ML20196D878

Technical Evaluation Rept of Dcrdr for Iowa Electric Light & Power Co Duane Arnold Energy Ctr

ML20196D878
Person / Time
Site:	Duane Arnold
Issue date:	02/18/1988
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML112241032	List: ML20196D878
References
CON-NRC-03-02-096, CON-NRC-3-2-96 SAIC-88-3121, TAC-56120, NUDOCS 8802230016
Download: ML20196D878 (15)

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SAIC-88/3121 TECHNICAL EVALVATION REPORT OF THE I DETAILED CONTROL ROOM DESIGN REVIEW FOR IOWA ELECTRIC LIGHT AND POWER COMPANY'S DUANE ARNOLD ENERGY CENTER TAC NO. 56120 I -

I February 18, 1988

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, I Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 I Contract NRC 03-82-096 Task Order No. 19

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TABLE OF CONTENTS I Section ELqt

1.0 INTRODUCTION

. . . . . . . . . . . . . . . . . . . . . . I 2.0 EVALUATION . . . . . . . . . . . . . . . . . . . . . . . 2 2.1 Establishment of a Qualified Multidisciplinary Review Team . . . . . . . . . . . . . . . . . . . . 3 2.2 System Function and Task Analysis . . . . . . . . . 3 2.3 Comparison of Display and Control Requirements With a Control Room Inventory . . . . . . . . . . . 4 l

2.4 Control Room Survey . . . . . . . . . . . . . . . . 5 1 2.5 Assessment of Human Engineering Discrepancies (HEDs) to Determine Which Are Significant and j Should Be Corrected . . . . . . . . . . . . . . . . 6 2.6 Selection of Design Improvements ......... 6 2.7 Verification That Selected Design Improvements Will 1 Provide the Necessary Correction ......... 9 2.8 Verification That the Selected Design Improvements l Will Not Introduce New HEDs . . . . . . . . . . . . 9 2.9 Coordination of Control Room improvements With '

l Changes From Other Improvement Programs Such as the Safety Parameter Display System, Operator Training, Regulatory Guide 1.97 Instrumentation, and Upgraded Emergency Operating Procedures .......... 9

3.0 CONCLUSION

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4.0 REFERENCES

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TECHNICAL EVALUATION REPORT  :

OF THE l DETAILED CONTROL ROOM DESIGN REVIEW FOR ,

l IOWA ELECTRIC LIGHT & POWER COMPANY'S DUANE ARNOLD ENERGY CENTER f

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1.0 INTRODUCTION

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The Iowa Electric Light & Power Company submitted a Detailed Control  ;

Room Design Review (DCRDR) Program Plan to the Nuclear Regulatory Commission f '

(NRC) on November 30, 1984 (Reference 1) in order to satisfy the Program Plan requirements of NUREG 0737, Supplement 1 (Reference 2) for the Duane i

Arnold Energy Center. The NRC staff reviewed the submittal with reference to the nine DCRDR requirements of NUREG 0737, Supplement I and the guidance provided in NUREG 0700 (Reference 3) and NUREG-0800 (Reference 4).

.l NUREG-0737, Supplement I requires that a Program Plan be submitted within two months of the start of the DCRDR. Consistent with the requirements of NUREG 0737, Supplement 1, the Program Plan should describe f how the following elements of the DCRDR will be accomplished:

1. Establishment of a qualified multidisciplinary n eview team.

l g 2. Function and task analyses to identify control room operator tasks p and information and control requirements during emergency operations.

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

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

l fsr. tors principles.

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5. Ar m sment of human engineering discrepancies (HEDs) to determine which HEDs are significant and shoula be corrected.

6. Selection of design improvements.

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7. Verification that selected design improvements will provide the necessary correction.

8. Verification that improvements will not introduce new HEDs.

9. Coordination of control room improvements with changes from other programs such as Safety Parameter Display System (SPDS), operator training, Regulatory Guide 1.97 instrumentation, and upgraded emergency operating procedures.

The staff coments on Iowa Electric 1.ight & Power Company DCRDR Program Plan review were forwarded to Iowa Electric Light and Power Company on February 13, 1985 (Reference 5). Based on the Program Plan review, the staff raised several concerns regarding the licensee's DCRDR process and an in progress audit was conducted between March 18 and 21, 1985. The results of this audit were documented in a report dated May 8, 1985 (Reference 6).

NUREG 0737, Supplement I requires that a Sumary Report be submitted at the end of the DCRDR. As a minimum, it shall:

1. Outline proposed control room changes.

2. Outline proposed schedules for implementation.

3. Provide sumary justification for HEDs with safety significance to be left uncorrected or partially corrected.

I lowa Electric Light & Power Company submitted a Sumary Report for the Duane Arnold Energy Center to the NRC on December 15, 1986 (Reference 7).

The NRC's contractor, Science Applications International Corporation (SAIC),

reviewed the Sumary Report with respect to the nine DCRDR requirements l specified in NUREG-0737, Supplement 1.

reflects the consolidated observations, This Technical Evaluation Report findings and conclusions of the review team members.

2.0 EVALUATION The purpose of the evaluation was to determine whether the nine DCRDR l requirements in NUREG 0737, Supplement I had been satisfied. The evaluation I

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was performed by comparing the information provided by lowa Electric Light

& Power Company with the criteria in NUREG 0800, Section 18.1, Revision 0, Appendix A of *he Standard Review Plan. The reviewers' evaluation of the DCRDR for the Duane Arnold Energy Center is provided below. I 2.1 Establishment of a Oualified Multidisciolinary Review Team l The DCRDR review team was comprised of representatives in the areas of  !

system and nuclear engineering, reactor operations, instrumentation and control engineering and training. Two human factors consultants '

participated in each phase of the DCRDR. Overall administrative leadership was provided by the DCRDR team leader, a utility employee. Additional personnel from other disciplines were available when needed.

It is the review team's judgment that the licensee has met the NUREG-0737, Supplement 1 DCRDR requirement for establishment of a qualified multi-disciplinary review.

2.2 Systen Function and Task Analysis The licensee used the plant specific Emergency Operating Procedures 1 (EOPs), and the interrelated procedural steps of Operating Instructions and )

. Integrated Plant Operating Instructions, referenced from the E0Ps, to  !

identify control room operator tasks and information and control requirements. The E0Ps were based on Revision 3 of the Boiling Water Reactor Owners' Group (BWROG) emergency procedures guidelines (EPGs), and included:

. o E0P - 1 Reactor Pressure Vessel Control l

l o E0P - 2 Primary Containment Control o E0P - 3 Secondary Containment Control o E0P - 4 Radiation Release Control o E0P - 6 Shutdown Outside Control Room I

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During the March 18 through 21, 1985 NRC In Progress Audit, the review j team concluded that these procedures represented an appropriate basis for l

g coeprehenrively identifying operator information and control requirements.  ;

P In addition, the licensee stated in the Sumary Report that the task l analysis included:

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1. Analysis of deviations between BWROG EPGs and plant specific E0Ps.

2. Analysis of Cautions, Warnings and Notes in E0Ps.

l 3. Analysis of E0P entry conditions.

The licensee further stated that the approach resulted in a complete and l conservative task analysis.

l Operator tasks and decision requircments as well as information and control requirements and characteristics were documented on task analysis forms and prescription of instrumentation forms, resnectively. A blank l

sample of each of these forms was provided in the Sumary Report. '

It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for a system function and task analysis to identify control room operator tasks and information and control requirements during emergency conditions.

l 2.3 Comoarison of Disolav and Control Reouirements with a Control Room Inventory I An inventory was developed based on available specifications and the photomosaic mockup of the panels. Information regarding instrumentation was I documented on the ' Verification of Instrumentation" form as presented in the Sumary Report.

Verification of the availability and suitability of displays and g controls was conducted by comparing the information contained in the two task analysis sumary sheets (Prescription of Instrumentation form and Verification of Instrumentation form). Discrepancies were documented as l HEDs.

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It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for a comparison of display and control requirements with a control room inventory.

2.4 Control Room Survey )

The licensee conducted a control room survey utilizing the generic g checklists published in the BWROG Control Room Survey Workshop and the )

P Survey Program Supplement. The following eight checklist categories were used in the survey:

1. Panel Layout and Design,

2. Instrum( M ation and Hardware, g

3. Annunciator Warning System,

4. Computers,

5. Procedures,

6. Control Room Environment,

7. Maintenance and Surveillance, and l 8. Training and Manning. l Each checklist item was evaluated by trained DCRDR team members. Any item which was not met with full stepliance was documented as a HED. The results of this survey generated approximately 2092 HEDs.

l An additional, independent survey wt 4 performed by the human factors I specialist to identify HEDs which may not have been identified by the BWROG checklists. This survey utilized general human factors principles found in l sources such as NUREG-0700, MIL STD 1472, EPRI documents and other human factors engineering documents. Deviations from the guidelines were identified and documented as HEDs. Where possible, an attempt was made to I associate a given HED with the most similar BWROG checklist item number.

Approximately 600 additional HEDs were identifieo during the human factors l survey, g It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for a control room survey to identify deviations from accepted human factors principles.

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r .g 2.5 Assessment of Human Enoineerino Discrepancies to Determine Which Are Sionificant and Should Be Corrected Each of the 3115 HEDs was assessed for potential operator error and consequence of that error based on the following questions:

1. Does the HED degrade performance?

2. Does the HED increase the potential for error?

3. Does the HED have serious consequences?

4. Is the HED a documented error?

5. Does the HED involve a documented violation of a technical specification or other unsafe condition?

6. Could the HED result in a potential violation of a technical specification or other unsafe condition?

Additional questions, as provided in Standard Review Plan 18.1, Appendix A, were used as necessary to clarify the above questions. A priority rating, indicating the level of safety significance, with I being the most significant, and 9 being the least significant, was assigned following analysis of these questions. All priority 9 HEDs were reviewed for cumulative effects and, if necessary, the assessment priority was increased.

The HED assessment information was documented on the HED Assessment / Correction form.

It- is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for assessment of HEDs to determine which are significant and should be corrected.

2.6 Selection of Desion Imorovements Four methods were utilized in addressing discrepancies. These methods included: surface enhancements, physical modifications to instrumentation and controls, non-physical operational changes (training, staffing levels, conduct of operations, and operating procedures), and no correction. The licensee indicated that alternative corrective measures were developed and these options were documented on the Assessment / Correction form.

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The HED correction sumaries for safety significant HEDs (Priority 1 through 6) are provided in Appendix ( to the Sumary Report. The sumaries of the 33 short-term enhancement ac(ification activities ace detailed enough to assure that human engineering standards and processes have been established at Duane Arnold and will be applied to the enhancement activities.

In addition to the short-term enhancements, the licensee also l I sumarized approximately 130 long term modifications. The panels and equipment included in these modifications include:

1. 1C02 Area and Process Radiation Recording

2. 1C03 Emergency Core Cooling System

3. 1004 Reactor Recirculation and Reactor Water Cleanup (

4. 1C05 Reactor Control

5. 1C06 Feedwater and Condensate

6. 1C07 Turbine Control

7. 1C08 Generator and Auxilicry Power l 8. 1C09 Containment and Accident Monitoring

9. ICl4 Main Steam Isolation Valve Leakage Control I 10. 1C15 Trip System A, Reactor Protection System

11. IC17 Trip System B, Reactor Protection System

12. 1C20 Turbine Plant Instrumentation l 13. 1C23 HVAC-Reactor Building and Main Plant

14. 1C24 Standby Gas Treatment System i 15. 1C25 Drywell Ventilation and Nitrogen Inerting

16. IC26 HVAC-Turbine Building and Control Room System 1C29 Instrumentation Air Isolation Valves l 17.

18. IC34 Off-Gas System l

19. IC40 Fire Protection l 20. IC43 Division I Core Spray Relays l

21. Division II Core Spray Relays l 22.

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1C208 Remote Shutdown 1C341 KAMAM Display Terminal

24. 1C388 Remote Shutdown I 25. IC407 Remote Shutdown

26. Annunciators

27. General l

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The summaries of the short and long term control room modifications i

' indicate that the licensee has made a commitment to an integrated human engineering upgrade of the control room and remote shutdown pansis. In i addition, the modifications will include the use of Human Factors Standards that have been implemented to ensure consistency is maintained in all design activities at Duane Arnold.

The licensee documented the modification implementation schedules in l Section 7.0 of the Summary Report. The implementation schedules are timed l to coordinate with refueling outages. The four phases are.

1. Short-Term Enhancements (underway)

2. Long-Term Enhancements Prior to Cycle 10.(October 1988)

3. Long-Term Enhancements Prior to Cycle 11 (May 1990)

4. Long-Term Enhancements Prior to Cycle 12 (October 1992)

Review of the schedules indicates that the safety significant HEDs will be addressed in the earlier phases. For example, the 19 Emergency Systems Panel (1C03) Hens will be ccrrected during the 1988 refueling outage. The 12 Condensate and Feedwater Panel (IC06) HEDs will be corrected during the 1990 refueling outage. It is the reviewers judgment that the schedules for implementation of modifications are directed toward correcting safety significant HEDs in a timely and integrated fashion.

The licensee documented thejustifications for not correcting or partially correcting approximately 125 Priority 1 through 6 safety significant HEDs. Priority 7 through 9 HEDs were assessed as non-safety i significant and not documented. Review of the justifications for non-  !

correction indicated that the HED descriptions and justifications for not correcting them were adequately detailed and technically reasonable.

It is the review team's judgment that the licensee has met the j I NUREG-0737, Supplement I requirement for selection of design improvements. l l

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2.7 yerification that Selected Imorovements Will Provide the Necessary Correction i Verification that selected improvements provided the necessary l correction and did not introduce new HEDs was conducted using a full-scale l photomosaic of the control panels, panel layout drawings, and walkthroughs of E0Ps and related Operating Instructions procedural steps performed at panel 1C03. A Verification Report was completed for all HEDs.

l In addition, implicit design conventions were made explicit and I dxumented in the Duane Arnold Energy Center Human Factors Design Guide, DGC-E101. This Guide will be used to ensure that future control room changes will adequately address human factors criteria.

I It is the review team's judgment that the licensee has met the NUREG- l 0737, Supplement I requirement for verification that selected improvements I provide the necessary correction.

l 2.8 Verification that Selected Imorovements Will Not Introduce New HEDs l l

As discus.ted in Section 2.7, the licensee conducted a verification that selected improvements will not introduce new HEDs using a mockup, panel layout drawings, and walk-throughs. The Duane Arnold Energy Center Human Factors Design Guide, DGC-E101 will be used to ensure future changes incorporate accepted human factors principles.

It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for a verification that selected improvements will not introduce new HEDs.

2.9 Coordination of Control Room Imorovements with Chanaes from Other Procrams such as Safety Parameter Disolav System. Ooerator Trainina.

Reaulatory Guide 1.97 Instrumentation. and Vooraded Emeraency Ooeratina Procedures The assistant DCRDR team leader was also the responsible design engineer for the SPDS installed at the Duane Arnold Energy Center in 1985.

The licensee stated that DCRDR recomendations have been incorporated into 9

' the SPDS enhancement prograa to include incorporating the SPDS function into I the plant process computer.

l A training specialist was a member of the DCRDR team. Control room improvements included recomendations to training programs to alert person-nel to particular control arrangements that are not in conformance with I human factors criteria but cannot be reconfigured due to space configura-tions, separation criteria, or overriding human factors considerations.

The licensee stated that comparison of the sumarized instrumentation g and control requirements to the Regulatory Guide 1.97 design requirements was not emphasized due to the the Regulatory Guide's more restrictive requirements. Most HEDs gener ated for these components involved location deficiencies. The licensee also stated that the DCRDR did, however, provide input to the "Engineering Specification For Reactor Water Level Instrumenta-tion" which defines the design requirements at the Duane Arnold Energy Center to address Regulatory Guide 1.97.

Coordination with E0Ps included recomendations to modify procedures to include more explicit instruction in particular areas of interest. In l addition, improvements to the Writer's Cuide were suggested by the DCRDR team to ensure that procedures would be updated to recomended standards during revisions from other requirements.

It is the review team's judgment that the licensee has met the NUREG-l 0737, Supplement I requirement for coordination with control room improve-ments with changes from other programs such as SPDS, operator training, Regulatory Guide 1.97 instrumentation, and upgraded E0PS.

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3.0 CONCLUSION

S The Iowa Electric Light and Power Company submitted the Detailed Control Room Design Review (DCRDR) Sumary Report for the Duane Arnold  !

Er.ergy Center to the NRC on December 15, 1986. SAIC reviewed the Sumary Report with respect to the nine DCRDR requirements specified in NUREG-0737, Supplement 1. This Technical Evaluation Report reflects the consolidated observations, findings and conclusions of the review team members. The l

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I conclusions are provided below organized by the nine NUREG-0737, Supplement 1 DCRDR requirements.

1. It is the review team's judgment that the licensee has met the NUREG-0737, Supplement 1 DCRDR requirement for establishment of a qualified multidisciplinary review team.

2. It is the review team's judgment that the licensee has met the NUREG-0737, Supplement J requirement for a system function and task analysis l l to identify control room operator tasks and information and control requirements during emergency conditions.

3. It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for a comparison of display and control l requirements with a control room inventory.

4. It is the review team's judginent that the licensee has met the NUREG-I 0737, Supplement I requirement for a control room survey to identify l

deviations from accepted human factors principles.

I 5. It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirenent for assessment of HEOs to determine I which are significant and should be corrected. I l 6. It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for selection of design improvements.

7. It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for verification that selected l improvements provide the necessary correction.

g 8. It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for a verification that selected improvements will not introduce new HEDs.

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9. It is the review team's judgment that the licensee has met the NUREG-0737, Supplement I requirement for coordination with control room improvements with changes from other programs such as SPDS, operator I training, Regulatory Guide 1.97 instrumentation, and upgraded E0PS.

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4.0 REFERENCES

l l 1. "Program Olan for Implementation of Detailed Control Room Design Review," at ched to Letter from R.W. McGaughy (IELP) to H.R. Denton  ;

(NRC), Nover.ber 30, 1984 I f 2. NUREG-0737, Supplement I, "Requirements for Emergency Response l Capability" (Genetic Letter No. 82-33), December 17, 1982. 1 I

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3. NUREG-0700, "Guidelines for Control Room Design Reviews," September 1981.

4. NUREG-0800, "Standard Review Plan," Section 18.1, "Control Room," and Appendix A, "Evaluation Criteria for Detailed Control Room Design Reviews (DCRDR)," September 1984.

5. Review of the Detailed Control Room Design Review Program Plan, I Letter to IELP from NRC, February 13, 1985.

l 6. Detailed Control Room Design Review, In-Progress Audit Report, Duane Arnold Energy Center, attached to Memorandum from W.H. Regan, Jr. (NRC) l to D. Vassallo, (NRC), May 9,1985.

7. "Detailed Control Room Design Review Sumary Report," attached to Letter from R.W. McGaughy (IELP) to H.R. Denton(NRC), December 15, 1986.

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