ML20215N598

Technical Evaluation Rept of Dcrdr for Cooper Nuclear Station

ML20215N598
Person / Time
Site:	Cooper
Issue date:	09/29/1986
From:	Johari Moore, Savage J LAWRENCE LIVERMORE NATIONAL LABORATORY
To:	NRC
Shared Package
ML20215N587	List: ML20215N586 ML20215N598
References
RTR-NUREG-0737, RTR-NUREG-737 TAC-64721, NUDOCS 8611070059
Download: ML20215N598 (20)

Text

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ATTACHMENT TO SER I

TECHNICAL EVALUATION REPORT OF i

NEBRASK A PUBLIC POWER DISTRICT'S DETAILED CONTROL ROOM DESIGN REVIEW FOR

~* COOPER NUCLEAR STATION James W. Moore Jack W. Savage

. Lawrence Livermore National Laboratory September 29,1986 f

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PDR ADOCK 0500 E ,

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' TABLE OF CONTENTS M

l. I n t r od u c t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . l

2. Ev a l ua t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.1 Establishment of a Qualified Multidisciplinary Review Team..................................................... 1 l 2.1.1 C r i t er i a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l 2.1.2 Dis c ussi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2,1,3 Conclusi on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

. 2.2 Punction and Task Analyses to Identify Control Room Operator Tasks and Information and Control Requirements During Emergency Operations . . . . . . . . . . . . . . . . . . . 2

% 2.2.1 Cri teria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2,2.2 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 l 2.2.3 Conc 1 talon . . . . . . . .m . . . . . i .T. 3 .' . . . . . . . . . . . . . . . . . . . .

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! 2.3 Comparison of Display and Control Requirements with a Control Room Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.1 Cr l t er ia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.2 Dis c ussi on . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.4 ~ A Control Room Survey to Ident!fy Deviations from l Accepted Human Factors Principles . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 i 2.4.1 Criteria . o . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.4.2 Dis cussio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ,

2.4.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

, 2.5 . Assessment of HEDs to Determine Which are  ;

i Significant and Should. Be Corrected . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 i 2.5.1 C ri t er ia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 i

1 2.5.2 Discussi on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 6

2.5.3 Conclusi on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2.6 Selection of Design Improvements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 7

2.6.1 Cri t er ia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2.6.2 D is cussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 i 2.6.3 Co ncl usi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 2.7 Verification that Selected Improvements will Provide i the Necessary Correction and W111 Not Introduce New HEDs..................................................... 8 2.7.1 C ri t er i a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1 2.7.2 Dis cussi on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 2.7.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 l

2.8 Coordination of Centrol Room Improvements with

- Changes From Other Programs Such as the Safety i Parameter Display flystem, Operator 'IYalning Reg.

l Oulde 1.97 Instrumentation, and Upgrtde'dEm,ergency Operating Procedures ." . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 i

8 i 2.8.1 Cri terla . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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t TABLE OF CONTENTS (Cont.)

.Pggg, 2.8.2 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.8.3 Concl usi ons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 2.9 Operating Experience Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 2.10 Summary Report ........................................... 10

'2.10.1 C rit er ia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 2.10.2 Dis c ussi on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 2.10.3 Conclusi ons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

3. Conclusi ons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

4. R e fe rence s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 5 Ap pe nd i x A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

6. Ap pe nd i x B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

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TECHNICAL EVALUATION OF ,

NEBRASKA PUBLIC POWER DISTRICTS l

l DETAILED CONTROL ROOM DESIGN REVIEW FOR ,

COOPER NUCLEAR STATION

1. INTRODUCTION -

j Nebraska Public Power District (NPPD) submitted the Summary Report for the Cooper

Nuclear Station Detailed Control Room Design Review (DCRDR) to the N'telear l Regulatory Commission (NRC) on February 4,1985. 'Ihat report was reviewed by IJtwrence Livermore National Laboratory (LLNL) personnel on contract to the NRC.

• Based on the results of that review and on the results of an earlier in-progress audit, the NRC staff requested that NPPD supplement the Summary Report. That supplement was provided on February 27,1986. LLNL review of the Supplemental Summary Report (SSR) indicated the need for a preimplementation audit. The preimplementation audit was

% conducted from May 13-16, 1986.

. 2. EVALUATION ,

LLNL has reviewed allinformation on the Cooper Station DCRDR available to date. The purpose of the review was to evaluate whether DCRDR requirements in Supl:lement I to NUREG-0737 had been satisfied. The evaluation was performed by comparing information provided by NPPD with criteria in Section 18.1, Rev. 0, Append.x A of the Standard Roview Plan. Our evaluation of the DCRDR for Cooper Station, a'ong with a summary of the criteria from the Standard Review Plan,is provided below.

2.1 ESTABLISHMENT OF A QUALIFIED MULT! DISCIPLINARY REVIEW TEAM-2.1.1 Criteria *

'Ihe organization for conduct of a successful DCRDR can vary widely, but is expected to conform to some general criteria. Overall administrative leadership should be provided by a utility employee. The DCRDR team should be given sufficient authority to carry out its mission. A core group of specialists in the fields of human factors engineering, plant ~ operations, instrument and control engineering, 'and nuclear engineering are expected to participate with assistance as required from other disciplines. Staffing to accomplish each DCRDR element should bring appropriate expertise to bear. Human factors expertise should be included in staffing for accomplishment of most, if not all, DCRDR elements. Finally, the DCRDR team should receive an orientation which contributes to the success of the DCRDR. Section 18.1, Appendix A, of NUREG-0800 describes criteria for the multidisciplinary review team in more detall.

2.1.2 Discussion

'Ihe qualifications of the review team members and their level of involvement in the the DCRDR tasks was found acceptable by the NRC review team in a previous Technical Evaluation Report (TER) 11 and in the staff's Safety Evaluation (SE) J 2 of September 5,1985 NPPD has since modified the multidisciplinary review team.

Modifications included changes in both team personnel and structure. Those

. modifications strengthened team capab!11 ties in the areas of human factors engineering and instrument and control engineering.

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< 2.1.3 Conclusion I This element continues to be satisfied. It should be fully satisfied if NPPD maintains the present multidisciplinary review team through completion of the DCRDR.

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b 2.2 FUNCTION AND TASK ANALYSES TO IDENTIFY CONTROL ROOM OPERATOR -

1 TASKS AND INFORM ATION AND CONTROL REQUIREMEN'Ili DURING EMERGENCY t OPERATIONS 2.2.1 Criteria The purpose of the function and tark analyses is to identify the control room operators' tasks during emergency operations and to determine the information and control capabilities needed by the operators to perform those tasks. An acceptable process for conducting the function and task analyses ist  ;

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l. Analyze the functions performed by systems in responding t: transients and

accidents in order to identify and describe those tasks operators are expegted to perform.

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2. For each task identified in Item 1 above, determine the information (e.g.,

parameter, value, status) whleh signals the need to perform the task, the

! control capabilities needed to perform the task, and the feedback information i needed to monitor task performance. Displays and controls are not identified i

at this stage. Operator tasks have been identified and described, and the i

information and control capabilities necessary to perform those tasks are being -

l determined. ,

f 3. Analyze the information and control capabilities determined in Item 2 above to

! determine those characteristics essential to adequate task performance.

Information characteristles include parameter type, dynamic range, set points, i resolution / accuracy, speed of response, units and need for trending, alarming, d

etc. Control characteristics include type (discrete or continuous), rate, gain, i response requirements, locking functions, and feedback information associated with control use.

li The described process is prescriptive. It should identify, in detail, what operators need j to do in order to control the systems ~which mitigate the consequences of transients and t

accidents. It sr.ould also identify an appropriate functional interface between the

operators and those systems. In addition to their use in the DCRDR, the function and i

! task analyses should provide the basis for complete and technically adequate Emergency

Operating Procedures (EOPs). Identification of tasks and necessary information and i control capabilities should be based on engineering analyses and should be independent of

} displays and controls in the control room.

i l 2.2.2 Discussion ,

Several shortcomings / concerns were described in detall Ip the LLNL TER of March 26,1985 11 and in the Staff 4 SE of September 5,1985 a2 Actions required to overcome the shortcomings / concerns were identified as:

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o Consistently document the task analysis process used to independently identify instrument and control needs and characteristics as identified in the l Emergency Procedure Guidelines and in the EOP operator verification and action steps.

. o Complete that part of the Function and Task Ana'ysis (FTA) that did not -

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1 Other procedures implicitly referenced in the EOPS that are required to l support the EOPs (e.g., entry / exit).

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Existing emergency procedures still in use afte implementation of the upgraded EOPs 2

EOPs which may be revised prior to implementation.

Safety Parameter Display System (SPDS) and Plant Management

Information System (PMIS) procedures required to support operator j performance during emergency operations.

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Auxiliary shutdown panel (ASP) (remote shutdown) and station blackout j procedures. i j NPPD's ~ response to the above items were reviewed in the Cooper SSR of

! February 27,1986 and discussed during the NRC preimplementation audit.

The audit team found that an auditable record of the FTA was available. Review of that record confirmed that NPPD has an acceptable process for conducting the FTA.

i Although availabk the auditable record was awkwardly arranged among several parts of I the Cooper documents. The audit team needed the expert guidance of the Cooper i DCRDR team members to locate and substantiate the auditability and consistency of the data and documentation. It is suggested but not required that the Cooper DCRDR team

! management consider the value and future usefulness of creating a written / illustrated i " users guide" for DCRDR processes and documents capable of leading a future user along r i the DCRDR auditable trail. Such a guide might include descriptions of sources of

} information (e.g., checklists, block diagrams, standards, etc.) who performed, and how i the tasks were executed to identify and define detalled equipment characteristics, and j where such details can be found in the project documents.

3 NPPD's February 27,1986 SSR continued commitments to expand the scope of the scope of the FTA to address all but one area identified in the staff's September 5,1985 SE. In

, the case of the exception, NPPD indicated that the PMIS/SPDS was a supporting element i for the Cooper EOPs but was not included in specific procedures for use during

' emergency operations. Based on that statement, expansion of the PTA does not need to include the PMIS/SPDS. Expansion of the FTA was not complete at the time of the ,

s preimplementation audit. Based upon discussions during the preimplementation audit the  !

j NRC. audit team found that the procedures for the ASP and Station Blackout had not yet been completed. Additionally, NPPD had not yet considered other procedures implicitly referenced in the EOPs which are required to support the EOPs.'

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0.2.3 Cor.clusion Previous conecens related to the documentation and scope of this element have been resolved by information provided in the February 7, 1986 SSR and during the preimplementation audit. This element should be fully satisfied when NPPD meets its commitments to expand the scope of the FTA. Items yet to be completed should use the -

same DCRDR guidelines, personnel, processes / procedures and be documented as previously.

2.3 COMPARISON OF DISPLAY AND CONTROL REQUIREMENTS WITH A CONTROL ROOM INVENTORY 2.3.1 Criteria lhe purpose of comparing display and control requirements with a control room inventory

% is to determine the availability and suitability of displays and controls required for performance of th'e EOPs. Success of this element depends heavily on the quality of the function and task analyses and the control room inventory. Display and control requirements should be derived from analyses which are sufficiently detailed to support development of complete and technically adequate EOPs. Characteristics appropriate to the task should be described for each display and control need identified by the function and task analyses. The control room inventory should be a complete representation of displays and controls currently in the control room. The inventory should include characteristics of current displays and controls appropriate to meaningful comparison with the results of the function and task analyses. Once an adequate control room inventory is developed, a systematic comparison of information and control capability requirements with existing controls and displays should be made. Displays and controls determined to be unavailable or unsultable should result in documented lluman Engineering Discrepancies (HEDs).

2.3.2 Discussion NPPD accomplished the comparison of display and control requirements with the actual control room inventory using the task analysis data sheets. Operators accompanied by review team subject matter experts (SME) walked down the control boards identifying necessary equipment or lack of necessary equipment. 'Ihe SME noted on the data sheets whether instrumentation and controls required for performance of the EOPs were available. The SME addressed suitability of the instruments and controls identified on the same sheet. Controls and displays not available or determined not to be suitable were documented as llEDs.

NPPD's commitment to expand the FTA is expected to result in the need to compare additional display and control requirements with the control room inventory. 'Ihat comparison should determine the availability and human factors suitability of displays and controls corresponding to the information and control capability requirements.

Required displays and controls which are unavailable ,or unsultable should be documented as llEDs.

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4 l .i 2.3.3 Conclusion  ;

I Based upon our review of documentation and discussions during the preimplementation l audit, it appears the NPPD inventory and comparison process is acceptable. However,

comparison of the control room inventory with any new or modified display and contro!

! requirements identified by the expanded task analysis needs to be completed before this -

! element is fully satisfied. j 2.4 A CONTROL ROOM SURVEY TO IDENTIFY DEVIATIONS FROM ACCEPTED

HUM AN FACTORS PRINCIPLES 2.4.1 Criteria

} We key to a successful control room survey is a systematic comparison of the control i 1 room with accepted human engineering guidelines. One accepted set of human

l. engineering guidelines is provided by Section 6 of NUREG-0700. Discrepancies between "

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the control room and human engineering guidelines should be documented as HEDs.

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] 2.4.2 Discussion he Cooper Control Room Survey was originally conducted in 1981 using BWR Owner's l* Group (BWROG) survey checklists. The original survey did not include all control room panels. In 1984, the NPPD completed the survey on all panels and supplemented the process using a supplemental BWROG checklist developed to address toples included in i NUREG-0700 checklists, but not included in the original Owner's Group checklists.

i The guidelines used by NPPD for the control room survey have been found acceptable by

! the NRC in Generic Letter 83-18, dated April 19,1983. The staff's September 5,1985 SE i did, however, indicate concern with the completeness of the control room survey. The j SE also indicated the need for NPPD to survey the PMIS/SPDS against accepted human factors engineering guidelines. In response to the concerns, NPPD reviewed the scope of l Its control room survey and confirmed that it was, with one exception, complete. The

} exception was a survey of the operator's communications abilities while wearing Self q Contained Breathing Apparatus (SCBA) and respirators.

I NPPD's February 27,1986 SSR contained commitments to survey the fiPDS portion of the PMIS/SPDS and to survey communleations while operators wore SC3A and respirators.

i Those commitments partially resolved previous concerns. Concerns remained about

} survey of the PMIS portion of the PMIS/SPDS and about the schedule for survey of

! communications in SCBA (the third refueling outage following submittal of 'the 1 February 27,1986 SSR). D ose remaining concerns were discussed during the l May 13-16,1986 preimplementation audit. Based on those discussions, we understand

!' that NPPD will survey the entire PMIS/SPDS against accepted human factors engineering j guidelines. De PMIS/SPDS survey should be used to guide NPPD's efforts to assure

! reasonable consistency in the operator's interfaces with the control room and the I PMIS/SPDS. We also understand that NPPD will survey communications in SCBA and  !

I respirators as soon as possible. '

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t 2.4.3 Conclusion j

! ,NPPD has an acceptable process for conducting a control room survey but has not yet

! completed that survey. . The PMIS/SPDS and the ability of operators to communicate while wearing SCBA and respirators remain to be surveyed. his element should be fully -

satisfied upon completion of a survey of those ' items per commitments made in the -

I February 27,1986 SSR and during the May 13-16,1986 preimplementation audit.

2.5 ASSESSMENT OF HEDs TO DETERMINE WHICH ARE SIGNIFICANT AND SHOULD BE CORRECTED 1

2.5.1 Criteria HEDs should be assessed for significance. De potential for operator error and the consequence of that error in terms of plant safety should be systematically considered.

Consideration of. the combined effects of HEDs on operator performance should be specifically included in the assessment process (e.g., the control room survey identifies a i r. umber of HEDs related to a particular display-all of those HEDs may affect the I operator's ability to read that display-while the impact of one of the HEDs may not be i very great the combined effect may be that readability is unacceptable). The result of the assessment process is a determination of which HEDs should be corrected because of l their potential impact on plant safety. Decisions about whether or not HEDs are i significant in terms of potential impact on plant safety should not be compromised by consideration of such issues as the means and potential cost of correcting those HEDs.

i 2.5.2 Discussion

? NPPD's assessment process gave all potential operator / control room interface problems a preliminary de'signation of " Human Engineering Observations"(HEO). HEOs determined

to- be significant were designated HEDs (i.e., Human Engineering Discrepancies). The l basic assessment process used by NPPD was previously found acceptgble, ,however, j several concerns were identified in the Staff's September 5,1986 SE. l' 'Ihe major i concern was use of a preliminary screening which eliminated a large number of HEDs from the full assessment process. A related concern was lack of an adequate auditable I record of the screening process. A final concern was NPPD's determination that lack of l a lamp test capability was not safety significant.

l In response to the above concerns, NPPD eliminated the preliminary screening from the assessment process. Full assessment of 351 HEDs previously eliminated by the l preliminary screening process resulted in the determination that many should be

! corrected. The concern about auditability of the preliminary screening process was

! resolved by elimination of that process. NPPD also reviewed the lamp test concern in 4

detail. The February 27,1986 SSR contains commitments to institute daily checks for

! failed indicating lights and to modify the most critical single bulb indicating lights to incorporate a push-to-test or dual bulb feature.

l 2.5.3 Conclusion

• 1 NPPD's methodology and process for the assessment of HEDs appears to be acceptable in l meeting the requirements of Supplement I to NUREG-0737 Actions and commitments J

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l 1 detallad in the February 27,1986 SSR have resolved previous concerns. However, we i recommend NPPD ensure all future HEDs identified by ongoing work be subjected to the ,

same assessment process as all previous HEDs.

2.6 SELECTION OF DESIGN IMPROVEMENTS

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i j 2.6.1 Criteria ne purpose of selecting design improvements is as a minimum, to correct safety significant HEDs. Selection of d2 sign improvements should include a systematic process for davelopment and comparison of alternative means for resolving HEDs. Both

enhancement and design modification may 'be considered. The selection of design improvements should work to bring the control room into agreement with acceptable hurran factors engineering guidelines. Existing control room conventions (explicit or i

.* impileit) should be documented and reviewed for completeness of application and for t

conlict with each other and with accepted human factors engineering guidelines. HEDs

! may be resolved by application of existing or revised control room conventions. HEDs may also be resolved by explicit, new control room conventions which should be developed and documented as part of the DCRDR process.

2.6.2 Discussiol -

We NPPD selection of design improvements process included the setup of two review teams. Rese teams were responsible for the following items:

o Resolutions of HEDs.

I o Integr:!ted enhancements and modifications for each panel.

!' o Detailed design of the corrections.

! o Verification of the design improvements.

o Implementation of the improvements.

I NPPD was assisted by Black and Yeach, who conducted feasibility studies on HEDs requiring studies. De NPPD review teams are using the Black and Veach studies as a l guide for final design decisions. The review teams are als standards and conventions developed from NUREG-0700 andgother usingrecent NPPD human factor human

! factors references.14-16 In our judgment, the NPPD human factors standards will nelp to assure a consistent interface between the control room and the operator.

Development of the standards should, however, continue based on concerns identified in Appendix A to this TER.

At the time of the preimplementation audit, the selection of design improvements

process had resulted in acceptable plans for design (nodifications (e.g., system layouts, equipment upgrades) and panel enhancements (e.g., system demarcation, hierarchical labeling, and color banding). Design improvements had not yet been selected for the annunciator system. NPPD.had received a Black and Veach report on that system but had not yet reviewed the report in sufficient detail to make decisions about correction of

annunciator HEDs.

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2.6.3 Conclusion The NPPD selection of design improvements process is acceptable. However, there are several items which remain to be completed in order to satisfy this element. They include upgrade of control room design standards, selection of design improvements for HEDs identified by ongoing DCRDR activities (e.g., comparison of display and control .

requirements with control room inventory, control room survey) and selection of design 1 nprovements for annunciation system HEDs.

2.7 VERIFICATION THAT SELECTED. IMPROVEMENTS WILL PROVIDE THE NECESSARY CORRECTION AND WILL NOTINTRODUCE NEW HEDs 2.7.1 Criteria l A key criterion of DCRDR success is a consistent, coherent, and effective interface

% between the operator and the control room. One good way to satisfy that criterion is

! through iteration of the processes of selection of design improvements, verification that l selected design improveme.nts will provide the necessary correction, and verification that

improvements will not introduce new HEDs. The verification processes should'be i

completed prior to implementation of design improvements in the control room.

Exceptions might be workspace/ environmental ~ HEDs for which " final verification" (i.e., final adjustment) may have to await implementation of the design improvement in the control room. Techniques for the verification process might include partial resurveys on mocked-up panels, applied experiments, engineering analyses, environmental surveys, and operator interviews. Each iteration of the selection and verification processes should reduce inconsistencies in the operator / control room interface while increasing the coherence and effectiveness of that interface. The consistency, coherence, and effectiveness of the entire operator / control room interface is important to operator performance. Thus, evaluation of both the changed and unchanged portions of the control room is necessary during the verification processes.

( 2.7.2 Discussion I

'Ihe September 5,1986 SE indicated that NPPD should describe the methods by which this element was satisfied. In response, NPPD established a " Cooper Nuclear Station DCRDR Change, Verification, Validation,. and Implementation Instruction." That instruction submitted as part of the February 27,1986 SSR details the organization and process for verification of design improvements. Tne process was discussed and documentation was received during the May 13-16,1986 preimplementation audit.

'Ihe NPPD DCRDR team leader provides the support, scheduling, and tracking of all proposed design changes. As part of the NPPD design change process, the design engineer will incorporate human engineering standards in the design change. NPPD stated during audit discussions, a change to Station Design Change Procedure 3.4 is underway to ensure design engineers implement recommended human engineering standards into this process. After the design change is prepared, it is reviewed by an independent reviewer to ensure correctness and conformance with human engineering standards. The review team then reviews the design change as a whole. The design change then goes to Station Operations ~ Review Committee (SORC), which is the normal design change process. The design changes will also be reviewed by the DCRDR review 860504:10/6/86

l I

f.eam after implementation. This will be accomplished by one of two methods: Control Room Walk-Throughs and Table Top Discussions. NPPD states additional verification that selected improvements will provide the necessary correction and will not introduce i new HEDs will be accomplished using surveillance during start up.

l 2.7.3 Conclusion .

'Ihe NPPD verification process as explained is acceptable. However, the process extends beyond implementation of changes in the control room and thus is not complete. NPPD should maintain an easily audited record of the verification process in order to allow the NRC to confirm that the process is complete. For HEDs which require interactive selection and verification of design improvements, the record should document the full process through final selection and verification of an acceptable improvement.

2.8 COORDINATION OF CONTROL ROOM IMPROVEMENTS WITH CHANGES FROM OTHER PROGRAMS SUCH AS THE SAFETY PARAMETER DISPLAY SYSTEM, '1 OPERATOR TRAINING, REG. GUIDE 1.97 INSTRUMENTATION, AND UPGRADED EMERGENCY OPERATING' PROCEDURES .

2.8.1 Criteria Improvement of emergency response capability requires coordination of the DCRDR with other activities. Satisfaction of Reg. Guide 1.97 requirements and addition of the SPDS will require modification and additions to the control room. Those modifications and additions should be specifically addressed by the DCRDR. Exactly how they are addressed will depend on a number of factors including the relative timing of various emergency response capability upgrades. Regardless of the means for coordination, the result should be an integration of Reg. Guide 1.97 instrumentation and SPDS equipment into a consistent, coherent, and effective control room interface with the operators.

Ideally coordination of the DCRDR with upgrade of the EOPs should begin with a detailed task analysis which supports both. Coordination of the DCRDR and upgrade of the EOPs which begins with the generic emergency response guidelines developed by the owners groups is also possible. The result of coordinating the DCRDR with upgrade of the EOPs should be a control room which supports complete and technically adequate EOPs.

'Ihere are two aspects to coordination of the DCRDR with training. One is the use of training to resolve HEDs. The~ other is to familiarize operators with control room modifications and enhancement which may be fairly extensive. The result should be operators who are thoroughly familiar with their revised control room interface and who have the specific knowledge necessary to deal with HEDs which are appropriately resolved by training.

2.8.2 Discussion

'Ihe staff's September 5,1986 SE indicated cone'ern about whether the required coordination of control room improvements was following a formal plan. NPPD responded to that concern in the February 27,1986 SSR by providing detailed information on the coordination activities. During preimplementation audit discussions, NPPD 860504:10/6/86

O e indicated that representatives from all the NUREG-0737 programs meet formally once a month to ensure the proper interaction and coordination of these programs. Dere is also a less formal daily interaction which further enhances the NPPD coordination activity.

NPPD's process for coordination was generally acceptable. However, the preimplementation audit team did identify two concerns involving coordination with -

. training. NPPD should assure verification of training resolutions for HEDs and scheduling of initial and requalification training. NPPD should also develop an improved plan for training the operators about the control room modifications resulting from the DCRDR. That plan should specifically address the need to identify and mitigate possible negative transfer of training.

2.8.3 Conclusions ne NPPD coordination process is generally adequate. Bowever, some enhanced

% coordination with training appears necessary.

2.9 OPERATING EXPERIENCE REVIEW .

Although it is not a DCRDR requirement, NPPD has conducted a review of LERs and Scram Reports. It was suggested to NPPD in the TER 11 that the operating experience review (OER) be extended to include experience at other BWRs similar to Cooper. NPPD committed to do this review in February 27,1986 SSR. However, the review was not complete at the time of the preimplementation audit.

2.10 SUMM ARY REPORT 2.10.1 Criteria A Summary Report is to be submitted at the end of the DCRDR. Supplement I to NUREG-0737 require.s that, as a minimum, the Summary Report shall:

1. Outline proposed 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.

Contrcl room changes should cont oute to a significant reduction of risk and to enhanced safety of operation. Long term risk reduction should be considered as should the potential for temporary declines in safety due to the.need for relearning following control room changes. Means to combat temporary declines should be included as part of the implementation plan.

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2.10.2 Discussion NPPD has submitted a Summary Report and a Supplemental Summary Report for the Cooper DCRDR. Those documents generally satisfy the requirements above. 'Ihere were, however, several concerns identified during the preimplementation audit. One concern involved reporting of the required information for DCRDR activities which are -

incomplete. . A second concern involved responses to several individual HEDs. A final +

concern involved the schedule for implementation of several control room changes.  :

Based on discussion during the preimplementation audit, we expect a January 31,1987 l SSR to:

1. Report the results of the task analysis enhancement / comparison of display and control requirements with a control room inventory.

% 2. Report.the results of the survey of operators' abilities to communicate in SCBA and respirators.

3. Report the status of a PMIS/SPDS survey against accepted human engineerir.g guidelines and provide a schedule for its completion (including a report of results).

, 4. Report the status of selection of design improvements for the annunciator system and provide a schedule for its completion (including a report of results).

5. Resportd to concernsrelated to DCRDR coordination with training as described in 2.8 above.

' 6. Report the status of the operating experience review and provide a schedule for its completion (including a report of results).

We recommend that, in cases where status information is required, NPPD provide results i instead, if at all possible. Provision of final results, through selection and verification of design improvements, will facilitate completion of the DCRDR evaluation.

'Ihe preimplementation audit team identified concerns related to correction of several HEDs. Based on discussions during the preimplementation audit, we expect a January 31,1987 SSR to provide more information about correction of HEDs identified in Appendix B of this TER.

'Ihe preimplementation audit team was concerned with the schedule for implementing two specific control room modifications. The first modification was upgrades of emergency lighting which is currently scheduled for 1989. In our judgment, NPPD should accelerate implementation of the emergency lighting upgrade if at all possible. - The second modification was annunciator system prioritization. 'Ihat modification is currently scheduled to span several refueling outages, In our judgment, the annunciator

prioritization modification would best be accomplished all at once (i.e., during a single refueling outage). Other modifications to the annunciator system have yet to be determined. 'Ihus, the need for annunciator system prioritization might most reasonably be considered as part of the larger annunciator system upgrade / enhancement effort 1

_11 860504:10/6/86

c within the DCRDR. We expect a January 31,1987 SSR to provide NPPD's response to the above schedule concerns.

2.10.3 Conclusions ne Summary Report requirement have not been fully satisfied. NPPD should submit the .

results described above.

3. CONCLUSIONS The DCRDR for Cooper Nuclear Station is incomplete. In LLNL's judgment, completion of several activities is essential for satisfaction of the DCRDR requirements in Supplement I to NUREG-0737. Those activities are:

1. Function and task analyses.

a. Complete task analysis related to other procedures implicitly referenced in the EOPs that are required to support the EOPs (e.g., entry / exit points).

b. Complete the FTA for the ASP and station blackout procedures.

c. Complete task analysis related to existing emergency procedures still in use after implementation of the upgraded EOPs.

d. Complete task analysis related to EOPs which may be revised prior to implementation.

2. Comparison of display and control requirements with a Control Room Inventory.

a. Compare new or modified display and control requirements, identified by

. // the enhanced FTA, with the control room inventory.

3. Control rmm survey.

a. Survey operators' abilities to communicate while wearing SCBA and respirators.

b. Survey the SPDS/PMIS against accepted human engineering guidelines..

The survey should be used to assure reasonable consistency of the systems with other control room conventions.

4. Assessment of HEDs.

a. Subject HEDs identified by ongoing DCRDR ' activities (1-3 above) to the same assessment process as all previous. HEDs.

5. Selection of design improvements.

a. Upgrade control room design standards.

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b. Select design improvements for HEDs identified by ongoing DCRDR activities (above),

c. Select design improvements for annunciator system HEDs.

6. Verification that HEDs are corrected and that new HEDs are not introduced. -

a. Perform preimplementation verification activities for improvements selected to correct HEDs identified by ongoir:g DCRDR activities (S above).

b. Perform proposed postimplementation verification activities during startup following HED correction.

7. Coordination with improvements from other programs.

s. Erisure adequate operator training related to control room modifications resulting from the.DCRDR. ,

b. Verify the training resolutions for HEDs actually correct the HED without

. introducing new HEDs.

c. Schedule initial and requalification training for ~ HED resolution as appropriate.

8. Other Activities

a. Complete.the OER.

In ' addition to completion of the above activities, NPPD should keep on auditable record of all activities necessary to complete the DCRDR. NPPD should also report DCRDR status and results as described in paragraph 2.10.2 above.

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4. REFERENCES

1. NUREG-0660, "NRC Action Plan Developed as a Result of the .TMI-2 Accident,"

May 1980, Rev.1, August,1980.

2. NUREG-0737, Supplement 1, " Clarification of TMI Action Plan Requirements-Requirements for Emergency Response Capability (Generic Letter 82-33)," .

December 17,1982.

3. " Response to NUREG-0737, Supplement 1, Emergency Response Capability,

~

Cooper Nuclear Station," letter from J. M. Pilant (NPPD) to D. G. Eisenhut (NRC), dated April 15,1983.

4. " Program Plan for Detail +. Control Room Design Review, Nebraska Public Power District, Cooper Statio: *

. dated February 1984, submitted by letter from J. M. Pilant (NPPD) to D. . . Eisenhut (NRC) dated March 1,1984.

S. NUREG-0700, " Guidelines 1or Control Room Design Review," September 1981.

6. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 18.1," Evaluation Criteria for Detailed Control*

Room Design Revie'ws (DCRDR)," September 1984.

7. "NRC Staff Review of the BWR Owners' Group (BWROG) Control Room Survey Program (Generic Letter 85-18)," letter from D. G. Eisenhut (NRC) to BWR Licenses, Applications, and Construction Permit Holders, dated April 19,1983.

8. " Review of.the Cooper Nuclear Station Detailed Control Room Design Review Program Plan Submittal," letter from D. B. Vassallo (NRC) to J. M. Pilant (NPPD) dated June 4,1984.

9. " Detailed Control Room Design Review In-Progress. Audit Report," (Ref audit conducted Novemoer 17-29, 1984), letter from D. B. Vassallo (NRC) to J. M. Pilant (NPPD) dated March 20,1985.

10. "NUREG-0737, Supplement 1-Detailed Control Room Design Review (DCRDR)-

Summary Report," letter from J. M. Pilant (NPPD) to D. B. Vassallo (NRC) dated February 4,1985.

I 1. " Technical' Evaluation Report (TER) Detailed Control Room Design Review, Nebraska Public Power District, Cooper Nuclear Station," Lawrence Livermore National Laboratory, March 26,2985.

12. " Detailed Control Room Design Review (DCRDR)-Evaluation of Summary Report," letter and attachment from D. B. Vassallo (NRC) to J. M. Pilant (NPPD) dated September 5,1985.

13. "fupplement to the Summary Report," (SSR) Detailed Control Room Design Review, Nebraska Public Power D! strict, Cooper Nuclear Station.

14. " Human Engineering Guide for Enhancing Nuclear Control Room," EPRI Report No. EPRI NP-2411, dated May 1982.

15 " Human Factors Methods for Nuclear Control Room Design," EPRI Report No. EPRI NP-lll8-SY, dated November 1979.

16. " Human Factors Guid[ for Nuclear Power Plant Control Room Development,"

Electric Power Researdh Institute, Report No. EPRI-NP-365, dated August 1984.

o, ~. .,

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,  ?

5. APPENDIX A Concerns related to " Cooper Nuclear Station. Control Room Human Factors Engineering Standards and Implementation Guidelines" and their application.

1. All control types (push buttons, switch handles, etc.) should be checked for -

consistency with the above standards. NPPD should determine whether those.

controls currently not covered by the standard should be modified or replaced to be consistent with the standard. The standard should then be updated to encompass all control types remaining in use.

2. Several techniques were found to be used for guiding operators through a sequence of control actions (e.g., manual operation of relief valves). NPPD should determine whether a single technique is applicable / preferable. If such is the case, it should be implemented in the control room and added to the standards,

3. Escutcheon plates (terminology, letter size, color, etc.,) should be addressed by the standard.

4. NPPD should assure as much consistency as reasonably possible between control room standards and PMIS/SPDS standards. A single comprehensive standard addressing both the control room and PMIS/SPDS interfaces with the operator

] (including allowable differences) is desirable.

5. White or red labels are to be used for "Significant Components," "Special Instructions," and " Resets." NPPD should determine whether all resets warrant "high priority" (i.e., white or red) labels. If so, implement the control room modification and standard as planned. Otherwise, modify the control room

] modification package and standard appropriately.

6. NPPD should determine whether system labels ~should be made consistent with other control room labels.

7. Lists of standard abbreviations and process units are included in the standard.

Standard nomenclature is not addressed by the standard (e.g., standard use of the terms torus, suppression pool, and suppression chamber). NPPD should assure that '

components, parameters, etc., are consistently identified by the same name throughout the control room, alternate shutdown facilities, in the EOPs, and in the PMIS/SPDS. One approach to accomplishing this standardization would be to upgrade the standard.

8. Symbols to be used in mimics and elsewhere on the control boards should be included in the standard.

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6. APPENDIX B Concerns related to the correction of certain HEDs.

173SS Discussions during the preimplementation audit indicated that the commitment in the February 27,1986 SSR would not be fully satisfied. If that commitment .

will not be satisfied, a' modified commitment and justification is required.

89SS A modified response indicating a procedure for control of operator aids is needed.

Il6S Discussion during the preimplementation audh indicated that this HED may have resulted from an invalid observation. If so, a modified response indicating that fact may be appropriate.

., 26T Discussions during the preimplementation audit indicated that EOPs referred to Class IE instrumentation for 'information related to suppression pool load limits. The February 27,1986 SSR indicates the SPDS will be used. NPPD should clarify its response to indicate the use of Class IE instrumentation. -

186SS Discussions during the preimplementation audit indicated that some items NPPD has committed to move may not be moved. If plans for correcting this HED have changed, NPPD should provide a modified commitment with justification.

349SS Labeling is to be used to associate certain controls with feedback.information.

'Ihe exact form of the labeling correction was not available during the preimplementation audit. NPPD should provide a detailed description of the proposed correction.

IIS A mod'ified response indicating that panel layout will be revised is needed.

10SS A modified implementation schedule is needed.

lli '"'A label is to be revised for the RHR 2/3 Core Height Level Manual Override Switch. 'Ihe information to be provided on the revised label was not available during the preimplementation audit. NPPD should provide a description of the label.

SSS One controller with a "close right-open left" arrangement is being removed from the control room. NPPD should indicate how many other controllers of this type l are in the Cooper control room and how they will be addressed by the DCRDR.

l l 10I NPPD's February 27,1986 SSR indicated the need for further review to select a

[ design improvement for this HED. NPPD should provide the results of that review.

36SS NPPD needs to identify the final resolution of this HED.

54SS No resolution or justification for not resolving this HED has been provided.

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• • e 29T NPPD should determine whether their proposed resolution satisfactorily corrects this HED. In the audit team's judgment, the operator is placed in a long-term monitoring situation by the conditions which led to identificatior. of the HED.

1he proposed resolution is unlikely to aid the operator in such a situation.

h a

D a

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