NUREG-0835, Forwards Revised SRP Section 18.2,App a to Section 18.2 & Resolution of CRGR Comments on Draft NUREG-0835 Re SPDS Designs
| ML20244D179 | |
| Person / Time | |
|---|---|
| Issue date: | 01/04/1985 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20235A905 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-0800, RTR-NUREG-0835, RTR-NUREG-737, RTR-NUREG-800, RTR-NUREG-835 NUDOCS 8501310590 | |
| Download: ML20244D179 (4) | |
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MEMORANDUM FOR: William J..Dircks, Executive Director for Operations FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
ISSUANCE OF SECTION 18.2 AND APPENDIX A TO THIS SECTION OF THE STANDARD REVIEW PLAN, .
- Section 18.2, " Safety Parameter Display System (SPDS)" and Appendix A to SRP Section 18.2 have been developed to provide guidelines for evaluating. Safety ~
Parameter Display System designs. This SRP revision incorporates draft L
NUREG-0835 as Appendix A. CRGR has previously reviewed draft NUREG-0835 at its meeting Number 57 'on February 15, 1984. ..
- In my memorandum of August 10, 1984, I indicated it was our recommendation to administratively change Section 18 of the SRP to include the contents of NUREG-0835 as an. appendix. Your memorandum of August 21, 1984, approved the conversfun of the NUREG to guidance in the SRP; however, you requested to receive a copy of the SRP prior to publication for use.
Enclosure'l is the SRP package as we intend to publish it. Enclosure 2 describes our re' solution of CRGR comments. This revision is effective immediately upon issuance; therefore; unless you disagree, we intend to publish the Federal Register Notice of Issuance and Availability n working days after you receive this memo.
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Enclosures:
} 1. SRP Section 18.2 an pendix A to Section 18.2
- 2. Resolution of CRGR o ,ents on Draft NUREG-0835 lo '
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,- En-losure 2
-Resolution of CRGR Comments on- -
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Draft NUREG-0835 .
CRGR reviewed draft NUREG-0835 at its Meeting' Number 57 on February 15, 1984.
Minutes of this meeting issued on March 16, 1984, expressed the CRGR concerns -
summarized below: .
- 1. Considerable ambiguity and complicated language. '
- 2. Use of NUREG document to generate / establish generic requirements is contrary to NRC policy.
- 3. Does not address when, how and by whom.the SPDS will be used. .
4.
Exceeds design requirements originally intended in Supplement I to NUREG-0737. .
- a. SPDS operability is belie'ved to be only required for plant conditions involving power, hot shutdown, or. hot standby conditions. .
[b. A need for audible alarms has not been previously identified.
^ c.. Time derivative data display is believed to have little -
practical value and should not be promoted as an acceptable substitute for clear trend information.
- 5. Document allows great flexibility on the part of individual reviewers and acceptance criteria to be defined based upon many available industry human factors documents. Guidance is referenced that has not been reviewed.
- 6. Acceptance guidelines are found in at least two sections (Sections 5 and 6) and it is difficult to determine minimum system capabilities that are considered necessary for system acceptance.
Since review of this document by CRGR, it has undergone a number cf revisions to address CRGR concerns. In addition, both ELD and our technical editors have reviewed the document and their comments have been incorporated. The
.. nafer change has been to make the proposed NUREG into en appendix to Section 18.2 of the Standard Review Plan. Our resolution of the specific CRGR comments that were summarized above is as follows:
- 1. The ambiguity and complicated languaoe have'been eliminated.
Redundant sections have also been eliminated and we have clarified that the document is for staff use in reviewing SPDS designs. The final version of the document has--been re7tewed by both EL3 and our technical editors.
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- 2. We. propose to publish th+s document as an appendix to Sectioh 18.2
.of the Standard Review Plan as a result of CRGR and EDD comments.
- 3. Supplement I to NUREG-0.737 describes the SPD,S as an operatpr aid in rapidly and reliably determining the safety status of the plant. )
It also explains that the SPDS will display ini'ormation to control room personnel who are responsible for the avoidance of degraded )
and damaged core events. We do not believe that a s.pecific user should be specified by the NRC. This is up to the utility and strongly depends on the operating philosophy of a utility.
, 4a. Although Supplement 1 to NUREG-0737 states that the SPDS will be operated during normal operations as well as abnormal conditions and will continuously display information, we have adopted CRGR's -
comment and have eliminated refueling and cold shutdown modes of operation as areas of NRC review. ,
3 4h. We have clarified the reference to audible alarms as follows:
" perceptual (audible or visual) cues are control room operator to return to the pr,provided to alert imary display format thewhile viewing secondary information." The main concern is that SPDS users are made aware of important changes in the primary display when they are viewing secondary displays.
4c. We have stressed that trend data are preferred and that time derivatives are acceptable only when the derivatives unambiguously r.eflect trends in critical plant variables.
- 5. The document does allow flexibility because of the variety of SPDS designs. We have tried to allow sufficient latitude for the review of different systems as well as different displays. We have
, eliminated reference to reviewer use of guidance that has not been I
reviewed. Industry can utilize non-reviewed human factors guidelines which the staff will review on a case-by-case basis.
- 6. Section 5 presents Hunan Factors Guidelines for reviewing the SPDS system while Section 6 presents guidelines for reviewing computer-driven CRT displays that may be part of an SPDS. We have clarified the distinction between the two sections. Minimum systen capabilities that are considered necessary for SPDS acceptanc'e are defined in Supplement 1 to NUREG-0737 as beiro those sufficient to provide information to plant operators about the following critical safety functions:
4 (1) Reactivity centrol .
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(ii) F.eactor core cooling and beat renoval from the primary systen I l
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c, (iii) Reactor coolant system integrity ,
(iv) Radioactivity control (v) Containment conditions -
.The human factors engineering review is directed a (1) confirming ~
- that means are provided to ensure that the dita displayed are valid, and (2) confirming that the licensee has committed to a human factors engineering program to ensure that the displayed information can be readily perceived and comprehended so as not to mislead the control room operator.
The parameter selection review is directed at confirning that the '
plant specificparameters selected as the bases for a critical ,
safety function are sufficient to assess the safety status of that- 2 function for a wide range of events. Justification for the choice of parameters can be provided by reference to analyses supporting approved generic emergency procedure guidelines.. The types of scenarios to be considered include those which result from events-identified in SRP Section 15.0. DHFS plans to' document the process used for parameter selection review. .
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