NRC Generic Letter 1983-18
| ML031080420 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/1983 |
| From: | Eisenhut D G Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| GL-83-018, NUDOCS 8304200321 | |
| Download: ML031080420 (17) | |
IAPR I 9 1983ALL BOILING WATER REACTOR LICENSEES OF OPERATING REACTORS. APPLICANTSFOR AN OPERATING LICENSE AND HOLDERS OF CONSTRUCTION PERMITSGentlemen:SUBJECT: NRC STAFF REVIEW OF THE BWR OWNERS' GROUP (BWROG) CONTROL ROOMSURVEY PROGRAM4 (Generic Letter 83-18)The NRC staff has completed its review of the BWR Owners' Group (BWROG)Control Room Survey Program. The results of the staff's review areprovided In the enclosed evaluation and letter to the Owners' GroupChalrman.-Th6-BWR Owners' Group submittal addresses the planning andreview phases of the Detailed Control Room Design Review (OCRDR) andprovides valuable guidance to users utilities. However, the BWROG SurveyProgram should not be interpreted as fully responding to NUREG-0737 TaskAction Plan Item I.D.I. Additional work is required.The NRC review consists of a discussion of our concerns about the scopeof the BWROG program and information or commintments that you shouldpresent in your program plan submittal. Since the BWROG survey programaddresses only the planning and review phases of DCRDR, you are expectedto complete the following tasks:a. Submit an individual program plan to the NRC referencing the BWROGGeneric Program Plan. The plant-specific submittal should:I. Document the qualifications of survey team members, and numberand extent of plant personnel participation.ii. Identify portions of the plant's DCRDR not performed~\in accor-dance with the methodology specified in the BWROG Program Plan.iii. Discuss your program for prioritization of HEDs, reporting ofDCRDR results, and implementation of control room enhancements..b. Complete the BWROG control room survey Checklist Supplement.SURN~AME~ ....... .... ............ ............ ................ .............. .............. ..............DA E ............. ............. ............ ............. ............. ............. ............'IIIiRC FORM 318 (10-60) NRCM 0240 OFFICIAL RECORD COPY £JSOPO: 1901-335-960NRC FORM 318 (10-80) NRCM 0240 -.OFFICIAL RECORD COPYUSGPO: 1981-335-OW
-1 .IIc. Prioritize HEDs, determine corrective actions, develop an implementationschedule, and report the results of the DCRDR to the NRC.d. Repeat portions of the task analysis using updated plant specificemergency operating procedures to account for differences in thenew procedures.e. Update operating experience review.This request for information was approved by OMB clearance number3150-0065 which expires May 31, 1983.Sincerely,Darrell G. Eisenhut, DirectorDivision of LicensingOffice of Nuclear Reactor RegulationEnclosure:NRC Comments*SEE PREVIOUS CONCURRENCES 42OFFICEt .,* ~.;.QKb... D.L.O .BA .- .~.RB.LfE..... -.DLA.RB.H.i ......, :.L.;AP .-.$.A --..... PIR ......... ............... ......... ........................SURAit A h=9. .. kick jDCrutchfield JMX iq a ..DEJ~SURNAUEE ~~~~~......H.S .t.i. ..G.C.k .D.C .rut.c.f.i.e.l.d..... FM .l.l.a.. W.l.a~"...g.... ...... .~ u ..... ............... ......... ........................DATE # I -3/43. ..... 3.... 31,6483 ... ....... ..1.. U ....... .4 2 ................................ .........................NRC FORllM 318 (10-80) NRCM 0240O FFICIA L R EC O RD C OPYDSGPo: t19815460o
-2 -c. Prioritize HEDs, determine corrective actions, develop an implementationschedule, and report the results of the DCRDR to the NRC.Repeat portions of the task analysis using updated plant specificemergency operating procedures to account for differences in thenew procedures.e. Up e operating experience review.This reques for information was approved by Of-1 clearance number3150-0065 whA expires May 31. 1983. Comments on burden and duplicationmay be directed o the Office of Management and Budget, Reports andManagement, Room 08, New Executive Office Building, Washington, D. C.Sincerely,vision of LicensingT e of Nuclear Reactor RegulationEnclosure:NRC CormientsDISTRIBUTIONDocketORB ReadingDEisenhutFMiragliaHThompsonJKramerVMooreSWeissMGreenbergDCrutchfieldGDickDL ; 5 DL RB D5 D SA DL:DIR 7OFFICE~ ... .. ........ ...#F,.... 6^ ... ... .1......... ........................ ....................................... ........................SURNAMEcc G i eld giia DEisenhut.....UE .. .. ........... ..... .. ..... .. ..... .. , *..... .. ... ....................... ................................... ...................... .............3/ Y83 03/2./ /83 0 /<< 83 /83 03/ /83DATE IO ..... .. ..... .... ............ ........................ .......... .............. ........................NRC FORM 318 (10-80} NRCM 0240OFFICIAL RECORD COPYUSGPO: 198-3319O
i.NRC REVIEW OFBWR OWNERS' GROUPCONTROL ROOM SURVEY PROGRAMAt the request of the BWR Owners' Group (BWROG), the Human Factors EngineeringBranch (HFEB) of the Division of Human Factors Safety (DHFS) reviewed BWROGControl Room Survey Program. Several meetings between the NRC and the BWROGwere held to resolve NRC concerns.We conclude that the BWROG Control-Room Survey Program as clarified in theSeptember 16, 1982 meeting between the NRC and BWROG, is an acceptableapproach to the planning phase and the review phase of the Detailed ControlRoom Design Review (DCRDR) called for in Supplement 1 to NUREG-0737 anddescribed in NUREG-0700. A summary of the issues clarified in theSeptember 16, 1982 meeting are included here.The BWROG effort was initiated prior to the publication of NUREG-0700 andNUREG-0801. The submission of the BWROG program was accomplished in anumber of stages and meetings with the NRC starting in July 1980. A workingmeeting was held with the NRC and BWROG on September 16, 1982 to review forcompleteness the material that had been submitted and to resolve and clarifysome open issues that were either not resolved or not documented.In order to prevent possible misuse of the BWROG Control Room SurveyProgram, it is necessary to emphasize that the BWROG Control Room SurveyProgram should not be interpreted as fully responding to Task Action PlanItem I.D.1. It only addresses the planning and review phases of the DCRDR.A key area-of NRC concern was what, specifically, was the scope of the BWROGprogram and at what point will a plant-specific program plan submittal berequired from the licensees?
-2 --ENCLOSUREA program plan report that is subnitted by a utility that is using the BWROGControl Room Survey Program should reference the BWROG program and includeinformation that covers the remaining areas of a program plan as describedin Supplement 1 to NUREG-0737. Utilities should address the availability ofhuman factors engineering expertise in the other phases of the DCRDR as wellas in any additional reviews or re-reviews and further surveys of additionaloperators. The BWROG should consider holding additional training workshopsto supplement the number of reviewers who attended the initial workshop.The BWROG Survey Program has already been utilized by a number of utilities.Some of the initial users have accumulated substantial amounts of additionaloperating experience since the survey was first performed. In addition, up-graded emergency operating procedures are currently being developed usingfunction based technical guidelines. In order to insure a high degree ofconfidence and consistency in the survey program, program plan. reportsshould contain the following commitments:1. Utilities will update their operating experience review toincorporate recent operating history, if their survey was performedprior to June 30, 1982.2. Utilities will use updated plant-specific emergency operatingprocedures to repeat portions of the task analysis to account fordifferences in the new procedures.Since the tRC has not seen specific details on the BWROG Survey Programperformed at each.plant, utilities in their program plan submittals shouldprovide the following information on the review phase: number and extent ofplant personnel (especially operating personnel) participation during thereview phase, attendance of plant personnel at BWROG Workshops and trainingcourses, specific procedures walked through in the control room as part ofthe systems review, additional work performed by the utility to completethe systems review, and plans for reviewing the remote shutdown panel.
-3 -ENCLOSUREThe BWROG program will provide each member utility with a list ofplant-specific human engineering discrepancies and a preliminary attempt toprioritize them. Utilities will be responsible for presenting their plansand schedules for assessment, implementation, and reporting phases in theirprogram plan. In addition, utilities should identify areas where theydeviated from the BWROG program, as reviewed by the NRC. The utility'ssubmittal should also provide the qualifications of the team membersfperforming the DCRDR.The NRC has not reviewed the preliminary prioritization methodologydeveloped by the BWROG. Therefore, utilities should address the methodologyused to determine discrepancy significance in their program plan report.Human factors engineering participation in the remaining phases of the DCRDRis considered to be very important. Therefore, it is necessary that asystematic documentation scheme be utilizied to provide continuity in theevent that other human factors consultants are involved in the remaining _phases.Following are a number of specific NRC comments and BWROG responses thatwere covered at the September 16, 1982 meeting:1. Comment:How does the review methodology used by the BWROG differ from thatrecommended in NUREG-0700?BWROG Response:NUREG-0700 includes four phases in the DCRDR:a. Planningb. Review ENCLOSUREc. Assessment and Implementationd. ReportingThe review phase is further divided into six processes:i. Review of operating experienceii. Analysis of system functions and operator tasksiii. Control room inventoryiv. Control room survey -v. Verification of task performance capabilitiesvi. Validation of control room functions.The BWR program is designed to address only the first two phases of thecontrol room design review (i.e., planning and review). The assessment.and implementation and reporting phases are the responsibility of theindividual utilities.The BWROG review methodology includes analysis of plant LERs and scramreports, operator interviews, checklist evaluations, and task analysisand walkthroughs of emergency procedures. The LER and scram reportanalysis and operator interviews'together correspond to Process i ofNUREG-0700. The task analyses and walkthroughs satisfy the intent ofProcesses ii, iii, v, and vi. The checklist evaluations correspond toProcess iv.2. Comm'ept:Does the planning phase of the BWROG program meet NUREG-0700recommendations?BWROG Response:The BWROG program was developed in advance of NRC requirements forcontrol room reviews in a conscientious effort to improve BWR control
-5. -ENCLOSURErooms. We believe the process used in developing the BWIROG programsatisfies the intent of NUREG-0700. A detailed description of thedevelopment process may be found in the BWROG program plan.3. Comment:What is the scope of the BWROG program plan?BWROG Response:The BWROG program plan covers the development and the methodology to beutilized for the detailed control room design review. The specified.qualifications of the design team and survey team members will besubmitted to the NRC at a later date.4. Comment:What is the role of human factors specialists in the BWROG DCRDR program?BWROG Response:The services of human factors specialists affiliated with theMassachusetts Institute of Technology and other academic institutionswere extensively utilized in both the planning and review phases of theBWROG program. In the planning phase, the consultants performed anindependent evaluation of the BWROG program, testing for completeness,adequacy, and validity. In the review phase, at least one humanfactors specialist participated full time on each survey team. Inaddition, the specialist performed an independent review of the controlroom,.the. results of which are available to each utility. Since thescope of the BWROG is limited to the planning and review phases, it isthe responsibility of individual utilities to arrange for human factorsconsultation, if required, in the assessment and implementation and
-6 -ENCLOSUREreporting phases. Human factors input during there phases isrecommended in plant-specific summary reports and in the descriptionof BWROG methodology submitted inthe program plan.5. Comment:Does the BWROG program determine, by analysis, what functions arenecessary to mitigate an event and to verify that the systems toaccomplish these functions do exist in the control room?BWROG Response:It is assumed, for the purposes of the control room design review, that.the technical guidelines developed by the BWROG adequately andcompletely define operator functions and tasks. The technicalguidelines are therefore used as a starting point for task analysesperformed by the BWROG survey teams. The validity of the technicalguidelines is to be evaluated separately by the NRC staff i-n responseto Item I.C.1 of NUREG-0737.6. Comment:Describe the systems analysis used in the BWROG program.BWROG Response:The technical guidelines developed by the BWROG are used as the basisfor task analysis and procedural walkthroughs. The followingmethodology is used:a. Operator tasks are defined.-b. Control and instrumentation requirements are specified for eachoperator task.
J-7 -ENCLOSUREc. The completeness of control room inventory is verified throughcomparison with instrumentation requirements established in thetask analysis.d. Task sequences are validated with walkthrough/talkthroughs.Traffic patterns, communication requirements and panelarrangements are considered.e. Each task is analyzed in terms of the following considerations:i. Is the sequence valid and complete?ii. Is sufficient information immediately available to theoperator to complete the task?iii. Do critical controls and displays identified for each taskconform to checklist evaluation criteria?iv. Do control/display relationships meet checklist criteria?v. Is manpower adequate to perform the task?vi. Are traffic patterns unobstructive?vii. Is direct feedback used to verify control functions?7. Comment:Validation of the allocation of functions should be based uponperformance criteria established as part of a reanalysis of operatorfunctions.
-P8 -ENCLOSUREBWROG Response:Task analysis used in BWROG program assumes that allocation of operatorfunctions and definition of operator tasks are adequately andcompletely defined by.the BWROG technical guidelines. It is thetechnical guidelines which form the basis of the BWROG program.8. Comment:The technical guidelines available at the time individual plantsurveys were performed had not been approved by the NRC. Whatfurther analysis, if any, will be performed when the final versionof the technical guidelines is available.BWRH G Response:Task analyses performed for each utility relied upon an early versionof the technical guidelines available at that time. Although subse-quent revisions to the technical guidelines do incorporate many changes,much valuable information was gained from the analyses performed. Itis expected that individual utilities will supplement this work withfurther analysis as plant-specific procedures are developed.9. Comment:Discu~ssthe methodology used in operator interviews. What precautionswere taken to assure impartial questioning and data recording?BWROG Response:The BWROG program recommends that a minimum of one-third of thelicensed operators at each plant participate in interviews, written
-9 -ENCLOSUREquestionnaires were distributed, followed by interviews with a memberof the survey team. An attempt was made to include a completespectrum of operator experience, education, ability, and physicalsize. Topics included in the questionnaires were selected to allow foroperator input on a wide variety of subjects and to address theconcerns for which operating experience must serve as the primary sourceof information. The questions were structured to avoid leading theoperator into specific answers or to limit his responses to specificareas. Each interviewer was trained in questioning techniques at aworkshop held in October 1980. Additional written guidelines wereprovided in a workshop supplement. distributed to survey team members.10. Comment:What method is used to prioritize and rate the safety significance ofHEDs identified in BWROG control room reviews?.BWROG Response:Assessment, prioritization, implementation, and reporting are not partof the BWROG program. However, a preliminary prioritization, based onpotential for error and degree of compliance, is. provided for theinformation of the utility as part of each Summary Report. Finalcorrective action recommendations will be determined in an item-by-itemreview of the HEDs, by each utility, addressing, in addition topotential for error and degree of compliance, the safety significanceof the components and systems involved, frequency of use, theconsequences of required operator retraining, and engineering and costfeasibility.
-10 -ENCLOSURE11. Comment:How does the BWROG control room review checklist compare to thechecklists found in Section 6 of NUREG-0700?BWROG Response:The BWROG checklists were developed prior to the issuance of NUREG-0700but were derived from essentially the same human factors standards andhave been reviewed in detail by a team of human factors specialists.While differences in presentation methods and areas of emphasis do*exist, the BWROG checklists are comparable in scope to those containedin NUREG-0700. Each is considered to be a valid set of human factorscriteria useful in the performance of control room design reviews.Credible results, with a high degree of similarity, can be expectedusing either document.Following the issuance of NUREG-0700, the BWROG compiled a ChecklistSupplement containing NUREG-0700 checklist items not directly addressedin the BWROG control room survey program. The desirability of includingthese items has been verified by the experiences of the BVJROG surveyteams. The Checklist Supplement is to be distributed for completion byindividual utilities.The level of detail provided by NUREG-0700 and the BWROG checklistsdiffers in certain respects. NUREG-0700 addresses many topics on adetailed, quantitative basis, whereas the BWROG believes a moregeneral, qualitative approach, coupled with survey team training, ismore appropriate. Control dimensions and actuation torques, chairdimensions, ventilation system air velocity, luminance ratios,communications system frequency response, and label character
-Ul -ENCLOSUREdimensions are examples. Where numerical values ere specified in theBWROG checklists (anthropometrics and background noise levels forexample) the values generally correspond closely to those in NUREG-0700and in some cases are more restrictive.A major difference between NUREG-0700 and the BWROG control room surveyprogram may be found in the evaluation of computer systems. The BWROGdoes not believe that a detailed design evaluation of the processcomputer is appropriate at this time since most plants place minimalreliance on the process computer for operational support. It isrecognized, however, that plants with advanced control rooms shouldaddress this area in more detail, and it is expected that human factorsconsiderations will be addressed during any future development ofcomputer-based operational aids.Several review areas are addressed by the BWROG which are not coveredin NUREG-0700. Among these are a comprehensive review of proceduresand limited reviews of training, manning, shift change, and maintenanceactivities as they relate directly to control room operation.12. Comment:What tasks must utilities address on an individual basis beyond thework performed by the BWROG survey teams?BWROG.Response:The BWROG survey program is designed to address only the planning andreview phases of NUREG-0700. Individual utilities are expected tocomplete the following tasks:
-12 -ENCLOSUREa. Submit an individual program plan to the NRC referencing the BWROGGeneric Program Plan. The plant-specific submittal should:i. Document the qualifications of survey team members.ii. Identify portions of the plant's DCRDR not performed inaccordance with the methodology specified in the BWROGProgram Plan.iii. Discuss the utility's program for prioritization of HEDs,reporting of DCRDR results, and implementation of controlroom enhancements.b. Complete the BWROG control room survey Checklist Supplement.c. Prioritize HEDs, determine corrective actions, develop animplementation schedule, and report the results of the DCRDR to theNRC.d. Consider the need for re-doing task analysis, based upon acomparison of final plant-specific emergency procedures(when available) with the version of the generic symptom-basedtechnical guidelines used during the DCRDR.These items will be emphasized in the BWROG control room surveyCheckJ ist Supplement.13. Comment:What are the relative strengths of the BWROG program?
-13 -ENCLOSURESWROG Response:The BWROG embarked upon the development of a DCRDR program in March1980 in a responsive, conscientious effort to identify potentialimprovements to BWR control rooms. Considering its early genesis, theparallels to NUREG-0700 are striking. Over a period of 2 years, theprogram has been implemented with successful results at 17plants. The BWROG considers the following points worthy of note:a. The program is generic in nature, a cooperative effort between BWRutilities, resulting in standardized review methodology.b. Extensive, multi-disciplinary design effort was involved in thedevelopment of the program. Reviews were performed by severalindependent agencies.c. Human factors specialists have been involved in each phase of theprogram.d. Impartial data gathering and standardized methodology were assuredthrough use of inter-utility survey teams. Survey team memberswere trained in design review techniques during a 6-day workshopfollowed by on-site instruction.e. Operational experience was incorporated into both the developmentand review phases.f. Integration of the DCRDR with other control room enhancementprograms was stressed from an early date.
-14 -ENCLOSURE9. Task analyses, operator interviews, and-operating experiencereviews were included in the review methodology. Task analyseswere based upon the new symptom based technical guidelinesbeing developed by the BWROG. The checklist reviews and operatorinterviews are relatively comprehensive.h. A final generic report will be prepared, summarizing results ofall BWR DCRDR to promote the exchange of experience, technology,and ideas between utilities...