ML22077A401

NEI INL Presentation March 23, 2022, NRC Workshop Isv Hfe Issue

ML22077A401
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/23/2022
From:	Nuclear Energy Institute
To:	NRC/NRR/DORL/LPL4
Jain B, NRR/DORL/LPL4, 301-415-6303
References
Download: ML22077A401 (16)

Text

NRC Workshop ISV HFE Issue March 23, 2022

©2022 Nuclear Energy Institute

Background - NRC IAP MP4a Meetings

• NEI members acknowledge that there was limited MCR modernization discussion during NRC Integrated Action Plan MP4a meetings which resulted in the Alternate Review Process published in DI&C-ISG-06, Rev. 2

• NEI members did not consider significant changes to the HSI of safety system digital controls upgrades

• NEI members recognize to improve NPP safety and reliability, MCR modernization is needed

• Key industry objective for MP4a new licensing process discussions was earlier License Amendment issuance to support reduced project risk

• NEI members are hoping for a path forward, which continues to allow industry to perform safety-related digital control system upgrades with MCR modernization, with the early license amendment issuance

©2022 Nuclear Energy Institute 2

Background - Alternate Review Process (ARP)

• Utilizing the Alternate Review Process, the licensee submits digital I&C design information earlier in project lifecycle

• Recognizes LAR includes an NRC approved software lifecycle process or information provided in the LAR describes lifecycle activities

• ARP pilot LAR relied on Vendor Oversight Plan (VOP) and regulatory commitment for later lifecycle activities

• Same process for potential I&C design changes post-License amendment approval apply to HFE design changes - 10 CFR 50.59 process applies

• Recognize that NRC plans to use NUREG-0711 for review of human factors engineering (HFE) information included in LAR

• NEI members believe the underlying regulation is 10 CFR 50.9, Completeness and accuracy of information

• NEI members propose to include LAR content (e.g., Implementation Plans or Results Summary Reports or similar content) addressing early project lifecycle HFE activities (per EPRI Digital Engineering Guide):

• Operating Experience

• Functional Analysis and Allocation

• Task Analysis

• Staffing & Qualifications

• For later HFE lifecycle activities, LAR will describe process for completion

©2022 Nuclear Energy Institute 3

Integrated System Validation (ISV)

• NEI members concerned that the Multi-Stage Validation (MSV) approach offered by NRC does not have precedent or clear guidance/acceptance criteria

• One option for consideration: Since Integrated System Validation (ISV) is a critical activity, LAR could include a license condition that ISV will be conducted in accordance with the LAR

• NEI members understand that the NRC safety determination cannot depend on a license conditions closure; therefore LAR could be approved prior to ISV completion

• Strategy for addressing NUREG-0711 Verification & Validation (V&V) element will be included in the LAR

• Licensee will keep NRC apprised of ongoing activity schedule (e.g., task or design verification, use of glasstop simulator) to allow for potential audit/inspection

• NEI members request NRC make their safety determination for ARP LARs based on:

• Early HFE activity IPs/RSRs (e.g., Operating Experience, Task Analysis) and

• A HFE program plan, based on INL research (slides to follow) which describes the later HFE activities assuring a successful ISV

©2022 Nuclear Energy Institute 4

HFE LAR Strategy

• LAR (per 10 CFR 50.9) would include:

• Early HFE activity IPs/RSRs (e.g., Operating Experience, Task Analysis)

• HFE program plan, based on INL research, describing the later HFE activities assuring a successful ISV

• License Condition to perform the ISV in accordance with the LAR

• Note that the ISV IP will be available for audit prior to ISV execution

• Perform the ISV to close the License Condition

• Note that the V&V Results Summary Report will be available for inspection

©2022 Nuclear Energy Institute 5

INL/MIS-22-66428 Human Factors Engineering in Support of Control Room Modernization Jeffrey C. Joe & Ronald L. Boring Human Factors and Reliability Department Idaho National Laboratory 1

U.S. Department of Energy Light Water Reactor Sustainability (LWRS) Program Goal Enhance the safe, efficient, and economical performance of our nation's nuclear fleet and extend the operating lifetimes of this reliable source of electricity Objectives

• Enable long-term operation of existing nuclear power plants

• Deploy innovative approaches to improve economics of light water reactors in the near-term and in future energy markets

• Sustain safety, enhance economics, enable revenue diversification 2

LWRS Plant Modernization Pathway LWRS Program researchers conduct Human Factors R&D on control room modernization to:

• Ensure modernization activities are:

o Technically sound o Regulatory compliant o Safety focused

• Develop principles and create state-of-the-art guidance on control room modernization

• Collaborate with industry (owners, operators, suppliers)

• Disseminate lessons learned to benefit industry and the regulator 3

History of Activities Opportunity to address technological obsolescence issues in the control room

• Digital technologies present chance to improve human factors of control room designs Industry expressed need for human factors support for modernization

• Guidance on conforming to NUREG-0711

• Experience on how to incorporate human factors in design

• Development of a flexible simulator for design engineering 4

Example of Meeting NUREG-0711 Requirements Created process to support iterative design evaluations that align with NUREG-0711 phases

• Evaluations conducted early (formatively) build support for later (summative) integrated system NUREG-0711, Rev. 3 validation Boring, Joe, et al. (2015) 5

Examples of HFE Activities NUREG-0711, Rev. 3 3D Modeling Tabletop reviews of the HSI Operator-in-the-Loop Studies 6

HFE Activities Crosswalk NUREG-0711 Elements in Black New HFE R&D Activities in Blue Activity Supports HFE Program Management Inserts HFE into overall Engineering process, establishes new end state vision, establishes HFE role as an integrator Operational Experience Review Capturing Lessons Learned and HFE design requirements for the new I&C system Ergonomic Analyses of Control Room Layout and 3D Early (Formative) input into placement of new I&C Modeling indications and controls Function Analysis & Allocation, Task Analysis, Staffing & Early (Formative) analyses to support design and eventual Qualification, Treatment of Important Human Actions installation of new I&C systems Development of Initial Prototype Human System Interfaces Early input into HSI design (HSIs)

Static and Dynamic workshops (at INL HSSL) Iterative evaluations of the I&C system with a focus on its design and indications and controls (i.e., HSIs)

Procedure Development, Training Program Development HFE and human systems integration-based analyses to evaluate the potential changes to the concept and conduct of operations HSI Inventory and Characterization, HSI Task Support Verification & Validation Verification, HFE Design Verification (i.e., Design Verification)

Integrated System Validation Verification & Validation Design Implementation and Human Performance Monitoring Implementation and Operation 7

HFE R&D for Control Room Modernization

• The LWRS Programs R&D collaborations support the long-term operation of the existing fleet by addressing technology obsolescence and human factors aspects of control room modifications

• HFE methods have been researched, developed, and deployed to produce results that are usable by the entire industry

• The HFE methods and HFE design recommendations support iterative design enhancements and produce results early in the modernization process

• Collectively, the HFE methods and recommendations address all elements of NUREG-0711 and increase the confidence in the final design 8

Questions?

lwrs.inl.gov Program Information www.osti.gov References 9

Biographical Sketches Jeffrey C. Joe, M.S., is a Distinguished Research Scientist in the Human Factors and Reliability Department at Idaho National Laboratory. His research skills and expertise are in the areas of Human Factors R&D, Human Factors Engineering, human reliability analysis, safety culture, and social psychology. He has 10+ years as a Principal Investigator/technical lead for multiple R&D projects under the DOE Light Water Reactor Sustainability program.

Ronald L. Boring, PhD, is Department Manager for the Human Factors and Reliability Department at Idaho National Laboratory. He was the founder of the Human Systems Simulation Laboratory and leads development of prototyping tools such as the Advanced Nuclear Interface Modeling Environment (ANIME) and human factors evaluation methods like the Guideline for Operational Nuclear Usability and Knowledge Elicitation (GONUKE) to support control room development at nuclear power plants.

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Disclaimer This information was prepared as an account of work sponsored by an agency of the U.S. Government. Neither the U.S. Government nor any agency thereof, nor any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness, of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. References herein to any specific commercial product, process, or service by trade name, trade mark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the U.S. Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the U.S. Government or any agency thereof.

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