ML20215D739

Addendum to Pre-Implementation Audit of Dcrdr for San Onofre Nuclear Generating Station,Units 2 & 3, Technical Evaluation Rept

ML20215D739
Person / Time
Site:	San Onofre
Issue date:	09/29/1986
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML13305A904	List: ML20215D739
References
CON-NRC-03-82-096, CON-NRC-3-82-96 SAIC-86-3080, SAIC-86-3080-ADD, NUDOCS 8610140272
Download: ML20215D739 (15)

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i SAIC-86/3080 PRE-IMPLEMENTATION AUDIT ,

OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR SOUTHERN CALIFORNIA EDISON COMPANY'S SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 Addendum to Technical Evaluation Report September 29, 1986 Prepared by:

Science Applications International Corporation 1710 Goodridge Drive

, McLean, Virginia 22102 f

Under Contract to:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 '

Contract No. NRC-03-82-096 ' (

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FOREWORD This audit report serves as an Addendum to the Technical Evaluation Report (TER), SAIC-86/3025, which was provided to the Nuclear Regulatory Commission (NRC) on March 27, 1986, and documents the findings from a Pre-Implementation Audit of the Detailed Control Room Design Review (DCRDR) being conducted by Southern California Edison (SCE) at its San Onofre Nuclear Generating Station, Units 2 and 3. The Pre-Implementation Audit was ,

conducted by a team comprised of two representatives from the NRC, two representatives from Science Applications International Corporation (SAIC),

and one representative from Comex Corporation, a subcontractor to SAIC.

The Pre-Implementation Audit consisted of extensive discussions held during the week of July 14, 1986, with representatives of SCE and its human factors consultant. DCRDR methodologies and resultant human engineering discrepancies (HEDs) were reviewed. Clarification of HED corrections and justification for no correction were provided to resolve concerns in the TER. SAIC's participation was provided under Contract NRC-03-82-096, Technical Assistance in Support of Reactor Licensing Actions; Program III.

This Addendum to the TER is based on the Pre-Implementation Audit and updates findings and conclusions contained in the March 27, 1986, TER.

SAIC previously participated in the Program Plan review, in a meeting with the licensee, and in an In-Progress Audit.

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l TABLE OF CONTENTS Section EAga INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I

1. Establishment of a Qualified Multidisciplinary Review Team .... I

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

3. Control Room Inventory ...................... 3

4. A Control Room Survey to Identify Deviations From Accepted Human Factors Principles .................... 3

5. Assessnwnt of HEDs ........................ 5

6. Selection of Design Improvements ................. 7

7. Verification That Improvements Provide the Necessary Correction and Verification That Control Room Modifications Do Not Introduce New HEDs. . . . . . . . . . . . . . . . . . . . . . . . 7

8. 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 Instructions (E0Is) ...................... 7

9. Analysis of Proposed Design Changes, Schedule for Implementing Design Changes, and Justification for No Corrective Action . . . 7 CONCLUSION .............................. 9 REFERENCES .............................. 10 ATTENDANCE LISTS ........................... 11 i

PRE-IMPLEMENTATION AUDIT OF THE DETAILED. CONTROL ROOM DESIGN REVIEW FOR SOUTHERN CALIFORNIA EDISON COMPANY'S SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 l

INTRODUCTION

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This report documents the findings from a Pre-Implementation Audit of i

Southern California Edison (SCE) Company's Detailed Control Room Design Review (DCRDR) for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. A DCRDR Summary Report was submitted to the NRC on January 31, 1984 (Reference 1), for which a Technical Evaluation Report (TER) (Reference

2) was provided recommending an In-Progress Audit. The In-Progress Audit was conducted on June 17-21, 1985. Subsequently, SCE submitted a Supplemen-I tal Summary Report (Reference 3) dated January 29, 1986. Based on Science Applications International Corporation's (SAIC's) review of the Supplemental Summary Report, the decision was made to conduct a modified Pre-Implementa-tion Audit in order to clarify the DCRDR review methodology, and to deter-mine the adequacy of design improvements for human engineering discrepancies (HEDs) or the justification for leaving the HEDs uncorrected. The Pre-Implementation Audit was conducted on July 14-15, 1986. The audit team determined that SCE's DCRDR has been adequately accomplished and fully

! satisfies the requirements for a DCRDR. This audit report documents the i resolution of all concerns that were identified in the TER. It is based on all information transmitted at this time and is arranged in order of the DCRDR elements identified in Supplement I to NUREG-0737 (Reference 4).

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1. Establishment of a Qualified Multidisciplinary Review Team t

Based on all information gathered through submittal of the licensee's Supplemental Summary Report, the reviewers conclude that the structure and management of the DCRDR team satisfies this Supplement I to NUREG-0737 requirement. .

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2. System Function and Task Analysis During the Pre-Implementation Audit, the licensee clarified two items concerning the task analysis methodology as follows:

a. Was the instrument accuracy as specified for operator information needs sufficiently detailed?

SCE responded to this item by indicating that instrument accuracy fell into the following three categories:

(1) 1-2.5% accuracy was specified for a setpoint.

(2) 0-15% accuracy was specified for a trend.

(3) N/A was specified for a position indication.

The audit team learned that accuracy was fully documented on the Instrument and Control Characteristics Form. A sample audit of the forms proved that the accuracy specified was suitable.

b. How were the information characteristics for scale intervals and divisions evaluated?

SCE identified the most suitable display increments and divisions from the Combustion Engineering (CE) generic task analysis for the CE Emergency Procedure Technical Guidelines (EPTGs). An additional source for determining the suitability of information characteristics was reports of instances noted by control room operators during the operator experience review. Finally, during the walk-through/ talk-throughs of the Emergency Operating Instructions (E0Is), the suitability of the controls and displays was rigorously evaluated by SCE's human factors consultants and operations personnel. Based on the information and documentation provided by SCE, the audit team determined that the task analysis

, methodology was complete and that information and control charac-teristics had been evaluated.

It is the reviewers' judgment, based upon a review of all ,DCRDR docu-mentation provided by the licensee, that SCE has satisfied the NUREG-0737, 4

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Supplement 1 function and task analysis requirement. However, IE Informa-tion Notice No. 86-64, dated August 14, 1986, indicates that many utilities may not have appropriately developed or implemented upgraded emergency I

operating procedures (EOPs). Accordingly, the licensee should verify that the problems with E0Ps identified in this Information Notice are not applicable to SONGS, Units 2 and 3. If there are problems, the licensee should consider reevaluating the adequacy of its DCRDR task analysis.

3. Control Room Inventory i As described by SCE and audited by the NRC audit team, the process for

comparing information and. control requirements with a control room inventory proved to be acceptable. In order to confirm that the process was adequate, t

the audit team traced the identification of two HEDs through the paper trail beginning with the EPTGs. From the EPTGs, SCE's human factors consultant and subject matter expert described operator tasks. Next, task elements embedded in task descriptions were identified; and last, the information and control characteristics associated with the task elements were defined. -

With this data, the team was then able to compare the specific characteris-tics with a control room inventory, thus generating HEDs from the mis-matches. Based on the documentation audited, the process was deemed thorough and accurate as evidenced by the proper paper trail to document the

! process and results.

The NRC audit team verified that SCE has satisfied this requirement of Supplement 1 to NUREG-0737. In addition, the licensee clarified that the i remote shutdown panel was analyzed using this methodology and the plant's ,

Abnormal Operating Instruction, entitled " Shutdown From Outside of the Control Room." This effort was found to be satisfactory.

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4. A Control Room Survey to Identify Deviations From Accepted Human Factors Principles j Three concerns resulted from SAIC's review of SCE's Supplemental ,

! Summary Report as follows: .,

a. Identification of personnel who performed the survey of the I control room computer systems and the scope of the effort I ,

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b. The recommendation to conduct a new study of the annuncia' tor system

c. The proposed corrective actions and schedule for implementing l' corrective actions to resolve HEDs from the annunciator system survey The licensee clarified that its human factors consultant surveyed the computer systems, including the Plant Monitoring System (PMS), the Accident Monitoring System (AMS), and the Critical Function Monitoring System (CFMS).

! Although the CFMS was provided by CE and included a human factors review by

! CE, SCE's human factors consultant provided an additional survey of the

, display design.

A result of the computer survey was the decision to replace the PMS because it was found to be obsolete. SCE now has a program for replacement of the system, which is scheduled for Unit 3's third cycle outage and for i Unit 2's fourth cycle outage. Human factors design criteria are being

! applied during the selection of the new system and will help to correct problems with the existing hardware. The audit. team also found that the j Shift Supervisor and the Station Technical Advisor are the primary users of the AMS and CFMS.

The second concern regarding the ongoing study of the annunciator system was discussed with the licensee. As stated by the licensee, the purpose of the study was to evaluate the findings and changes that have been implemented from the DCRDR. The study verified that no new problems exist and that the DCRDR annunciator survey is complete. Additionally, the licensee indicated at the Pre-Implementation Audit that the nuisance alarm rate has been reduced from a previous high of 100 per day to the current I rate of 2 per day.

The third concern addressed was the notation in the licensee's Supplemental Summary Report that some of the annunciator design change packages (DCPs) had been designated as " cancelled" and as " remaining." The audit team learned that the intent of a " cancelled" DCP was the transfer of the change to another DCP. The " remaining" DCPs were either completely implemented or the implementation was in progress. The audit team concluded 4

that the annunciator system survey was complete and that the system, though not perfect, has been substantially upgraded.

In conclusion, the NRC audit team determined that a complete control room survey has been conducted which satisfies this requirement of Supple-ment I to NUREG-0737.

5. Assessment of HEDs Three concerns which resulted from SAIC's technical evaluation of the assessment process and the scheduling of HED corrections were as follows:

a. The method by which human engineering observations (HE0s) were assessed

b. How weights were determined for degree of safety importance, potential for operator error, and potential for unsafe condition, or technical specification violation ,

c. The prioritization and scheduling of HED. corrections Through discussions with the licensee, the audit team found that the 25 HE0s which were not converted into HEDs were either not safety-related or were a duplicate of an existing HED. The criteria for converting an HE0 to an HED was a "yes" response to any question on the HE0 assessment question-naire. This clarification adequately resolved the audit team's concern.

SONGS' human factors consultant provided a description of how a weight factor was determined for each of the HED assessment criteria. In the first step, the paired-comparison technique was applied to the three criteria. f Each criterion was paired and compared with every other criterion and a 1 was assigned to the criterion judged to be more important. This comparison resulted in the assignment of 67% to potential for error, 0% to degree of safety significance, and 33% to potential for unsafe condition or technical 4

specification violation.

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A B C Total Weiaht A - 1 1 2 2/3 = .667 8 0 1 0 0 0/3 = .000 C 0 1 - 1 1/3 = .333 (1 = row criterion more important than column criterion.)

The assignment of 0% to degree of safety significance was thought to be unreasonable. Therefore, in the second step a dummy variable was added to the paired-comparison technique so that none of the criteria would receive a weight of 0%. The modified comparison resulted in the assignment of 50% to potential for error, 17% to degree of safety significance, and 33% to potential for unsafe condition or technical specification violation.

A B C D Total Weicht A - 1 1 1 3 3/6 = .500 B 0 -

0 I 1 1/6 = .167 .

C 0 1 - 1 2 2/6 = .333 Dummy 0 0 0 - 0 .

While the modification of the paired-comparison technique had ensured I that none of the criteria would receive a weight of 0%, it had also altered the ratio between potential for error and potential for unsafe condition or l

technical specification violation. Prior to the modification, this ratio was .667 to .333 or 2:1. In order to maintain this ratio, the weights were adjusted by shifting .055 from potential for error to potential for unsafe condition or technical specification violation. This adjustment maintained the 2:1 ratio (.555 to .278) and resulted in the final weight assignment of 55% to potential for error,17% to degree of safety significance, and 27% to unsafe condition and/or technical specification violation. The audit team found this methodology and the resulting assignment of criterion weights to i be acceptable.

In conclusion, the audit team received ample clarification to resolve concerns with the method to assess the safety significance of HEDs. The criteria and process applied were thorough and rigorous and resulted in the (

Also, HED corrections were found identification of the most serious HEDs.

to be scheduled in a time frame responsive to the seriousness-of the HED.

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Thus, the audit team concluded that this requirement of Supplement I to I

NUREG-0737 has been satisfied.

6. Selection of Design Improvements Based on SCE's description provided in its Supplemental Summary Report, the reviewers concluded that the process to select design improvements was thorough and meets this requirement of Supplement I to NUREG-0737.

7. Verification That Improvements Provide the Necessary Correction and Verification That Control Room Nodifications Do Not Introduce New HEDs SCE's description of the procedures to accomplish these two require-ments was given in its Supplemental Summary Report. Based on that infor-mation, in addition to information collected during the June 17-21, 1985, In-Progress Audit, the reviewers concluded that the procedures were adequate and satisfy these requirements of Supplement I to NUREG-0737. During the Pre-Implementation Audit, SCE assured the NRC audit team that for future control room changes those procedures will be reapplied and will include input from a human factors specialist. -

8. 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 Instructions (E01s)

As described in its Supplemental Summary Report, SCE established the mechanisms and procedures for integrating all emergency response initiative i

programs. This requirement of Supplement I to NUREG-0737 has been satisfied.

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9. Analysis of Proposed Design Changes, Schedule for Implementing Design Changes, and Justification for No Corrective Action Extensive discussions were held during the Pre-Implementation Audit to .

l clarify HED corrective actions and justifications for no or partial correc- [

l tive actions. The discussion encompassed a list of HEDs as outlined in the l appendices to the TER along with reviewers' questions. All questions were l answered by SCE, and through its clarification the NRC audit team concurred 7

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with SCE's' response for corrective action or the explanation for not provid-ing a design solution on all but two items.

The first of these unresolved items concerned an HED (No. 58-A21-03) written for inconsistencies with the Control Element Assembly (CEA) displays. The proposed corrective action called for component relocations.

At the Pre-Implementation Audit, SCE indicated that relocation of the CEA displays woul'd require changes in Combustion Engineering (CE) software that would be inconsistent with all other CE software. A CE representative present at the audit committed to investigating this inconsistency on a generic basis for all CE plants. Subsequent to the audit, this investiga- .

tion revealed that all CE plants have this inconsistency; however, an initial evaluation indicated that the costs associated with correcting this inconsistency would far outweigh the benefits. The NRC concurred with this conclusion.

The second unresolved item concerned the use of color on the CFMS Cathode Ray Tube (CRT). During the June 17-21, 1985, In-Progr.ess Audit, the audit team performed a minisurvey of the engineered safety features panel which resulted in the identification of several potential HEDs. One of the HEDs identified was that the CRT for the CFMS uses blue-on-black background which provides very low contrast and is very difficult to read. In the Supplemental Summary Report, SCE indicated that the blue color is clearly l

visible to operators seated at the CFMS console and, thus, this was not an HED. The audit team did not agree with SCE's position, but decided to defer this item to the future Post-Implementation Audit of the SPDS at SONGS,

Units 2 and 3. This item will be fully evaluated by the SPDS audit team.

The audit team and SCE also reviewed the schedule for 'cplementation of i HED corrections for those HEDs listed in the Appendices to the TER. In all cases the audit team's questions were answered, and it was concluded that corrections were being implemented according to an acceptable schedule.

i CONCLUSION A DCRDR Pre-Implementation Audit has been conducted for SCE's SONGS, Units 2 and 3. The audit afforded the licensee an opportunity to respond to questions and concerns that had been documented in SAIC's Technical Evalua-l 8 l

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tion Report. As a result of extensive discussions and audit of documenta-tion, the NRC audit team was able to conclude that the DCRDR processes, results, design solutions, and documentation have addressed all reviewers' concerns and have satisfied the requirements of Supplement I to NUREG-0737.

SCE was conmended for accomplishing a thorough and effective DCRDR that resulted in numerous modifications and improvements to its control room.

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t REFERENCES

1. Control Room Design Review Report, San Onofre Nuclear Generating Station, Units 2 and 3, SCE Document Nos. 37327 and M37328, Revision 0, Southern California Edison Company, San Diego Gas and Electric Company, January 31, 1984.

2. Technical Evaluation of the Detailed Control Room Design Review for Southern California Edison Company's San Onofre Nuclear Generating Station, Units 2 and 3, prepared by Science Applications International Corporation for the U.S. Nuclear Regulatory Commission, March 27, 1986.

3. Detailed Control Room Design Review Supplemental Report, San Onofre Nuclear Generating Station, Units 2 and 3, SCE Document No. M37328, Volumes 1, 2, 3 and 4, Southern California Edison Company, January 1986.

4. NUREG-0737, Supplement 1, " Clarification of TMI Action Plan Require- '

ments - Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.

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DCRDR AUDIT SAN ONOFRE UNITS 2 AND 3 July 14, 1986 Hast Company EhgBR Clay E. Williams SCE/ Licensing (818)302-2643 Faust Rosa NRC/0NRR/DPLA/EICSB (301) 492-7831 Joel Kramer NRC/0NRR/DPLA/EICSB (301) 492-8408 Bob Pearce C-E (203)285-3043 Charles Lacugna Bechtel (213) 807-5554 Dennis Cox SCE/ Licensing (818) 302-1658 David H. Schultz NRC/SAIC/Comex (206) 786-8388 Bethany H. Drum NRC/SAIC (703) 556-7176 Carol Kain NRC/SAIC (703) 734-5590 Jose Ibarra SCE/ Nuclear Engineering (818) 302-3442 Daryl Harmon C-E (203) 285-4574 Dorothy Schaefer SCE (818)302-2749 George E. Reeder SCE (818)302-2437 Jerry L. Prickett SCE (818)302-3348 Nichael J. Thomas SCE (818)302-2336 Nark Sanders (HFC)/SCE i

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