ML20113D222

Comments on Detailed Control Room Design Review Program Plan

ML20113D222
Person / Time
Site:	Waterford
Issue date:	01/04/1985
From:	Johari Moore LAWRENCE LIVERMORE NATIONAL LABORATORY
To:	NRC
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ML20106B272	List: ML20113D222
References
NUDOCS 8501220575
Download: ML20113D222 (17)

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F COMMENTS ON THE DETAILED CONTROL ROOM DESIGN REVIEW PROGRAM PLAN FOR LOUISIANA POWER AND LIGHT

, UNIT 3 0F THE WATERFORD STEAM ELECTRIC STATION James W. Moore Lawrence Livermore National Laboratory January 4,1985 '

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1. INTRODUCTION Lawrence Livermore National Laboratory (LLNL) has evaluated the program plan submitted by Louisiana Power and Light (LP&L) for conduct of a detailed control room design review (DCRDR) at Waterford 3 Steam Electric Station.

The purpose of the evaluation was:

1. To determine whether the planned program would result in a successful DCRDR.

2. To determine whether an in-progress audit is necessary.

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3. To provide an audit agenda when necessary.

4 To provide constructive feedback to Louisiana Power and Light.

Evaluation was against the requirements of Supplenent 1 to NUREG-0737.

Additionil guidance was provided by NUREG-0700 and Appendix A to Section 18.1 of NUREG-0800, Standard Review Plan (SRP). This report provides the results of this evaluation, i~

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2. DISCUSSION 2.1. DCRDR Review Team Supplement 1 to NUREG-0737 requires the establishment of a qualified multidisciplinary review team to conduct a DCRDR. Guidelines for review team selection are found in NUREG-0700 and the criteria for evaluating DCRDRs are cor.tained in Appendix A to SRP Section 18.1 of NUREG-0800.

Louisiana Power and Light plans to establish a multidisciplinary review team consisting of core team members and an undefined number of supporting team memberse ARD Corporation is the human factors consultant to LP&L for the j e Waterford 3 DCRDR.

e The LP&L Program Manager (PM) will have overall responsibility for the planning and administration of the DCRDR project.

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, The LP&L'DCRDR Project Manager (DPM) will coordinate and manage the DCRDR activities with the appropriate technical review leaders.- He is:

- Responsible for integration of human factors engineering related action items into the control room.

- Responsible for scheduling and directing the evaluation and '

reporting process of Human Engineering Discrepancies (NEDs).

e The Lead Human Factors Specialist (LHFS) from ARD Corporation will work with the DPM and other technical review leaders through all

' phases of the DCRDR.and provide the necessary human factors technical leadership.

He will coordinate all activities of the Human Factor Specialists to ensure a valid and comprehensive review.-

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J The LHFS will be supported by the project director for ARD and four other Human Factor Specialists.

e An LP&L Technical Advisor will provide technical review guidance on specific items related to previous human factor activities.

e An LP&L Licensing team member will be responsible for providing support in resolution of licensing issues. This team member will be a nuclear engineer.

e An LPAL engineer who is also a licensed SRO will provide Operations support.

O e An Architect Engineer from Ebasco Services, Inc. (ESI) will provide .

management of appropriate engineering support for the DCRDR from supporting ESI staff.

e A Training Specialist will aid the DCRDR effort with matters related to instructional materials and training.

j e A Computer Specialist provided by LP&L will assist in Computer and Plant Performance engineering sections of the DCRDR.

Additional supporting staff will be drawn from the Operations area at Waterford 3. LP&L states that criteria for selection of LP&L. review team was based upon guidelines in Draft NUREG-D801. The resumes of the core staff of the team infer a wide area of experience and education. We are concerned that there is a lack of detailed description of team members' specific experience. We reconnend that the NRC review the specific experience and .

participation of individual team members during an on-site audit.

1 Figure 2.2 of the Waterford 3 Program Plan indicates the involvement of the review team in all phases of the DCRDR. As indica'.ed by the Involvement l

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Summary Matrix (Fig. 2.2), the Human Factor Specialists will be involved in all phases of.the review process on an "as needed" hasis. We feel this is a weak commitment. We recommend that the human factors specialists be actively

involved in all phases of the DCRDR.

2.2. Function and Task Analysis Supplement 1 to NUREG-0737 requires the licensee / applicant to perform systems function and task _ analyses to identify control room operator information and control needs during emergency operations. Supplement 1 to NUREG-0737 recommends the use of function and task analyses that have been used as the

, basis for developing emergency operating procedures technical guidelines and

.o plant-specific emergency operating procedures to define these needs. The Waterford 3 program states that they will use a top-down approach, as outlined in NUREG-0700, for their systems function and task analysis (SFTA).

The plan states that system-event sequences will be identified using the Waterford 3 Event Tree Report (ETR) and Combustion Engineering Owner's Group

(CEOG) document CEN-152. A brief description of the process used to select I

certain sequences is provided. We are unable to comment on the validity, comprehensiveness, or methodology for use of the ETR since it was not provided i

for our review. The Program Plan states that CEN-152 will be used for 4

development of plant-specific E0Ps. It is not stated how the plant-specific E0Ps will be derived from the emergency response guidelines (EPGs) or how tasks required to perform the E0Ps will be identified.

i The Program Plan states the task analysis will be performed to provide operator information and control needs. A Task Analysis form is to be designed in support of this effort. The Program Plan does not provide sufficient detail on the p ocess to be used to determine plant-specific information and control needs to perform each operator task. The plan also

'does not describe in sufficient detail the method by which the documents used will provide an auditable record.

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In order for the SFTA to be acceptably accomplished for all emergency conditions, the systems function and task analyses should:

e Be independent of existing control room design. -

o Identify and analyze the appropriate operating events, plant safety-related systems, and functions which must be exercised and analyzed, e Identify the E0Ps and tasks which must be executed and analyzed.

O, e Identify reference sources to be used, who will use them and how they will be used in the transition from CE0G generic guidelines to the plant-specific characteristics of information and controls needed by the operator to mitigate the effects of the emergency conditions.

e Completely cover all emergency operations included in the EPGs.

To enhance the acceptability of the description of the methodology, the applicant's documentation should include the following:

e Discussions of the approaches and information sources used (e.g.,

documents, guidelines, operations personnel, multiple approaches, plant-specific calculations, etc.).

e The rationale and methodology used in the selection of event j

sequences, along with a descriptio'n of how it was verified that the selected sequences adequately cover the complete range of systems and systems operations needed to mitigate abnormal plant conditions.

e The details of the process used to identify the functions, systems, subsystems, and events selected for analysis.

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. e A discussion of who will perform the work and how the independent reference sources, the documented independently determined information and control needs and characteristics, and the inventory

process were coordinated to ensure independence, coupleteness, and accuracy.

t An essential part of the above is the method by which the independent reference sources were documented and used to ensure the independence of the

determination of characteristics of the information and control needs from the existing characteristics of equipment presently in the control room.

It appears that'Waterford 3 intends to meet the requirements of Supplement 1

] , to NUREG-0737. However, a't present, the contents of the Program Plan are not l detailed or complete enough to conclude that this requirement will be met. We recomend that the SFTA be included es an audit topic.

2.3. Control Room Inventory 1

l Supplemerit 1 to NUREG-0737 requires the licensee / applicant to make a control room inventory and to compare the operator display and control requirements determined from task analyses with the control room inventory to determine the suitability of existing controls and displays and identify those that are

! missing.

LP&L intends to perform an inventory using the direct observation method to

! compile a complete list of all control room instrumentation and controls. The inventory will be accomplished on a system-by-system basis. The inventory infomation will initially be recorded on a Control Room Inventory form and

! then transferred to a computer-based data management system. .

l The Program Plan discusses a verification process in which LP&L will verify I

the presence (or absence) of instruments and equipment in the control room. '

The description of the verification process is not sufficient to draw con-clusions about the adequacy of the process.

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, A validation process consisting of two phases is discussed. The initial phase will consist of a table-top walk-through and the second a control room table-top talk-through. The second phase is not to be conducted until the LP&L simulator is available. The simulator as stated in the Program Plan will not be available until 1986. I l

The methodology used in the LP&L verification and validation processes should be further explained. It is not clear from the Program Plan how the control room inventory, verification process, and validation process will be used to i

make comparison with the independent operator information and control needs identified in the SFTA. Description of the comparison process is needed. We recommend that the comparison process be included as an audit topic.

< G 2.4 Control Room Survey Supplement 1 to NUREG-0737 requires that a control room survey be conducted to f identify deviations from accepted human factors principles. NUREG-0700 provides guidelines and criteria for conducting a control room survey. The objective of the control room survey is to identify for assessment and possible correction, the characteristics of displays, controls, equipment, panel layout, annunciators and alarms, control room layout, and control room ambient conditions that do not conform to good human engineering practices.

1 The Waterford 3 plan states that an initial survey was conducted according to criteria in NUREG/CR-1580. A supplemental survey is to be conducted concentrating on the differences between NUREG/CR-1580 guidelines and I NUREG-0700 guidelines.

We recommend further explanation of the control room survey methodology be provided. This explanation should be adequately documented. Identification of which team members will conduct the control room survey would allow a j better understanding of the completeness and accuracy of the survey. We are l I

concerned as to how comprehensive the supplemental survey mentioned in the 4

Program Plan will be. We recommend the control room survey as an audit topic.

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2.5. Assessment of Human Engineering Discrepancies Supplement 1 to NUREG-0737 requires that HEDs be assessed to determine which

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HEDs are significant and should be corrected. NUREG-0700 contains guidelines for the assessment process.

The Waterford 3 Program Plan states that all HEDs generated as part of the DCRDR will be separated into nine major categories by the LHFS. Each one of these categories will be evaluated by an Assessment Team member. The progr m indicates each HED will be evaluated independently. Each HED will be assigned one of three priority levels as follows:

0 I Highest Significance - could substantially affect a safety system or '

operator response during an emergency situation.

J II Significant - could substantially affect or has substantially

affected a nonsafety system or operator response during routine '

nonemergency operation.

I!! Least Significant - could or has affected operator response in a nonsubstantial way.

The Program Plan states that an evaluation will also be conducted for the cumulative impact of Category III HEDs.

1 When all the independent evaluations are complete, the Program Plan indicates the Assessment Team will meet as a whole and discuss each HED. The l

methodology as discussed for HED assessment in the Program Plan indicates a sound and comprehensive approach to this task. We recommend explanation of who the members of the Assessment Team will be.

2.6. Selection of Design Improvements i J ~

Supplement I to NUREG-0737 requires selection of control room design 4

improvements that will_ correct significant HEDs. It also states that improvements that can be accomplished with an enhancement program should be done promptly.

1 The Waterford 3 Program Plan states the selection of recommended improvements i will be done by a DCROR HED Recommendation Review Committee. This committee will consist of the LHFS, the DPM, the I&C Engineer, representatives of the Station Project Engineer, and the Station Operations Engineer.

o The following is a list of the procedures the committee will follow as stated in the Program Plan.

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1. The committee will meet to review the HEDs, one at a time, and discuss each HED recommendation briefly to clarify any points of

, concern.

2. Using a rating system, each committee member will evaluate each recommendation on a number of factors. Among the factors will be-viability, soundness, and feasibility.

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The recommendation that is the most feasible will be the committee's preferred recommendation and will be submitted to the station 4

Operations ~and Engineering Departments for consideration.

4 l The committee may generate its own acceptable recommendations for I

those HEDs for which none of the proposed ' recommendations were acceptable. It will be the LHFS's responsibility to ensure that the recommendations developed and accepted by the committee are in accordance with applicable precepts of sound human factors engineering practice.

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1 Upon completion of the above process, the committee results will.be given to the Waterford 3 Operations and Engineering Departments. If a decision is made by Operations or Engineering not to accept any of the recommendations, a j

justification will be prepared and signed by the rejecting person and ,

alternatives will be examined.

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The Program Plan states the departments will develop an implementation i schedule predicated upon safety significance, availability of equipment.

outage time availability, and engineering design lead time.

The proc,ess, as described in the Program Plan, for selecting design

, inprovements appears adequate. The Sumary Report should include an inplementation schedule for the NRC's review. We recomend that an audit include a review of documentation of HEDs and corrective actions.

2.7. Verification that Design Improvements Provide the Necessary Correction I and Do Not Introduce New HE)s j Supplement 1 to NUREG-0737 requires that the licensee / applicant verify that i

selected design improvements will provide the necessary correction and will j not introduce new HEDs. The Program Plan does not specifically address these j issues as separate elements. We recommend that these items be an audit topic and that the steps taken to satisfy these requirements be described in detail in the Summary Report, f 2.8. Coordination of Control Room Improvements with Other Programs I

l Supplement 1 to NUREG-0737 requires that control room improvements be coordinated with changes from other programs; e.g., Safety Parameter Display System (SPDS), operator training, Regulatory Guide 1.97 (R.G.1.97) and j

Emergency Operating Procedures (EOPs). The program plan does not discuss specific methods and procedures to be used for the coordination effort. We recommend the licensee provide an explanation of methods and procedures used

to satisfy this requirement. This requirement should be included as an audit topic.

2.9. Other Topics l

i 2.9.1. Documentation and Document Control i

l The Waterford 3 plan describes a complex computer-based Database Management

! System (DBMS) which will be implemented to provide accessibility and auditability of DCRDR project data and files. The plan states the DPM and LHFS will manage the DRMS.

O 1he plan covers much of the data to be included in the DBMS and describes the

methods for accessing data and fer maintaining security of the system.

However, it is not clear whether the system has been formally established. We recomunend documentation of the operation and data access of the DBMS after implementation. This will allow'the NRC to fully understand the capabilities and function of the system, particularly the audit capability. We also

! recommend that LP&L maintain hardcopy files of original working documents throughout the DCRDR process.

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2.9.2. Operating Experience Review (0ER) i i

The Waterford 3 program plan states the OER consists of two tasks:

i j 1) An examination of both in-house and industry-wide historical

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l 2) A survey of control room operating personnel.

Waterford 3 lists the following documents from similar Combustion Engineering

Plants which will be reviewed as part of the OER.

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1) Licensee Event Reports (LERs) l l

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2) Significant Event Reports (SERs)

3) Significant Operating Event Reports (SOERs)

Review of these generic documents is, appropriate since Waterford 3 does not I

have any operating experience.

i The operations personnel survey will be an open-ended, self-administered questionnaire. The survey will provide coverage of the following nine topics.

e Workspace Layout and Environment -

e Panel Design e , Annunciator Warning System j g e Communications '

i e Process Computers

) e Corrective and Preventive Maintenance i

e Procedures e Staffing and Job Design e Training i

Waterford 3's methodology for the operating personnel surveys differs slightly from suggested guidelines. The method described in the Waterford appears '

sound and comprehensive, s'

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3. CONCLUSIONS Based upon our review of the LP&L Waterford 3 DCRDR Program Plan, we conclude that LPAL plans to conduct a DCRDR that generally meets the intent of Supplement 1 to NUREG-0737 Our review, however, identified several concerns which are listed below. In most instances, our concerns are that the Waterford 3 Program Plan generally describes what is planned, but does not

! include details of how the DCRDR will be accomplished; e.g.:

e Who is involved.

e Who is responsible for which tasks.

e - What disciplines are utilized.

O e The steps, processes, and methodologies used to guide the execution of the plan.

! e How task quality, completeness, and accuracy are checked and

verified.

The fo119wing items supplement the conenents and concerns already expressed in j

the body of this report. Numbers in parentheses refer to the sections of this i report.

4 A. Review Team (2.1)

Waterford 3 should maintain resumes detailing team member's specific

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experience. We are also concerned that human factors specialists be i

j actively involved in all phases of the DCRDR. The LP&L constitment to use human factors specialists needs to be further explained, i B. Function and Task Analysis (2.2) i i The Program Plan does not describe the SFTA in sufficient detail to

' allow a full understanding of the methodology used in determining j

plant-specific information and control needs. LP&L will need to l

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c have further documentation available for NRC review in order to complete the evaluation process. We recommend the SFTA as an audit

, topic.

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C. Control Room Inventory (2.3) t i

Waterford 3 needs to describe in sufficient detail the personnel, i

procedures, and methodology used to allow us to determine the accuracy and completeness of the process. We recommend this as an audit topic.

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! D. Control Room Survey (2.4)

- 1 We are concerned as to how comprehensive the Waterford 3 j supplemental survey will be. Identification of which team members will conduct the control room survey should be available to allow a

! better understanding of the depth, accuracy and completeness of the

• survey. Identification of the criteria to be used during the

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• supplemental survey to upgrade from NUREG/CR.1580 guidelines to NUREG-0700 guidelines is also needed.

i l E. Assessment of HEDs (2.5)

! We recomend an explanation of who the Assessment Team Members will  !

) be.

F. Selection of Design Improvements (2.6)

! An implementation schedule acceptable to the NRC should be contained j in the Sumary Report. We recommend that during an audit NRC evaluate j the acceptability of HED corrective action.

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G. Verification of Design Improvements (2.7) and Coordination with Other Programs (2.8)

These items were not specifically addressed in the Program Plan and should be covered in detail in the Sumary Report.

In order to resolve the concerns discussed above, we recommend that a DCRDR audit be conducted at Waterford 3.

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1. Detailed Control Room Design Review Program Plan for Waterford 3.

• September 28, 1984.

2. Supplement I to NUREG-0737 (Generic Letter 82-33), " Requirements for Emergency kesponse Capability," NRC, December 17, 1982.

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

1 4 NUREG-0801, " Evaluation Criteria for Detailed Control Room Design Refiews," NRC, (draft).

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5 Appendix A to Section 18.1 of NUREG-0800, Standard Review Plan, NRC, September 1984 1

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