NUREG-0801, Forwards Comments on Program Plan for Detailed Control Room Design Review (Dcrdr).Program Plan Addresses All Required Elements of DCRDR.In-progress Audit Not Planned

Forwards Comments on Program Plan for Detailed Control Room Design Review (Dcrdr).Program Plan Addresses All Required Elements of DCRDR.In-progress Audit Not Planned

ML20197G402
Person / Time
Site:	Columbia
Issue date:	05/03/1984
From:	Russell W Office of Nuclear Reactor Regulation
To:	Novak T Office of Nuclear Reactor Regulation
References
CON-WNP-0754, CON-WNP-754, RTR-NUREG-0700, RTR-NUREG-0737, RTR-NUREG-0801, RTR-NUREG-700, RTR-NUREG-737, RTR-NUREG-801 NUDOCS 8405170444
Download: ML20197G402 (7)

Text

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Nflembers l!EMORN10011 FOP,: Thomas ii. Ilovak, Assistant Directnr for Licensing Division of Licensing FR0it: William T. Russell, Deputy Director Division of Huuan Factors Safaty

SUBJECT:

REVIEW C0;'.hEtiTS Otl WASilliiGT0li PUBLIC PO'JER SUPPLY SYSTEtt UETAILED C0iiTROL ROOli DESIGil REVIEll PROGPld PLNI FCR liUCLEAR PROJECT NO. 2 Enclosed for transnittal to the 'Jashington Puolic Pcwer Supply Syst n (Supply Systen) are tne stati comments on their Prcgran Plan fur the hiiP-2 Detailed Control Hocm Design Review (DCRDR). Staff approval of the Prcgram Plen is not required.

The staff review was based on the requireuents of Supplement 1 to liUREG-073/

and the guidence coni.cined in i;UREG-0700 and drart huREG-0C01. Je fino that the Supply Systen's Program Plan hos adcressed all or the requiruc elecents of a OChDR, and have only ninor concerns as to tneir planned approach. ;le do nut plan to conduct an in-prograss audit at i. iip-2.

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'Jillian T. Russell, Ocputy Director Division of Huaan Factors Safety

Enclosure:

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STAFF REVIEW, WASHINGTON PUBLIC POWER SUPPLY SYSTEM DETAILED CONTROL ROOM DESIGN REVIEW PROGRAM PLAN NUCLEAR PLANT NO.'2 The Washington Public Power Supply System (Supply System) submitted a detailed control room design review (DCRDR) Program Plan for Nuclear Plant No. 2 (WNP-2) on February 17, 1984. The submittal complied with the requirements of Supple-ment 1 of NUREG-0737 and the condition specified in Attachment 2, Item 1 of Operating License NPF-21. The Supply System has had an ongoing human factors design review of the WNP-2 control room since 1980 which has included a control icom human factors review by the BWROG, a Preliminary Design Assessment and report, and a subsequent NRC on-site audit. With the exception of those items ,

identified in the staff's Preliminary Design Assessment audit report as requiring attention during the DCRDR, the WNP-2 control room has had a reasonably thorough survey for potential human factors , problems. This survey has included the remote shutdown panel.

In general, the staff has found..the WNP-2 human factors review program to be well organized, adequately supported by Supply Syste[n management, and designed to iden-tify and implement control room design changes needed to improve man-machine ,

interfaces and ensure safe and reliable plant operation. Our review of the WNP-2 Program Plan has taken into account the Supply System's past performance in the area of human factors, and we have not provided comments on those portions of the l Program Plan that address completed items. Our comments that follow are primarily on those DCRDR tasks yet to be conducted, and involve what the Supply System is planning to do, who will perform the tasks, and how they are to be accomplished.

1. Qualifications and Structure of the DCRDR Team Review team management, organization, qualifications and structure as de-scribed for the DCRDR program and outlined in Figure 3-2 is very good. However,

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we cannot determine that this organization will carry over into the post-licensing DCRDR activity. For example, Figure 6-3, which illustrates the plant operation (post-licensing) phase review process, suggests that this will be a Supply System activity. Oe cannot determine who will make up the " Task Force Team" referred to in this figure, nor if they will constitute an appropriate multi-disciplined

) organization. The magnitude and importance of the human factors activities still to be conducted for the WNP-2 DCRDR requires the continued efforts of a multi-disciplinary review team such as is described in Figure 3-2 of the Program Plan.

2. System Function and Task Analysis The Program Plan describes a planned function and task analysis that should satisfy the requirements of Supplement 1 to NUREG-0737. We concur in the approach

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adopted by the Supply System.

3. Comparison of Control and Display Recuirements with a Control Room Inventory The Supply System reports thatman inventory of control room instruments and controls has been conducted. We agree that an inventory is available that can be _

used with results of the function and task analysis to identify missing or im- .

properly located instruments and controls.

4. Control Room Survey The Program Plan notes that "BWRCS Survey checklist items not completed, due to the plant construction status, and the BWROG Supplemental Survey checklists will be completed during the plant operating phase by the WNP-2 Task Force and reported in the WNP-2 Summary Report." Based on our comments on the makeup and qualifications of the plant operation phase DCRDR review team, we are concerned that an appropriate multi-disciplirary team may not be available for this task.

, We also point out that the NRC Preliminary Design Assessment audit identified

a number of survey-type items that must be completed during the DCRDR. Some of these items are conditions of License NPF-21.

5. HED Assessment The Program Plan outlines an adequate and effective process for HED assess-ment. However, the Program Plan does not identify the makeup of the task force team that will be analyzing and categorizing HEDs. We also note that priority 1 (Prompt / Prior to Fuel Load) no longer appears to have significance -- i.e.,

that " prompt" appears to refer only to prior-to-fuel-load corrections. This needs to be clarified, since " prompt" should still have significance for an operating plant.

6. Selection of Design Improvements e The ' Program Plan suggests thatsthe recomended solution to each HED is prepared by the " reviewer" who identified that problem. We are concerned that this process will not provide for theyamination of alternative design solutions.

The Supply System should ansure that " review reports" prepared by individual task force members do consider alternative design solutions, and that the subse-l ,

quent task force meetings address ~this point. We are also concerned that the Supply System ensure that the task force team include all of the disciplines needed to arrive at appropriately human-factored design solutions. We are also unable to determine how the Plant Operating Comittee will function in reviewing the task force design improvement recommendations. For example, what is the procedure for handling a design change recomendation that might be rejected by the Plant Operating Comittee?

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7. and.8. Verification That Improvements Will Provide Corrections And That Control Room Modifications Do Not Introduce New HEDs The' Program Plan outlines a process for verifying that selected design improvements, both individually and collectively, adquately correct discrepancies and do not create other safety problems. We believe that this procedure will be 4

adequate. However, it should be applied to all design improvements, including those improvements accomplished through enhancement techniques.

9. Coordination with Other Improvement Programs The Program Plan notes that " Improvements that are introduced are coordi-nated with changes resulting from other improvement programs, such as new in- ,'

strumentation (RG-1.97), upgraded emergency procedures, and new Graphic Display Systems;" and/ " Human Factor affecting activities within the control room are reviewed by the Task Force to ensur,e configuration control and integration between related activities. Specific design and layout reviews include such areas as RG-1.97, RG-1.47, Safety Parameter Display System, new BWR Emergency Procedure

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Guidelines and Procedures, TMI-related tasks, and other engineering changes."

l We' believe that this approach should be adequate to ensure proper coordination.

l However, the task force will need procedures for identifying changes associated with other improvement programs and for bringing these changes to the attention of the task force for their review.

Conclusions We find the WNP-2 DCRDR Program Plan adequate to satisfy the requirements of Supplement 1 to NUREG-0737. Our main concern is with ensuring that an adequately qualified review team remains actively involved in the DCRDR through preparation of the Summary Report and final resolution of proposed design improvements. The following additional comments, applying to soecific items in the WNP-2 Program

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Plan, are provided as additional guidance / input to the Supply System DCRDR review team: ,

Figure 3-2. Since some HEDs may be resolved through training, and since the DCRDR needs to be coordinated with training programs, we recommend that a Supply System training engineer be made a part of the task force.

Paragraph 5.1.1. The DCRDR Summary Report is scheduled to be transmitted to the NRC 6 months before the first refueling outage. Prior to that time, there should be sufficient operating experience to permit some input of this nature to the DCRDR.

Paragraph 5.1.2. The comment for 5.1.1 applies. Time will be available to develop some operator input to Ihe DCRDR that can be based on actual WNP-2 operating experience.

.m The staff-Supply System meeting of Novemberh2,1983 resulted in the deferral _

of a number of HEDs identified during the Preliminary Design Assessment to the .

DCRDR. A list of those HEDs which are to be reevaluated and reassessed during the DCRDR is attached to this review report.

. . , . , s HEDs TO BE ADDRESSED IN THE WNP-2 DCRDR HEDs are identtfied by the Part and Finding number as given in the staff's Human Factors Engineering Preltminary Design Assessment Audit Report.

Finding Finding Part A Part'E (Cont'd) 1.3 5.51 5.52 Part 0 5.53 1.27 5.54 2.2 5.55 3.55 5.56  ;

3.57 5.58 3.59 5'59 -

5.32 5.62 5.38 5.63 .

5.39 ,

5.66 5.47 5.70 6.91 6.97 Part F .->^*

3.76 '

5.72

• 7.6 5.73 5.75 6.114 8.50 Part E 8.51 1.33 8.52 1.34 A complete review of annunciator control system design, 3.66 location and operation is also required as a part of the 3.71 DCRDR. HEDs that currently address the annunciator control 4.29 system are as follows:

5.11 0 3.60 0 3.70 F 3.79

0. 3.61 F 3.18 F 3.80 0 3.63 F 3.77 l

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