ML25150A114

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Human Factors for Control Room Digital Modifications:Key Lessons Learned
ML25150A114
Person / Time
Issue date: 05/30/2025
From: Brian Green
NRC/NRR/DRO
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Download: ML25150A114 (14)
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Human Factors for Control Room Digital Modifications:

Challenges & Solutions Brian Green, Ph.D.

U.S. Nuclear Regulatory Commission Senior Technical Advisor for Human Factors t,NPIC HMIT=

N 14th International Topical Meeting on Nuclear Plant Instrumentation, Control &

Human-Machine Interface Technologies

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Background===

  • Plants conducting large scale digital modernization efforts experienced certain challenges applying NRC guidance.
  • Alternative Review Process (ARP) in Interim Staff Guidance (ISG)-

06

- ISG includes a process for early regulatory approvals when the application incorporates an approved topical report called the ARP

- Scope of current control room modifications has gone beyond the original scope of the ISG-06

- Includes a reference to NUREG-0711 design process for HFE testing

- NUREG-0711 describes integrated system validation (ISV) which happens late in the design process (inconsistent with philosophy of ARP)

  • NRC and licensees conducted several public meetings to understand challenges and identify success paths.

~u.S.NRC United States uclca r Rcgulacory Co mmissio n Protecting People and the E11viro11ment Planning and Analysis HFE Program Management Operating Experience Review Function Analysis &

Allocatlon Task Analysis Staffing&

Qualification Treatment of Important Human Actions Design Verification and Validation Human Factors Verification and Validation Implementation and Operation Design Implementation Human Performance Monitoring Figure 1-1 Elements of the HFE program's review model 8ANS

Identified Three Challenges

1. Timing of validation testing
2. Modifications to the simulator needed for testing
3. Challenges preparing the application
a. Understanding Plant Specific Current Licensing Basis
b. Implementation Plans & Results Summary Reports

't7U.S.NRC United States uclca r Regulatory Commissio n Protecting People and the Environment

~ U.S.NRC United S1an*~ Nudo:111 Rq;uhnory Commi"ion Protecting People and 1hr E1wirom111ml NUREG-0711, Rev_ 3 Human Factors Engineering Program Review Model 8ANs*

1. Solving Validation Timing Challenge:

Multi-Stage Validation (IEEE 2411-2021)

  • Multi-stage Validation (MSV) entails a staged approach to validation testing, where results are obtained at stages throughout the design process.

- ISV testing represents the final stage within this approach

  • With sufficient information, the NRC could approve a LAR based on early-stage MSV results, without the availability of final ISV testing results.

- The NRC can consider these early-stage test results along with ISV implementation planning information provided by the applicant.

- Can credit activities already planned by the licensee t7U.S.NRC Uni1cd S1a1cs uclcar Regul:uo ry Commission Protecting People a11d the E11viro11ment 8ANS

Rough Timeline Comparison HFE Analyses Design Evaluation (ISV)

LAR Submittal Implementation Analyses (Validation 1)

Design (Validation 2)

LAR Submittal Evaluation (ISV)

Implementation ISV Approach in NUREG-0711 ISV Approach in NUREG-0711 supplemented by MSV (IEEE 2411)

SER SER MSV stages defined by licensee

2. Solving Simulator Modification Challenges:

Glass Top Simulators

  • Modern glass top simulators provide additional flexibility that is not possible when modifying existing plant simulators.
  • NUREG-0711 has several criteria related to testbeds. It does not prescribe which simulator must be used.
  • Glass top may be an adequate testbed if fidelity is sufficient to support the goals of the test.

- See NUREG-0711 criteria

  • Subject matter experts evaluate glass top for deviations

- Document and assess to ensure they dont impact the credibility of validation tests

't7U.S.NRC Un ited States uclcar Regulatory Co mmission Protecting People and the Environment 11.4.3.3 Validation Testbeds A testbed is the HSI representation used to perform validation evaluations. One approach an applicant can use to acceptably meet criteria 1 through 7 in this section is to use a testbed that is compliant with "Nuclear Power Plant Simulators for Use in Operator Training" (ANS, 2009).

(1)

Interface Completeness - The applicant's testbed should represent completely the integrated system. It should include HSls and procedures not specifically required in the test scenarios.

Additional Information: Adjacent controls and displays may affect the ways in which personnel use those addressed by a particular validation scenario.

(2)

Interface Physical Fidelity - The testbed's HS ls and procedures should be represented with high physical fidelity to the reference design, including the presentation of alarms, displays, controls, job aids, procedures, communications equipment, interface management tools, layout, and spatial relationships (3)

Interface Functional Fidelity - The testbed's HSI and procedure functionality should be represented with high fidelity to the reference design. All HSI functions should be available.

(4)

(5)

(6)

Additional Information: High fidelity covers the HSI modes of operation (i.e., the changes in functionality that can be invoked by personnel selecting them), or changes in plant states.

Environmental Fidelity - The testbed's environmental fidelity should be represented with high physical fidelity to the reference design, including the expected levels of lighting, noise, temperature, and humidity. Thus, for example, the noise contributed by equipment, such as air-handling units, computers, and communications equipment should be represented in validation tests.

Data Completeness Fidelity - Information and data provided to personnel should completely represent the plant's systems they monitor and control.

Data Content Fidelity - The testbed's data content fidelity should be represented with high physical fidelity to the reference design. The presentation of information and controls should rest on an underlying model accurately mirroring the reference plant.

The model should provide input to the HSI such that the information accurately matches that which is presented during operations.

8ANs*

3a. Preparing the Application:

Plant Specific Regulatory Basis

  • Operating Part 50 plants responded to NRC orders after TMI

- NUREG-0660, Detailed Control Room Design Review (DCRDR) using NUREG-0737, NUREG-0700 (Rev 0)

  • Scope of NUREG-0700 Rev 0 is part of the current licensing basis for many plants, however, that guidance was not intended for modifications. Applying it to digital modifications is tricky (especially since the use of digital technology was limited compared to today).
  • Updates to NUREG-0700 have occurred over the years, but plants have been reluctant to voluntarily commit to using it despite the improved focus on digital systems.

8ANS.

NUREG-0700 Revision 0 (1981) - Guidelines for Control Room Design Reviews

  • Little nuclear specific HFE guidance was available at the time. Technical content was based on other industries, mostly military
  • Has criteria that look like the current NUREG-0700, but also has HFE process information that looks like NUREG-0711 that was used to help licensees/reviewers conduct the DCRDRs described in NUREG-0737 and Supplement 1 NUREG-0700 Revision 1 (1996) - Human-System Design Review Guideline - Process and Guidelines By the mid-1980s it was apparent that guidance for digital modifications was necessary
  • NRC (and its contractors) had gained experience with the DCRDRs and wanted to include that in the update
  • Adds guidance about computer-based displays, controls, alarms, and local control stations. (See Section 1.2) - several topics were being researched but were not included in this publication (these additional topics were eventually added in Revision 2)

NUREG-0700 Revision 2 (2002) - Human-System Interface Design Review Guidelines

  • DCRDRs are no longer necessary because they were a one-time evaluation to establish a baseline design, but it was apparent that the design process information was still necessary to support modifications and new builds Removes HFE Process information - content consolidated into NUREG-0711 - NUREG-0700 maintains the HSI design criteria in Revision 2 NUREG-0700 Revision 3 (2020) - Human-System Interface Design Review Guidelines
  • Recent revision updates and modernizes technical basis and provides new guidance on integrated alarms, computer operator support systems, human-automation interaction including adaptive automation, and degraded HSI and I&C conditions.

NUREG-0700 Revision 4 (TBD 2025-2026) - Human-System Interface Design Review Guidelines

  • Recent revision that updates and modernizes technical basis and provides new guidance on topics that were not included in Rev 3 including:

Section 1 Information Display, Section 3 Analog HSIs, Section 6 Large-Panel Human-System Interface, Section 7 Soft Controls, Section 10 Communication System, Section 15 Integration of HSI resources Cheat Sheet: Historical Perspectives on NUREG-0700 8ANs*

3b. Preparing the Application:

Clarifying Implementation Plans (IP) & Results Summary Reports (RSR)

Suppose youve given me your Grandmas famous cake recipe, and Ive promised to make it for your birthday.

Will the cake I make be as good as Grandmas?

Is there any information I can share today that would give you confidence?

baking experience?

ingredients and tools?

keep the dog off table?

NRC considers both the process (IP) AND the results (RSR).

Information about the process gives confidence when looking at small inspection samples.

5.3 Applicant Products and Submittals The product of the applicant's task analysis is a listing of the tasks to be undertaken, and the requirements for performing each task. The task analysis generates inputs to other elements in the H FE process.

The applicant should provide either an IP or a completed RSR. If the applicant submits an IP, it should describe the methodology for conducting the task analysis. The NRC will review it using the criteria set out in Section 5.4 below. Then the applicant will submit the RSR when the work described by the IP is completed.

If the applicant submits a completed RSR, the NRC will verify the results using the criteria in Section 5.4 below. At a minimum, the RSR should include the following:

't7U.S.NRC United States uclca r Regu latory Comm issio n Protecting People and the Environment 8ANs*

Recent Successes

  • Two licensees have submitted license amendment requests (LARs)

- NRC Acceptance Reviews complete for both

- Technical Reviews began for one

- Neither has been completed yet, but HFE approaches is not a barrier

- One licensee conducted two MSV tests

  • Both licensees used MSV-like approaches
  • Both licensees propose/use high-fidelity glass top simulators
  • Both submitted IPs which will be supplemented by RSRs when design work is complete t7U.S.NRC Uni1cd S1a1cs uclcar Regul:uo ry Commission Protecting People a11d the E11viro11ment 8ANS

Next Steps

  • NRC recommends pre-application meetings to help identify issues and identify success paths early on.
  • NRC supports development of a new draft standard ANS 3.5.1 use of simulators for non-operator licensing purposes
  • Working on update to NUREG-0800 Chapter 18 to document positions described here

- Will update HFE material in ISG-06 t7U.S.NRC Uni1cd S1a1cs uclcar Regul:uo ry Commission Protecting People a11d the E11viro11ment 8ANS

References Institute of Electrical and Electronics Engineers. (2021). IEEE Guide for Human Factors Engineering for the Validation of System Designs and Integrated Systems Operations at Nuclear Facilities (IEEE Std. 2411-2021). Institute of Electrical and Electronics Engineers, Inc. https://standards.ieee.org/ieee/2411/10357/

Nuclear Energy Agency. (2019). Multi-Stage Validation of Nuclear Power Plant Control Room Designs and modifications (NEA Report No. 7466). Organisation for Economic Co-Operation and Development. https://www.oecd-nea.org/jcms/23694_Media/7466-multi-stage-validation Nuclear Regulatory Commission. (1980). Clarification of TMI Action Plan Requirements (NUREG-0737).

https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0737/index.html Nuclear Regulatory Commission. (2018). Digital Instrumentation and Controls, DI&C-ISG-06, Licensing Process-Interim Staff Guidance Revision 2. https://www.nrc.gov/reading-rm/doc-collections/isg/digital-instrumentation-ctrl.html Nuclear Regulatory Commission. (2012). Human Factors Engineering Program Review Model (NUREG-0711, Revision 3).

https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0711/index.html Nuclear Regulatory Commission. (2020). Human-System Interface Design Guidelines (NUREG-0700, Revision 3).

https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0700/index.html Nuclear Regulatory Commission. (1980). NRC Action Plan Developed as a Result of the TMI-2 Accident Volumes 1 and 2 (NUREG-0660), (ADAMS Accession Nos. ML063250131 and ML063210138)

Backup Slides 8ANS.

ISG-06

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