ML20212H371

Technical Evaluation of Dcrdr for Millstone Nuclear Power Station,Unit 2

ML20212H371
Person / Time
Site:	Millstone
Issue date:	01/14/1987
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20211C650	List: ML20212H371
References
CON-NRC-03-82-096, CON-NRC-3-82-96, RTR-NUREG-0660, RTR-NUREG-0737, RTR-NUREG-660, RTR-NUREG-737, TASK-1.D.1, TASK-TM SAIC-86-1997, TAC-56139, NUDOCS 8701210377
Download: ML20212H371 (25)

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SAIC-86/1997 TECHNICAL EVALUATION .

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OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR THE MILLSTONE NUCLEAR POWER STATION, UNIT 2 S

b January 14, 1987

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Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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j l repared by:

v{ I Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102

FOREWORD This Technical Evaluation Report (TER) documents the findings of a review of Northeast Utilities' (NU) Detailed Control Room Design Review

.(DCROR) for its Millstone Nuclear Power Station, Unit 2. Science Applications International Corporation's evaluation was performed in support of the Nuclear Regulatory Commission under contract NRC-03-82-096, Technical Assistance in Support of Licensing Actions: Program III. SAIC previously participated in the review of the Program Plan, an on-site meeting, review of the Summary Report, and a pre-implementation audit.

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TABLE OF CONTENTS Section EARR BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . .* . .

1 PLANNING PHASE . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

1. Qualifications and Structure of the DCRDR Team . . . . . . 3 REVIEW PHASE . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1. Function and Task Analysis and Conparison of Display and Control Requirements With a Control Room Inventory . . . . 4

2. Control Room Survey . . . . . . . . . . . . . . . . . . . . 7 ASSESSMENT AND IMPLEMENTATION PHASE ................ 10

1. Assessment of HEDs .................... 10

2. Selection of Design Improvements ............. 12

3. Verification That Improvements Provide the Necessary Corrections and Do Not Introduce New HEDs . . . . . . . . .

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4. Coordination of the DCRDR With Other Improvement Programs ......................... 14

5. Implementation Schedule for HED Corrections . . . . . . . . 15 CONCLUSIONS AND RECOMMENDATIONS .................. 16 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . l8 r

APPENDIX A - Attendees of the Pre-Implementation Audit . . . . . . . 20 APPENDIX B - Example HED With General Resolution . . . . . . . . . . 21 APPENDI.(_Q . . Exargple of NUREG 30700 fr_1.ter.ia.Matri (.,...,.,,. ,..,a . ..._. .22. .

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l TECHNICAL EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW

. FOR THE MILLSTONE NUCLEAR POWER STATION, UNIT 2 This report documents the findings of a review of Northeast Utilities' (NU) Detailed Control Room Design Review (DCRDR) for its Millstone Nuclear-Power Station, Unit 2. The purpose of the review was (1) to determine whether the DCRDR conducted by NU is acceptable and (2) to provide a basis for feedback to NU. The requirements set forth in Supplement I to NUREG-0737, " Requirements for Emergency Response Capability," December 1982 (Reference 11), served as the basis of the review. -

i NU's DCRDR of Millstone 2 began with the submittal of tne Program Plan i

to the U.S. Nuclear Regulatory Commission (NRC) on February 26,1985(Refer-ence 1). An on-site meeting was held June 24, 1986 by NRC with NU to discuss areas and issues of the Program Plan needing clarification (References 3 and 4). The DCRDR Summary Report was submitted by NU Septem-ber 30, 1986 (Reference 6). Based upon discussions held in the June 24, a pre-implementation 3986 meeting and the review of the Summary. Report, audit was determined to be necessary and was conducted December 2-4, 1986.

The attendees of the pre-implementation audit are listed in Appendix A. The l findings from a review of the Program Plan, Summary Report, and from discussions and documentation reviews during the on-site meeting and pre-implementation audit, follow a brief overview of the background of the DCRDR requirements.

i BACKGROUND Licensees and applicants for operating licenses are required to conduct a Detailed Control Room Design Review (DCRDR). The objective is to " improve the ability of nuclear power plant control room operators to prevent acci-dents or cope with accidents if they occur by improving the information provided to them" (NUREG-0660, Item 1.D.1). The need to conduct the DCRDR was confirmed in NUREG-0737 and in Supplement I to NUREG-0737. DCRDR 1

u requirements in Supplement I to NUREG-0737 replaced those in earlier docu-ments. Supplement I to NUREG-0737 requires each applicant or licensee to conduct its DCRDR on a schedule negotiated with the NRC. Guidelines for konducting a DCRDR are provided in NUREG-0700 while the assessment processes for NRC are contained in NUREG-0800. (The NUREG documents cited are listed as References 9 through 13).

A DCRDR is to be conducted according to the licensee's own Program Plan (which must be submitted to the NRC). According to NUREG-0700, it should include four phases: (1) planning, (2) review, (3) assessment and implemen-tation, and (4) reporting. The product of the last phase is a Summary Report, which according to Supplement I to NUREG-0737, must include an outline of proposed control room changes, their proposed schedules ,for implementation, and summary justification for human engineering discrepan-cies with safety significance to be left uncorrected or partially corrected.

Upon receipt of the licensee's Summary Report and prior to implementation of proposed changes, the NRC must prepare a Safety Evaluation Report (SER) indicating the acceptability of the DCRDR (not just the Summary Report).

The NRC's evaluation encompasses all documentation as well as briefings, discussions, and audits.

The purpose of this Technical Evaluation Report is to assist the NRC by

! providing a technical evaluation of the NU DCRDR process and results.

The DCRDR requirements as stated in Supplement I to NUREG-0737 can be summarized in terms of the nine specific = elements listed below: 'ut -

1. Establishment of a qualified multidisciplinary review team.

2. Use of function and task analysis to identify control room operator tasks and information and control requirements during emergency operations.

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

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

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5. Assessment of human engineering-discrepancies (HEDs) to determine

,which HEDs are significant and should be corrected.

6. Selection of design improvements that will correct those discrepan-cies.

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

8. Verification that improvements can be introduced in the control room without creating any unacceptable human engineering discrepan-cies.

9. Coordination of control room improvements with changes result.ing from other improvement programs such as SPDS, operator training, new instrumentation (Reg. Guide 1.97, Rev. 2), and upgraded emer-gency operating procedures.

PLANNING PHASE The overall conclusion of the NRC staff in its review of NU's DCRDR Program Plan for Millstone 2 was that "...a DCRDR is planned th'at generally meets the intent of Supplement 1 to NUREG-0737. However, the Program Plan does not reflect the level of understanding necessary to successfully complete all DCRDR activities and meet the requirements of Supplement I to l NUREG:.0737.f-usTherNRCnstaff recommended that a' meeting be held between NU l and the NRC to discuss the review of the Program Plan.'

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1. Qualifications and Structure of the DCRDR Team

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The NRC concern resulting from its review of the Program Plan was the I

need for clarification of the following aspects of the Millstone 2 DCRDR team:

e The presence of a nuclear engineer on the Core Review Team, e The identity of the consultants on the Core Review Team.

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4 e The levels of effort for all DCRDR participants.

e The identity and qualifications of the person who will;give final

, approval for HED resolutions.

e The methods and duration of instruction during review team orienta-tion.

NU provided information which clarified these aspects during the June 24, 1986, meeting (Reference 3). This information and subsequent information provided in the Summary Report were found to be acceptable in resolving the NRC concerns for this requirement. NU has met this requirement of Supple-ment I to NUREG-0737.

REVIEW PHASE NU's review or investigation phase activities as describe.d in the Summary Report included the fol, lowing:

1. Task Analysis .

2. Control Room Survey

3. Operating Experienca Review Activities I and 2 address specific DCRDR requirements contained in Supplement 1 to NUREG-0737. A review of operating experience is not required by Supplement I to NUREG-0737. Therefore, the results of this activity will not be given attention in this report other than as they relate to specific DCRDR requirements.

1. Function and Task Analysis and Comparison of Display and Control Requirements With a Control Room Inventory A review of the Program Plan identified the need for further informa-tion and clarification in the following areas:

e The adequacy and comprehensiveness of the Combustion Engineering Owners' Group (CEOG) Emergency Procedure Guidelines (EPGs) and Millstone 2 E0Ps as the basis of the task analysis.

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e The personnel (and their qualifications) involved in identifying and analyzing deviations from the CE0G EPGs.

e. The method for determining plant-specific requirements.

e The use of the Task Data Forms.

e The adequacy and comprehensiveness of the comparison / verification activity relative to the task analysis.

NU provided information which clarified many of these aspects during the June 24, 1986 meeting. However, concerns remained from a review of the Summary Report in the following areas: -

e The scope and type of tasks analyzed.

e The use of the Task Data Forms in the identification of character-istics of needed instruments and controls and for evaluation of existing instruments and controls.

In accordance with an agreement reached between the CE0G and the NRC in an August 29, 1984 meeting, the CEOG task analysis took as its starting point the EPGs. CEOG partitioned the EPG steps into tasks, individual opera-tor actions, and identified information and control requirements for these

tasks / actions. The needed characteristics of the information and

:ontrol

! re'quirkments ~were"also idehtifi'ed'.~ CE0G's Generic ~16formatFon and" Control Characteristics Review (ICCR, Reference 8) provides a consolidated list of information and control requirements for supporting operations in accordance with the EPGs, and the characteristics of these requirements.

NU described its task analysis approach during the pre-implementation audit. NU was assisted by Combustion Engineering in the initial stages of the task analysis. First, Combustion Engineering (CE) generated generic and plant-specific information and control requirements using the CE0G EPGs, Millstone 2 E0Ps, and plant subject matter experts. Task listings were I developed from Millstone 2 E0Ps down to the level of detail of specific task elements / operator actions (e.g., " read containment temperature"). CE then determined the information and control requirements to perform each task and 5

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the characteristics needed for required instruments and controls. CE stated during the pre-implementation audit that approximately 20% of the tasks and 50% of the task elements from the EPGs were plant-specific. }heNRCaudit

team determined that the scope and type of tasks analyzed were acceptable .

In parallel with CE's ICCR effort, the Millstone 2 Core Review Team transferred "EOP task requirements" (i.e., E0P tasks) to the Task Data Forms. Second, the Core Review Team inserted / transferred information and i

control requirements from the ICCR to the Task Data Forms and verified the availability of instruments and controls in the control room to satisfy the information and control requirements. Human Engineering Discrepancies (fiEDs) were identified for missing or inadequate instruments and controls.

Third, the E0P steps were walked- through using the E0Ps and Task Data F.orms in order to identify the dynamic aspects of the operator's tasks and vali-date the integration of controls and displays. HEDs were identified for any questionable tasks or discrepancies in control / display integration. Fourth, the ICCR was used to record characteristics of needed instruments and controls to verify the suitability of existing instruments and controls in i

the control room. HEDs were identified for instruments and controls not

] suitably designed. Fifth and finally, the ICCR was used to record " status h versus demand" criteria and instances where demand indications were used 'in the control room rather than status indications were noted as HEDs for future review.

The NRC audit team's review of this approach consisted of walk-throughs Vf" selected Turtions of Iq 2525 " Standard Post ' Trip Actions" tnd E0P 2532

" Loss of Coolant Accident" and task analysis documentation reviews. The NRC audit team concluded that the task analysis and comparison of display and control requirements with a control room inventory and the use of the Task Data Forms therein was performed satisfactorily and meets the requirements of Supplement I to NUREG-0737. However, NU should verify that discre-pancies/ problems noted in the Task Data Forms are written as HEDs (e.g.,

i discrepant pressure indicator and pressure trend). If any discrepancies noted in the Task Data Forms are found to not be written as HEDs, NU should determine if and how the resolution of other HEDs are affected and take i

appropriate measures. (e.g., discrepant pressure indicator's and pressure trend's is impact upon the resolution of HED TA-179).

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2. Control Room Survey A review of the Program Plan identified the need for further informa-

' tion and clarification in the following areas:

, e The nature and use of the "other guidelines" and their effect upon the use of NUREG-0700.

e The personnel involved in performing and supervising the check-lists.

e The meaning of the word " classification" in reference to docu-menting core team member opinions. ,

e The means for addressing all dynamic criteria in NUREG-0700.

NU clarified the first three areas above through discussions held in the June 24, 1986 meeting and informatica provided in the Summary Report. The concern regarding the means for addresaing all dynamic criteria in NUREG-0700 was satisfied partially. In addition to this concern, the following areas were identified from a review of the Summary . Report as needing further l

information.

e The survey approach and criteria for evaluation of the process computer and SPDS.

e The evaluation of control-display relationships within the control room.

In the June 24, 1986 meeting NU provided a matrix of NUREG-0700 criteria and the activities (i.e, operating experience review (OER), control room survey (CRS), task analysis (TA)) performed, which evaluated each cri-terion (see Appendix C). In order to determine that all NUREG-0700 criteri-I were addressed by the appropriate activity, the matrix was reviewed by verifying that the dynamic criteria (criteria requiring knowledge of operator tasks or operations in order to evaluate) of NUREG-0700 were l

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addressed -by activities that were oriented toward knowledge of tasks or operations (i.e., OER and TA). The review found all but the following three criteria to be addressed by either the TA and/or the OER: ,;

6.'4.3.1.a Need to know procedural sequence or tasks on which to base )

judgment of positioning order.

6.5.1.3.a Need to know operating position (s), which would be thorough-ly identified by walk-throughs or less objectively / rigorous-ly evaluated by the results of the OER.

6.5.2.3 Need to know operational implications upon zone markings to evaluate present zone markings / coding. ,

Discussions held during the pre-implementation audit determined that criterion 6.4.3.1.a was addressed in the task analysis and operating experience review, but still needed to be so indicated in the. criteria matrix. With respect to criterion 6.5.2.3, NU determined that zone marking was not necessary in the Millstone 2 control room and what little there was in tie control room was evaluated for clarity. Criterion 6.5.1.3.a (pre-i viously typed mistakenly as 6.5.3.1.a) was not addressed during the audit and was deferred to SAIC for further clarification. Criterion 6.5.1.3.a requires the evaluator to know the normal operatir.g position of the operator  ;

in order to assess the visual angle and viewing distance to displays to be read and thus the needed character height. A review of the liEDs NU has e identified from the investigation phase activities indicates that read-ability problems have been found and are going to be resolved so that readability of displays (e.g., labels, annunciators) is going to be improved in the control room. We believe that NU has addressed sufficiently NRC concerns regarding the evaluation of dynamic NUREG-0700 criteria.

NU stated in the letter accompanying the Summary Report that "The Safety Parameter Display System (SPDS) for Millstone Unit No. 2 is not required to be fully operational until March 25, 1987 or startup for Cycle 8 operation, whichever is later. Appropriate checklists from NUREG-0700 that apply to the SPDS cannot be executed until that time. Ther,efore, the results of that portion of the CRDR will be submitted to the NRC staff on or about August 1, 1987 in the form of an addendum to this summary report."

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4 However, NU did not provide a description of the SPDS survey approach and the criteria used from NUREG-0700 to evaluate the SPDS. NU stated during the pre-implementation audit that Millstone 2 personnel were inv,olved in the design of the SPDS and that the SPDS will serve as a mode for the process compute'r. After the vendor provides the SPDS, Millstone 2 personnel will conduct a survey of it using all the criteria of section 6.7 (process computers) of NUREG-0700. Any .HEDs produced from this survey will go through the usual DCRDR HED assessment and resolution process and may result in improvements implemented. The NRC audit team found NU's description of

the SPDS/ process computer survey approach and use of NUREG-0700 criteria to be acceptable. The NRC will expect the results of the SPDS/ process computer survey to be submitted by NU as a supplement to the Summary Report.

1 The Summary Report did not clarify how the integration and layout' of controls and displays were evaluated other than to say "the walk / talk thru process of Task Analysis was performed for identification of the dynamic aspects of the operator's task per Figure 10" (the figure indicates the NUREG-0700 criteria addressed by the task analysis). The NRC expressed a concern during the pre-implementation audit that there was no direct evidence / documentation of an evaluation of control-display relationships based upon requirements derived from an analysis of tasks. NU stated that i although there was no systematic approach to evaluate control-display rela-tionships based upon requirements developed a-priori, the walk-throughs of the E0Ps were used to identify control-display integration problems. A

' review of the HEDs identified by NU found that the walk-through activity l

generated HEDs documenting such problems. Based on this evidence and I further clarification of the purpose of the walk-through activity, we believe that NU has addressed the control-display relationship aspect of the control room adequately.

In summary, NU has per formed satisfactorily the portions of the control room survey conducted up to the present. NU still must complete the survey of the SPDS/ process computer. Provided NU completes this survey as i

described during the pre-implementation audit, then NU will have met this

(; requirement of Supplement I to NUREG-0737 successfully.

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ASSESSMENT AND IMPLEMENTATION PHASE

1. Assessment of HEDs  ;

A review of the Program Plan identified the need for further informa-tion and clarification in the following areas:

e The methodology for assigning HEDs to the four HED categories either is not provided in the Program Plan or has not been developed, e The structure and content of the four categories is somewhat ambiguous (e.g., how is " problem" defined?) and is not adequate as the basis for assigning HED correction implementation priorities, e There is an apparent lack of criteria on which to base the answers to the questions in the triage assessment.

e The triage approach precludes the assessment of HEDs for signifi-cance relative to operator performance which is a consideration that should be given to all HEDs and incorporated in the categori-zation scheme, e The questions in the triage methodology for assessment of HEDs seem to be partially for resolving the HEDs as well.

e No functional meanings have been described or attached to the 1 to

( 10 significance ratings.

e The assessment of HEDs according to Figure 6 of the Program Plan appears to end before the task analysis has been completed.

l NU provided information in the June 24, 1986 meeting and in the Summary j Report that responded to and clarified the above concerns. The NRC found NU's responses to be acceptable in resolving the concerns from the Program Plan review (Reference 3).

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The NRC identified the following arias from the Summary Report review related to the assessment results, which were to be audited:

e , Category 1 HEDs that have not been corrected at the time of the audit and any interim measures.

e HEDs considered to be non-HEDs.

The NRC audit team learned during the pre-implementation audit that no Category 1 HEDs intended for correction have been implemented. NU stated that implementation of HED corrections was awaiting the results of the NRC's review of the Millstone 2 DCRDR. The results of the NRC's review of NU's proposed HED corrections are discussed in the Selection of Design Improve-ments section of this report. A review of a sample (about 80%) of the non-HEDs found NU's disposition of these HEDs to be acceptable.

The NRC audit tean also reviewed documentation from which NEDs were derived and assessed, including the operator surveys. HEDs from the opera-tor surveys, which covered all negative operator comments under general categories, such as " control room layout," were documented. The sample review of the operator surveys and HED documentation found no instances of operator comments that were overlooked or not considered for documentation as HEDs. Although the categorical grouping of specific comments or discrep-ancies in an HED enhances the documentation of HEDs, NU's resolutions for specific discrepancies were in some instances explicit, in others it was general. For example, the statement "All but three items have been addressed in the Survey and TA phases of the review..." appcars in HED ER-01 (see Appendix B). Although NU may have addressed each specific discrepancy, the operator survey and HED documentation did not provide the NRC audit team with a documentation trail to follow. The review of the operator survey documentation relied on the memories of the Core Review Team members' memories and was successful for the most part. However, enough discrep-ancies were noted by the NRC audit team to cast some doubt on the assignment of resolutions to each operator concern for each HED. NU should review those portions of the HED resolutions that are general in nature to verify that the operators' concerns have been addressed and resolved appropriately.

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In summary, all previous concerns of the NRC have been satisfied. l Provided NU has verified that operator concerns in HEDs have been addressed l and resolved appropriately, this requirement of Supplement I to NUREG-0737, will have been met.

2. Selection of Design Improvements The NRC review of the Program Plan found that no specific approach to select design improvements was described. NU presented its approach for selecting design improvements in the June 24, 1986 meeting and in the Summary Report. The NRC found the methodology described to be satisfactory for determining final design improvements and corrections to HEDs.

During the pre-implementation audit, the NRC examined the following aspects of NU's design improvements selection process:

e Design guides and standards developed for control room .modifica-tions.

e Proposed corrections to HEDs.

e Justifications for not taking corrective action on Category I HEDs.

NU indicated during the pre-implementation audit that the design guides and standards for Millstone are being developed from the DCRDR, not for the DCRDR. At the time of the audit, only the abbreviations and acronyms standard had been developed. The NRC audit team found this standard to be acceptable. NU intends to develop a set of standards for future changes to the control room. The NRC audit team commends this effort and encourages NU to apply such standards to those locations in the plant where operators and other personnel must interface with . plant systems (e.g., remote shutdown panel and other local control areas).

A sample (about 20%) of proposed corrections to HEDs were reviewed to determine the adequacy of NU's resolution of HEDs both individually and col'lectively. The NRC audit team found these HEDs to be resolved acceptably and concludes that NU has developed a satisfactory control room improvement package.

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The NRC audit team reviewed all category I HEDs for which corrective action will not be taken. NU's justifications for not taking. corrective 4

4ction ,were found to be acceptable in each case.

In summary, the approaches taken by NU for selecting design improve-ments and the proposed changes to the control room were found to be accept-able by the NRC audit team. The NRC recommends that NU document all guidelines and standards for use in the design change process in order to assure proper human factors consideration and referencing, and for maintain-ing consistency with the changes made to the control room previously. NU has met this requirement of Supplement I to NUREG-0737.

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3. Verification That Improvements Provide the Necessary Corrections and Do Not-Introduce New HEDs The NRC review of the Program Plan found that no specific approach to i verify design improvements was described. Subsequently, NU presented its

[ approach for verifying design improvements in the June 24, 1986 meeting and I in the Summary Report. The NRC found the general methodology described to I be satisfactory for verifying and validating (V&V) design improvements.

Since this process was not completed at the time of the June 24 meeting, the

! NRC deferred final conclusions regarding the adequacy of the V&V process until the detailed and actual approach could be presented.

NU provided a detailed description of its V&V process during the pre-l implementation audit. The verification activity consisted of the Core l Review Team producing several iterations of control board improvements l documented on drawings. Approximately half of the control room operators provided input into the design and verification process. Although the verification process was not based upon systematic comparison of the

) proposed changes with structured evaluation criteria, the iterative approach i'

to selecting and verifying design improvements was rigorous and was

. performed by experienced and qualified personnel. An indication of the 4

adequacy of the verification process was provided by the results of the

, validation effort. Only four new HEDs, none of safety signific.ance, were i produced by the validation effort.

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The validation approach consisted of^three E0Ps being walked-through by two operators. The three E0Ps were Loss of Coolant Accident, Standard Post Trip Actions, and Electrical Emergency. Approximately 95 to 99% of the

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I steps 1,n all emergency operations were addressed by the walkthrough of these l

three E0Ps. Approximately 80 to 90% of the control boards were exercised by the walkthroughs.

l In summary, the NRC audit team found the verification and validation

processes acceptable in assuring that the proposed improvements provided the necessary corrections and did not create new HEDs of safety significance.

I NU has met this requirement of Supplement I to NUREG-0737.

4. Coordination of the DCRDR With Other Improvement Programs ,

The review of the Program Plan identified the need for clarification of the following areas:

! e The identity of the person (s) responsible for the coordination i function and the mechanism by which the function can be carried out.

i e The nature and level of effort of the Core Review Team members in the other improvement programs.

1 NU provided information that clarified these aspects during the June

! 24, 1986 meeting. A review of the Summary Report identified the need to obtain further information on the training provided to operators on changes to the control room. The NRC audit team obtained the needed information through interviews of operations and training personnel and review of docu- ,

mentation involved in scheduling and modification of training. Coordination of training with changes to the control room is controlled procedurally at the site level and involves the Training Program Control Committee, which consists of the Training Supervisor and the Plant Operations Supervisor.

The documentation involved in processing plant changes and modifications to the, training program was found to be adequate for their purposes.

i The Training Department at the time of the pre-implementation audit was assessing 19 HEDs assigned by the DCRDR Core Review Team for resolution by 14

l training. The Training Department assessnient will determine what additional types of training will be done, how existing training will be changed to resolve the HEDs, or if alterations to existing training are . required to

'esolve, r the HED. The NRC audit team determined that NU should inform the NRC of any Category I HEDs from those being assessed by the Training Department for which no corrective action will be taken. Also, NU should describe the corrective actions to be taken for the HEDs resolved through training. Since modifications to the Millstone 2 simulator will lag the accomplishment of plant modifications, the NRC audit team recommends that NU

• consider retaining the control boards mock-up as a training aid. The NRC l audit team's specific concerns here are for the adequacy for operator training on the large number of changes to occur in the control room result-

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ing from the DCRDR and the potential negative transfer of training ,and accompanying human errors. Approaches other than those using the control boards mock-up may be valid in satisfying these concerns. NU should provide the NRC with the aforementioned information concerning the 19 HEDs assessed l

by the Training Department and indicate NU's plans for the use of the mock-i up in training.

5. Implementation Schedule for HED Corrections l

A review of the Summary Report found that NU's proposed schedule for j implementing HED corrections in the control room will last 5 years. The NRC audit team reviewed the schedule with members of the DCRDR Core Review Team j to obtain an understanding of the rationale for this schedule. Changes to the control room will generally be accomplished on a panel-by-panel basis across three refueling outages. Panels C06, 7, and 8 will be changed during l, the next refueling outage due to the relative extensiveness of the changes.

l' Panels CO2, 3, 4 and 5 will be changed in the 1989 refueling outage, includ-ing the addition of a SG PRESS indication. Panels C01, 01X, and 25 will be changed in 1991. The changes to be accomplished in 1991 were reviewed and their implementation schedule was found to be acceptable relative to the l safety classification of the HEDs involved'in the change package. The overall implementation schedule for HED corrections was found to be accept-

!, able.

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i CONCLUSIONS AND RECOMMENDATIONS The methodologies and results of the Millstone 2 DCRDR were' reviewed by,

' he t NRC and its consultants through discussions held on-site during two s separate occasions and audits of documentation. The findings were that the methodologies were performed satisfactorily and the disposition of HEDs identified is acceptable. With the exception of those discrepancies noted below, NU has completed its DCRDR and satisfied the requirements of Supplement I to NUREG-0737. A summary of the status of each requirement for the Millstone 2 DCRDR is as follows:

e Qualifications and Structure of the DCRDR Team NU has satisfied this requirement.

e Function and Task Analysis and Comparison of Display and Control Requirements With a Control Room Inventory

, Although NU has performed these activities satisfactorily, .it must verify that discrepancies noted in the Task Data Forms are written as HEDs and assess the impact of HEDs overlooked upon other HEDs in order for these requirements to be satisfied completely, e Control Room Survey In order to satisfy this requirement, a survey of the SPDS/ process  ;

computer system must be performed.

e Assessment of HEDs

, Although NU has performed this activity satisfactorily, it must

{ verify that operator concerns in HEDs produced from the operator surveys have been addressed and resolved appropriately in order for

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this requirement to be satisfied completely.

e Selection of Design Improvements NU has satisfied this requirement.

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.u e Verification That Improvements Provide the Necessary Corrections and Do Not Introduce New HEDs

, NU has satisfied this requirement.

e Coordination of the DCRDR With Other Improvement Programs In order to complete the activities necessary to address this requirement satisfactorily, NU must finish its assessment of the 19 HEDs assigned for resolution by training and inform the NRC of any Category I HEDs from this group for which no corrective action will be taken. In addition, NU should describe the corrective actions to be taken for the HEDs resolved through training and indicate,its plans for the use of the mock-up in operator training.

NU is planning to submit to NRC a description of the results of the survey of the SPDS/ process computer on or about August 1, 1987 in.the form of an addendum to the Summary Report. It is recommended that NU also report the results of the other remaining activities described above in order for the NRC to close out its review of the Millstone 2 DCRDR.

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REFERENCES

1. " Millstone Unit No. 2 Control Room Design Review Implementation Plan,"-

attachment to letter from W.G. Counsil, NNECO, to J.R. Miller, USNRC, dated February 26, 1985.

2. " Nuclear Regulatory Commission Staff Comments on the Millstone 2 Detailed Control Room Design Review Program Plan," attachment to memorandum from D.H. Beckham, USNRC, to G.C. Lainas, USNRC, dated May 18, 1985.

3. "NRC Meeting on June 24, 1986 with Northeast Utilities Concerning the DCRDR for Millstone 2," attachment to Informal Technical Communication from M.L. Fineberg, SAIC, to R. Ramirez, USNRC, dated July 15, 1986.

i 4. " Millstone Unit 2 Control Room Design Review (CRDR) - Status Update,"

transmitted to NRC from R.K. McCarthy, NUSCO, dated July 10, 1986.

5. " Millstone Nuclear Power Station, Unit No. 2 Control Room Design Review i Implementation Plan Response to NRC Staff Comments," attachment to letter from J.F. Opeka, NNEC0, to A.C. Thadani, USNRC, dated August 12,

. . 1986.

6. " Millstone Nuclear Power. Station, Unit No. 2 Control Room Design Review Summary Report," attachment to letter from J.F. Opeka, NNECO, to A.C.

! Thadani, USNRC, dated September 30, 1986.

7. " Pre-Implementation Audit Plan for the Safety Evaluation of the

. Millstone 2 Detailed Control Room Design Review," enclosure to memorandum from D.M. Crutchfield, USNRC, to D. Jaffe, USNRC, dated November 13, 1986. -

! 8. "C-E Owners Group Generic Information and Control Characteristics Review," CEN-307, dated August 1985.

l l 9. " NUREG-0660, Vol.1, "NRC Action Plan Developed as a Result of the THI-2 I Accident," U.S. NRC, Washington, D.C., May 1980, Rev. 1, August 1980.

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10. NUREG-0737, " Requirements for Emergency Response Capability," U.S. NRC, Washington, D.C., November 1980.

11. NUBEG-0737, Supplement 1, " Requirements for Emergen y Response Capability," U.S. NRC, Washington, D.C., December 1982, transmitted to reactor licensees via Generic Letter 82-33, December 17, 1982.

12. NUREG-0700, " Guidelines fcr Control Room Design Reviews," U.S. NRC, Washington, D.C., September 1981. -

13. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 18.1, Rev. O, U.S. NRC, Washington, D.C., September 1984. ,

l 19 l

+ Pf,',- "

APPENDIX A Attendees of the Pre-Implementation Audit

~

- NU Reoresentatives John D. Becker Asst. Sup. Operator Training Unit 2 Robert K. McCarthy I&C Engineering Walter C. Mission Project Engineering

Everett P. Perkins Licensing Engineer Unit 2 Thomas A. Shaffer CRDR Program Manager

Alan Stave NUSCO/ Human Factors USNRC Representatives .

Leo Beltracchi USNRC Whitney Hansen Comex Corporation / Operations Timothy K. O'Donoghue SAIC/ Human Factors 9

D 8 e

20 l

,r- , - - ------,_m.- , . ,-,r,- - . - - , - . , ,-,,--.,,.,w,----- , , , , , , , , - ,-.,,,,.-na,,, ,,,,, ,,- ,,, -.4a--. . . - . - , - , , - - - , - - - --

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APPENDIX B MP2 HUMAN ENGINEERING DISCREPANCY HED No. rR-01

. TITLE:

CONTROL ROOM LAYOUT PRIORITY: s 3

COMMENT:

The comments below were received from the operators concerning the control room layout Reviewer Date Ref. Source R. Sabeh 9-23-85 Ouestionnaire OER IDENTIFICATION: Panel:

Component Name: SEE BELOW ID OR NO.:

DESCRIPTION:

The things that bother the operators most about the control

. room layout are:

C06 Location of vital equipment and indicator size on C0lX, ESAS (RCl4, ESAS, RCP).

7 - No bathroom t 6. /. s. N ..

Control Room is too small Too much traffic Temp / Humidity (dry) in winter 7"-Mirror imaging [ J. e . >.)

RESOLUTION: (Code A )

Correct All but three items have been addressed in the Survey and TA phases of the review. They are:

1. Control room is too small - this has been addressed by the incorporation of new furniture and equipment which provides more efficient space utilization.

2. The traffic problem is self-controlled by the operatcrs in that only authorized personnel are allowed; however, the

, administrative policy should be reviewed to limit the .

authorized access for business purposes.

3. The Control Room does not have any humidification for winter heating and it should be added. The tests made during

the survey were performed in the summer, however the dryness is a common complaint.

See Memo MP2-CRDR-86-031 l

i I.

Approved Signature: // Date: 7!L#!f0 f \

/ / Additional page(s) attached i 21

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! t, -

1 .

1 .

t I ' -

MILLSTONE UNIT 2 (MP2) 1 . 3 DETAILED CONTROL ROOM DESIGN REVIEW

! CRITERIA MATRIX ,

i I *

! 6.1 Control Room Workspace i

NUREG-0700 DATA COLLECTION COMMENTSIREFERENCE METHOD i 6.1.5 General Layout OER CRS TA l

6.I.1.1 Accessibility of hstrument S 5 P 6.1.1.1 a & b: .

l Related to 6.5.1.1 a

Equipment i A

=

s im

'N 6.1.1.2 Consistensy of Manning with 5 $ P 6.1.1.2 b: y i Equipment Layout OER primary source for this item c.,

1 l

6.l.l.3 Furniture and Equipment Layout 5 P 6.l.i.3 a:

! Related to 6.7.2.3 i ,

.I 6.1.1.4 Document Organization and Storage 5 P 6.1.1.4 a(th Related to 6.7.l.8 a(l).

6.1.1.5 b & c:

6.1.1.3 Spare Parts, Operating Expendables S P and Tools Related to 6.5.4.1 e ** .

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]

• P refers to Primary Source for obtaining data

• • 5 refers to Secondary Source for obtaining data ,