ML20245D668

Dcrdr Preimplementation Audit Rept for Philadelphia Electric Co Peach Bottom Station,Units 2 & 3

ML20245D668
Person / Time
Site:	Peach Bottom
Issue date:	09/14/1988
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20244E030	List: ML20244E027 ML20245D668 ML20245D791
References
CON-NRC-03-82-096, CON-NRC-3-82-96 SAIC-88-1816, TAC-56149, TAC-56150, NUDOCS 8809230090
Download: ML20245D668 (14)

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SAIC-88/1816 DETAILED CONTROL ROOM DESIGH REVIEW PRE-IMPLEMENTATION AUDIT REPORT FOR PHILADELPHIA ELECTRIC COMPANY'S PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 TAC Nos. 56149 and 56150 September 14, 1988 SAIC m u * = w cc, par san Submitted to: i U.S. Nuclear Regulatory Conslission Washington, D.C. 20555 l- Contract NRC-03-82-096 Task Order No. 19 l

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y TABLE OF CONTENTS Section Eggg INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . .-. . . I NRC POSITION . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 DISCUSSION . . . . . . . -..................... .

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1. Establishment of a Qualified Multidisci Team ... . . . . . . . . . . . . . . . plinary Review

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2. Function and Task Analysis . . . . . . . . ... . . . . . 4

3. Comparison of Display and Control Requirements With a Control _ Room Inventory . . . . . . . . . . . . . . . . . 5 1

4. A Contro1' Room Survey to Identify Deviations From Accepted Human Factors Principles. . . . . . . . . . . . -6

5. Assessment of HEDs to Determine Which Are Significant and Should.Be Corrected. . . . . . . . . . . . . . . . . . . 6

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

7. Verification That Selected Improvements Will Provide the Necessary Correction and Verification That Improvements Will 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 Emer Procedures (EOP) . . . . . . . . .gency Operating

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9. Other. . . . . . . . . . . . . . . . . . . . . . . . . . 8 CONCLUSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 GUIDANCE TO LICENSEE . . . . . . . . . . . . . . . . . . . . . . . 10 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Attachment 1 -

Audit Plan Attachment 2 -

List of Meeting Attendees ,

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TRIP Procedure Revision Schedule j

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, ,s DETAILED CONTROL ROOM DESIGN REVIEW PRE-IMPLEMENTATION AUDIT REPORT i

FOR PHILADELPHIA ELECTRIC COMPANY'S PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 INTRODUCTION l

This report documents the findings of the Nuclear Regulatory Commission (NRC) audit team during the pre-implementation audit of the Detailed Control Room Design Review (DCRDR) for Philadelphia Electric Company's (PEco's)

Peach Bottom Atomic Power Station, Units 2 and 3. The DCRDR audit was conducted on July 14 and July 15, 1986. The NRC audit team consisted of a '

representative from the NRC Electric Instrumentation and Control Systems Branch (EICSB); a consultant from Science Applications International Corpo- '

ration (SAIC); and a representative from Comex Corporation, a subcontractor to SAIC. The audit was conducted on-site at the Peach Bottom Atomic Power Station and at PEco's control room mock-up facility in Philadelphia, Penn-sylvania. This report was prepared by SAIC, but is intended to reflect the consolidated observations, conclusions and recommendations of the NRC audit team members. An outline of the audit plan and a list of audit attendees are included in Attachments 1 and 2 to this report.

NRC POSITION Item I.D.1, " Control Room Design Reviews," of Section I.D., " Control Room Design," of the NRC Action Plan, NUREG-0660 (Reference 1), developed as a result of the TMI-2 accident, states that the operating licensees and l applicants for licenses will be required to perform a Detailed Control Room Design Review (DCRDR) to identify and correct design discrepancies. Supple-  !

ment 1 to NUREG-0737 (Reference 2), dated December 17, 1982, confirmed and clarified the DCRDR requirement in NUREG-0660. As a result of Supplement 1 tc NUREG-0737, each applicant and licensee is required to conduct its DCRDR on a schedule negotiated with the NRC.

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NUREG-0700 (Reference 3) describes four phases of the DCRDR to be performed by the applicant and licensee. The phases are:

1. Planning

2. Review

3. Assessment and implementation j

4. Reporting.

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NUREG-0800 (Standard Review Plan), Revision 0, Section 18.1 (Reference 4) provides the necessary review guidelines for evaluating each phase.

As a requirement of Supplement I to NUREG-0737, the applicants and licensees are required to submit a Program Plan that describes how the following elements will be accomplished: '

1. Establishment of a qualified multidisciplinary review team.

2. Function and task analysis to identify control room operator tasks and information and control requirements during emergency operations.

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

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

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

6. Selection of design improvements.

7. Verification that selected design improvements will provide the necessary correction, and will not introduce new HEDs.

8. Coordination of control room improvements with changes from other programs such as safety parameter display system (SPDS), operator training, Reg. Guide 1.97 instrumentation, and upgrade of emergency operating procedures (EOPs).

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~ .. s The NRC requires each applicant and licensee to submit a Summary Report at the end of the DCRDR. The report should describe proposed control room cnanges and implementation schedules, and provide justification for leaving  ;

safety-significant HEDs uncorrected or partially corracted. '

DISCUSSION PEco submitted the DCRDR Program Dlan (Reference 5) for Peach Bottom  !

Atomic Power Station Units 2 and 3, by letter dated October 31, 1983. The NRC's "Respnse to Peach Bottom Program Plan Submittal" (Reference 6), dated December 2, 1983, was forwarded to PEco.

Peach Bottom Units 2 and 3 were selected by the staff for an in-progress audit of the DCRDR. An in-progress audit plan (Reference 7) was sent from the NRC to PEco by letter dated December 27, 1984. The audit plan defined the main elements of the in-progress audit of the Peach Bottom Units j 2 and 3 DCRDR. The audit plan also defined the appropriate elements of  !

Supplement I to NUREG-0737 which would be used by the NRC audit team to evaluate the licensee's review activities.

The purpose of the audit was to check the Peach Bottom Units 2 and 3 DCRDR compliance with the requirements of Supplement I to NUREG-0737. The efforts of the audit team were directed at an evaluation of the content and l products of the DCRDR rather than the form of the process. The form of the DCRDR process was evaluated by the NRC's Human Factors Engineering Branch (HFEB) during the Peach Bottom Units 2 and 3 Program Plan review (Reference

6) and was found acceptable.

During the in-progress audit, PECo was informed that the NRC audit team was interested in otiserving a validation walk-through on the mock-up when the DCRDR reached that stage. Findings from the one-day audit of validation walk-through activities were transmitted to PEco by letter dated December 17, 1985 (Reference S).

PECo submitted the DCRDR Sumary Report to the NRC by . letter February 28, 1986 (Reference 9). The Summary Report was evaluated by SAIC who sub-mitted a DCRDR Technical Evaluation Report to the NRC on June 23, 1986 l (Reference 10). The SAIC evaluation of the Summary Report resulted in the identification of several issues that needed to be resolved prior to the

,_ closeout of the Peach Bottom DCRDR.

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3 , k As a result of the Summary Report evaluation, SAIC con:1uded that PECo met six of the nine DCRDR requirements of Supplement 1 to NUREG-0737. The pre-implementation audit team concentrated on evaluating the three i Supplement I to NUREG-0737 requirements that had not been satisfied by the Summary Report and earlier meetings. The consnents which follow contain j audit findings and previous review conclusions regarding all nine DCRDR I requirements identified in Supplement I to NUREG-0737.

1. Establishment of a Oualified Multidisciolinary Review Team j

Based on the in-progress audit arid DCRDR Summary Report review, it is SAIC's judgment that PECo meets this Supplemeat 1 to NUREG-0737 requirement. i

2. Function and Task Analysis The DCRDR task analysis of all eleven emergency operating procedures, as defined by Revision 2 of the Boiling Water Reactor Owners Group (BWROG) generic emergency procedures guidelines (EPGs) was performed. However, Revision 3 to the EPGs, including the procedure for secondary containment control and radioactivity control were not included in the function and task analysis. PEco did not include them because they were not implemented at Peach Bottom at the time of the DCRDR.

The NRC requires that all licensees include the Revision 3 EPGs in the DCRDR. Item 1 of the pre-implementation audit required that PEco discuss plans and schedules for completing the function and task analysis for the l- secondary containment control and radioactivity control procedures based on '

the BWROG Revision 3 EPGs. The site staff engineer responsible for Revision l 3 procedure development attempted to describe how the plant was responding.

A schedule was introduced (Attachment 3) which shows the start date to begin the revision of the plant EPGs, called Transient Response Implementa-tion Procedures (TRIP), to incorporate Revision 3 as of July 14, 1986. It became apparent, however, that the responsibility for Revision 3 did not reside with the DCRDR team, which had been managed by PECo headquarters personnel. The plant team's intentions ware to revise the TRIP procedures and then validate them. It did not plan to use the DCRDR mock-up for this purpose. It was apparent that the plant team had confused the function and task analysis DCRDR methodology with this validation procedure, j

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In practice, the implementation of Revision 3 was being accomplished

. utilizing standard plant procedures which had been in place prior to~ the-DCRDR and which have not been revised to incorporate DCRDR methodology.

Representatives of the original DCRDR review team who attended the audit i stated ti,at all data and forms used in the original DCRDR had been provided to.the plant team. However, it was apparent that there had been a "discon-l nect" in the transfer of information concerning the need- to accomplish {

Revision 3 within the DCRDR groundrules, and to incorporate. the DCRDR' l methodology . generally into future revisions to the control room equipment and procedures.

As illustrated in Attachment 3, General Physics Corporation has been contracted by the. Peach Bottom plant staff to develop the . Revision 3 procedures and to train plant personnel on the use of the new procedures.

At the time of the pre-implementation audit, General Physics had not been assigned the responsibility of performing a task analysis which 'would be consistent with the DCRDR task analysis. The plant personnel did, however, make a verbal commitment to ask General Physics to do a task analysis on the Revision 3 procedures which is consistent with the task analysis performed-during the DCRDR.

In conclusion, PEco needs to perform the following tasks before this requirement will be judged complete. First, PEco needs to develop a method-ology which ensures that the Revision 3 procedures now being developed by '

General Physics are developed consistently with the DCRDR task analysis.

Second, PECo needs to perform a task analysis of the new Revision 3 procedures and make sample task analysis worksheets available for auditing.

3. Comoarison of Display and Control Requirements With a Control Room Inventory Item 2 on the agenda, stans and schedules for completing a control room inventory based on identification of new operator tasks and control requirements from the Revision 3 function and task analysis was discussed with plant personnel. The plant team's instruction to General Physics, which is in the process of develeping the Revision 3 procedures, is to make the Revision 3 TRIP procedures correspond to the existing control room instrumentation, as opposed to the DCRDR methodology of using the function and task analysis to determine what is required and then using the inventory I to determine whether what is required is installed. There was no indication 5

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- that . the basic idea of. making the procedures' fit the existing control ' room 'j will be' altered.: lIf the procedures are found not to- fit the existing d

. instruments during. validation, then the procedures will be. conservatively changed to fit the' existing plant'.

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.The validation of the Revision 3 procedures will be done by the plant.'

personnel ~and General Physics Corporation personnel using ' Administrative p Procedure. A-94. Procedure A-94 has not been updated to coordinate it.with l- the DCRDR. processes. . i l

In conclusion, the methodologies being used by plant personnel and f General Physics Corporation' personnel to develop the Revision 3~ procedures L

i ere inconsistent with DCRDR processes used to determine the availability and suitability of instrumentation. .l This supplement to NUREG-0737 requirement 1 cannot be closed until the licensee provides NRC with evidence -that the Revision 3 procedures have been subjected to an activity which.is consistent I with'the DCRDR inventory.

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4. A Control Room Survey to Identify Deviations From Accented Human Factors Principles i

Based on the in-progress audit and DCRDR Summary Report review, it is

'SAIC's judgment that PEco meets this Supplement I to NUREG-0737 requirement.

5. . Assessment of HEDs to Determine Which Are Significant and Should Be D Corrected Based on the in-progress audit and DCRDR Summary Report review, it is.

SAIC's judgment that PECo meets this Supplement I to NUREG-0737 requirement.

6. Selection of Desian Improvements

. Based on the in-progress audit review, DCRDR Summary Report review, and pre-implementation audit review of the mocked up design improvements, it is SAIC's judgment that PECo meets this Supplement I to NUREG-0737 requirement.

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7. : Verification That Selected Innrov== ants Will Provide the' Necessary

' Correction and Verification That Improvements Will Not Introduce New a Uf.01 L -

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3 Based on the in-progress audit'and DCRDR Summary Report review, . it is SAIC's judgment that PEco meets this Supplement 1.to NUREG-0737 requirement.

, 8. Coordination' of Control Room improvements With Chances From' Other

' Proarams -Such as the Safetv Parameter Disolav System (SPDS). Operator:

IDinina. Rea. Guide 1.97 Instrumentation. and Unaraded Emeraency 09eratina Procedures'(EOPs)

The licensee. commented on agenda item 3 whf,h is the plan- used to coordinate control room improvements with other Supplement I to NUREG-0737.

initiatives. The coordination described was the validation step used in the DCRDR which utilized. upgraded E0Ps on the enhanced mock-up containing the contemplated control room changes. These changes included the " interim" SPDS and the Reg. Guide 1.97 instruments with enhancements (yellow stripes on -instruments). As bids have not yet been received on the new plant process computer system, which will include the. SPDS, a. method' of coordinating it with the other initiatives has not been devised.

At. the present time there is no simulator for Peach Bottom. Operators are trained on the Limerick simulator. Singer-Link, through General Physics Corporation has been awarded the simulator centract and = installation is to

be completed in 1988. The simulator will be designed to reflect the modifications made to the control room as a result of the DCRra. Use of the simulator. as a validation and coordination tool may be possible,- but-scheduling of . the control room DCRDR modifications for the two units in conjunction with tiie' installation of the simulator (with DCRDR changes incorporated) makes this difficult.

Operator trainirig requirements for each DCRDR-related modification are identified on the lied forms. Training is currently handled under the modification package procedures.

It'is the audit team's judgment that the interin SPDS, operator train-ing, Reg. Guide 1.97, the upgraded E0Ps and the simulator are being appro-priately coordinated with the DCRDR. However, in order to ensure that the PEco meets this Supplement I to NUREG-0737 requirement, PEco should provide 7

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a description of how the installation of the new SPDS will be coordinated with other initiatives.

9. Other Proposed Schedules for Implementing Corrective Actions The PEco personnel described their classification of HEDs methodology in answering agenda item 4 concerning plans and commitments for correcting HEDs and asking for assurance that priority 1 HEDs and labeling and enhancement corrections will be implemented prior to the startup following the next refueling outage. This classification procedure resulted in only j priority I and 2 HEDs being scheduled for accomplishment. Most of the corrections are to be accomplished through enhancements, e.g., color l padding, hierarchical labeling, mimicking, etc., although some meters will be moved.

Only the remote shutdown panels are scheduled for accomplishment during k the next refueling outage. The rationale was that these are so seldom >

utilized that the operators are most unfamiliar with them, and therefore their correction is of prime safety significance. As unit 3 will undergo an extended outage next time, the audit team expressed some concern that more work would not be done. The extensive work package planned was offered as an explanation for the delay. The answer provided for not doing paint,  !

tape, and label changes during the next outage was that as most changes are enhancements, it is best to do it all at once and do it correctly the first ;

time.

Human Factors in Future Modification to the Control Room Discussions with PECo indicated that it did not have a formal method-ology for ensuring the human factors will be consistently integrated into future contrcl room modifications. The licensee was requested to supply a copy of a proposed new instruction which will show how human factors con-siderations and other DCRDR methodologies will be implemented when making future changes in the control room.

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CONCLUSIONS t The DCRDR pre-implementation audit team conclusion was similar to that

" reached earlier;. PEco meetsfive of the eight Supplement I to NUREG-0737 DCRDR requirements. Those requirements fulfiTied and those needing further resolution are repeated below.

1; The licensee estaD11shed a qualified multidisciplinary review' team- !

which meets the Supplement I to NUREG-0737 requirement.

2. With regard to the function and task analysis requirement, PEco

, has not completed an analysis of the BWROG Revision 3 upgraded E0Ps which is consistent with the DCRDR. .

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3. With regard to control room inventory, PEco has not compared the BWROG Revision 3 upgraded E0P task requirements with the control room inventory.

4. The licensee has performed a control room survey which meeta the requirement of Supplement I to NUREG-07.97.

5. The licensee'has performed an assessment of HEDs which meets the requirement of Supplement I to NUREG-0737.

6. The licensee has selected design improvements which meet the requirement of Supplement I to NUREG-0737.

7. The licensee has performed a verification that the selected design improvements previde the necessary corrections and will not introduce 'new HEDs. This meets the Supplement I to. NUREG-0737

. requirement.

8. With regard to the coordination of control room improvements with changes, the audit team concluded that the interim SPDS, operator training, Reg. Guide 1.97 instrumentation, upgraded E0Ps and the new control room simulator are being appropriately coordinated with the DCRDR. However, the licensee has not developed a formal process for coordinating the new SPDS and future control room j modifications with the DCRDR.

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GUIDANCE TO LICENSEE The NRC ~ audit team leader 'nformed PEco that a Sup::emental Summary ,

Report submittal would be needed tu close out the Peach Bottom Supplement 1 l After further consideration, the audit to NUREG-0737 DCRDR requirement.

team believes that these issues could be better resolved "on line" during a meeting between the NRC and PEco in Bethesda. The minutes of this meeting could serve as documentation of issue resolution. In either case, PECo will  ;

need to resolve the following items in its supplemental submittal, or during i a meeting, in order to close out the Peach Bottom DCRDR.

1. The licensee must adequately explain the manner in which DCRDR methodology will be utilized when' Revision 3 TRIP procedure changes are incorporated in accordance with requirement 2.

2. PEco must illustrate how the checklists similar to those used in the DCRDR which will be utilized by General Physics when preparing the TRIP procedures in accordance with requirement 3.-

3. PEco must show how the design and installation of the SPDS will be coordinated with other NUREG-0737 Supplement 1 initiatives in  !

accordance with requirement 8.  !

4. A copy of the new instruction being prepared which will show how human factors considerations and other DCRDR methodologies will be implemented when making future changes in the control room.

i A list of the above items has oeen forwarded to the licensee by the NRC project manager.

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REFERENCES

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

2. Supplement I to NUREG-0737, " Requirements for Emergency Response'Capa- j bility" (Generic 1.etter No. 82-33), U.S. Nuclear Regulatory Commission, I December 1982.

3. NUREG-0700, " Guidelines for Control Room Design Reviews," U.S. Nuclear.

Regulatory Commission, September 1981.

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4. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis ,

Reports for Nuclear Power Plants," Section 18.1, September 1984. l

5. Detailed Control Room Design Review Program Plan for Philadelphia Electric Company's Peach Bottom Atomic Power Station. Docket Nos. 50-277 and 50-278, Philadelphia Electric Company, October 31, 1983.

6. " Response to Peach 80ttom Program Plan Submittal ," U.S. Nuclear i Regulatory Commission, December 2,1983.

7. "Results of NRC's In-Progress Audit of Peach Bottom Atomic Power Station, Units 2 and 3 Detailed Control Room Design Review," U.S.

Nuclear Regulatory Commission, April 16, 1985.

8. " Final DCRDR Validation Walk-Through Audit Results for Philadelphia

' Electric Company's Peach Bottom Atomic Power Station, Units 2 and 3," i U.S. Nuclear Regulatory Commission, December 17, 1985.

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9. " Philadelphia Electric Company's Peach Bottom Atomic Power Station Control Room Design Review Final Report," Philadelphia Electric Company, February 28, 1986.

10. Technical Evaluation Report of the Detailed Control Room Design Review for Philadelphia Electric Company's Peach Bottom Atomic Power Station, Units 2 and 3, Science Applications International Corporation, June 23, u 1986.

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ATTACHMENT 1 i i

1 AUDIT PLAN 1 1

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