similar to Cooper. NPPD committed to expand its operating experience review in the February 27, 1986 Supplement I to the SR.
l That expansion was not complete at the time of-the May 13-16, 1986 preimplementation audit.
NPPD's February 2,1987 Supplement 2 to the SR indicated that an initial effort to expand the operating experience review was not successful. A second effort, involving 79 LERs from six BWR'4s, is currently underway. NPPD committed to report the results of that l
effort in Supplement 3 to the DCRDR SR.-
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This commitment will be satisfied when NPPD completes its current effort to review the operating experience of plants similar to Cooper.
2.10 DCRDR Results Staff review of NPPD's February 4,1985 SR and February 27, 1986 Supplement 1 indicated that SR requirements were generally ,
satisfied. However, there were several concerns identified in the staff's November 4,1986 Supplement 1 to the SER. Those concerns involved reporting of the required information for incomplete DCRDR activities, specific responses to several HEDs, and schedules for implementation of several control room changes.
i The February 2,1987 Supplement 2 to the SR provided results of-DCRDR activities completed since the May 13-16,.1986 preimple-mentation audit and the status of ongoing activities. NPPD committed to report results of ongoing DCRDR activities in Supplement 3 to the SR. Appendix B of the February 2, 1987 Supplement 2 to the SR also provided resolutions for concerns related to several previous responses to HEDs. Finally, NPPD committed to modify implementation schedules for emergency lighting and AWS concerns. NPPD's responses in all areas are generally acceptable. However, several specific concerns related to
! resolutions for certain HEDs do remain. Those concerns are identified in Attachment 1.
SR requirements will be satisfied when results of ongoing DCRDR activities are reported and the specific concerns in Attachment 1 are addressed.
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3.0 CONCLUSION
The Cooper DCRDR is incomplete. Several activities must be finished in order to satisfy the DCRDR requirements in Supplement 1 to NUREG-0737.
Those activities are:
- 1. Function and task analyses - Complete expansion of the function and task analyses.
- 2. Comparison of display and control requirements with a control room inventory - Compare information and control capability requirements identified by the expanded function and task analyses with the control room inventory.
- 3. Control room survey - Complete survey of the PMIS.
- 4. Assessment of HEDs - Assess HEDs identified by 2.0, 3.0, and 4.0 above.
- 5. Selection of design improvements - Select design improvements for HEDs identified by 2.0, 3.0, and 4.0 above and for Priority Two and Three multi-input windows in the AWS.
- 6. Verification that HEDs are corrected and that new HEDs are not introduced - Complete verification of all HED corrections including i training resolutions discussed in 2.8 above.
- 7. Coordinationhwithimprovementsfromotherprograms-Develop schedules foy initial and requalification training to resolve HEDs.
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- 8. Operating experience review - Review experience of similar plants per commitment in the February 2, 1987 Supplement 2 to the DCRDR SR.
- 9. DCRDR results - Resolve concerns in 2.10 above.
NPPD's February 2,1987 Supplement 2 to the Cooper DCRDR SR contains commitments to complete the above activities on an acceptable schedule.
An auditable record of those activities should be maintained. NPPD has-committed to submit Supplement 3 to the SR 60 days af ter the 1988 refueling outage. That schedule is acceptable. The schedule should:
- 1. Identify actual staffing for each of the above activities.
3 2. Confirm completion of those activities.
- 3. Provide information about the results of those activities.
Evaluation of the Cooper DCRDR will continue through completion of the i above activities. Final staff evaluation will be reported in Supple-ment 3 to this SER.
- Principal Contributor
- Dennis I. Serig Dated: May 21, 1987 a
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.a-l REFERENCES i
NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," t J May 1980; Revision 1, August 1980.
- NUREG-0700, " Guidelines for Control Room Design," September 1981.
4 NUREG--0737, " Clarification of TMI Action Plan Requirements," November 1980;
- Supplement 1, December 1982.
NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 18.1, Rev. O, September 1984.
Letter from J.M. Pflant-(NPPD) to D.G. Eisenhut (NRC).
Subject:
" Response to NUREG-0737 Supplement 1," dated April 15, 1983.
Letter from J.M. Pilant to D.G. Eisenhut.
Subject:
"NUREG-0737, Supplement 1 - Cetailed Control Room Design Review (DCRDR)," dated March 1,1984.
Letter from D.B. Vassallo (NRC) to J.M. Pilant.
Subject:
" Review of Detailed Control Room Design Review (DCRDR) Progran Plan Submittal," dated June 4, 1984.
Letter from J.M. Pilant to D.B. Vassallo.
Subject:
" Response to NRC Review of Detailed Control Room Design Review (DCRDR) Program Plan Submittal,"' dated August 9, 1984.
i Letter from J.M. Pilant to D.B. Vassallo.
Subject:
"NUREG-0737, Supple-ment 1 - Detailed Control Room Design Review (DCRDR) Summary Report," dated February 4, 1985.
Letter from D.B. Vassallo to J.M. Pilant.
Subject:
"Results of NRC's In-progress Audit of Cooper Nuclear Station Detailed Control Room Design Reivew (DCRDR)," dated March 20, 1985.
i Letter from D.B. Vassallo to J.M. Pilant.
Subject:
" Detailed Control Room.
Design Review (DCRDR) - Evaluation of Sumary Report," dated September 5, 1985.
Letter from J.M. Pilant to D.R. Muller (NRC).
Subject:
"NUREG-0737, Supple- i ment 1 - Detailed Control Room Design Review (DCRDR) Supplement to the
> Summary Report," dated February 27, 1986.
Letter from W.0. Long (NRC) to J.M. Pilant.
Subject:
" Detailed Control Room Design Review - Safety Evaluation," dated November 4, 1986.
4 Letter from G.A. Trevors (NPPD) to NRC Document Control Desk.
Subject:
"NUREG-0737, Supplement 1 - Detailed Control Room Design Review (DCRDR),
Supplement II to the Summary Report," dated February 2, 1987.
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ATTACHMENT 1 NRC STAFF CONCERNS RELATED TO SPECIFIC CONTROL ROOM K0DIFICaTIONS RESULTING FROM THE COOPER NUCLEAR POWER PLANT DETAILED CONTROL ROOM DESIGN REVIEW
- 1. Appendix B to the February 2,1987 Supplement 2 to the DCRDR Summary Report indicates that " pistol grip" handles for pump controls will be identified by a 1/2" yellow tape band around the handle. In contrast, small-rotary selector switches for pump controls will be identified by a white collar.
In the staff's judgment, a more consistent approach to coding pump controls (including pump controls with handles other than those described above) would enhance the operator interface with the control room. NPPD should review the proposed coding of pump _ controls to assure that new HEDs are not introduced into the Cooper control room.
- 2. Resolution / Notes f ar HEDs 644 and 667 in Appendix A to the February 2, 1987 Supplement 2 to the Summary Report indicates use of the abbreviation / standard process unit "SPIG." SPIG is not included in Attachment A.1 or A.2 to the Cooper Nuclear Power Plant Control Room Human Factors Engineering Standards and Implementation Guidelines. NPPD should confirm that all abbreviations / standard process units used in the Cooper control room are appropriate and are included in the standards and guidelines.
- 3. The Resolution / Note for HED 646 in Appendix A to the February 2, 1987 Supplement 2 to the Summary Report indicates use of "-100" as a scale value for SUPPR P00L TEMP. That value does not appear appropriate.
NPPD should confirm its correctness.
4 The HED Description for HED 642 refers to a missing "-100" scale. mark.
NPPD should indicate the parameter this scale measures.
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