ML20207L128
| ML20207L128 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/30/1986 |
| From: | Walton R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K584 | List: |
| References | |
| RTR-NUREG-0700, RTR-NUREG-700 208.1-(B), 208.1-(B)-R01, 208.1-(B)-R1, NUDOCS 8701090645 | |
| Download: ML20207L128 (23) | |
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,. TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (B) )
SPECIAL PROGRAM f REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 1 TITLE: HUMAN FACTORS !
Human Factors Review Program l NUREG-0700 PAGE 1 0F 22 REASON FOR REVISION:
Revised to incorporate TVA engineering coments.
PREPARATION PREPARED BY:
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/ DATE TAS: V qh ft$, h tM i8 Effi' l @C SIGNATURE DATE CONCURRENCES ,
- b. s !Lblfb CEG-H: U / d b 'E SRP: . /2-30 85 SIGNATURE DATE
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- SRP Secretary's signature denotes SRP cdnturrences are in files.
DATE APPROVED BY:
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- ICSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE l 8701090645 870102 l PDR ADOCK 05000327 P PDR
f I TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (B)
SPECIAL PROGRAM REVISION NUM8ER: 1 f-PAGE 2 0F 22
- 1. CHARACTERIZATION OF ISSUE (S):
Concerns: Issues:
OE-QM3-3 a. Control Room design review plan is "The program plan for control inadequate to find and resolve all l room design review is not problems affecting safe shutdown.
adequate to assure identifica-tion and resolution of all b. Human Factors Engineering has not human engineering concerns been implemented for control panels that could significantly affect or stations.
safe shutdown of TVA's nuclear plants." c. Human Factors Review has not been implemented for control panels WI-85-100-007 or stations.
" Human Factors Engineering and/or reviews have not been imple- d. There are too many poor engineering mented for control panels and practices in Human Factors area.
stations. CI expressed that this is a violation of NUREG- e. Possible violation of NUREG-0700.
f- 0700. CI further stated that
(. there are too many poor engi-neering practices in this area. CI has no further information. Anonymous concern via letter."
XX-85-122-020, -021, -022 "Sequoyah: Human Factors Engineering and/or reviews have not been implemented for control panels and stations.
CI expressed that this is a violation of NUREG-0700. CI further stated that there are too many poor engineering practices in this area.
CI has no further information.
Anonymoes concern via letter."
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? ( X NO Identified by TVA-SON-NSRS Date January 29. 1986
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (B) ,
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REVISION NUMBER: 1 PAGE 3 0F 22 Documentation Identifiers:
NSRS Investigation Report I-85-241-SQN, " Human Factors Control Room Design Review," for Employee Concern XX-85-122-020, (01/29/86)
- 3. DOCUMENT NOS.. TAG NOS. LOCATIONS. OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
No specific identification stated. Employee Concerns (ECs) relate to all active TVA nuclear plants on adequacy and conduct of control
- room design rev~ sws (CRDR), engineering design practices, and implementation of modifications.
- 4. INTERVIEW FILES REVIEWED:
WI-85-100 and XX-85-122. No additional information was found.
For concern OE-QMS-3 two memos discussing this concern were found (App. A, 5.g99, 5.hhh) v 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
- 6. WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REOUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA 7 See Appendix A.
- 7. LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
- 8. EVALUATION PROCESS:
I a. Reviewed baseline documents related to Human Factors l Engineering and review at SQN.
o FSAR l 0 NUREG-0700, NUREG-0801 I
o Regulatory Requirements, TMI actions, NUREG-0737 and NUREG-0737 Supplement 1
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- b. Determined project's Human Factors Engineering activities and status of those activities
- c. Considered significance or shortcomings in either the program
, or program status.
- d. Reviewed transcripts of NRC Investigative Interviews to gain additional information regarding the concerns.
- 9. DISCUSSION. FINDINGS. AND CONCLUSIONS:
Discussion:
- a. Background. Reauirements, and Procedures In November 1980 NRC published NUREG-0737, which presented i
those items from the TMI action plans of NUREG-0660 that NRC had approved for implementation as of that date.Section I.D.1 of NUREG-0737 states that ". . . all licensees and applicants for operating licenses will be required to conduct CJ a detailed control room design review to identify and correct
- design deficiencies."
I Subsequent to this requirement, NRC published NUREG-0700 in September 1981. This document presents detailed guidelines that NRC expects applicants to use when performing their l reviews. Although NUREG-0700 is not a requirement, NRC expects applicants to clearly document the approach to reviews and to justify any deviations. In addition to these two documents, NRC published NUREG-0801 in October 1981.
This NUREG presents the criteria NRC will utilize when evaluating an applicant's control room design review.
In January 1983 NRC issued Supplement 1 to NUREG-0737, which provided further clarification of details for the required control room design reviews.
A review of the transcript of the NRC interview of the concerned individual (CI) (App. A, S.tt) reveals that the CI commented that at the time he expressed his concern the control room reviews were not in progress, but that at the time of the interview he was aware that NUREG-0700 reviews were in progress at some of the plants. It is also clear from the transcript that the CI intended his concerns to include the human factors engineering of local control
( panels / stations as well as the main control room.
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SPECIAL PROGRAM REVISION NUM8ER: 1 PAGE 5 0F 22 The NRC requires a review of the control room only which they define in NUREG-0700 to include remote shutdown facilities.
- Thus this investigation has been limited to an examination of the TVA review of the main and auxiliary control rooms, and a few remote boards which contain switches required to transfer control from the main control room (MCR) to the auxiliary control room (ACR).
TVA's initial response (App. A, 5.q) to NUREG-0737 in 1980 indicated that they had conducted a preliminary design review of the Sequoyah control room, and participated in a review with NRC and its consultant, the Essex Corporation. Based on these reviews, several immediate modifications were made to the control room. TVA noted that they were required by license DPR-77 condition 2.C.22.c to complete a long-term control room design review prior to restart af ter the first s refueling outage. They further stated they would use NRC guidelines (NUREG-0700), when issued, in the long-term control room design review.
l g To meet the requirement in supplement 1 to NUREG-0737 for a detailed control room design review, TVA issued Special Engineering Procedure OE-SEP 82-17 in April 1983, titled L " Control Room Design Reviews for All TVA Nuclear Plants' (App. A, 5.e) which includes the main and auxiliary control rooms. This SEP was subsequently revised on May 2, 1984 and again on August 20, 1985. This plan was originally submitted to NRC on June 9, 1983 (App. A, 5.n) and NRC returned their comments on December 23, 1983 (App. A, 5.0).
In addition to providing their comments, NRC requested a meeting with TVA to discuss the review program. NRC was concerned about the task analysis portion and felt the requirements presented in Supplement 1 to NUREG-0737 would not be satisfied. Thus, a meeting was held on June 14, 1984 at which TVA presented their response to the NRC comments.
The TVA response presented to the NRC at this meeting is l; included with the TVA summary of the meeting (App. A, 5.aaa). The CRDR status report of April' 25, 1986 indicates l
- ( App. A, 5.nn) the program plan OE-SEP 82-17 was revised on U August 20, 1985 to incorporate NRC's comments. TVA SEP 82-17 incorporates the guidelines presented in NUREG-0700 but does !
not establish a schedule for completion as discussed in Section 2.6 of NUREG-0700. A tentative schedule was submitted to NRC in a meeting held in Bethesda, MD, on December 4,1984 ( App. A, 5.p).
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l Independent of these meetings, on June 15, 1984 NRC issued an order confirming licensing commitments on emergency response capability (App. A, 5.mm), requiring that TVA submit a Summary Report of their CRDR to NRC by November 1986 that includes proposed improvements and a schedule for imp'iementation.
In June 1985 the Office of Engineering issued new Engineering Program Directives (OEPs) that replaced the old Engineering Procedures Manual (EN DES-EPs), including OE-SEP 82-17.
Consequently, the CRDR is now under the Sequoyah Site Director and is controlled by SQN Standard Practice SQA-179 (App. A, 5.f). This procedure covers the details of the CRDR specific to Sequoyah, including descriptions of the detailed steps and worksheets to be used.
The Sequoyah procedure specifies that there is a clear distinction between review of the existing man / machine interface for human factor enhancements and the implementation of enhancements. Standard Practice SQA-179
& addresses the review function and the recommendation of
! enhancements only. These recommendations are to be reviewed and approved by plant management, who are also responsible for implementation. If any CRDR recommended modifications are not approved the site director must provide a justification (App. A, 5.f). The implementation of approved enhancements is then to be controlled by established TVA procedures.
The CRDR team is to develop an action plan that includes corrective actions for identified human engineering discrepancies (HEDs). The Sequoyah Site Director will be responsible for final disposition of this plan and is to use this plan to devel a the summary report to NRC.
There are several TVA engineering procedures in place to guide the implementation of any control room modifications that may result from the CRDR.
Division of Nuclear Engineering Procedure NEP-6.1, " Change Control" (App. A, 5.pp), de 'ines the process by which plant design changes, including tuntrol room design changes, are to be identified, scoped, coordinated, reviewed, and approved.
This procedure includes the application of human factors engineering principles in these changes and requires the project engineer to coordinate the design and design review
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effort with apprcpriate DNE organizations. A checklist is provided in the procedure to aid in this process. All future changes to TVA Nuclear Plant control room / control boards are to be handled by this procedure.
Prior to inception of this procedure, and more specific to control room design, the Division of Engineering Design applied procedure EN DES-EP 3.36, (App. A, 5.uu). This procedure directed the Electrical Engineering Support Branch (EEB) to conduct a review for human factors engineering of
- any design change to a nuclear power plant main control room or auxiliary control room. However, this EP was cancelled in 1985 along with the other EPs. The Electrical Engineering Branch (EEB) presently has proposed another procedure, which has not yet been approved for use. This new procedure (App.
A, 5.kk) will require a human factors review for future changes to the main control room, the auxiliary control room, or local control stations.
The DNE EEB, Operator Interface Section, presently has the
, g; responsibility to address the application of human factors 1 0 engineering principles in control room / control board changes. A number of engineering design guides are used in this process (App. A, 5.g. 5.h, 5.1, 5.j, 5.k).
A review of these design guides by the evaluation team indicates that the necessary features to provide proper human factors designs are addressed and that these procedures are adequate to assist in any modifications that may be required in the control room (App. A, 5.qq).
- b. Control Room Design Review Program Plan i Employee concern OE-QMS-3 questioned the adequacy of the Control Room Design Review Program Plan (DE-SEP 82-17) to i
identify and resolve all human engineering concerns that could significantly affect the safe shutdown of TVA's Sequoyah Nuclear Plant.
1 The evaluation team has reviewed the program plan as a basis l' for conducting CRDR and evaluated its adequacy for identifying human factors concerns and human factors
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discrepancies, and for proposing modifications to resolve
< these. The results of the CRDR will be contained in a
! Summary Report to the NRC, which will present TVA's proposed modifications and a schedule for implementation.
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PAGE 8 0F 22 Also, it should be noted that although the CRDR has been completed, the program plan was evaluated for its adequacy as a plan; implementation of the plan was not addressed. The program plan (SP SQA-179, R1) was approved for use on May 21, 1986 and supersedes an earlier generic TVA program plan.
This earlier generic program plan was the subject of comments by the staff'of the NRC Licensing Division on December 23, 1983, and the current plant-specific SQA-179, R1 encompasses consideration of these comments as discussed above.
The essence of this standard practice:
o States that the program plan addresses the man-machine interfaces of the MCR, the ACR, and the transfer devices, thus encompassing the control room as defined in NUREG-0700.
o Establishes the responsibility of all employees to identify operational and procedural matters requiring correction. Although this does not relieve the CRDR team
, from its responsibility to identify HECs, it does improve the probability of discovery o Provides guidance that is essentially a copy of NUREG-0700 guidelines. As such, the plan encompasses the basic requirements for a complete and comprehensive review process o Gives a listing of the required documentation, which could readily serve as a road map for the conduct of a CP9R and a checklist to ensure that necessary steps in t..e process were completed. It thus adds further assurance that appropriate action has been taken to '
j identify HECs and that they have been assessed and resolved 1 Coordination and integration of related programs are tabulated and discussed in detail. These are sufficient to establish a program of required activities. The task analysis portion of the CRDR will evaluate the human factors aspects of the tasks of performing all the emergency operating procedures (EOPs). The development of the E0Ps is part of the Procedure Generation Package that has been developed by the E0P team. The coordination of Emergency Operating Procedure (EOP) and CRDR teams in SQA-179 is clear and provides a viable delineation of responsibilities. The methodology described for verification and validation of
(. procedures using a simulator operating under a dynamic I
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PAGE 9 0F 22 environment addresses earlier NRC staff comments. This approach is consistent with typical methods for assessing the ability of operators to demonstrate their operating skills and effectiveness. The list of.35 E0Ps has been provided separately to this evaluation team (App. A, 7.g). After examining this list it is the judgment of the evaluation team i that it meets the intent of NUREG-0737 Supplement 1 for l analysis of emergency procedures. '
The compcsition of the CRDR team is in accordance with NUREG-0801. The list of actual team members is not included l for the plant-specific program plan. However, the team
, members and their backgrounds are listed in the status report of April 25, 1986 (App. A, 5.nn). Based on these data; the ,
team composition, which includes some who are well known by reputation, their educational and experience qualifications are considered appropriate for the designated assignments.
The CRDR team management and responsibility of the review team leader is in accordance with NUREG-0801. In fact, e Table 1 of the CRDR program plan is essentially a copy of NUREG-0801, Exhibit 2-1.
SQA-179 references the basic standards in common use in industry and government as well as throughout the nuclear power industry. Appendix A of SQA-179 is a copy of Section 6.0 of NUREG-0700 and as such forms a guideline for the conduct of a CROR.
I The training and preparation of the CRDR team are included in the CRDR program plan. In addition to including the guidelines of NUREG-0700, the CRDR plan SQA-179 also considers such items as:
i o Control / display integration o Feedback of control activation l
o Safe and efficient movement of personnel during task performance o Suf ficiency of staf f for crew workload distribution o Sequential grouping of controls and displays The checklists and instructions presented in SQA-179 have p their origins in standard accepted references in the field.
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SPECIAL PROGRAM REVISION NUMBER: 1
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- c. Performance of the Control Room Desian Review The TVA program plan for the CRDR consists of eight main tasks. These are:
o Develop the CRDR plan o Perform an operator experience review o Survey the main control room (MCR) and the auxiliary control room (ACR) 4 o Perform task analysis o Assess for priority o Develop recommendations for corrective action o Prepare an action plan o Prepare the Summary Report for NRC I
The development of the CRCR plan took place during the period from November 1980, when NRC issued the TMI Action Plan (NUREG-0737), until the end of 1984. During this period several discussions were held with NRC as described above, and the plan was developed. The final revision to the CRDR plan (DE-SEP-82-17) occurred in August,1985 ( App. A, 5.e),
at which time NRC comments and the lessons learned from having initiated the program were incorporated ( App. A, 5.nn).
The actual implementation of the program began August 23, 1983, when a training course on human factors was conducted for the CRDR team members (App. A, 5.11). The review of l operator experience was conducted in several steps.
Initially the operators completed a basic questionnaire and the results were used to develop an addendum to the questionnaire. This new questionnaire was then given to the operators, who the CRDR team felt could best provide answers ]
(App. A, S.nn).
In addition to using questionnaires, the CRDR team interviewed 17 operators after having first received instruction in effective interview techniques from a consultant human factors specialist.
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PAGE 110F 22 For the survey of industry experience, the team reviewed an INPO sort of Licensee Event Reports (LERs), Significant Event Reports (SERs), and INP0 Operations and Maintenance Reminders (0MRs) involved either directly oi indirectly with control room design or control room operators. A detailed review was also performed of all Sequoyah LERs and reactor trips to identify any with control room or operator involvement.
Finally, the results of the CRDR effort at Watts Bar were also reviewed for applicability to Sequoyah. These efforts were completed in March 1986.
Surveys of the MCR and the ACR were initiated in September 1984. The associated tasks of performing a sound survey, a lighting survey, and a survey of the HVAC for the MCR were completed during 1984 and 1985 (App. A, 5.x). The MCR/ACR surveys were completed in March 1986.
The CRDR team performed a task analysis for all emergency operating procedures (EOPs) identified for SQN. There were 35 E0Ps, which had been developed by the site E0P team and
< were analyzed by the CRDR team. The task analysis was l
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completed in April 1986 (App. A, 5.nn).
In March'1986 the Essex Corporation (Essex) reviewed the Sequoyah CRDR documentation (App. A, 5.vv). Essex reviewed only the documentation related to the operating experience review, the control room surveys, and the task analysis, as the remaining portions of the CRDR were not complete. Based on their review, Essex concluded that the SQN CRDR documentation is responsive to the guidelines of NUREG-0700; adequately describes the HECs; and provides a track to data collection methods and NUREG-0700 guidelines. The report summarized the documentation as ". . . adequate and, when complete, should provide an adequate basis for control room design improvements and for NRC audit." The report also mentioned that Essex would work with the CRDR team to develop additional task analysis information. In addition to reviewing CRDR documentation, Essex has also provided consulting services in essentially all phases of the CRDR since February 1986, including significant participation in the preparation of the Summary Report (App. A, 7.b). In November 1986, on completion of the Summary Report, Essex provided a summary evaluation of the TVA CRDR program in which they commented:
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. . . TVA has structured and implemented a comprehensive program to identify and resolve those issues which, from a human factors prespective, could adversely impact plant safety and operations. In so doing, we feel that TVA has complied with regulatory requirements as presented in NUREG 0700 and NUREG 0737, Supplement 1." (App. A, 5.jjj)
At the time of the last status summary in April 1986~
! (App. A, 5.nn) priority assessment, corrective action recommendation, and action plan preparation were expected to be completed by August 1986. As of this evaluation these tasks have been completed, the preparation of the Summary
, Report is in progress (App. A, 7.b), and TVA expects to caet the November 1986 date as ordered by NRC (App. A, 5.mm).
(Post Evaluation Note: The Summary Report was actually transmitted to the NRC on 11/26/86; App. A, 5.kkk)
A possible contributing factor to the concerned individual thinking the control room design review was not in progress
,~ is the length of time which elapsed between the NRC issuing U the requirements and any visible activity of the review.
Part of the reason given for the length of time the CRDR team has taken to perform their review was a lack of manpower committed to perform the necessary assignments, as pointed out by memo ( App. A, 5.x) in September 1985. This problem was further clarified in October 1985 (App. A, 5.rr) as being due to the CRDR team management structure. In December 1983, prior to the development of the Office of Power and Engineering and the owner / operator concept, NUC PR requested that the CRDR team have a co-manager and a co-team leader from NUC PR. Under this arrangement, the co-managers and co-team leaders lacked direct control of the team members' assignments because they had no administrative responsibility over the individual team members.
This structure also increased the dif ficulty of coordinating technical and schedule issues. In addition to these direct effects of the management structure, and the fact that the members were not dedicated to the CRDR activity, the individual CRDR team member's immediate supervisor would of ten redirect the individual to other activities the supervisor felt were the individual's primary responsibilities (App. A, 5.rr).
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PAGE 13 0F 22 NRC had been concerned about these deficiencies in the management of the CRDR ef fort as early as November 1984 (App. A. 5.z). Due to the inconsistencies of TVA's reports on the status of the Watts Bar control room modifications, NRC felt this was a serious deficiency in the management of the CRDR team. NRC was concerned that no one individual was responsible for CRDR within TVA.
In February 1986 the co-manager, co-team leader structure was replaced by a single manager and a single team leader. Since that time the CRDR team has been operating with this structure.
- d. Engineering Practices
, The employee concern issue "d" alleges that "there are too many poor engineering practices" relative to human factors.
This is a vague and subjective expression of concern, the validity of which can only be determined by a detailed review of the human factors engineering design. In the transcript of the NRC interview with the concerned individual (CI) (App.
t A, 5.tt), the CI expressed his concern for the Watts Bar plant and made the assumption that Sequoyah is designed exactly like it in many areas. The assessment of the control room design by the CRDR team will provide the basis for resolving this EC.
l During the early 1970s, when the Sequoyah control room was designed, no specific human factors design guidelines were available for consultation by the design engineers. At that time a design engineer had to rely on a few military standards, a personal understanding of how the system functioned, whatever experience the engineer and coworkers had from other plants, and, of course, the NSSS supplier. It was common in the industry to have the NSSS supplier also supply the control room, with coordination from the utility,
- or perhaps to bring in an outside consultant. It is only l recently that NUREG-0700 and numerous studies relating to human factors engineering in nuclear power plant control rooms have become available.
Findings:
- a. Standard Practice SQA 179, I t was reviewed by the evaluation team for adequacy to serve a, a program plan for CRDR of the Sequoyab Nuclear Plant. This document describes a program k
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PAGE 14 0F 22 which when implemented properly will be adequate to achieve the objective of identifying and resolving human engineering concerns that could significantly affect the safe shutdown of TVA's nuclear plant.
- b. Human factors engineering resulting from the CRDR has not yet been implemented for the Sequoyah control room. The Summary Report of the.SQN CRDR due to NRC in November 1986* is required to contain recommendations for modifications to the control room. The Summary Report is also required to present a schedule for implementing the modifications. TVA has engineering design guides to assist with the engineering of changes that will be required in the control room.
- c. The human factors review of the Sequoyah control room required by NUREG-0737 Supplement 1 was initiated in 1983 and has been completed. The Summary Report of the CRDR was transmitted to the NRC in November 1986 as required by the confirmatory order.
f d. The poor engineering practices in the human factors area are t identified in the 1399 human engineering concerns (HECs) identified by the CRDR (App. A, 7.b). The assessment of these HECs resulted in 455 human engineering discrepancies (HEDs) which will require some corrective actions.
- The application of human factors engineering principles for future TVA engineering design activities is specified and controlled by NEP 6.1 (App. A, 5.pp). Although EP 3.36 (App.
l A, 5.uu), which was a procedure specific for human factors engineering, was cancelled in 1985, the EEB has proposed another procedure to replace it. This new procedure will require a human factors review for future changes to the main control room, the auxiliary control room, or local control stations.
- e. NUREG-0700 provides guidance for licensees when conducting a CRDR. This NUREG does not define a regulation and as such cannot be violated. In fact NUREG-0700 allows alternative approaches as long as deviations are identified and justified. The requirement to conduct a CRDR is contained in NUREG-0737 Supplement 1 (Generic Letter 82-33). TVA has conducted the required CRDR, has complied with the guidance of NUREG-0700, and the program plan has been reviewed and commented on by NRC.
p
- The report has been transmitted to the NRC on 11/26/86 (App. A, 5.kkk) l ,
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 15 0F 22 Conclusigns:
- a. Issue "a" that the CRDR plan is inadequate is not valid. The l evaluation team concludes that SQN CRDR program plan as described in Standard Practice SQA-179 is adequate. I
- b. Issue "b" that human factor engineering has not been implemented is valid; however, human factors engineering for the control room is presently in progress as part of the development of corrective actions for the HEDs identified in the CRDR. Implementation of the corrective actions to be recommended in the Summary Report of the CRDR should provide resolution for this issue.
- c. Issue "c" regarding human factors reviews is valid in that the control room design review had not been completed at the time of the expressed employee concern. Also, the time of performance of the review has been rather lengthy, considering that NUREG-0737, which requires the review, was issued in November 1980 and the review was not completed 7- until November 1986. However, the human factors review of
( the control room has been conducted and the Summary Report of that activity should provide satisfactory resolution of this issue.
- d. Issue "d" regarding poor engineering practices is valid, based on the fact that the CRDR team identified 1399 HECs, of which 455 were assessed as HEDs. Implementation of the corrective actions that are recommended in the Summary Report of the CRDR should provide adequate resolution of poor engineering practice in the control room. TVA also has procedures in place and proposed to address human factors
! engineering in future design changes.
- e. Issue "e" that NUREG-0700 has been violated is not valid because NUREG-0700 is not a requirement and cannot be violated. TVA has conducted a CRDR as required by NUREG-0737 Supplement 1.
- 10. CORRECTIVE ACTION:
No corrective action is required.
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PAGE 16 0F 22 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. NUREG-0737, " Clarification of TMI Action Plan Requirements,"
November 1980,Section I.D.1, " Control Room Design Reviews"
- b. NUREG-0737, Supplement 1, " Clarification of TMI Action Plan Requirements," (01/83)
- c. NUREG-0700, ' Guidelines for Control Room Design Reviews," ,
(09/81)
. d. NUREG-0801, " Evaluation Criteria for Detailed Control Room Design Review," Draft Report for Comment, (10/81)
- e. TVA, Office of Engineering, Special Engineering Procedure OE-SEP 82-17. " Control Room Design Reviews for All TVA Nuclear Plants," R2, (08/20/85) c f. Sequoyah Nuclear Plant Standard Practice SQA-179, " Conduct of U the Detailed Control Room Design Review and other Major Human L
Factor Reviews at Sequoyah Nuclear Plant," R1, (05/21/86)
- g. EN DES Design Guide E18.1.11. " Human Factors Engineering in Design of Operator Work Stations," R0, (05/11/82)
- h. EN DES Design Guide E18.1.12, " Human Factors Engineering in
- Control Console, Cabinet, and Panel Layout," R0, (04/30/82)
- 1. EN DES Design Guide E18.1.13, " Human Factors Engineering in Alarm Systems," R0, (07/16/82)
- j. EN DES Design Guide E18.1.14, " Human Factors Engineering in Controls and Visual Displays," R0, (04/30/82)
- k. EN DES Design Guide E18.1.15, " Human Factors Engineering in Operator / computer Interface and Dialog," R0, (05/19/82)
- 1. NSRS Investigation Report I-85-241-SQN, " Human Factors Control Room Design Review," (01/27/86) k 02480 - 12/04/86
. TVA EMPLOYEE CONCERNS REPORT.NUM8ER: 208.1 (8)
SPECIAL PROGRAM
. REVISION NUMBER: 1 PAGE 17 0F 22 APPENDIX A (Cont'd)
- m. NSRS Investigation Report I-85-471-BFN, " Human Factors Control Room Design Review," (01/31/86) i
- n. Letter from D. S. Kammer, TVA, to E. Adensam, NRC, "TVA's Generic Control Room Design Review Program Plan,"
(A27 830609 001), (06/09/83)
- o. Letter f rom T.M. Novak, NRC, to H. G. Parris, TVA, "[NRC) l Comments on TVA Program Plan for Control Room Design Reviews," (A02 831229 001), (12/23/83)
- p. TVA memo from S. D. Love to Nuclear Engineering Branch Files, "All Nuclear Plants - Meeting to Discuss Efforts by TVA to Address Safety Evaluation Report (SER) Concerns in the Control Room on Watts Bar and Implications to Generic Control i Room Design Review Efforts," (NEB 850107 261), (01/07/85)
- q. Letter from Mills, TVA, to Schwencer, NRC, "Open NUREG-0737
- c. - items on SQN," (A27 801219 022), (12/29/80) t .'
- r. TVA memo from Coffey to Mills. " Browns Ferry, Sequoyah, Watts Bar, and Bellefonte Nuclear Plants - Preparation of Responses to NRC Comments on The TVA Program Plan for Control Room Design Reviews," (L28 840321 888), (04/05/84)
I
- s. TVA memo from Darling to Cantrell, "SQN - Human Factors Control Room Design Review (CRDR) - Meeting Minutes -
Division of Engineering Design (EN DES) and Office of Nuclear Power (NUC PR)," (DES 840612 012), (06/08/84) l t. TVA memo f rom Martin to Electrical Engineering Files, "SQN-
, Control Room Design Review (CRDR) - Meeting Notes,"
l (EEB 840709 923), (07/06/84)
- u. TVA memo from Darling to Cantrell, "SQN - Offices of Nuclear Power (NUC PR) and Engineering (OE) - Human Factors Control Room Design Review (CRDR) - Meeting Minutes,"
(L28 841012 895), (10/26/84) l l
02480 - 12/04/86 l
t _ -. -
9
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 1
(
PAGE 18 0F 22 APPENDIX A (Cont'd)
Control Room Design Review (CRDR) - Meeting Notes,"
(EE8 841019 901), (10/17/84)
Control Room Design Review (CRDR) - Completion of Phase 1 and 2 - Remaining Work," (L28 850801 917), undated
Control Room Design Review (CRDR) - Status Meeting (Telephone Conference)," (B43 850920 938), (09/12/85)
- y. TVA memo from Hutton to Teague, "SQN - Control Room Design Review (CRDR)," (L33 840619 802), (06/21/84)
- z. Letter from Novak, NRC, to H. G. Parris, TVA, " Request for Meeting to Discuss the Control Room Design Review for TVA Nuclear Facilities," (L44 841127 353), (11/19/84)
( aa. TVA memo from Vineyard to Rankin, "SQN and WBN - Emergency Operating Procedures (EOP) Procedure Generation Package (PGP)," (843 851031 916), (10/31/85) bb. TVA memo f rom Brickey to Electrical Engineering Files,
" Control Room Design Review (CRDR) - All Nuclear Plants,"
(B43 850911 901), (09/10/85) cc. TVA memo from Vineyard to Rankin, "SQN - Control Room Design Review (CRDR) - Task Analysis," (B43 850514 903), (05/10/85) dd. TVA memo from Abercrombie to Hutton and Vineyard, "SQN -
Control Room Design Review (CRDR) - Task Analysis,"
t (S01 850228 883), (03/01/85) ee. TVA memo from Vineyard to Rankin, "SQN - Control Room Design
! Review (CDRD) Task Analysis," (EEB 850129 903), (01/25/85) ff. TVA memo from Abercrombie to Hutton and Vineyard, "SQN -
Control Room Design Review (CRDR) - Task Analysis,"
(S01 850109 966), (01/14/85) l gg. TVA memo from Wallace to These Listed, "All Nuclear Plants -
Emargency Procedure Generation and Task Analysis,"
(L33 840601 805), (06/11/85)
I k l
j 02480 - 12/04/86 i
_ _ _ _ _ . . _ _ _ . _ _ _ _ _ . - . - - _ ~ .- __ _
,, TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (8)
SPECIAL PROGRAM REVISION NUMBER: 1
(
PAGE 19 0F 22 APPENDIX A (Cont'd) hh. TVA memo from Zinsnerman to Electrical Engineering Files, "Sequoyah Nuclear Plant Main Control Room (MCR) Sound / Noise Survey," (EEB 850114 938), (01/10/85)
, ii. TVA memo from Baumgartel to Electrical Engineering Files, "Sequoyah, Watts Bar, and Browns Ferry Nuclear Plants -
Control Room Design Review (CRDR) - Core Review Team
, Training - Human Factors Training Course," (EEB 830912 928),
(09/09/83) jj. TVA memo from Chandler to Vineyard, "SQN - Control Room Design Review (CRDR)," (843 851218 914), (12/17/85) kk. SQN Proposed Human ~ Factors Engineering Review Instructions
Generic Letter 82-33," (A27 830115 016), (04/15/83) nun. SQN letter from Adensam, NRC, to Parris, TVA, " Confirmation
, and Order on Emergency Response Capability,"
(A02 840620 001), (06/15/84) nn. SQN memo from Martin to CRDR Files, "SQNP - Status of CRDR,"
(not sent to RIMS), (04/25/86) i oo. SQN CRDR Schedule, (02/25/86) pp. Division of Nuclear Engineering, Nuclear Engineering Procedure NEP-6.1 (was OEP-ll), " Change Control," R0, (07/01/86) qq. Bechtel memo from D. L. Damon to W. E. Purcell, "TVA Concern l #208, Human Factors Issues," ION #189,(06/17/86) rr. TVA memo from C. F. Dilworth to J. W. Hutton, " Control Room Design Reviews (CRDR) - All Nuclear Plants,"
(B43 851010 923), (10/09/85) l ss. Letter from B. J. Youngblood, NRC, to S. A. White, TVA, i
" Concerns Regarding the TVA Nuclear Program," (A02860224020),
(02/18/86) tt. Letter from B. J. Youngblood, NRC, to S. A. White, TVA, l " Transcript of Interview of Dallas R. Hicks," (06/23/86) k i
02480 - 12/04/86
+ ', TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 20 0F 22 APPENDIX A (Cont'd) uu. TVA Engineering Procedure EN DES-EP 3.36, " Operator Interface Design Changes," R2, (ESB 840719 205), (07/23/84) vv. Memo from H. P. Van Cott, Essex Corp., to J. R. Walker, TVA,
" Review of Sequoyah Nuclear Plant (SNP) Control Room Design Review Documentation," Essex Control #00798/7/86, (03/28/86, revised 04/09/86) ww. TVA memo from F. W. Chandler to J. A. Raulston, " Control Room Design Review (CRDR) - All Nuclear Plants," (B43 850522 927),
(05/21/85) xx. Letter from T. J. Kenyon, NRC, to TVA, (A02 850107 012),
(12/27/84) yy. Letter f rom T. M. Novak, NRC, to H. G. Parris, TVA, "Draf t Safety Evaluation Report Regarding the Procedures Generation Package for the Watts Bar and Sequoyah Nuclear Plants,"
(A02 850724 005), (07/22/85) zz. TVA, Sequoyah Nuclear Plant, Employee Concerns Task Group, Operations, CEG, Subcategory: Accessibility, Element:
Accessibility Problems, Report Number: 305.01 - SQN, R1 aaa. TVA memo from M. C. Brickey to Electrical Engineering Files,
" Main Control Room Design Review - All Nuclear Plans,"
(EEB 840626 927), (06/22/84) bbb. INP0/TVA Pilot Systems Review, INP0 82-014, (06/82) ccc. Human Engineerina Principles for Control Room Design Review, INPO 83-036(NUTAC), (09/83) ddd, Control Room Design Review Survev_ Development Guideline, INP0 83-042(NUTAC), (11/83) eee. Control Room Design Review Task Analysis Guideline, INP0 83-046(NUTAC), (12/83) fff. Potential Human Factors Deficiencie: in the Design of Local Control stations and Operator Interfaces in Nuclear Power Plants, Pacific Northwest Laboratory, NUREG/CR-3696, PNL-4952, April 1984 k
02480 - 12/04/86
, TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 t
1 PAGE 21 0F 22 i'
APPENDIX A (Cont'd) ggg. TVA memo f rom E. J. Sheehy to Nuclear Engineering Branch Files, "All Nuclear Plants - Unresolved Comments on Program Plan for Plants (Special Engineering Procedure SEP 82-17),
(845 850802 256), (08/02/85) hhh. TVA memo from F. W. Chandler to John A. Raulstog "All Nuclear Plants - NEB Employee Concern on the Program Plan for Control Room Design Review (CRDR) of TVA's Nuclear Plants,"
(843 850919 903), (09/13/05) iii. TVA Telecopy to Bechtel 11/06/86, 19:23, TVA Comments on j Bechtel Report 208.1 (B) Prelim.
jjj. Letter from H. D. Van Cott, Essex Corp., to W. S. Raughley, TVA, Essex Control #00798/47/86, (11/13/66) kkk. Letter f rom R. Gridley, TVA, to B. Youngblood, NRC, "Sequoyah Nuclear Plant - Detailed Control Room Design Review,"
(L44 861126 809), (11/26/86)
- 6. WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REQUIREMENTS OR OTHER
-APPLY OR CONTROL IN THIS AREA 7 NUREG-0737, " Clarification of TMI Action Plan Requirements,"
November 1980, and Supplement 1, December 1982. NUREG-0737 states,
. . . all licensees and applicants for operating licenses will be required to conduct a detailed control room design review to identify and correct design deficiencies."
NUREG-0700, " Guidelines for Control Room Design Reviews," September 1981. This NUREG-0700 provides the guidelines to assist the licensees and applicants for operating licenses in performing the control room design reviews required by NUREG-0737.
NUREG-0801, " Evaluation Criteria for Detailed Control Room Design Review," October 1981. This NUREG-0801 is not a requirement but presents the criteria NRC will utilize when evaluating the applicant's detailed control room design review required by NUREG-0737.
Special Engineering Procedure OE-SEP 82-17, " Control Room Design Reviews for All TVA Nuclear Plants," R2, (08/20/85) (originally '
issued R0, 04/12/83)
Sequoyah Nuclear Plant Standard Practice SQN 179, " Conduct of the Detailed Control Room Design Review and Other Human Factor Reviews at Sequoyah Huclear Plant," R1, (05/21/86) 02480 - 12/04/36
.= )
,, TVA EMPLOYEE CONCERNS REPORT NUMBER: 208.1 (8) l SPECIAL PROGRAM
~ REVISION NUMBER: 1 PAGE 22 0F 22 APPENDIX A (Cont'd)
NRC Order Confirming Licensee Commitments on Emergency Response Capability, Dockets 50-327 and 50-328, (06/15/86)
EN DES Guide E18.1.11, Human Factors Engineering in Design of Operator Work Stations, R0, (05/11/82)
EN DES Guide E18.1.12, Human Factors Engineering in Control Console, Cabinet, and Panel Layout, R0, (04/30/82)
EN DES Guide E18.1.13. Human Factors Engineering in Alarm Systems, R0,(07/16/82)
EN DES Guide E18.1.14, Human Factor Engineering in Controls and Visual Displays, R0, (04/30/82)
EN DES Guide E18.1.15 Human Factors Engineering in Operator / Computer Interface and Dialog, R0, (05/19/82)
- 7. LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIDNS RELATED TO ELEMENT.
- a. W. E. Purcell, personal visit to Knoxville, TN, (08/27,28/86)
- b. Telecon, W. E. Purcell, Bechtel, to P. B. Nesbitt/J. A.
Martin, .TVA, (10/14,15/86)
- c. Telecon, W. E. Purcell, Bechtel, to P. 8. Nesbitt, TVA, (10/27/86)
- d. RFI, #SQN 652, (10/22/86)
- e. Telecon, W. E. Purcell, Bechtel, to P. 8. Nesbitt, TVA,
. (10/23/86)
- f. RFI #SQN-659, (10/23/86)
- g. TTB 140, Item 3, (10/28/86) l L
02480 - 12/04/86
g I '
C) .' ,
REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -
69 * .
FREQUENCY - REQUEST OFFICE OF I4UCLEAR P0HER RUN TIME - 12:57:19 *
() ONP - ISSS - RHM EMPLOYEE CONCERil PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN IllFORMATION CATEGORY: EN DES PROCESS 8 OUTPUT SUBCATEGORY: 20801 HUMAN FACTORS REVIEH PROGRAM
() S GENERIC KEYHORD A H APPL QTC/NSRS P KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN. .
KEYWORD C
) NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTI0tl KEYHORD D OE-QMS-3 EN 20801 N HBN YYYY SS THE PROGRAM PLAN FOR CONTROL ROOM DE K-FORM SIGN REVIEH IS NOT ADEQUATE TO ASSUR
() E IDEllTIFICATION AND RESOLUTION OF A LL HUMAtl ENGINEERING CONCERNS THAT C
)
OULD SIGNIFICANTLY AFFECT SAFE SHUTD i OHN OF TVAS NUCLEAR PLANTS.
() HI 100-007 EN 20801 N HBN YYYY SR HUMAN FACTORS ENGINEERING AND/OR REV STANDARDS l T50211 K-FORM IENS HAVE NOT BEEN IMPLEMENTED FOR C NONCONFORMANCE I ONTROL PANELS AND STATIONS. CI EXPR ENGIllEERING l O ESSED THAT THIS IS A VIOLATION OF NU GENERAL REG -0700. CI FURTHER STATED THAT T HERE ARE TOO MANY POOR ENGINEERING P RACTICES IN THIS AREA. CI HAS NO FU O RTHER INFORMATION. ANONYMOUS CONCER N VIA LETTER. l l
XX 122-020 Ell 20801 fl SQN YYYY t-85-241-SQfi SS SEQUOYAH: HUMAN FACTORS ENGIrlEERIllG STAT 3DARDS T50214
() REPORT AND/OR REVIENS HAVE NOT BEEli IMPLEME NTED FOR C0t1 TROL PANELS AND STATIONS NONC0f1FORMANCE ENGIllEERING
. CI EXPRESSED THAT THIS IS A VIOLA GENERAL TI0tl 0F NUREG -0700. CI FURTHER STA
() TED THAT THERE ARE TOO mat 4Y POOR Et1G INEERING PRACTICES III THIS AREA. CI HAS NO FURTHER INFORMATION. ANONYM OUS CONCERN VIA LETTER.
C) XX 122-021 EN 20801 N BLN YYYY I-85-439-BLN SR BELLEFONTE: HUMAN FACTORS EllGINEERIN STANDARDS T50214 REPORT G AND/OR REVIENS HAVE fl0T BEEN IMPLE fl0NCONFORMANCE MENTED FOR CONTROL PANELS AND STATIO El1GINEERING
() NS. CI EXPRESSED THAT THIS IS A VID LATION OF NURFG -0700. CI FURTHER S GENERAL TATED THAT THERE ARE TOO MANY POOR E IJGINEERING PRACTICES Ill THIS AREA. i
() CI HAS NO-FURTHER IllFORMATIOil. Alloti l YMOUS CONCERN VIA LETTER. '
"" XX 122-022 Ell 20801 11 BFil YYYY I-85-471-BFN SR BROHN'S FERRY: HUMAtt FACTORS ENGINEE STANDARDS T50214
() REPORT RING At1D/OR REVIENS HAVE fl0T BEEN IM PLEMENTED FOR CONTROL PANELS AllD STA NONC0f1FORMANCE EllGINEERING TIONS. CI EXPRESSED THAT THIS IS A GEllERAL VIOLATION OF 11UREG -0700. CI FURTHE C) R STATED THAT THERE ARE TOO MANY P00 R El1GINEERIllG PRACTICES Ill THIS AREA
. CI HAS NO FURTHER INFORiiATION. A 7 N0tlYMOUS C0tiCERil VIA LETTER.
() 5 C0tiCERNS FOR CATEGORY EN SUBCATEGORY 20801 1
C) i I
.O
-- - I