ML17266A503

Forwards Responses to NRC Requests for Addl Info Re FSAR

ML17266A503
Person / Time
Site:	Saint Lucie
Issue date:	09/24/1981
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
L-81-420, NUDOCS 8109280436
Download: ML17266A503 (246)

Text

RKSUL4iTORl INFORMATION O'ISTRIBUTION SYSTEM (BIDS)

ACCESSIOV NSR;8109280436'OC DATE! 81/09/24 ~ NOTARIZED: NO DOGKEiT> ¹ FACILii50 389 St'8 Lucie Planti Unit 2i., Flor ida Power L LEight Go ~ 05900389 NA>>REI AU THOR AF F ILI AT'ION .'AUTHi, UHRI 9 i R E!

~ ~ Floriida Power 8 Light Co, RECIP VA SKI

~ RECIPIENT AFF IL>>IAT'IO>>V KiISENHUT'PD.G. Division of Licensing

SUBJECT:

" For wards responses to NRC requests for addi info re FSAR; OISTRISOTION COOEi>> 800>>S COPIES RECEEVEO:LO'R J.'NCL( Q SIZE>>'

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-.4 FLORIOA POWER & LIGHT COMPANY September 24, 1981 L-81-420 Office of Nuclear Reactor Regulation Attention: Hr. Darrell G. Eisenhut, Director Division of Licensing U, S. Nuclear Regulatory Commission 9 ff ie Washington, D. C. 20555.

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Dear Hr. Eisenhut:

Re: St. Lucie Unit 2 Docket No. 50-389 Final Safety. Analysis Report Re uests For Additional Information Attached are Florida Power 5 Light Company (FPL) responses to NRC staff requests for additional information which have not been formally submitted on the St. Lucie Unit 2 docket. These responses will be incorporated into the St. Lucie Unit 2 FSAR in a future amendment.

Very truly yours, obert E. Uhrig Vice President Advanced Systems' Technology REU/TCG/ah Attachments

'ggol cc: J. P. O'Reilly, Director, Region II (w/o attachments)

Harold F. Reis, Esquire (w/o attachments) )/s

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PDR ADOCK 05000389 PDRr I

PEOPLE... SERVING PEOPLE

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Attachment to.L-81-420 .

September 24, 1981 A. Minutes to Power Systems Branch meeting held on September 25, 1981.

B. Appendix 15C-4 (Station Blackout Analysis).

C. Minutes to fire protection meeting held on September 23, 1981.

D. Revised response to questions asked by NRC revi'ewer Greg Harrison concerning Appendix R (initially submitted on September 21, 1981)

E. Revised response to Question 8430.64.

F. Revised Pressure Isolation valves submittal (Initially submitted on September 9, 1981, L-81-394).

G. Minutes to Emergency Planning meeting held on September 24, 1981.-

H. Response to Human Factor Engineering Control Room Design Review/Audit Report, St. Lucie Unit 2.

8109280436

POWER SYSTEMS BRANCH MEETING

,(9/25/81)

1. FPL will provide assurance that when the grid or generator voltage is at its lowest expected limit (230 KV), relay settings will be such that the voltage on the 480 V system is not below its rating and that when starting the largest 4.16 KV motor the undervoltage protection does not operate.

2. Coincident logic will be provided.

3. FPL will provide the relay settings for the second level of voltage pro-tection relays in  % bus voltage and time.

4. FPL will provide assurance that no damage will occur to safety related motors when at the low voltage limit for transfer to the SUTRF:

(1) For motors that are on the bus are are running.

(2) For motors that are starting.

5. Provide one line diagrams for each case showing the voltage at each bus.

. 6.

7.

Analysis in accordance with the requirements of 120 V level.

FPL commits PSB-1 is to be to testing prior to fuel load in accordance with PSB-l.

to the

8. FPL will provide a statement that C-E has stated the required KW of pressurizer heaters needed following LOOP and when the heaters are required.

APPENDIX 15C-4 STATION BLACKOUT ANALYSIS

~ .The station blackout event is outside of .the. design basip for St.

Lucie Unit 2. Nonetheless, an analysis was performed as requested by the NRC in response to the decision of ALAB-603. This analysis shows that St, Lucie Unit 2 can successfully endure a complete loss of AC power for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Howev'er", it is expected that AC power would be restored either one of the following within 30 minutes to one hour as a result of corrective actions:

l. Offsite power is restored;

2. One or both of the St. Luc'ie Unit 2 diesel generators are started.

Maintenance of natural circulation during this event is assured by operator action, starting 30 minutes after event initiation, to keep the coolant in the RCS piping at subcooled conditions.

,The results of this analysis have shown that:

l. Natural circulation and core cooling can be maintained;

2. The reactor core remains in a subcritical condition;

3. There is no fuel failure;

4. The RCS coolant pressure remains within limits; and,

5. The resulting radiological doses are within limits.

Therefore, this analysis shows that St. Lucie Unit 2 can successfully endure station. blackout event. Florida Power and Light will implement operator training and emergency procedures to ensure that plant operators would take appropriate actions to assure maintenance of natural circulation.

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I I'gt 15C.4 Total .Loss of AC Power (Station Bl ackout) 15C.4.1 Identification of Event and Causes

. The Station Blackout event results from a loss of offsite by failure of both standby diesel generators to start..

Power'ollowed For Unit 2, this event results in a loss of all onsite AC power except that supplied by inverters from the two safebuards batteries.

This provides power to the 120 VAC (safeguards) instrument power and other required DC loads.

15C.4.2 Sequence of Events and Systems Operation Table 15C.4-1 shows-a chronological list of the timing of systems actions from the initiation. of a station blackout event to the time that offsite power is restored t A descrsptlon of he se-quence of events is given below for each safety function Reactivity Control: oem"S .

As a result of the loss of power to the reactor coolant pumps~ an automatic reactor trip signal is generated by the RPS on low reactor coolant system flow, as measured by steam generator delta-pressure (DP). The. reactor trip signal interrupts power to the reactor trip switchgear which in turn releases the CEA's to drop into the cor e. The negative reactivity inserted by the CEAs is sufficient to maintair the core subcritical, throughout the rest of the transient.

Reactor Heat Removal:

Following coastdown of the reactor coolant pumps, flow through the reactor is maintained by natural-circulation. Heat is trans-ferred to the secondary system through the steam generators.

Primary .System Integrity:

A Power Operated Relief Valve (PORV) opens to limit the RCS pres-sure increase following turbine trip. Steam released from tne PORV is contained in the quench ta'nk. Letdown is isolated by the closing. of. the letdown control valve on loss of offsite power.

Late in the transient, the Safety Injection Tanks provide borated water to the RCS increasing RCS inventory and helping to maintain subcooling in the hot leg.

Secondary System Integrity:

A turbine trip signal (TTS) is generated following the loss of offsite power and causes the turbine stop valves to close. The thin Steam Safety Valves (t)SSVs) open to lirrit the pressure in-crease.

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• Those safety'actions necessary to maintain he plant in hot shutdown.

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Auxiliary feedwater is automatically actuat erator level. Flow is provided by the turb derives.all its control power from the. stat ~ %v.

operator opens the. Atmospheric .Dump Valves .(ADVs) and regulates them from .the control .room to maintain steam.,generator, pressure below the setpoint of the MSSVs and to reduce the primary system temperature to maintain subcooling in. the hot .leg.

Restoration of AC power:

Although the analysis which follows shows acceptable results as-suming no AC power for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, in actuality AC power mould be restored to the plant prior to this timi (wife'u zoo,auT,s. <o ~e b~ n) bye84dt.o~ >~

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1) Offsite power is restored and the onsite buses are manuall'y connected to the startup transformers. Equipment is manually loaded on these buses~ according to plant emergency proce-dures>>ow

2) One (or both~gait 2 diesel generators is started and safe-guards loads manually sequenced onto its 4.16 KV bus .

15C.4.3 Analysis of Effects and Consequences A; Mathematical Models The HSSS response to a Station Blackout was simulated using the CESEC-III computer program.

.B; Input Parameters and Initial Conditions The initial conditions assumed for this event are 'contained in Table 15C.4-2. These conditions were chosen to provide the largest anC most rapid depletion of RCS inventory and shutdown margin. The highest initial pressurizer pressure, least negative Doppler cc-efficient and most positive moderator temperature coefficient maximize the power and RCS pressure early in the transient re-sulting in inventory loss through the PORY. The major contributors to the RCS depressurization are the pressurizer heat losses and RCS leakage. Maximum values of these parameters were sel:ected based on technical specifications, plant operating data and reactor coolant pump test results. The lowest initial pressurizer water volume minimizes the available RCS inventory. Initial core inlet temperature, core mass flow rate and pressurizer pressure have a negligible impact on the primary system depressurization. The eval-uation of shutdown margin depletion was performed using the most negative modera.or 'emperat.re coefficient and the least negative CEA worth for trip. This m:nimizes tne shutdown margin remaining at the end of the transient.

TR The disposition of normally operating systems is 15C.4-3.

15C.4-4.

The utilization of safety systems is g C'c C. .Resu1ts The dynamic *behavior of important NSSS parameters following a Station Blackout is presented in Figures 15C.4-1 to 15C.4-12.

Table 15C.4-1 summarizes some of the important results of this event and the times at which the minimum and maximum parameter values discussed. below occur. The loss of all AC electrical power initiates, among other things, a simultaneous'oss of feedwater, loss of load, and loss of forced reactor coolant flow. As indicated in Figure 15C.4-1, the core power increases initially Ae to positive reactivity feedback and.reaches a maximum value within a few seconds. Subsequent to loss of power to the reactor coolant pumps, the primary coolant flow decreases and a low flow reactor trip occurs as indicated in Tabl 15C.4-l.

Reactor coolant flow vs. time is shown on Figure 15C.4-7. Sub-sequently, due.to the insertion of large negative reactivity by the scram rods, the core power decreases ver apBPy and approaches the deca heat value. Z) ~~+ . ~'up+ < II During the initial few seconds prior to reactor trip, the reduced steam generator heat rejectioh capability leads to a rapid in-crease in both the primary and secondary fluid temperatures. The volumetric expansionr due to these increases in temperature produces sharp increases in primary and secondary pressures as well as an insurge of primary coolant into the pressurizer. The variations of the primary and secondary pressures are illustrated in Figures 15C.4- 3, and 15C.4.9.. The initial rapid inc~eases in both pres-sures are terminated by the opening of the PORV and llSSVs. The primary relief valve closes rapidly, as the primary system pres-sure decreases below the setpoint value within a few seconds after opening of the valve. The secondary safety valves cyc'le open and closed until the operator, opens the atmospheric dump valves.

MSSV and. ADV fTow vs. time are shown on Figures 15C.4-11 and 15C.4-12, respectively.

The steam generator liquid level decreases during the transient and reaches a minimum. value after auxiliary feedwhter flow is automatically actuated using the steam-driven auxiliary feedwater pump. Steam generator level increases until norrral water level is reached. The op rator subsequently controls auxiliary feedwater to maintain normal level. See Figure 15C.4-6.

The. RCS pressure and temperature gradually decrease at fairly constant rates in the long term as a result of pressurizer heat and ~~

loss, RCS leakage,low heat transfer rates at the steam generators, the operator manually reducing secondary side pres-sure. Since the RCS pressure decreases at a higher rate than the PCS temperature, -.'.".e pressure approaches the saturation pres-sure.

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Saturation occurs in the reactor vessel head p 8 P ressure drop without a significant decrease .h r a peratures would result in saturated conditions in the hot leg.

Credit is taken for operator action to maintain at least 10 F subcooling -in the hot leg. This- is accomplished by further.

opening the atmospheric dump valves to reduce the secondary system pressure and temperature. The increased heat r emoval in the steam generators caused by the larger hT across the steam generator tubes reduces the primary system temperatures. Voiding is restricted to the vessel head and natural circulation is not adversely impacted for more than 4 .hours.

The Safety Injection Tanks (SITs) provide borated water to the RCS after RCS pressure is reduced below their discharge pressure. No credit is taken for the negative reactivity added as a result of this disch'arge.

At 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, sufficient AC power is assumed'to be"restored"'to power to the charging pumps and pressurizer heaters. 'rovide These will be used o pressurize the RCS and to continue hot subcooling. leg Operability of the turb:ne driven auxiliary feedwater pump requires at least 50 psia secondary pressure. At 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initi=

ation of the event; the sec'ondary pressure will be greater than 300 psia. Less than 100,000 gallons of auxiliary feedwater are used during the event. The condensate storage tank capacity is ~~ 4~ W~

300,000 gallons.

Conclusions The maximum RCS pressure is 2.501 psia ( including reactor coolant pump andelevation heads). This is well below 110K of design pressure.

0 Natural. circulation is maintained for at least the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period that offsite AC power and diesel generator power are assumed unavail-able. During this time voids are restricted to the reactor vessel head and subcooling is maintained in the hot leg.

The radiological release due to a Station Blackout results in no more than a 0.4 rem 4 hour- inhalation thyroid dose at the exclusion area boundary.

The average RCS temperature at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is above 430 F. This is above the temperature at which the shutdown margin would be depleted.

Therefore, the core remains subcritical following reactor trip for the duration of the event.

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Table 15C.4-1 ~0 y

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SEQUENCE OF EVENTS, CORRESPONDING 5 e TIMES AND

SUMMARY

OF RESULTS '

FOR THE STATION BLACKOUT EVENT Setpoint or Time Sec Event Value 0.0 Loss of all on - and off-site AC power 1.5 LoQ Primary Coolant Flow Reactor Trip, X 2.0 Auxiliary Feedwater Actuation Signal, X of Narrow Range Tap Span 2.4 Power Operated Relief Valve Opens, psig 2385 2.6 Maximum Core Pow'er, X 104.8 r

5.5 pressure, Maximum RCS psia '..... 2541.

6.0 Maximum pressurizer pressure, ps 1 a 2460 6.3 Main Steam Safety Valves Open, psiq 995

".8;5' .Power Operated Relief Valve Closes, psig 2361

2. -Total Primary Relief Valve Release, ibm 554 2 $ ,2 Maximum Secondary System Pressure, psia 1038 182. 0 Auxiliary Feedmater reaches Steam Generators, gpm 500 1800:0 1'. . Operator Opens and Controls Atmospheric Dump Valves, psia 900

2. Main Steam Safety Valves close, psig 945.

3. Total Main Steam Safety Valve Release, ibm 116630

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Setpoint or Time Sec Event Value 2258.0 Voiding Occurs in Reactor Vessel Head 8600.0 Operator Begins to Reduce Steam Generator Pressure ..

to Maintain Hot Leg Subcooling 11785-'0 Main Steam Isolation Valves close, psig 435.0 12540.0 Safety Injection Tanks actuated, psia 583.0 14400.0 l. Operator Restor es AC Power

2. Total Atmospheric Dump Valve Release, ibm 363300.0

TABLE 15C.4-2 ASSUMED. INITIAL CONDITIONS FOR STATION BLACKOUT ANALYSIS ASSUMED VALUE

'ARAMETER Initial Core Power Level, MWt 2630 Core Inlet Coolant Temperature, F 551 Core Mass Flow Rate, 106 ibm/hr 133.9 Pressurizer Pressure, psia ~

2350 Initial Pressurizer Water Volume, I Level 40 Steam Generator Water Level, X of Narrow Range Tap Span 70 Doppler Coefficient Multiplier 0.85 Moderator Temperature Coefficient, 104 hp/ F To determine initial power transient, 0- 10 seconds +0:4 To determine degree of shutdown margin depletion 207 CEA Worth for Trip, 10 2 hp 6.68 Pressurizer Heat Loss, 106 BTU/hr 0.546 Primary Coolant Leakage, gpm: 16 Identi,fied Leakage, gpm a) Technical Specification Steam Generator Tube Leakage b) Primary Safety Valve Leakage c) Other Identified Leakage Unidentified Leakage RCP Controlled Bleedoff RCP Seal Leakage

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TASLE 15C.4-4 SL2-FSAR UTILIZATION OF SAFETY SYSTEMS FOR STATION BLACKOUT .

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1. Reactor Protection S stem

2. En ineered Safet Features Actuation S istems

3. Diesel GeneraLors and Sun ort S stems

4. Reactor Trio Switch Geax

5. Hain Steam Safet 'alves

6. Pressurizer Safetv Valves

7. Main Ste"m Isolation Valves

8. Main Feedwater Isolation Valves

9. Auxilia Feedwater S stem 2,4

10. Safet In'ect'on S stem ll. Shutdown Coolin S stem CCW & ICW

12. Atmos heric Dumo Valve S stem X C

13. Containm nt Isolation S stem

14. Containment Sorav S stem

15. Iodine Removal S stem

16. Containm nt Combustible Gas Contxol S stem

17. Containment Coolin Svs tern Notes: l. Both diesel generators fail for this event.

2. Only those portions powered from the safeguard batteries are available.

3. Safety Injection Tanks are available.

4. Auxiliary Feedwater is automatically actuated - Only the turbine driven pump is available.

5. AOVs can be manual.ly operated from the control room.

6. Portions of this system are actuated on loss of instrument air.

Systems not checked are not utilized durin this event.

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PIRE PROTECTION MEETING September 23, 1981 FPL commits to provide the capability for St. Lucie 2 to go to cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of a fire event using only onsite power.

2. FPL will provide a list of equipment that is required to achieve and maintain cold shutdown.

FPL will address the below instrumentation that is recommended to be included on the hot shutdown panel:

a. Pressurizer pressure and level

b. Reactor coolant hot leg temperature and either cold leg temperature on TAVG c;- Steam generator pressure and-level (wide range)

d. Source range flux monitor

e. Actual flow measurements for all pumps used (aux.

feedwater) f) Level indication for all tanks used (CST)

4. FPL will review and comment on the below listed NRC position:

The types of repairs allowed for cold shutdown were discussed.

While the replacement of cabling will be permitted, mechancial" repairs such as replacing a valve or pump will be reviewed to demonstrate practicably within the limited time available.

Procedures for repairing damaged equipment should be prepared in advance along with replacement equipment (i.e., cable made-up with terminal lugs attached). Also, replacement equipment will be stored onsite. All repairs should be of- sufficient quality control to assure safe operation. Repairs not permitted are the removal of fuses for isolation, the use of jumper cables and the use of clip leads behind control panels.

If repairs were to be made in the area where the fire occurred, the licensee would have to demonstrate that sufficient. time was allowed to cool the area and protect the repairs from remaining heat sources.

Question State all areas where PSL-.2 takes exception to Appendix "R" to 10CFR50.

Answer St. Lucie //2 is committed to complying with 10CFR50 Appendix "R".

Sections III B-0 Me will comply.

~session Verify that penetrations through fire barriers will be rated the same as the barrier.

Answer The fire rating of sealing media for penetrations of fire barriers separating redundant components necessary for safe shutdown will be the same as the fire barrier fire rating.

SL2-FSAR POWER SYSTEMS BRANCH 430e64 In Subsection 10.4.4-4 you have discussed tests and initial field inspection but not the frequency and extent of in-service testing and inspection of the turbine bypass system. Provide this information in the FSAR- (SRP 10.4.4, Part II-)

~Res oese FPL will provide an inservice inspection program .that wild. cover periodic operability testing of the turbine'bypass system, .The operability of these valves will be verified at least quarterly.

Yh~ nlkcsrLag pre@su"e isolation valvula h,:o bean idertiCied as Event V isoL.ae'W ooivt.e aed shalh. bl~ included in "re Se Lmie Unit. Ro Prime@

COO QAt 5'@SLED~ ~'eCZ<~ fQ ~i~-te Ssfet Xnlectimz F.. P Headee A Valvoa No.

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T. P Header 5 Valve Ãe-Loop 281 V 3P37 V-3260 V>>3247 V-326s.

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I In lieu of a continuous leak rate, a continuous pressure surveillance test, similar to St. Lucie Unit No. 1 shall be used to monitor pressure isolation valves on St. Lucie Unit No. 2.

The following valves shall be monitored continuously and either have or will have'instrumentation on the low pressure side. Alarms are provided in the Control Room and will annunciate a high pressure condition.

I. -Valve No.

V-3227 Instrumentation is presently available V-3217 for these valves V-3247

. V-3237 V-3527 V-3525 The following valves shall be monitored for leakage after a cold shutdown, and shall have instrumentation installed locally on the low pressure side of each valve.

II Valve No.

V-3258 V-3259 V-3261

, V-3260 V-3526 V-3524 V-3480 V-3481 V-3652 V-3651 Test Method In the event of a pressure increase the amount of leakage shall be cal-culated in accordance with the St. Lucie Unit No. 2 operating procedure No. 2-0410052.

The limiting conditions of operation shall be added to the St. Lucie Unit No. 2 technical specification which are under development.

A review of St. Lucie Unit No. 1 operating records has not shwon problems with the subject check valves.

The attached drawings show a high pressure pipe and valves in blue and the low pressure in pink.

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PA

EMERGENCY PLANNING MEETING September 24, 1981 Bethesda, MD

1. FPL will obtain a letter of agreement from DOE (Savannah River) addressing support for emergency response activities.

2. FPL commits to provide a revised state REP when this revised plan is available.

3. FPL will revise table 2.2a in the Emergency Plan to clarify that there is only one S.T.A. and one N.P.S. on shift.

4. FPL will revise table 2-2a to add clarification on the position of emergency communicator.

5. FPL will revise table 2-2a to remove the note associated with shift of.

personnel titles and possible title changes. The responsibilities the listed individual will not change with a change in title.

6, FPL cannot meet the NRC .staff position on staffing augmentation time expressed in table B-1 of NUREG 0654 Rev. 1. FPL will'notify the NRC of its intent to app'eal, reque'st exemption or comply with, the NRC position.

7. FPL agrees to place the INPO letter of agreement into Emergency Plan.

8. FPL agrees to place the Radiology Associates letter of agreement into the Emergency Plan.

9. FPL agrees to place the C-E letter of agreement into the Emergency Plan. when available.

10. FPL will .provide a update REEF Medical Plan with a signature page.

ll. FPL will provide additional specification in the letters of agreement Martin'County Sheriffs, Lawwood Medical Center with St. Lucie County and and the St. Lucie County Fort Pierce Fire District as discussed in NUREG 0654.

12. FPL will revise the Emergency Plan to specify the procedures for accomo-dation of NRC and FEMA personnel at the EOF.

13. FPL commits to provide additional specifications regarding specific resources available for federal response to emergencies including ex-pected arrival times.

14. FPL agrees to provide a followup message format to offsite agencies into the Emergency Plan.

15. FPL will revise the Emergency Plan to include a general system description of the alert and notification system.

16. FPL will provide a description of written messages intended for" the public.

17. FPL will provide a draft 'of the public information that will be pro-vided for annual dissemination.

18. FPL will revise the Emergency Plan to describe that the means of rumor control is via the close communication between FPL and the state and county and that this is. described in the public informa-tion.

19. FpL will incorporate the applicable instruments from FSAR table 11.5-1 that are specifically relied upon in the emergency classification into the Emergency Plan.

20. FPL will provide a description of the radiological monitors program which illustrated the coordination between FPL and the state and provide a statement that coordination with DOE will be provided by the state.

21. FPL will revise the Emergency Plan to include a reference to the pro-cedures used for determining the source term of potential releases of radioactivity.

22. FPL will specify that the meteorological data displaysare in both Unit 1 and Unit 2 control rooms.

23. FPL will revise the Emergency Plan to refer to the procedures and verify that the E-Plan and the procedures cover the items listed in draft SER section 13.3.2.9..

24. FPL will revise the E-plan to refer to the procedures covering item (5) of SER section 13.3.2.9.

25. FPL will revise the E-plan to expand the narrative on monitoring and decontamination capability that exists at the offsite assembly areas identified on page 5-16 of the Plan including reference to applicable procedures.

26. FPL will revise the E-plan to address the items affecting site evacuation routes. See SER section 13.3.2.10 item,(2).

27. FPL will revise the E-Plan to identify that offsite personnel emergency exposure will not exceed 10 CFR 20 guidelines.

28. FPL will revise the E-Plan to include reference to procedure HP-1. This resolves item (2) of draft SER section 13.3.2.11.

29. FPL will revise the E-Plan to incorporate items (3) and (4) of draft SER section 13.3.2.11.

30. FPL will revise the E-Plan to provide for accountability of all onsite individuals within 30 minutes of the declaration of an emergency and for all onsite individauls continuously thereafter.

31. FPL will revise the E-Plan to provide a summarized table of evacuation times for normal and inclement weather.

32. 'FPL will revise the'E-Plan to specify that the bases for the choice of recommended protective action is the EPA PAG's.

33. FPL will revise the E-Plan to include in the drill program communica-

, tion tests with the plant offsite monitoring teams and the aspect of understanding the content of messages for all the communication tests and that some drills will be unannounced.

34. FPL will revise the E-Plan to identify, by title, the individual with the overall authority and responsibility for radiological emergency response planning.

35. FPL will provide the revised E-Plan by January 15, 1982.

ST. LUCIE 2 FPL/NRC. MEETING Se tember 24, 1981 Emer enc Plannin Attendees:

J. Sheets FPL.

D. B. Matthews NRC/IE/DEP F. G. Pagano NRC/IE/DEP D. J. Perrotti NRC/IE/DEP V. Nerses NRC/NRR/DL H. F. Buchanan FPL K. N. Harris FPL B. Frechette FPL B. W. Kelsey FPL J. J. Maisler FPL H. M. Mercer, FPL F. D. Lomax NRC S. Ramos (part-time) NRC E. Williams NRC

DRAFT

'MERGENCY PREPAREDNESS EVALUATION REPORT BY THE DIVISION OF EMERGENCY PREPAREDNESS OFFICE OF INSPECTION AND ENFORCEMENT IN THE MATTER OF ST. LUCIE 2 NUCLEAR STATION DOCKET NO. 50-389 SEPTEMBER 1981

13.3 Emer enc Pre aredness Evaluation 13.3 ~ 1 Introduction Evaluation by the Nuclear Regulatory Commission (NRC) of the state of emergency preparedness associated with the St. Lucie Unit 2 Nuclear Station (site) involves I

review of Florida Power and Light Company's (FP8L, applicant) emergency prepared-nessand the Federal Emergency Management Agency's (FEMA) findings on State and local radiological emergency preparedness. This evaluation addresses the applicant's emergency preparedness. Supplement(s) to this evaluation will address the findings and determinations of FEMA on the adequacy of the State and local emergency response plans and the NRC staff's overall conclusions on the status of emergency preparedness associated with the St. Lucie site and related Emergency Planning Zones.

The St. Lucie site is located on Hutchinson Island in St. Lucie county on the east coast of Florida, about eight miles south of Fort Pierce, Florida, and eight miles north of Stuart, Florida, with the plume exposure pathway Emergency Planning -Zone (plume EPZ) located within the counties of St. Lucie and Martin.

The plume EPZ covers the area within approximately 10 miles of the site and includes the city of St. Lucie, the town of Jensen Beach and a portion of the Indian River. The Atlantic 0'cean covers about 50 percent of the plume EPZ to the east of the site.

FP8L filed, by letter dated December 30, 1980, a comprehensive revision to the St. Lucie Unit 1 Radiological Emergency Plan (Unit 1 Plan), Revision 7, dated January 2, 1981, in accordance with the new emergency planning rule which became effective November 3, 1980. Since the submittal of Revision 7, FP8L has responded to NRC staff comments on Revision 7 and has submitted to the NRC: 1) Revision 8 (minor revision, April 1, 1981), 2) Revision 9 (major revision, August 1, 1981),

and, 3) by letter dated September 1, 1981, a revision to the Unit 2 FSAR which included a revised St. Lucie Plant Radiological Emergency Plan that incorporated Unit 2.

On June 8-19, 1981, the Emergency Preparedness Licensing Branch (EPLB) conducted an Emergency Preparedness Implementation Appraisal (EPIA) at St. Lucie Unit l.

St. Lucie SER Nerses/Perrotti LUCIE/B

Revision 9 to the Unit 1 Plan provided partial resolution for those plan deficiencies identified during the EPIA.

~ ~ ~ ~ ~ ~ ~

This Emergency Preparedness Evaluation Report applies to the St. Lucie Plant (Units 1 and 2) Radiological Emergency Plan (hereinafter referred to as the Plan), as submitted by FPKL on September 1, 1981, as a change to the Unit 2 FSAR.

The Plan was review'ed against the requirements of 10 CFR 50.47(b), 10 CFR 50, Appendix E, and the criteria of the 16 Planning Standards in Part II of the "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654/FEMA-REP-l, dated November 1980.

Section 13.3.2 of this report lists each standard followed by a synopsis of applicable portions of the Plan as they apply principally to the standard and those items for which resolution is required. Section 13.3.3 of this report provides our review conclusions.

Evaluation of the

~

13.3.2

~ Emer enc Plan

13. 3. 2. 1 Assi nment of Res onsibi lit (Or anizational Control)

Standard Primary responsibilities for emergency response by the nuclear facility 1'icensee, and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organi-zations have been specifically established, and each principal response organiza-tion has staff to"respond .and to augment its initial response on a continuous basis.

Emer enc Plan Evaluation The Plan describes the functions and responsibilities of the State and local.

organizations that are part of the overall response organization for Emergency St. Lucie SER 13-2 Nerses/Perrotti LUCIE/B

E

~

Planning Zones.,The Plan illustrates the overall State of Florida

~

Emergency Response Organization. ~

The State of Florida Bureau of Disaster Preparedness (BDP) is the State agency authorized to receive initial notification from FP8 L and is responsible for mobilizing the State and county emergency response agencies in accordance with thp Florida Radiological Emergency Plan for Nuclear Power Facilities (State Plaijl. This plan appears in Appendix A to the St. Lucia Plan and includes the St. Lucie and Martin County plans. However, the State of Florida REP, submitted under correspondence dated December 30, 1980, has undergone substantial changes and must be re-submitted. The Plan describes the BDP's defined responsibilities.

The State of Florida Department of Health and Rehabilitative Services (DHRS),

Radiological Health Services, is the State agency authorized to provide the BDP with technical support and expertise in radiological matters. The Plan describes the DHRS defined responsibilities. The Plan also describes other State agencies that provide support to the BDP.

P The 'Plan -identifies the counties within the plume EPZ and those within the ingestion pathway EPZ, and, in general, the responsibilities of these local organizations.~

The Boards of County Commissioners are responsible to take action to protect life, health, safety, property, and the environment from the consequences of nuclear power accidents. The decision to implement protective action recommenda-tions will be made jointly by Chairman, Boards of County Commissioners, and the Governor or State Director, Division of Public Safety Planning and Assistance

'(DPSPA). If time does not permit State involvement in initial decision making, the decision to take protective actions may be made by the Chairman, Boards of County Commissioners, or their designated alternates.

Alerting, warning, and evacuation of populations, hosting responsibilities, including shelter location and operation, and evacuee registration, monitoring, and decontamination is described in the State Plan.

St. Lucie SER 13-3 Nerses/Perrotti LUCIE/B

Responsibility for direction and control rests with the Chairman, Board of County Commissioners, unless a disaster declaration under provisions of Florida Statutes, Chapter 252, is in effect. If a disaster has been declared, responsi-bility for dir ection and control rests with the Governor or Director, DPSPA.

The County Disaster Preparedness Directors, who report to the Boards of County Commissioners, are responsible for actual plan development and updating. The Disaster Preparedness Coordinator (DPC) for St. Lucie County has the major responsibility while the DPC for Martin County functions in a supporting role.

The DPCs receive initial notification from FP8L simultaneously with BDP via the National Alert >laming System (NAMAS) for Site Area or General Emergencies.

For an Alert, the notification will be made to BDP and County EPCs (within approximately 15 minutes) by telephone with NAMAS as backup. The State BDP is notified (within approximately 15 minutes) and in turn notifies the County DPCP of an Unusual Event.

Updated written agreements have been executed with the Federal, State, and local agencies and organizations identified in the Plan as providing radiological support, hospital support and transportation, fire protection, traffic control on land and waterways, and law enforcement during an emergency. Appendix A, State of Florida REP, contains an agreement signed by FP8 L, State and county officials.

Letters of agreement involving emergency support by offsite support agencies/

organizations are discussed further in Section 13. 3. 2. 2, below.

An agreement letter between FP8 L and the Department of Energy (formerly ERDA)

Savannah River Operations Office (DOE-SROO), dated April 12, 1977, that was included in Revision 8 to the Unit 1 Plan has been deleted from the Plan.

following item requires resolution:

The

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(1) Provide an updated agreement letter with DOE-SR00.

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(2) Submit an updated State plan.

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St. Lucie SER 13-4 Nerses/Perrotti LUCIE/B

13.3.2.2 Onsite Emer enc Or anization Standard I

Onshift facility licensee responsibilities for emergency response are unambig-uously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and -the interfaces among various onsite response activities, and offsite support and response activities are specified.

Emer enc Plan 'Evaluation The Nuclear Plant Supervisor (NPS), designated as the Emergency Coordinator, has the responsibility and authority to implement the Plan and initiate any necessary emergency actions. He is relieved by the Nuclear Water Engineer following proper turn'over procedure. The Emergency Coordinator operates from the Technical Support Center. The Emergency Coordinator will not delegate the

~

responsibility for the decision to notify and make protective action recommenda-

~ ~ ~ ~ ~

tions to offsite authorities. The Plan identifies a line of succession, up to

~ ~ ~ ~

the Plant Manager, for the position of Emergency Coordinator.

~

~

Station staff emergency assignments have been made and the relationship between the emergency organization and normal staff complement are specified and illus-trated in the Plan. Positions and/or titles of shift and plant staff personnel, both onsite and offsite, assigned emergency functional duties are listed.

The shift staffing specified in the Plan does not meet the specific staffing recommendations expressed in Table B-1 of NUREG-0654. Clarification is needed in Table 2-2a of the Plan with regard to the position of the individual on shift assigned the task of notification and maintaining communications, and the identi-fication of two Nuclear Plant Supervisors and two Shift Technical Advisors (STA) on each shift. Additionally, Table 2-2a indicates that changes in the number of Nuclear Watch Enginers (from 1 to 2), Nuclear Control Center Operators, SRO and RO (from 2 to 4), Nuclear Operators (from 1 to 2) and Nuclear Turbine Operators (from 1 to 2) are pending NRC/FP&L negotiation.

St. Lucie SER 13-5 Nerses/Perrotti LUCIE/B

4L The response time for augmentation capability does not meet the specific staffing recommendations at 30 and 60 minutes expressed in Table B-1 of NUREG-0654 in any position. Table 2-2a of the Plan indicates a capability for additions within I

45-90 minutes af ter noti fi cati on.

Mhen an emergency condition arises, the NPS is designated as the Emergency Coordinator and it is his responsibility to evaluate the situation. If, in his judgment, conditions meet or exceed any of the emergency classification action levels, it is his responsibility to implement the Plan. There is 24-h'our-per-day communication linkage'capability between the St. Lucie site and Federal, State, and local response'gencies and organizations to ensure rapid transmittal o'f accurate notification information and emergency assessment data.

The authority, responsibility, and duties of the plant'staff personnel for "copying with emergencies are defined for both the normal operating staff, and the augmented staff. The Plan describes the functions of the onsite emergency organization, licensee headquarters support, and State and local government I

support groups. However, the interface between and among these gro'ups and the onsite Technical 'Support Center (TSC), Operations Support Center (OSC), and near-site Emergency Operations Facil'ity (EOF) has not been illustrated.

The Plan describes the expanded response phase initiated by the Emergency Coordinator. His notification mobi lizes the FP8L Offsite Emergency Organiza-tion as well as local, State, and Federal emergency response organizations.

The Emergency Control Officer. (ECO), a designated corporate officer, has the

'uthority to establ',sh policy and ex'pend the funds necessary to cope with any emergency situations that may arise.

'I The Recovery Nanager (RN), a designated corporate officer, has the responsibility for directing FP8 L's expanded emergency resp'onse organization. The RM can report to the General Office Emergency Center, the near-site EOF or the onsite TSC depending on his assessment of. situation.

St. Lucie SER 13-6 Nerses/Perr otti LUCIE/B

The Expanded Response Organization is described and illustrated in the Plan.

Additional staff support can be provided to augment. the operating staff onsite and offsite. The ECO will have access to t,his support through the offsite Emergency Roster mai ntained by the Emergency Planning Supervisor (EPS).

Lines of succession for the ECO and Managers of the Offsite Emergency Organiza-tion are controlled by procedures maintained by the EPS.

The Plan identifies the Institute for Nuclear Power Operations (INPO) and Combustion Engineering Company (CE) as possible sources of additional technical, personnel, and material support. The Plan also identifies Radiology'Associates, Inc. as providing medical support at the Lawnwood Medical Center. Written however, are not provided for INPO, CE or Radiology Associates, 'greements, Inc. In addition, the written agreements involving the Mt. Sinai Radiation Emergency Evaluation Facility (REEF), the Energy Research and Development Agency (ERDA), the Radiation Emergency Assistance Center Training Site (REACTS),

and the REEF Medical Plan are on the order of 3-5 years old and require updating.

The REEF Medical Pl an e

also requires a signature page.

The letters of agreement with offsite police, ambulance, hospital, and fire support identify the emergency measures to be provided. However, the letters do not delineate the limits on the actions of the support groups, the mutually acceptable criteria for their implementation, or the arrangements for exchange of information.

The following items require resolution:

0, e Clarify the position of the individual assigned the tasks of notification/

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c~ i'drp~.Ci~m Gg~/~ Iten 7c> ycfp<<j gB 0~<>~~ojin Cc~si" ruuiiocaru .~

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2) Clarify Table 2-, 2a regarding the Mv NPSs and we STAf on each shift. If there are two NPSs on each shift indicate which one becomes the Emer'gency

/

Coordinator in an emergency situation. +~d- ~oC< C%upy L/

a St. Lucie SER 13-7 Nerses/Perrotti LUCIE/B

( /JPQ,itic.k NE ](sttI I $ (R

3) Provide final cgan 'es in the shift staffing for /he~ 6sjtions of uclear (fl  %

/f rg{

Match Engineer;~) clear Control Center Operator, u 1'ear Operator, and Ig.

Nuclear (Turbine Operator as- discussed .above.

P (4) Provide an onsite shift staff and augmentation ca ability for shift staffing that meets the specific staffing recommendations expressed in Table B-1 of NUREG-0654. '+~zfiS~

/-"PE fi're rovide letters of agreement for INPO, CE, <- and Radiology Associates, Inc.

P

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+P>O /clice pfi& + ctC/dcf lb /4(4e g. 4.

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/g /~ C~ gZ Pcsype6<rf<g pi PV< OCO p 8"' i Update the letters o'f agreement withfREEF, ERDA, IREACTS, and the REEF M dical Plan. (~<>~-'f'~'~ ~ n,q ipgj al C'r y.P"g zzr p~..rebec! p(an r 3ignc/~op, QprscmrI ,

) Provide additional s P ecification in the 1 etters of agreement with the gg St. Lucie County and Hartin County Sheriffs, Lawnwood Medical Center, and

~

t e St. Lucie County - Fort Pierce Fire District as discussed above.

~

~ ~

~ <- O~C-Pre~. d~ zz cia/~tr-e& acjosv11dg2<cn (8) Provider"an illustration of the interface between and among the onsite e e dncy organization, licensee headquarters support, State and local go er mqnt support groups, TSC, OSC and EOF.

13. 3.2. 3 Emer enc Res onse Su ort and Resources Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.

Emer enc Plan Evaluation Request for support under the Federal Radiological Monitoring and Assessment Plan (formerly Radiological Assistance Plan (RAP) and Interagency Radiological Assistance Plan (IRAP)) will be coordinated through BDP, DHRS. The Emergency St. Lucie SER 13-8 Nerses/Perrotti LUCIE/B

Coordinator has the responsibility to notify Federal, State, and local officials, as appropriate, upon declaration of an emergency. .

FP8L has provided facilities for representatives from Federal, State, and local government organizations and groups at the EOF. The Plan, however, does not provide information concerning specific licensee, State, and local resources available to support Federal response or the expected arrival times of Federal assistance at the site.

The Plan states that FPKL will dispatch a representative to the St; Lucie County EOC which has been identified as the primary EOC for an emergency at St. Lucie.

In addition to the St. Lucie site primary and backup radiological laboratories, the Plan identifies a hot lab backup at the site using portable equipment, the State's Mobile Emergency Radiological Laboratory (MERL) available within three hours of notification, and laboratory facilities at FP8 L's Turkey Point Plant which can be used.

The following item requires resolution:

(1) Additional specification ~is needed regarding

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specific licensee, State and local resources available to support the Federal response, and the expected arrival times of Federal assistance at the site.

13.3.2.4 Emer enc Classification S stem

'tandard,.

A standard emergency classification and action level scheme, the bases of which include facility system;and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

V St. Lucie SER 13-9 Nerses/Perrotti LUCIE/B

Emer enc Plan Evaluation The four standard emergency classes (i.e., Unusual Event, Alert, Site Area Emergency, and General Emergency) have been established by the applicant.

Observable and measurable emergency action levels (EALs) which, if exceeded, will initiate each emergency class, consistent with the criteria of Appendix 1 of NUREG-0654, have been established. EALs are provided using specific instru-mentation, parameters, and equipment status. Emergency Plan Implementing Procedures (EPIP) contain specific information and guidance for determining the appropriate EAL and properly classifying the emergency condition, as well as the appropriate actions to be taken.

An upgraded Emergency Classification System, contained in Section 3 of the Plan submitted by FP&L on September 1, 1981, incorporates Unit 2 into the emergency preparedness program. This upgrade is currently under review by the staff. A supplement to this report will provide the staff's conclusions as to the adequacy of the Emergency Classification System for the"St. Lucie site.

Standard Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all responses organizations; .the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instructions to the populace within the plume exposure pathway Emergency Planning Zone have been established.

'I Emer enc Plan Evaluation The Plan is activated with the declaration of an emergency. The NPS will continue as the Emergency Coordinator until properly relieved by the Plant Manager or his designated alternate.

~

The Plan and associated procedures establish and describe a notification and verification system

~ ~ ~

which is consistent

~

with Appendix 1 to NUREG-0654. The system provides for rapid

~

~ notification. of St. Lucie SER 13-10 Nerses/Perrotti LUCIE/B

the FP8I onsite and offsite Emergency Organizations, Florida Bureau of Disaster Prepardness Emergency Operations Center (EOC), St. Lucie County EOC, Hartin County EOC, and the NRC Operations Center.. The essential communication links are manned continuously and will be periodically tested to assure availability.

The information to be reported to the offsite agencies in the event of an emergency has been predetermined in accordance with the recommendations in NUREG-0654 and the format of the initial notification message is included in the Plan. The Plan specifies that follow-up messages will be made by the Emergency Coordinator to BDP, however, the format and content of follow-up messages is not specified. The initial message format could be used for follow-up messages provided additional information is supplied: including the

'type of actual or projected release; the projected integrated dose at the site boundary and at 2,5, and 10 miles including the affected sector(s); the request for any needed onsite support by offsite organizations; and the prognosis for worsening or termination of the event.

The Plan specifies that FP8 L has committed to purchase and install an alert (siren) system. The Plan, however, does not indicate that the system will meet the recommended criteria set forth in Appendix 3 to NUREG-0654. The Plan speci-fies that the State Plan provides information on warning of the public and discusses warning procedures in St. Lucie and Hartin counties. The State Plan also provides the guidance for keeping the public informed about the potential hazards, emergency response, and protective measures that can be taken to minimize or avoid public health affects. The Plan, however, does not address written messages intended for the public.

The following items require resolution:

04 Provide followup'messages from the facility to offsite authorities.

(2) Describe an Alert and Notification System that meets the design objectives of Appendix 3 to NUREG-0654. ~ The Plan should address the administrative and physical means, and the time requirea to promptly notify the public

~ ~ ~

of an emergency. The Plan should commit to the establishment of such a

~

system and indicate when the system will be implemented.

St. Lucie SER 13"11 Nerses/Perrotti LUCIE/B

I (3) Provide 13.3.2.6 a description of written messages intended for the public, con-sistent with the licensee s classification scheme.

Emer enc Communications Standard Provisions exists for prompt communications among principal response organizations to emergency personnel and to the public.

Emer enc Plan Evaluation Primary and backup communication links which include provisions for 24-hour per-day notification are provided'ith the Federal, State, and local emergency response organizations within the 10-mile EPZ. The Plan includes organizational titles and alternates for both ends of the communication links.

"~

~ ~

The offsite communication systems include the NA>!AS, commercial telephone, dedicated telephone lines, company radio and Local Government Radio (LGR).

The Plan provides for periodic testing of the entire communication system.

The Plan describes the communications between the State and,local EOC, radiological monitoring teams, NRC headquarters, NRC Regional EOC, interim EOF, and interim TSC.

The Plan describes the arrangements for offsite medical support and contains written agreements for offsite medical care and for transportation to these facilities. The Plan describes a coordinated communication-link for fixed and mobile medical support facilities.

St. Lucie SER 13-12 Nerses/Perr otti LUCIE/B

13.3.2.7 Public Education and Information Standard F.

Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e. g.

listening to a local broadcast station and remaining indoors); the principal points of contact with the news media for dissemination of information during an emergency (including physical location or locations) are established in advance and procedures for coordinated dissemination of information to the public are established.

Emer enc Plan Evaluation The Plan specifies that the State of Florida BDP and St. Lucie County and Martin County Oisaster 'Preparedness Agencies have the responsibility for conducting the public information program with FP&L providing support for the program by supplying the information requested by those .agencies. This program will include information on radiation, respiratory protection, sheltering, evacuation procedures, warning and notification systems, and who to contact for additional information.

The State Plan contains discussion on evacuation of "special needs" population.

Transient and permanent population will be provided an opportunity to become aware of the information. Mhi le the Plan indicates that'he information will be disseminated periodically, it does not specify that the program will be updated and disseminated on an annual basis.

FP8 L will conduct an annual program for personnel of the news media which will acquaint these persons with the Plan, provide information concerning radiation, and provide points of contact for release of public information during an emer-gency.

FP8L has established an Emergency News Center near the interim EOF. The Emergency Information Manager (EIM) is responsible for disseminating information to the public via the media. The EIM will work with the NRC, State and local

~ ~ ~

~

news media representatives and will assure that exchange of information among

~ ~

St. Lucie SER 13-13 Nerses/Perrotti LUCIE/B

designated spokespersons i's'accomplished in a timely manner. The Plan indicates that this timely exchange of information will aid in responding to rumors, how-ever, the Plan does .not address coordinated arrangements for dealing with rumors.

The following items require resolution:

nc ude in the ub ic nfo atio p ogram p ovi ions ~f r,- an ual sse 'ion f in mati ~ to th ublic n prov'de a draft f t is mate 'al for re iew.

(2) Provide a coordinated arrangement for dealing with rumors. "

13. 3. 2, 8 Emer enc Facilities and E ui ment 1

Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained. ~ 'I Emer enc . Plan Evaluation Emergency facilities to support an emergency'esponse have been established as follows:

(1) Control Rooms The Control Rooms contain those controls, instruments and communications equipment necessary for operation of the plant under both normal and emergency

- conditions. The ventilation system, shielding, and structural integrity are designed and built 'to permit continuous occupancy during postulated accidents.

For any emergency response, the Control Room of the affected unit serves as the initial point of control.

(2) Technical Support Center (TSC).

The interim TSC is located adjacent to the Unit 1 Control Room. The role of the 'TSC is to provide command and control functions, provide dose assessment, St. Lucie SER 13-14 Nerses/Perrotti LUCIE/B

and provide technical assistance to the Control Room and EOF staffs. The Emergency Coordinator and his staff will be located at the TSC. Activation of the interim TSC wi 11 be initiated by the Emergency Coordinator in the event of an Alert, Site Area Emergency or General Emergency. Arrangements will be made to staff the interim TSC in a timely manner.

(3) Operational Support Center (OSC)

The OSC provides an area for operations, maintenance, health physics, and chemistry personnel to assemble and be assigned to duties in support of the The OSC is located in the first floor maintenance area of emergency response.

the Service Building. PAX communications are maintained between the OSC and Control Rooms. Activation of the OSC will be initiated by the Emergency Coordinator for, Alert, Site Area Emergency and General Emergency. Arrangements will be made to staff the, OSC in a timely manner. In th'e event the OSC becomes untenable, the Emergency Coordinator will designate an alternate location..

(4) Emergency Operations Facility (EOF)

The interim EOF is designated as the Unit 2 site construction office building.

The interim EOF provides the central point from which evaluation and coordina-tion of all FP8L we'll activities -related to an emergency can be carried out and from which FP8L can provide information to Federal, State, and local authorities.

The interim EOF contains emergency radiological monitoring equipment and supplies, untimely communications network including LGR and commercial telephone lines, essential precalculated emergency data and reports, and plant drawings. Activation of the interim EOF be initiated by the ECO during a Site Area Emergency or General Emergency. Arrangements will be made to staff the interim EOF in a manner.

An alternate EOF is maintained at FP8L's Malton Transmission and Distribution Substation, approximately 5 miles .west of the plant. This facility will be used if the interim EOF becomes untenable. Continuity of EOF functions during any transition between the interim and alternate facilities will be maintained by, the General Office Emergency Center and interim TSC.

St. Lucie SER 13-15 Nerses/Perrotti LUCIE/8

A permanent EOF has been proposed by FP8L. Following the formal submittal by e FP8L, a review (5) General Office of the permanent EOF Emergency Center will be completed.

The General Office Emergency Center is an area within the Power Resources Management area at the FP8L General Office in Miami, FLorida. It is equipped with a dedicated telephone to the Plant Manager's office. The ECO and his staff will man the center to direct the Offsite Emergency Organization and to provide support and resources to, the onsite organization until the ECO directs the organization to staff the interim EOF.

The Plan describes, in general, radiation monitoring systems portable radiological sampling and analysis equipment, and a meteorological measurements system, including an offsite back-up source of data. However, additional specification of the Area and Process Radiation Monitoring systems is required including type of detector, location, range of measurement and alarm set point. The Plan does

~

not describe other onsite monitoring systems that would be used to initiate

~ ~ ~

~ ~ ~

emergency measures, including hydrologic and seismic monitors, and process monitors (e.g., liquid levels, flow rates or line-up of equipment components).

~ ~ ~ ~

~ ~

FP5L is in the process of upgrading the onsite meteorological measurements program in accordance with Appendix 2 to NUREG-0654. At a later date a supplement to this report will provide the staff's evaluation and conclusions on the adequacy of the upgraded .system.

The Florida DHRS maintains a system of 39 TLD stations in the vicinity of St.

Lucie. Stations are provided in each 22<'ector at approximately the 1 mile, 5 mile, and 10 mile radii.

Labo'ratory facilities are provided as discussed in Section 13. 3. 2. 3, above.

The plant's onsite laboratory serves as thy primary facility with back-up provided by portable equipment. Analysis of onsite environmental samples will be performed at the State's MERL. This mobile lab can be in position near the site within three hours of notification and serves as the central point for

~ ~

St. Lucie SER 13-16 Nerses/Perrotti LUCIE/P

the receipt of all offsite field monitoring data and coordination of sample media. The Plan specifies that the State Plan describes field monitoring

~ ~

~

teams including team composition, transportation, communications, equipment

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The Plan specifies that plant procedures

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and estimated deployment times.

provide for activation of emergency field monitoring teams; howver, there is no desciiption in the Plan of a coordinated program for Environmental Radio-logical Monitoring, including pr'ovisions to acquire data from or for emergency access to offsite monitoring and analysis equipment.

Designated 'emergency equipment that is maintained at key locations throughout the plant will be inventoried, operationally checked and inspected, at least once each calendar quarter,and following each use. The Plan provides'eneral emergency equipment lists for the Control Room, OSC, and the interim EOF.

The following items require resolution:

pP (1) Provide a description of the Area and Process Monitorin Systems, including

.type of detector, location, range of measurement and'larm set

~ I t andb other onsite monitoring systems that would be used to initiate emergency I,

measures'I (2) Provide for a coordinated Environmental Radiological Monitoring Program, including procedures which interface with the offsite support from the State of Florida and DOE.

(3) Provide a list of general types of emergency equipment located at the interim TSC referenced in Section 7.4 of the Plan.

13.3.2.9 Accident Assessment I'tandard Adequate methods, systems', and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

St. Lacie SER 13-17 Nerse's/Pe'rrotti LUCIE/B

Emer enc Plan Evaluation The Plan identifies specific instrument readings and other observable and measurable parameters which, if exceeded, will indicate an emergency as discussed in Section 13-.3.2.4 of this evaluaton. General descriptions are given for effluent monitors, area radiatioh monitors, grab sampling equipment and containment monitors. Specifications of instrumentation utilized for accident k

assessment are contained in procedures. Post accident sampling capabilities are also described in procedures. However, the Plan does not address the methods and techniques (procedures) to be used for determining the source term of potential releases of radioactivity material (e.g. the relationship between containment monitor readings and the radioactive material available for release from containment).

N The Plan does not indicate whether the plant radiation monitoring systems meet the upgraded requirements of NUREG-0737.

~ ~

A plant procedure 'provides the details on the method. for estimating initial doses using current meteorological data, process monitor data and post-LOCA radiation monitors. Dose calculations will be updated periodically during the ll course of an accident and the results will be provided to State and county authorities. Default values, using conservative estimates of release rates, can be utilized if assessment instrumentation is not available (offscale or inoperable) and field sample analysis has not yet been completed.

The Plan specifies that meteorological data displays are avai Able in the Control Room. It is not clear, however, if Unit 2 Control Room has meteoro-logical data displays. Communication systems between the Control Room, the interim TSC, interim EOF and State EOC provide access to meteorological data.

The Plan describes, in general terms, the capability for field monitoring by plant perso'nnel during the period from the onset of an emergency to the time required for State monitoring teams to get in position in the vicinity of St.

Lucie (estimated to be approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />). Additional. information regarding

~ ~

~

the capability for offsite monitoring by plant personnel is needed, including

~ ~ ~ ~ ~

St; Lucie SER 13-18 Nerses/Perrotti LUCIE/B

field team composition, activation, notification means, monitoring equipment and deployment times. In addition, the capability to detect and measure radioiodine concentrations in air, in the plume exposure pathway EPZ, as low as E-07 microcuries per cubic centimeter, under field conditions, has not been addressed in the Plan.

The Plan compares the estimated integrated doses with the protective action guides. However, it is not clear that the means have been established for relating the various measured parameters to dose rates for key 'isotopes and for estimating integrated dose from the projected and actual dose rates.

The following items require resolution:

C (1) Describe the methods and techniques to be used or determ ning the source

, term of potential releases of radi oacti ve material.

(2) Identify the plant radiation monitoring systems that

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meet the re uirement of NUREG-0737.

s Specify whether Unit Control Room has meteorological data displays.

sf~.'3) 2 (4) Provide additional information on the offsite monitoring capability by~

plant personnel,, including those elements described above."(A

'I

~~

(5) Provide the capability for detection and measurement of radioiodine concentrations in airs in the plume EPZ, as low as E-07 microcuries per cubic centimeter, under field conditions.

(6) Describe the means for relating the various measured parameters to dose rates for key isotopes and for estimating integrated dose from projected and actual dose rates.

St. Lucie SER 13-19 Nerses/Perrotti LUCIE/B

13. 3.2. 10 Protective Res onse Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with'ederal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

Emer enc Plan Evaluation The Plan establishes guides for determining when protective actions are required onsite to include evacuation, use. of protective clothing and respiratory protection, and the use of radioprotective drugs.

The actuation of fire alarms, radiation alarms, evacuation alarms, telephone calls, and public. address announcements, as applicable, will immediately alert

~ ~ ~ ~

employees., visitors, contractors, and other onsite personnel to hazardous

~

conditions and actions they must take. Such actions may be to assemble in emergency teams, report to accountability stations, evacuate specific areas 0

within the site, and even to evacuate the site.

The Plan. describes the monitoring and decontamination of onsite personnel during a local evacuation; however, it is not clear that the monitoring capa-I bility exists at the designated offsite assembly areas specified in the Plan.

Nor is it clear what decontamination capability is provided at the offsite assembly areas.'he Plan describes and illustrates the evacuation route to the offsite assembly areas; however, it does not include alternatives for inclement weather, high density traffic and specific radiological conditions.

specifies that onsite "reaction time" (time measured from the time

~

The Plan an of accident until the initiation of evacuation) should not exceed 30 minutes.

~

an St. Locie SER 13-20 Nerses/Perrotti LUCIE/B

Security Guard Forces will assist in personnel accountability onsite. The Plan, however, does not describe the capability for 30 minute accountability and for accountability of all onsite personnel continuously thereafter.

The Plan provides for recommending offsite protective measures to State and local authorities for the population-at-risk in the plume EPZ depending on the projected dose to.the environs. The particular recommendation may be sheltering or evacuation depending on the magnitude of the projected dose, the meteoro-logical conditions and the nature of the release.'he Plan, however, does not contain evacuation time estimates that could be utilized by the Emergency Coordinator in determining what protective actions should be recommended to appropriate State and local authorities. Nor does the Plan contain the bases for the choice of recomm'ended protective actions from the plume exposure pathway during emergency conditions, including the expected local protection afforded in residential units or other shelter for direct and inhalation exposure.

The Plan refers to the State Plan regarding plans to implemen>. protective measures for the plume EPZ, including those criteria in NUREG-0654, J. 10.a. through d.

(Evacuation maps, population distribution maps, and means for notifying all segments of the 'population, including those whose mobility may be impaired. )

The Plan must be a stand-alone document and should include this information.

The Plan species that control of radioactive contamination and public safety in offsite areas are the responsibility of the respective County Disaster Preparedness Departments, DHRS, and BDP. The State Plan describes the capability for offsite monitoring and describes, in'detail, the mission of DHRS, including evaluating the potential radiation to the public from contamination of media in~ingestion pathway EPZ, and making recommendations for protective actions to appropriate authorities.

Upgraded evacuation time estimates, currently under review by the staff, must satisfy the criteria of Appendix 4 to NUREG-0654. A supplement to this report will provide the staff's conclusions as to the acceptability of the evacuation time estimates't.

Lucie SER verses/Perrotti LUCIE/B

t 5

The following itemrequire resolution:

(1) Sp ecif what monitorin g and deco ntamination capability exists at the offsite assembly areas'dentified on page 5-16 of, the Plan, including provisions for extra clothing and decontaminants suitable for the type of contamination expected.

(2) Include in Figure 5-1 of the Plan, "Site Evacuation Routes," alternates for inclement weather, high density traffic and specific radiological

'conditions.

I (3) Provide for accountability of all onsite individuals within 30 minutes of the declaratio.> of an emergency and "for all onsite individuals continuously thereafter.

(4) Provide,, in the Plan and appropriate EPIPs, a summary of the evacuation time estimates.

(5) Provide the bases for the choice of recommended protective action as delineated above.

I (6) Provide: evacuation maps showing evacuation routes and areas, preselected 't monitoring points,, relocation centers and shelter areas; population distri-by sector format, around the facility; the means for notifying 'ution, the transient and resident population; and, the means for protecting those persons whose mobility may be impaired, 13.3.2. 11 Radiolo ical Ex osure Control Standard Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Workers .and Lifesaving Activity Protective Action Guides.

St. Lucie SER 13-22 Nerses/Per rottj LUCIE/8

Emer enc Plan Evaluation The applicant has established a radiation protection program for controlling radiological exposures in the event of an emergency. Mith the exception of individuals providing ambulance service and medical treatment services, emer-gency exposure guidelines have been provided for the various categories of radiation workers. These guidelines are'onsistent with the EPA Emergency Morker and Lifesaving Activity Protective Action Guides. It is not clear, however, that emergency procedures shall be worked out in advance for per-mitting onsite volunteers to receive radiation exposures in the course of lifesaving and other emergency activities.

The Plan provides for 24-hour-per-day determination of doses received by onsite workers and offsite response personnel and for appropriate record keeping.

The Plan provides for personnel decontamination facilities. Onsite contamina-tion control measures for personnel, equipment, and access co ".rol are provided.

Clarification is needed in regard to action levels for determining the need for decontamination of personnel during an emergency condition. In addition, the Plan has not clearly established provisions for onsite contamination control measures for drinking water and food supplies, and criteria for permitting return of areas and items to normal use during an emergency/recovery condition.

The Plan addresses the handling of contaminated waste, including special circumstances, during an emergency condition.

The following items require resolution:

(j.) Provide emergency exposure guidelines for those individuals providing ambulance service and medical treatment service.

pP (2) Describe the procedures that shall be worked out in advance for permitting onsite volunteers to receive radiation exposure in the course of emergency activities.

St. Lucie SER 13-23 Nerses/Perrotti LUClE/9

(3) Specify action levels for determining the need for decontamination of III personnel. during emergencies.

(4) Provide contamination control measures with regard to drinking water and food supplies and criteria for permitting return of areas to normal use during an emergency/recovery condition.

13. 3. 2. 12 .Medical and Public Health Su ort Standard Arrangements a'r e made for medical servi,ces for contaminated and injured individuals.

Emer enc Plan Evaluation FP8L has made arrangements, confirmed in writing, with a qualified hospital located in the vicinity of the site for receiving and treating contaminated or exposed persons. This hospital will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day and shall maintain the capability and facilities to provide decontamination, first aid, ill I

and emergency medical treatment to injured or 4

persons from the site.

Arrangements for back-up hospital and medical center equipped for the defini-tive evaluation and treatment of radiation injuries have also been confirmed in writing. Letters of agreement with these hospitals are discussed in Section 13.3.2.2 of this report.

The Plan provides for onsite first aid capability.

FP8L has made arrangements, confirmed in writing, for ambulance service for transporting persons from the site to the primary hospital in the event of a radiological as well as a nonradiological accident.

St. Luci e SER 13-24 Nerses/Perrotti LUCIE/B

13. 3. 2. 13 Recover and Reentr Plannin and Postaccident 0 erations Standard General plans for recovery and reentry are. developed.

Emer enc Plan Evaluation The Plan describes the general plans for recovery and reentry. It is the responsibility, of the Recovery. Manager (Manager, Power Resources Nuclear) to determine when an emergency situation is stable and has entered the recovery phase. As the Recovery Manager, he is responsible for the overall aspects of the recovery operation. The Plan establishes criteria that must be met before recovery operations can begin. The Plan specifies that all applicable Federal, State and local, agencies will be informed that the emergency has shifted to a I

recovery phase.

.The Plan describes'he Expanded Response Organization which includes key

~

personnel- in the areas of public relations and information, command and control,

~ ~ ~

technical services, engineering support, security, and logistics.

~ ~ ~ ~

~

The Plan specifies that the State Plan provides the process for periodically estimating population exposure.

13.3.2. 14 Exercises and Drills Standard I 5/

~

Periodic exercises are (will be) conducted to evauate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises oi drills are (will be) corrected.

St. Lucie SER 13-25 Nerses/Perrotti LUCIE/B

Emer enc Plan Evaluation The Plan ensures that a major exercise will be conducted on an annual basis that will involve participation of offsite emergency support personnel within the county and State emergency organizations. This exercise will simulate emergency conditions requiring the escalation to a General Emergency. The scenario=will be varied such that all plans and preparedness organizations are tested within a 5-year period. One exercise will start between midnight and 6: 00 a. m. and another between 6: 00 p. m. and midnight once every 6 years. The Plan -does not provide for exercises to:be conducted under various weather conditions or for unannounced exercises as recommended by the specific Planning Standard N. 1 of NUREG-0654.

If The Power Resources Emergency Planning Supervisor is responsible for the planning, scheduling, and coordinating of drills and exercises involving offsite agencies.

The site Health Physics Supervisor will have the same responsibility for all onsite emergency drills. , All drills and exercises involving the plant are approved by the Plant Manager.

Each drill and exercise is conducted to test the state of emergency prepared-ness and is designed to meet a list of specific objectives which are specified in the Plan. The Emergency Planning Supervisor and Health Physics Supervisor will coordinate and implement Plan revisions and required corrective actions resulting from the drills and exercises.

'I Drills are supervised

'I instruction periods aimed at testing, developing, and maintaining skills in the following areas and frequencies:

Radiological monitoring drills - annually.

Health Physics drills - semiannually.

Medical emergency drills - annually I

Fire drills - in accordance with Technical Specifications. Communication links and notification procedures are tested at least semiannually.

St. Lucie SER 13-26 Nerses/Perrotti LUCIE/B

Communication drills - communication with State and county governments will be tested monthly; communications with Federal response agencies and States within the 50-mile EPZ will be tested quarterly, and communications between the site, State EOC, St. Lucie EOC, State and field assessment teams will be, tested annually.

The Plan has not incorporated communication tests for the plant offsite monitor-ing teams into the radiological monitoring drills. In addition, the description of the communication drills does not include the aspect of understanding'he content of messages.

Following an exercise, the Emergency Planning Supervisor, plant management, FP8 L observers, and principal participants in the exercise will meet to discuss and evaluate the exercise. Plant management will be responsible for any neces-sary changes in the Plant Emergency Procedures and for recommending changes in the Plan to the Emergency Planning Supervisor. Recommended changes in the Plan will be submitted to the Emergency Planning Supervisor.

The following items require resolution:

(1) Provide for exercises to be conducted under various weather conditions

'nd for e

~

unannounced exercises.

) tI (2) Include in the drill program communication tests with the plant offsite monitoring teams and the aspect of understanding the content of messages for all the communication tests.

13.3.2. 15 Radiolo ical Emer enc Res onse Trainin Standard Radiological emergency response training is provided to those who may be called upon to assist in an emergency.

St. Lucie SER 13-27 Nerses/Perrotti LUCIE/B

Emer enc Plan Evaluation The Plan provides for training and retraining of personnel on the emergency tasks for which they are responsible as specified in the Plan. The St. Lucie Plant Training Supervisor is responsible for the conduct and documentation of initial'raining and periodic retraining programs for on-site FP8L emergency organization personnel, except Emergency Teams. Emergency Team Leaders are responsible for,training team members and reporting the conduct of such training to the Training Supervisor.

The Plan describes specialized training and retraining for personnel assigned to the emergency organization, including the Emergency Coordinator, TSC staff, first aid and rescue team, fire brigade, security team, radiological monitoring team, Shift Technical Advisor, Onsite'mergency Organization, and Offsite Emergency Support Organization.

FP8L will provide training and annual retraining for those of~...ite organizations whose services may be required in an emergency, such as fire, police, medical support, -local'disaster preparedness officials,'nd rescue personnel. The I

training will be consistent with the organization s emergency functions.

13, 3. 2. 16 Res onsibi lit for the Plannin Effort: Develo ment Periodic Review, and Distribution of Emer enc Plans Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Emer enc Plan Evaluation II The Emergency Planning Supervisor has the majority of the responsibilities associated with the emergency planning effort. These responsibilities include, but are not limited to, ensuring changes are made in the Plan after approval

~ ~

by'he Vice President - Power Resources; coordinating periodic reviews of the

~ ~

St. LQcie SER 13-28 Nerses/Perrotti LUCIE/B

Plan; coordinating drills and exercises involving offsite agencies; and ensuring that all elements of the total emergency organizations (FP8L, State, local) are informed of revisions to the Plan. Other emergency planning responsibilities have been assigned to other onsite and offsite FP8L personnel.

The Plan does not identify, by title, the individual with the overall authority and responsibility for radiological emergency response planning.

The Plan and letters of agreement will be reviewed and updated, as necessary, at least every year. The Facility Review Group will conduct periodic reviews of Emergency Plan Implementing Procedures.

The Plan contains supporting plans and agreements,' specific table of contents and a listing of procedures required to implement the Plan.

An independent audit of emergency preparedness will be performed by the FP8 L equality Assurance Department at least annually. Audits will verify compliance with Federal regulations and Technical Specifications provisions. Plant manage-ment, the Emergency Planning Supervisor, and the Manager, Power Resources-Nuclear will evaluate the audit findings and recommend corrective actions to the Vice President - Power Resources.

Revisions to the Emergency Plan and Emergency Plan Implementing Procedures will be distributed in accordance with plant procedures.

Notifications lists and rosters will be updated quarterly.

The following item requires resolution:

(1) Identify, by title, the individual with the overall authority and responsi-bility for radiological emergency response planning.

13.3.3 Conclusions Based on the NRC review against the criteria in "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support St. Lucie SER 13-29 Nerses/Perrotti LUCIE/B

of Nuclear Power Plants," NUREG-0654, Revision 1, November 1980, the staff

~

concludes that the St. Lucie Nuclear Station Radiation Emergency Plan, upon

~

~

satisfactory correction of those items requiring resolution as identified in

~ ~ ~

Section 13.3.2 of this evaluation, and those plan deficiencies identified

~ ~ ~ ~

~ ~

during the EPIA (referred to in the Introduction to this Report), will provide an adequate planning basis for an acceptable state of emergency preparedness and will meet the requirements of 10 CFR Part 50 and Appendix E thereto.

After receiving the findi ngs and determinations made by FBlA on State and local

~

emergency response plans, and after reviewing the revision(s) to the Plan, a supplement to this report wil'l provide the staff's overall conclusions as to whether the plans provide reasonable assurance that adequate protective measures can and will be taken in the event of an emergency.

The final NRC assessmentof the state of emergency preparedness for the St. Lucie Nuclear Station will be made following implementation of the revised emergency plans to include revision/development of procedures, train'ing and qualifying of personnel, installation of equipment and facilities, and a. joint exercise involving participation of the response organizations (site, State, and local).

St. Lucie SER 13"30 Nerses/Perrotti LUClg/B

RESPONSE TO HUMAN FACTOR ENGINEERING CONTROL ROOM DESIGN REVIEW/AUDIT REPORT ST. LUCIE UNIT 2 FLORIDA'OWER AND LIGHT COMPANy Attached is the response to the NRC's Preliminary Control Room Design Review/Audit Report generated and based on their site visit on August 3 through August 7, 1981.

This response addresses the findings of the HFEB's review based on the NRC's Preliminary Design Assessment and the Human Factors Engineering Design Review/

Audit performed at the site.

NRC Human Factor design discrepancy priorities were left unchanged, i.e.

a) priority rating of one (1) and two (2) discrepancies should be corrected prior to issuance of an Operating License b) -

priority rating of three (3) should be evaluated and proposed actions reported as part of the long term design, review in accordance with the requirements'. NUREG-0700 c) priority ratings of three superscript one (e.g. 3 1 ) are considered to involve simple corrective action relative to the potential for

..imprbving operator performance, these discrepancies should be corrected prior to fuel loading and where Florida Power and Light took exceptior note was made in the associated response.

The fol3owing sections werc numbered.to conform to the guideline of the draft version of NUREG-0700 and address the NRC team's observations of the control room design, layout and control room operators'nterface with the control room 'environment on an item by item basis.

At present, Florida Power and Light Company and Essex Corporation are esta-blishing a detailed schedule for integrating the: attached findings into a coherent project file and backfit program.

Those items which the NRC felt could not be evaluated are listed at 'the end of the response. These items will be addressed and scheduled for completion prior to fuel loading.

An outline of the annunciator, labeling and demarcation review program is attached.

ANNUNCIATORg LMELING AND DEMARCATION REVXE 5 PROGRAM OUTLINE A variety of board improvement studies are underway for thc Saint Lucie 2 control room. These include:

o Annunciator improvement study o Summary labeling and demarcation study o Control room relabeling effort

.Each of these represent front-of-the-board modifications designed to enhance board operability. All the. above are interrelated, e.g., plant abbreviati'ons affect annunciator and component label verbage, summary labeling affects component label contents, etc.

The thrusts and activities of thc board, improvement studies are identified below:

Annunciator Study objectives of this effort are to:

o Improve readability of tiles by selection of fonts, size

- and contrast o Improve information transfer via:

coding (visual) coding (auditory) syntactic rules standardized abbreviations and word meanings o Evaluate layout of tiles During the course of the annunciator study, all tiles are to be reengraved.

Annunciator reengraving will be conducted to be in compliance with NUREG-0700.

Activities conducted with regard to the annunciator study are identified below:

o Grouping analysis to identify where tile locations are not "readable from associated control locations o Coding analysis - identification and analysis of potcn"ial coding schemes for the Saint Lucie 2 annunciator, study. Coding extends to vision and audition. Options being examined include:

audible coding color 'coding I location coding (matrix and location) o'eadability and system analysis. Analysis of readability via symbol characteristics (size, font, etc.) . Development of standard layout and abbreviations on tiles.

Summary Labels and Demarcations Study objectives of this effort are to:

o Provide component search and localization. aids via panel demarca-tion of 'stems and function

o Reduce 'visual load and localization requirements by provicing hierarchical labeling scheme Method of demarcating systems and functions will be by line demarcation, with provisions of summary labels.

Analytical studies, which will precede implementation of demarcation and summary labeling, include:

o Analysis of operational groups of controls and displays o Readability and system analysis (in conjuction with annunciator study),

o An analysis of implementation which will identify feasible (where possible} areas of identifying component groups by demarcation (line placement, label placement, etc.).

Summary labeling and demarcation will conform to the requirements of

/

NORHG-0700.

Control Room Relabelincn Effort objectives of this effort are to provide:

o Readable labels o Usable coding schemes

' e o Standard syntax and abbreviations

.o: Permanent and maintenance-free labels Relabeling is to be conducted'in .conjuction with both the annunciator study (abbreviations and syntax} and demarcation and summary labels (label content, hierarchy) . A coding analysis will be conducted to determine the best means to code label information (power train, safety train, etc.) .

Label characteristics will be in'accordance with NUREG-0700.

RESPONSE TO HUMAN FACTORS ENGINEERING CONTROL ROOM DESIGN REVIEW/AUDIT REPORT lo CONTROL ROOM WORKSPACE PRIORITY PINDING II The view of portions of the Radiation Monitoring Panel and the HVAC Panel from the Operator Console is obscured by other boards.

RESPONSE

l.a. The Radiation Monitoring Panel has an associated Keyboard and CRT located on the operator's control desk. The CRT and Keyboard are the intended operator interface and control station. Local displays and access are provided on the Radiation Monitoring Panel as back up indication and also for maintenance and test purposes.

l.b ~ The HVAC Panel controls are not routinely used or monitored during power operations. The fans are started during the startup of the unit a>d are rotated on a scheduled basis. The annunciators are visible from the Operator Console and would alert the operator to an unusual circumstance.

In addition visual access to these panels cannot be improved since it is not feasible to move the panels to more visually accessible areas without causing a more significant disruption in the control room work space environment. This item will be handled as part of the long term design review and reported on in accordance wi th NUR'EG-0700.

PRIORITY FINDING 2~ There are two large floor obstructions in the form of thick plywood sheets attached to the floor. One is between the control console mockups and one is near the restroom location.

RESPONSE

2~ The plywood sheets referenced in the above finding are presen'tly covering two block outs which will be used as control cable routing paths. The block out located between the control console mockups will be covered by the operator's work desk and will not provide a traffic interference problem. The second

=block out located near the restroom was provided for the positioning of the auxiliary control panel and vill- not provide any traffic flow restrictions.

Presently a review is being conducted for relocating

.the'auxiliary contro1 panels If the panel is relocated, then the subject block out will be filled thus'eliminating the tripping hazards

Page 2 of 59 1 ~ CONTROL ROOM WORKSPACE (Cont ~ )

PRIORITY FINDING 3'he temporary phone attached to Panel 202 has a long cord which presents a tripping hazard in an operator pathway. It was noticed that phone cords in Unit 1 presented a similar tripping hazard.

RESPONSE

3~ The temporary phones will be removed and the permanent communication system will be installed prior to issuance of an operating license thus eliminating the sub5ect tripping hazard.

PRIORITY FINDING

4. The two Control Transfer Panels for the Remote Shutdown Panel are both at distant locations from the shutdown panel. These separated remote transfer locations can delay and complicate transfer of between thc Control Room 'and the Remote 'ontrol Shutdown Panel.

RESPONSE

4." . The two remote control Transfer Panels are located to comply with present fire protection requirements.

,Transfer of equipment is accomplished by a field operator while the control room operators are in route to their assigned local control stations thus expediting the equipment transfer operation.

Appropriate training and procedure will be developed for the transfer.

PRIORITY FINDING 3 5~ The Turbine Backpanel and the DEH Control Cabinet werc 53 inches apart. This is less than the 96 inches minimum separation distance recommended for opposing vertical control panels.

RESPONSE

Thc only routine operator activity 'in this area is the hourly required log reading of the Unit Auxiliary and/or startup transformer megawatt meters and Generator output meter. There are no safety the,'urbine related or control activities performed in this area. Fault Pressure Relays and Lockout Relays are located in this area, but are operated on a once-an-outgage frequency.

IS 1

I Page 3 of 59 1 ~ CONTROL ROON WORKSPACE (Cont.)

PRIORITY FINDING

6. There are no provisions for key storage and no procedures for key access control for keys used in the Control Room and for keys used at the Remote Shutdown Panel.

RESPONSE

Key storage will be provided as well as the necessary key access control procedures for those keys used in the Control Room and Remote Shutdown Panel prior to fuel load. The Remote Shutdown Panel SXS block keys will be maintained at RAB control access point.

PRIORITY PINDXNG

'. 3 7. The shift supervisor's office location beyond Panel 206 will not provide him with good voice and visual contact with the main control area.

RESPONSE

7~ The St. Lucie Unit No. 2 shift supervisor's office is located such that it faces the main control boards thus placing the supervisor in direct line of sight and communication with the Control Room.

PRXORXTY FINDING

8. Controls on the vertical boards of some standup consoles a'e located too high and are beyond the reach of a 5th percentile female operator.

Examples:

. a.) Panel 204: Reactor Channels MB and MD Reactor Trip pushbuttons b.) Panel 201: Reactor Channel MA Reactor Trip pushbutton

RESPONSE

8. Discrepant controls will be easier to reach without possible inadvertent operation of other controls due

.to the addition of a guard rail. This will provide thc 5th percentile operator with a stable support to grasp while leaning slightly. This item will be evaluated as part of the long term review and reported on in accordance with NUREG-0700.

Page 4 of 59 1~ CONTROL ROOM WORKSPACE (Cont.)

PRIORITY FINDING 3 9. Some displays and annunciators were located outside of the visual f ields of the extreme height operators. In particular, a line of sight from the viewer t'o the instrument face made less than a 45 degree angle with the display plane.

RESPONSE

9. At present Florida Power and Light is unaware of any annunciators.which are located outside of the visual fields of the extrcme height operators. All annunciators are located in the top section of the subject control boards which place them in the 45 .

degree angle display plane from the viewers'ine of sight. However, there were twelve horizontal indicators noted on RTGB 203 which due to their orientation made them difficult to read. A suitable backfit will be investigated and a proposed backfit will be reported as part of the long term design review in accordance with NUREG-0700.

PRIORITY FINDING

.10..- All of the panels had controls which were less than 3 inches from the front edge of the benchboard. The benchboard handrails had not been installed at Unit 2 at the time of the review.

RFSPONSH

10. The St. Lucie Unit No 2 handrails will be installed

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at a lower .position on the subject benchboards so as to not obscure the view of those controls and displays, which are located on the front edge of the benchboards, from the operator console. The handrails will be installed prior to issuance of an operating license.

Page 5 of 59 1 ~ CONTROL ROOM WORKSPACE: (Cont.)

I 4

PRIORITY FINDING Displays and controls on vertical panels throughout the control room are located above and below the guideline heights. For vertical panels, controls and displays should be located between 34 inches to 70 inches above floor level .

Examples:

a.) HVAC Panel b.) Radiatior Monitoring Panel

RESPONSE

There is no room to reposition the HVAC and Radiation Monitoring Panel controls in question above the 34 inch plane. These controls are infrequently operated and do not pose any control/display problems with regard to interpretation. This item will be evaluated as part of. the long term review and reported on in accordance with NUREG-0700.

PRIORITY FINDING

12. The normal lightirig level in the backpanel areas was inadequate. The level at Backpanel 206 was 5.5 ft-candles, which is even less than the minimum requirement of 10 ft-candles for a passageway.

RESPONSE

12. , Incident light levels will be reviewed and brought up to acceptable levels as outlined in NUREG-0700.

Page 6 of 59 1 ~ CONTROL ROOM WORKSPACE: (Cont ~ )

PRXORXTY FINDING

13. 'lare .was a problem throughout the control room. At the time of the review, no diffusing grid had been placed over the fluorescent lighting as has been done in Unit 1. The glare in Unit 2 had a varying impact irom one instrument to the next, with the worst case being nearly total obscuration of displayed information.

RESPONSE

13 A re-evaluation of the glare problem will be performed after the diffusing grid has been installed ~ Those items then still found to have glare problems will have suitable backfits implemented prior to issugance of an operating license.

PRIORXTY FINDING

14. There is no direct 'means of testing the operability of control room emergency lighting.

RESPONSE

14. There will be a direct means of testing the operability of the control room emergency lighting system prior to issuance of an operating license.

PRXORITY FINDING

15. The emergency lighting illumination levels were too low for accurate reading of panel displays and labels. Readings varied from 22.6 to 1.9 ft-candles. The Panel 204 readii>g was 8.3 ft-candles.

RESPONSE

15. Lighting diffusers were not installed at the time of the Audit. Upon installation, incident light readinc s will be taken. Eased on the data from the above, additional lights, as required, will be installed to bring emergency control room illumination to acceptable levels as outlined in NUREG-0700. This item will be shceduled for implementation prior to issuance of an. operating license.

I Page 7 of 59

1. CONTROL ROOM WORKSPACE:. (Cont.)

PRIORITY PIN DING

16. The two separate Control Transfer Panels for the Remote Shutdown Panel are not provided with security devices to prevent unauthorized transfer of control between the Control Room and the Remote Shutdown Panel.

RESPONSE

16 ~ ~ The Remote Control Transfer Panels will have a security seal for security purposes. Operations of any control transfer switch is annunciated in the control room. These provisions will be implemented prior to issuance of an operating license.

Page 8 of 59 2~ COMMUNICATIONS PRIORITY FINDING The communications equipment and procedures for Unit 2 were not completed and could not be evaluated.

RESPONSE

The SL-2 communications system is currently under

,design. The system will be reviewed in accordance with the communication section of NUREG-0700.

Page 9 of 59

3. ANNUNCIATORS PRIORXTY FINDING The function of the annunciator tile labeled ANNUNCIATOR POMFR SUPPLY on annunciator Panel K is not clear.

RESPONSE

The tile vill be re-engraved to read""Annunciator Backup Power Supply" prior tn the issuance of an operating license.

PRXORXTY FXNDXNG

2. There are no anriunciators for the HYDRAZINE system.

RESPONSE

2~ Results of an engineering review of the system has identified any/all required annunciators for the Hydrazine system. These will be added to the annunciator system prior to issuance of an operating license.

PRXORITY FINDXNG 3~ There is no annunciator or 'alarm to warn of unauthorized transfer of control from the Control Room to the Remote Shutdown Panel.

RESPONSE

3~ Florida Power and I ight feels this is not a valid finding. Any control function, when transferred from the Control Room to the Remote Shutdown Panel, initiates an alarm in the control room alerting the operator of the transfer.

t Page 10 of 59 l I It

3. ANNUNCIATORS (Cont.)

PRIORITY ltXNDIWG 4; Some annunciator tiles with multiple inputs do not have reflash capability.

RESPONSE

4~ lfultiple input annunciator windows will undergo assessment as to reflash capability. Any that do not "reflash" and require the function will be provided with the "reflash" and "reaudible" function. This item will be reviewed and implemented prior to issuance of an operating license.

PRIORITY FINDING

5. The annunciator system does not have a separate First Out Panel for the reactor systems. . Annunciator Panel C, foi the turbine, is the only annunciator panel with First Out reset capability.

RESPONSE

5'he print to Sequence of Events Recorder is currently employed out sequence of events of Reactor Trip signals. The initiating signal is printed as part of this sequence. Therefore the SER is the main means of identifying the cause of the trip. This item will be addressed as part of the long term design review and reported on in accordance with NUREG-0700.

PRIORITY FINDING

6. There is a general lack of prioritization in the control room annunciator panels. A consistent prioritization coding scheme, based on importance, severity, or need .for operator action, has not been applied.

RESPONSE

6. Presently there is an Annunciator Review Program in progress. One of the outputs of this program is to,

develop a consistent prioritization coding scheme.

The detailed engineering review is scheduled for completion prior to fuel load with scheduling of implementation being included as part of the long term design review.

Page 11 of 59 3o ANNUNCIATORS (Cont.)

PRIORITY FINDING 74 On all annunciator panels, the only indication that an annunciated condition has been cleared is the extinguishment of the light.

RESPONSE

7,. The present annunciator system is consistent with Plorida Power and Light's standard design philosophy. Clearing of an annunciator is indicative of a back to normal condition which is a safe condition and requires no operator action. It is felt that having the operator responsible for acknowledging return to normal conditions during a plant transient or other evolution requiring his attention could impede his judgement and affect his response time in reacting to a given situation. This item will be reviewed as part of the long term design review and reported on in accordance with NUREG-0700.

PRIORITY PINDING 1

8. The annunciator audible alarms are only marginally louder than the ambient noise in the control room.

RESPONSE

8. The volume, frequency, and modulation of annunciator audibles are adgustible. Audible signal characteristics wi.ll be manipulated to conform to the NUREG-0700 guidelines prior to issuance of an operating license.

PRIORITY

9. The annunciator audible alarm devices for Panels 201, 203, and 205 are located behind the panels, making it difficult for operators to localize the source of an alarm.

RESPONSE

9. The sound sources will be mounted such that signals will propagate directly into the control area without having to pass through the control room boards. Thi,s item will be implemented prior to issuance of an operating license.

-Page 12 of 59 3i ANNUNCXATORS (Cont.)

PRXORITY 'FINDING

10. The annunciator illumination system does not ensure that an indication of alarmed conditions will be provided to the operator if failure of an annunciator light flasher occurs. Xn case of flasher failure of an alarmed tile, the tile light should illuminate and birn steadily.

RESPONSE

I'0. Each annunciator panel has a test function which illuminates every window and verifys the flasher function. Any dark window indicates bulb or annunciator failure. Any annunciator that does not flash has a failed flasher. The test will be performed once a shift.

PRIORITY PIN DXNG 3 11. Some annunciators used in startup will be normally lit during full power operation.

Example:

a.) PONER HIGH RATE OP CHANGE and TRIP BYPASSED tiles on annunciator Panel L.

RESPONSE

11. An engineering review will be conducted tc identify annunciators which will be normally power operations.

lit during full This item mill be reviewed as part of the. detail design review and reported on in accordance with NUREG-0700.

PRIORITY PINDXNG

12. None of the annunciator panels in the control room have labeling of thei.r vertical or horizontal axes to aid in matrix location and identification of individual tiles'ESPONSE

12.  ; Hatrix type location cues will be added to the annunciator panels and annunciator response procedures. This item will be implemented prior to fuel load.

Page 13 of 59 3, ANNUNCIATORS (Cont.)

PRIORITY FINDING 1 13. Blank annunciator tiles on almos't all annunciator panels are illuminated during normal operation.

RESPONSE

13. Blank annunciator tiles will be extinguished. This will be accomplished prior to fuel load, PRIORITY FINDING

14. Many annunciator tile legends are wordy.. Some tiles have as many as 14 words.

RESPONSE

14. Annunciator verbage is being reviewed and will be limited in content in accordance with NUREG-0700.

Annunciator tiles are to be re-engraved, using standardized abbreviations and syntax, limiting number of words/abbreviations per tile.'his item is scheduled for implementation prior to issuance of an operating license.

PRIORITY FINDING I

15. Annunciator font size (.2 inches in height:) is too small for reliable reading from the operator annunciator control positions.

RESPONSE

15. Annunciator tiles are to be re-engraved, using larger, more readable font. This item is scheduled for implementation prior to issuance of an operating license.

PRIORITY FINDING

16. The operator cannot read all of the annunciator tiles on Panels 205 and 206 from the annunciator acknowledge control location because of the oblique viewing angle from the control location.

RESPONSE

16. The operator would walk to the annunciator panel regardless of the location of the acknowledge control. This item will be included as part of the detail control room design review reported on in accordance with NUREG-0700.

Page 14 of 59

3. ANNUNCIATORS (Cont.)

PRXORITY FINDING 1 17. The space between legend lines on annunciator tiles is less than 1/2 the character height.

RESPONSE

17. The space between legend lines on the annunciator tiles will comply with NUREG-0700. This item will be implemented prior to issuance of an operating license.

PRIORXTY FIHDXNG

18. One annunciator board on the Line Repeat Panel has two redundant sets of controls located within 12 inches of each other.

4

RESPONSE

18. One set of annunciator controls will be removed prior to fuel load.

PRXORXTY FXNDING

19. There are no separate silencing controls qn any annunciator control systems.

RESPONSE

19, Florida Power and Light intends to install a three second automatic annunciator master silence on Unit No. 2 prior to issuance of an operator license. The three second master silence would automatically silence the incoming audible alarm after three seconds giving the operator sufficient time to glance at the incoming alarm to determine its significance; however, still allowing him freedom to continue the task at hand until such time as he could reset the subject alarm. After the audible signal is silenced it would be reactivated and the process repeated for an incoming alarm.

Page 15 of 59 3i ANNUNCIATORS (Cont.)

PRIORITY, FINDING

20. The relative location of annunciator control button groups is not the same from panel to panel and the annunciator control buttons are not arranged in the same order in the control group at each panel.

RESPONSE

20. The annunciator control button will be located such that they are in the same configuration in the control group as each panel and where possible they vill be placed in the same general locale on the subject panels. In addition, these controls will be demarcated to assist in distinguishing them from other control push buttons. This backfit will be implemented prior to issuance of an operating license.

'PRIORITY FINDING 31 21. Annunciator Panel N contains a tile with a temporary label. The HASTE lfANAGEMENT LOCAL ALARM GROUND DETECTED POWER FAILURE tile label is handwritten on the face of the tile.

1

RESPONSE

21. The subject tile will be engraved in accordance with the annunciator tile lettering specification to be issued as part of the annunciator labeling review which is scheduled for engineering completion prior to fuel loading.

Page 16 of 59 4

4~ CONTROLS PRIORITY FINDING 1.. Some controls needed to perform system operating ~

tasks are not in the control room.

Examples:

a.) Auxiliary Feedwater Pump Start Bypass control b.) Condensate Pump 2C control

RESPONSE

l.a.) Auto-start of the Auxiliary Feedwater System has not been installed. The future design will include the s,tart bypass control and will be implemented prior to issuance of an operating license.

b.) Condensate pump 2C control is either the 2B or 2A control switch, which ever is powering the 2C pump.

2C pump is manually aligned to either the 2A or 2B 4160 bus, depending on which pump it is replacing.

The control switch for that associated pump then becomes the control switch for 2C pump. No further a'ction is required on this item.

PRIORITY FXNDXNG 3l 2~ The Fire Pump 1A and 1B Stop controls on Panel 202 are unnecessary controls on that panel. These controls are not related to systems operations controlled from that panel.

RESPONSE

2~ The Fire Pump controls will be reviewed as part of the long term effort and reported as part of NUREG-0700.

PRXORITY FINDING 3~ Some process controllers on Panels 205 and 206 have inopertive OPEN/CLOSE pushbuttons that are disconnected and have no control function.

Examples:

a.) HIC-3618

.b.) HIC-3628

c. ) HXC-3638 d o) HIC-3648 e.) SI Loop 2A2 Check Valve Leakage

RESPONSE

3~ The non-functional control buttons will be removed and the holes blanked. This item will be completed prior to issuance of an operating license.

Page 17 of 59

4. CONTROLS (Cont.)

PRIORITY FINDING 1 4~ The Turbine Trip pushbutton is not protected to prevent unintentional operation.

RESPONSE

4~ An elevated switchguard will be provided on this switch. This will be implemented prior to fuel load.

PRXORXTY FINDING 5~ The SX Loop Check Valve Leakage HXC-3638 process controller operates in reverse of the conventional operation of other process controllers in the control room.

RESPONSE

5~ These control buttons are not functional and will be removed and the holes covered prior to issuance of an operating license.

PRIORXTY FINDING

6. Some rotary switches do not conform to the OPEN-Right (Clockwise)

/ CLOSE-Left (Counterclockwise) convention for switch positions.

Examples:

a.) Generator No. 2 switch on Line Repeat Panel has OPEN-Left /

CLOSE-Right positions.

b ~ ) Turbine Drain Valve controls on Panel 201 have OPEN-Left /

AUTO-Center / Cf.OSE-Middle / OPEN-Right positions.

c.) Loop 2A2 and Loop 291 Charging Line Valve controls have RESET-Left / CLOSE-Middle / OPEN-Right positions'ESPONSE

6. Present Florida Power and Light convention is: 1) Valve control switches operate such that open is to the right and closed is to the left with red lights indicating flow/opened and green lights indicating no flow/closed. 2) Breaker control switches to operate such'hat closed is to the right and open/trip is to the left with red lights indicating energized/closed and green lights indicating de-energized/open.

'In addition the convention is to have the green indicating light on the left of the control switch and the red indicating light on the right. Shape coding of breaker control handles (ie.) thumb switches will be used to reduce operator confusion. The control board is scheduled to be reviewed for consistency of convention application with discrepancies resolved prior to issuance of an operating license.

The turbine drain valve control on panel 201 will be corrected t'.o conform to the above mentioned convention prior to issuance of an operating license.

Page 18 of 59

4. CONTROLS (Cont . )

PRIORITY FINDING 31 7~ Some keyswitches have a black ring that might be interpreted as a color code while other keyswitches do not. There is no apparent significance of this difference.

RESPONSE

7. 'he black ring indicates that the valve is "Locked

'Open." Absence of the black ring means the valve is "Locked Closed." One valve does not conform to this, and will be changed prior to fuel loading.

PRIORITY FINDING

8.

The Matrix Relay Hold pushbuttons on the RPS Panel are difficult to depress for the period of time required to perform system tests. The control resistance of these pushbuttons is too high for'asks requiring activation for more than a few seconds'ESPONSE

8. The Matrix Relay Hold pushbutton is used only for testing., The procedure for performing this test will indicate when the pushbutton must be operated and require only short intervals of operation.

PRIORITY PINDING

9. The backlit legend pushbuttons and the backlit legend indicator lights in several arrays on Panels 201 and 202 are identical in appearance, size, and shape Control/display substitution errors are possible.

Examples:

a.) DEH Valve Test panel b.) Generator Megavar displays c.) Diesel Generator controls and displays

RESPONSE

This finding will be addressed and resolved through

.control and display labeling and coding.

Implementation will be complete prior to issuance of an operating license.

Page 19 of 59, v

4. CONTROLS (Cont'. )

PRXORITY FINDING 2 10. Covers on backlit legend pushbuttons and indicators are interchangeable and are not coded to identify their correct location in the control/display arrays.

RESPONSE

10. Identifying markings will be placed on the removable portion of the units and the housing, thereby identifying the appropriate positions of removable control or display units. This item will be implemented prior to issuance of an operating license.

PRXORXTY FXNDING 31 Some keyswitches do not conform to the keyswitch orientation convention used in the control room..

Examples:

a.) Minimum Flow Header A Xsolation Valve V-3496 switch on Panel 206.

b.) DEH Turbine Control OPC switch on Panel 201.

RESPONSE

Keyswitch positions will be oriented to be consistent with Control Room conventions and backfits implemented prior to fuel loading.

PRXORITY FXNDING 12 'otary switches positions.

and keyswitches have unlabeled

~

Examples:

a.) SXAS Blcok Channel SA and SB keyswitches on Panel 206 b.) MSIS Block Channel SA and SB keyswitches on Panel 206 c.) Trip Circuit Reset rotary sw5:tches on 'the RPS Panel

RESPONSE

12.. These positions will be labeled prior to issuance of an operating license.

o Page 20 of 59 I>. CONTROLS (Cont.)

PRIORITY FINDING 3 13. Some rotary selector switche's can be stopped in positions between the'etented operating positions.

Example:

a.), Seal Cooler Heat Exchanger Isolation Valves HCV-14-11A1, A2, Bl, and B2 on Panel 203.

RESPONSE

13. Florida Power and Light agrees with priority assignment of this item. Due to the unique design of switch and long lead time for procurement, implementation may be after fuel load but will be implemented at the first opportunity after delivery but no later than first refueling. Emphasi's during training and temporary labeling will be used as an interim measure.

PRIORITY FINDING

14. The handles of rotary control switches on Panel 201 obscure the view of position markings on the switches.

Examples:

a.) Generator Field Ground Detector b .) Voltage.Adjuster c ) Base Adjuster

~

d.) Diesel Generator Ammeter e ~ ) 4.161iV 2B3 Ammeter

RESPONSE

1.4.. This finding will be addressed by either. onc or both of the following:

a.) modification of, or provision of different switch handles which do not obscure the switch position'arks and/or b.) relocation of switch position labels such that they are visable from the normal switch operating position.

This item will be addressed as part of the long term effort and reported on as required by NUREG-0700.

Page 21 oi 59 4~ CONTROLS (Cont.)

PRIORXTY FXNDXNG 15 ~ Status indicator flags on some J-handle and rotary pointer switches are obscured by the switch handle.

Examples: (Panel 202) a.) Circulating Water Pump 2A1 control b.)'irculating Water Discharge Valves MV-21-2Al and 281 c.) Screen Wash Pumps 2A and 2B

RESPONSE

15'heexistingfinding will be addressed through modification of handles or use of 'different handles. This item will be addressed as part of the long term effort and reported on as required by NUREG-0700.

PRIORITY FXNDXNG

16. Rotary selector switches on Panel 201 have pointers engraved.in the switch handle that are not marked with a contrasting color to make thorn readable.

Examples:

a.) Exciter Supply Breaker b.) Generator Ground Detector c.) Voltage Adjuster d.) Base Adjuster

RESPONSE

16. The switch handles will be provided with high contrast pointers. This item will be implemented prior to fuel loading, PRIORXTY FINDING

17. There is unacceptable parallax between the indicator pointer and the green band used to indicate the operating setpoint band on some process controllers, Examples:

a.) Pressurizer Pressure PIC 1100-X and 1100-Y on Panel 203 b.) Boric Acid Flow FRC-2210Y on .Panel 205 c.) Reactor Hakeup Water Flow FRC-2210Z on Panel 205 d.) Liquid Waste Flow FXC-6627 on Panel 205

. RESPONSE

17.

• This item will be addressed and resolved as part of the detailed review and reported on in accordance with the requirements of NUREG-0700.

Page 22 of 59

5. DYSPLAYS PRIORITY FINDING 2 Assuming its label is correct, the AUX FEEDQATER HDR C PLOW/PRESSURE indicator FI-09-2C/PI-09-SC on Panel 202 should display values of two different variables. The installed meter can display only one

,,variable.

RESPONSE

The correct meter will be capable of displaying both variables. The proper indicator will be installed prior to fuel loading.

PRIORITY FINDING There is no distinction between the three backlit indicators labeled HI POWER TRIP on the RPS Matrix Test Panel nor between the two indicators labeled HI RATE+

RESPONSE

20 The above components will be appropriately item will be implemented prior to issuance of labeled'his operating license.

PRIORITY FINDING The data channel identification labels for HVAC Panel trend recorders PR-25-1A, PR-25-1B, and PR-25-2 do not indicate which recorder scale to use with each variable displayed on the multi-range, multi-channel recorders.

RESPONSE

30 The scales for the above will be appropriately labeled and identified., This item will be implemented prior to issuance of an operating license.

Page 2'3 of 59 5 DISPLAYS (Cont.)

PRIORITY FINDING 31 4. On Panel 201, the GENERATOR EXCXTER FIELD DC VOLTS meter scales are not marked to indicate positive and negative values .

RESPONSE

4~ The display will be appropriately labeled "Voltage Regulator Null Meter." This will be accomplished prior to fuel loading.

PRIORITY FXNDING 31 5~ On Panel 201, the VIBRATXON PHASE ANGLE METER-VBI I and the ECCENTRICITY PHASE ANGLE METER ECC-22-1 do not have indications of positive or negative above and below zero. Also, their scales are graduated in 10's above zero and in 30's below zero.

RESPONSE

5~ The extreme values for these displays will be appropriately labeled. These are standard meters throughout all Florida Power and Light power plants and t:o change them could have a negative effect ~

This labeling effort will be completed prior to fuel loading.

'PRIORITY FXNDING

6. The upper scale'n horizontally oriented meters is difficult for a standing operator t:o see without crouching.

'.)

Examples:

b ~ ')

STEAM GENERATOR DELTA P CORE FLON c.) COOLANT LOOP TRfPFRATURE TCOLD/THOT d~) PRESSURI7ER PRESSURE

RESPONSE

6. This finding will be further evaluated and reported on as required by NUREG-0700.

Page 24 of 59

5. DISPLAYS (Cont.)

PRIORITY FINDXNG 3 7~ Extrcme values at the top and bottom of the scales on vertical meters are obscured due to meter design.

Example (Panel 203) a.) CONTROLLED BLD-OFP FLOH FIA-1150

RESPONSE

7~ This item will be addressed as part of the detail'ed control room design review and reported on in accordance with NUREG-0700.

PRIORITY PINDING

8. The LED displays generally have poor readability due to glare, scratchable face plate surfaces, and poor

'contrast.

Examples:

a.) LINE REPEAT PANEL be) PANEL 203 c.) MEGAVAR PANEL d.) PRESSURIZER PRESSURE RES POiISE 8~ Glare and potential face plate scratching will be addressed through display shielding to reduce incident light to the display surface and protect face plates.

Display contrast vill be further evaluated and reported on within the reporting requirements of NUREG-0700.

PRIORITY PINDING On Panel 204, the CEA Secondary Rod Position display is made up of a high contrast checkerboard pattern of bright yellow on wnite. This pattern is very disturbing to look at because of color afterimages ~

RESPONSE

This will be the subject of the long term review and reported on in accordance with NUREG-0700.

Page 25 of 59 e

5. DISPLAYS (Cont.)

3'0..

PRIORITY FINDING Several meters, primarily G.E. circular meters, have confusing scale markings. The scale spacing is non-linear and there are no graduations near the zero marking on the meter scale. Also, it is not clear what downscale meter pointer position indicates a meter failed condition.

Examples:

a.) GENERATOR AMPERES AM-8810B and AM-8810C on Panel 201 b.) GENERATOR KILOVOLTS VM-881

'ESPONSE

10. These meters are not operated at the lower ranges.

The scales are such that accuracy and readability are of high quality in the normal operating range ~

Downscale meter position will be reviewed as part of the long term design review. Normal operating ranges will be marked on meter face.

PRIORITY FINDING 31 11. Several meter scales have thick black marks to extend ma)or tick marks to the scale numerals., These marks give the misleading appearance of minus ( - ) signs in front of the meter scale numerals.

Examples: (HVAC Panel) a.) PDIS-25-1B b.) PDI-25-15B

RESPONSE

11. The marks viewed as being interpreted as minus ( - )

signs will be removed. This will be accomplished prior to fuel loading.

Page 26 of 59

5. DISPLAYS (Cont,)

PRIORITY FINDING

12. There are several displays which use unconventional scale graduations.

Examples a.) Panel 201: DIESEL GFNERATOR 2B MVARS VARM-1616 b.) Panel 204: WIDE RANGE POWER JX-001B c.) Panel 203: LOOP 2A COLD LEG T&fP TIC-ill d.) Diesel Gen 2B Frequency I

RESPONSE

12.. The displays listed in thc finding will be modified as follows:

Meter faces vill be color coded to reflect normal operating, ranges prior to issuance of an operating license, Displays will be reviewed for scale convention during the long texm control room xeviev and reported on in accordance with NUREG-0700.

PRIORITY FXNDING 31 13.'reen Florida Power and Light tape (denoting equipment turnovex to Florida Power and Light) and meter calibration certification stickers obstruct labels and meter scales in several places and generally clutter the appearance of the boards.

RESPONSE

13. The above clutter will be removed prior to plant low pover operation and after system turnovers have been completed.

PRIORITY FXHDING

14. Some meters in the control room have white bezels while others have black bezels ~ There is no well defined difference in meaning between the tvo bezel colox's ~

RESPONSE

14. White meter bezel means post accident instrument.

Slack has no significance.

0 Page 27 of 59 5~ DISPLAYS (Cont.)

PRIORITY FINDING

15. On the Line Repeat Panel there is either a reversal of Green-Left/Red-Right convention of indicator light positions or the colored lamps are incoxrectly installed.

RESPONSE

15. The lamps have been reversed to conform to the predominant control room convention.

PRIORITY

16. Thexe is a widespread use of amber and bluecolors for electrical system status lights while a red/green/amber convention is used on most other.

systems in the control room.

RESPONSE

16. The established lighting color convention will be followed. Implementation will be prior to issuance of an operating license.

PRIORITY PINDIHG 17 ~ The CONTAIR4ENT H2 PURGE CONTROL VALVE PCV-25-S on the HVAC Panel violates the conventional color coding of indicator lights by using green to indicate OPEN and red to indicate CLOSED.

, RESPONSE

17. The lights have been changed to conform to the control room color convention.

Page 28 of 59

5. DISPLAYS (Cont.)

PRIORITY FINDING

18. On Pariel 203, the PRESSURIZER .PRESSURE HETERS PIC-1105 and PIC-1106 indicate an increase in pressure by a downward movement of the pointer.

RESPONSE

18. The meters will be rotated and new scales installed such that they indicate an increase in pressure by an upward movement of the poin"er. This item will be implemented prior to issuance of an operating license.

PRIORITY FINDING 31 19. On process controller vertical scales, circular meters, and large horizontal trend recorders, the pointers obscure scale numerals.

Example:

a~) GENERATOR TEfPERATURE TR-2 2>>3 0

RESPONSE

19. Normal operating bands will be marked on meters prior to issuance of an operating license. The obscuration of numerals ~Oil be reviewed as part of the long term evaluation in accordance with NUREG-0700.

PRIORITY FINDING 31 20. The CONDENSATE STH GEN BLOHDOHN CONDUCT CR-05-1 trend recorder does not have a legend to distinguish between pen colors.

RESPONSE

20. An'ppropriate label will be provided whi'ch clearly identifies pen colors and their meanings. This will be implemen ted pr ior to fuel load.

Page 29 of 59 5~ DISPLAYS (Cont )

~

PRIORITY FINDING 2 21. The 0-5 psi operating bank on the CONTAIlMENT PIS-07-2B display on Panel 206 is very small PRESSURE compared to the full range of the display scale (0-100 psi) ~

RESPONSE

21. The correct instrument is scaled 0-15 psi. This instrument is correct for its intended use during accident conditions and will be installed prior t'o issuance of an operating license.

PRIORITY FINDING 22 ~ Throughout the control room, there is a lack of demarcation of the "normal," "safe," "caution," and "danger" ranges on display instruments.

RESPONSE

22 ~ This item will be addressed as part of the ongoing labeling and demarcation program which is scheduled to be implemented prior to issuance of an, operating license, PRIORITY FINDING

23. The Reactor Protection System Trip Status Panel has indicator lights, which indicate OPEN on the bottom or left and CLOSED on the top or right. Both of these indicator light positions are opposite of normal convention.

RESPONSE

23. The position of these lights will be corrected to conform to the established Control Room convention prior to issuance of an operating license.

Page 30 of 59 5~ DISPLAYS (Cont . )

PRIORITY FINDING

24. There are no lamp tests in the control room other than those for the annunciators.

RESPONSE

24. A method will be developed to verify operability of

,the indicating lamps in the Control Room prior to fuel loading'ne or more of the following will be utilized for the verification:

a.) direct indication by lamp test circuit, eg.,

annunciator test b.) dual filament bulbs c,) verification via redundant intelligence available on the board d.) evaluation of manufacturers filament life rating to determine changcout requirements e.) the safety related HOV position indication and breaker indication for safety related pumps will be periodically tested as part of the pump and value test program f.) non-safety related MOV and breaker indications will be tested as part of the periodic equipment rotation program PRIORITY FINDlNG 3 "

25. On Panel 201, the BATTERY 2A and BATTERY 28 'status are single blue lights. There is no 'ights indication whether the light indicates normal or abnormal state when lit.

RESPONSE

25. The above lights labels will be mor'e clearly defined and will conform to established color cable convention. This will be accomplished prior to fuel loading.

PRIORITY FINDING

26. On the HVAC Panel, each of the following systems has three associated indicator lights, two of which are red: CONTAX&fENT FAN COOLERS:

2HVS-IA, lB, 1C, 1D

RESPONSE

26. The red lights indicate speed ~ Center is, the slow speed; the right red'ight is the fast speed. These lights will be appropriately labeled. This backfit will be implemented prior to issuance of an operating license.

V Page 31 of 59 0

5~ DISPLAYS (Cont. )

PRIORITY FINDING 27, Several recorders are supplied with paper which is scaled differently than the scale on the recorder face. For example, the BORON CONCENTRATION RECORDER AP-2203 on PANEL 205, if installed as planned, will have four selectable ranges but will have only a single full range paper (0-2000). Thus, if the operator selects (0-500) range, a reading of 250 will be recorded as 1000, etc.

Other examples:

a.) Panel 201: GENERATOR FREQUENCY RFCORDER F-REC-881 ~

b.) Panel 202: FEEDWATER AND STEAH GENERATOR BLOWDOWN PIER-05-lo

RESPONSE

27. a.) Will have proper scales prior to operating license.

b.) Will have proper scales prior to operating license.

Boron concentration changes gradually over core.

life. There would be no sudden transients requiring the use of multiple scales during normal'peration.

This recorder will use lined unscaled paper. The shift operator is aware of'his boron concentration and relies on periodic chemistry readings for verification.

PRIORITY FINDING 31 28. The trend. recorders on the HVAC Panel have data legend labels on the glass window wnich obscure the

.graph paper. The operator must open the recorder in order to read information..

RESPONSE

28. Labels will be repositioned so that displayed information is unobscured. This will be implemented prior to fuel loading .

Page 32 of 59

5. DXSPLAYS (Cont.)

t PRIORXTY FINDING

29. Hultipoint impact recorders have too many data channels on each recorder. Some recorders have as many as 24 data channels. Similar impact recorders in Unit 1 were found to be overprinting their data.

RESPONSE

29. These impact recorders are used for trend values. An oif normal condition would be seen as a departure from normal trend at which time the point would be readable. This will be looked at as part of the long term service in accordance with NUREG<<0700.

PRIORITY PINDING 31 30. A (0-125) non-linear scale is used on the REACTOR MAKEUP WATER FLOW FRC-2210X display where a linear scale would do gust as well.

RESPONSE

'0. Florida Pover and Light agrees v'h priority assignment of this item. Due to the unique design of the instrument and long lead time for procurement, replacement may be after fuel load but will be implemented at the first opportunity after delivery but no later than first refu'cling. Emphasis during training and temporary labeling measured'RIORITY vill be used as an interim PENDING

31. Several displays have no labeling to indicate in what

, 'nits their scales are measured.

Examples:

a;) Panel 205: WASTE GAS FLOW RECORDER-FR-6648 b.) Panel 203: PRESSURIZER SPRAY-NIC-1100 c.) Panel 206: REFUELING WATER TANK LEVEL-LR-07-20

RESPONSE

31. Appropriate labels vill be installed prior to issuance of an operating license.

PRIORXTY FENDING

32. The POWER METER on the Reactor Protection System Panel has a broken glass face.

RESPONSE

32 ' The glass will be replaced prior to fuel loading.

Page 33 of 59 6~ LAMLS AND LOCATXON AIDS PRXORITY FINDING A number of controls and displays on Panel 203 have labels which are either missing or appear to be incorrect.

RESPONSE

All labels will be reviewed as part of the labeling study. Those missing'labels will be installed and those incorrect labels will be corrected. This discrepancy will be corrected prior to issuance of an operating licensees PRIORITY FINDING 2~ Many trend recorders on Panel 205 and the HVAC Panel have blank labels or labels which do not identify the display's function.

RESPONSE

2. . This item will be reviewed during the labeling study and blank labels and/or non-descriptive labels will be corrected prio'r to issuance of an operating license, PRIORXTY FIHDXHG 3~ On the back of Panel 201, the AUX and MAIN TRANSFER switches and indicator lights are not labeled.

RESPONSE

3~ These switches could not be located, however all labeling will be reviewed and corrected as required and reported on in accordance with NUREG-0700.

PRIORITY FINDING 31 4 ~. There are missing labels on the Plant Auxiliary Panel for switches and for switch position indicators ~

RESPONSE

4~ Those missing labels on the Plant Auxiliary Panel will be installed prior to fuel loading.

Page 3~i of 59

6. LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDING 1 5. So me of the Auxiliary Feedwater Pump and Valve controls have unlabeled "Auto" positions.

Example:

a.) AUX FW PUMP/2A DISCH to SG2A VALVE

RESPONSE

5~ Those pump and valve controls with unlabeled "Auto" positions will have these positions properly labeled prior to issuance of an operating license. This item will be included as part of the ongoing labeling s'tudy ~

PRIORITY FINDING

6. The MATRIX RELAY TRIP SELECT rotary control on the RPS Panel has unlabeled positions

RESPONSE

6. The unlabeled positions on the Matrix Relay Trip switch are to insure that we have a break before make to avoid tripping the reactor during relay testing.

PRIORXTY FINDING 7, On Panel 201 the BATTERY VOLTS 2A meter VM-1000 is incorrectly labeld as BATTERY VOLTS 2B.

RESPONSE

7. Volt meter VM-1000 will have its label corrected prior to issuance of an operating license.

r PRIORITY FINDING 31 8. The LOOSE PARTS MONITOR CABINET contains switches whose control functions and positions are not labeled.

RESPONSE

8. Correct labels will be provided prior to fuel loading.

Page 35 of 59 6~ LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDXNG 31 9. Several toggle switches on the Reactor Regulating System Panel and on the Reactor Coolant Pump Vibration Monitor Panel have unlabeled switch positions;

RESPONSE

9. Appropriate labels will be provided prior to fuel loading.

PRIORITY FINDING

10. On Panel 206, the key switch positions on the MSIS block switch are not labeled.

RESPONSE

10. The MSIS block key switches will have their positions marked and properly labeled prior to issuance of an operating license.

PRIORITY FINDING

11. ~

LPSX LOOP 2A FLOll METER on Panel 206 is mislabeled.

It should read 2A1..

RESPONSE'PSI LOOP 2A FLOP METER on Panel 206 will have its label corrected as part of the labeling program review. This item will be corrected prior to issuance of an operating license.

PRIORITY, FINDING 12;, The LPSI HEADER PRESSURE METERS 2A and 23 on Panel 206 are either mislabeled or in the wrong panel locations.

RESPONSE

12. These recorders/indicators are required to be powered from two independent safety grade power sources. To comply with the additional requirements of NUREG 1.75 these displays were located in the associated electrical train to achieve the required separation. As an interim measure prior to issuance of an operating license, demarcation will be used to make these items stand out. The detail control room review will include evaluation of relocating the recorders.

Page 36 of 59

6. LABELS AND LOCATION AXDS (Cont ~ )

. PRIORITY FINDING

13. The CONDENSER VACUUM DXSPLAY (PI-10-7B) on Panel 201 has a mislabeled seal,e. It should read "Inches HG Vacuum" instead of "Inches Hg ABS" ~

RESPONSE

13. The condenser vacuum display will be labeled as "inches HG" prior to fuel loading.

PRIORXTY FXNDING

14. The BORON CONTROL VALVE on Panel 205 is m'islabeled.

It should read BLENDING VALVE.

RESPONSE

14. The Boron Load Control Valve (V-2525) is a diluting valve and not a blending valve.

PRIORITY FINDING 31 "

15. The FEEDWATER PUMP 2A FLOW label on Panel 202 is incorrect. It should read FEEDHATER PUMP 2$ FLOW.

RESPONSE

15. The indicator will be appropriately labeled prior to fuel loading.

PRIORITY FINDING

16. The functional difference between the dual Steam Generator meters on the four ENGINEERING SAFEGUARDS LOGIC CABINETS is not labeled.

RESPONSE'6.

Appropriate labels will be provided prior to issuance of an operating license.

Page 37 of 59

6. LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDING

17. There is no hierarchical arrangement of labels by system and subsystem throughout the control room.

RESPONSE

17. A labeling and demarcation effort is underway.

Hierarchical labeling and demarcation will be provided. This program is scheduled for completion prior to issuance of an operating license.

PRIORITY FINDING 31 18. On Panel 201, component identification labels are not consistently larger than component status (e.g.

"start", "stop", "auto") labels.

RESPONSE

18. Component identifying labels will be provided which are larger than component status labels, This will be done prior to fuel loading'RIORITY FINDING 0 19,

RESPONSE

Label placement convention the control room.

is inconsistent throughout

19. Label placement is under review. However, as part of labeling effort, label visibility will take precedence over location consistency (except where substitution errors are likely due to inconsistent label locations). This item* will be completed prior to issuance of an operating license.

PRIORITY FINDING

20. Labels on Panel 201 have been placed under displays and are often obscured'y the overhanging bezel of the display they are intended to identify.

RESPONSE

20, 'uring relabeling, labels will be placed in nonobscured locations prior to issuance of an operating license.

Page 38 of 59 6~ LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDING

'31 label for the backpanel that contains the L 21, The & N PROCESS AND COOLING MATER TBiP. SELECTOR is below the switch array and is obscured.

RESPONSE

21. The label will be relocated to a more visible position. This item will be completed prior to fuel loading.

PRIORITY FINDING

22. 'helabel WASTE GAS FLOW trend recorder on Panel 205 has no to indicate what parameter is being monitored'ESPONSE

22. -

The parameters on all recorders will be appropriately labeled prior to issuance of an operating license.

PRIORITY FINDING 31 23. On Panel 202, the labeling for the light pairs representing the UHS CANAL BARRIER VALVES (I-S3 13, 14) is ambiguous. There is one label for two light pairs.

RESPONSE

23.." The labeling will be changed to reflect the proper labeling of the two individual 'valves I-S3-21 and I-S3-21-14 respectively. This item will be complete prior to fuel loading.

PRIORITY PXNDING 31 24. On Panel 201, labels for rotary switch control positions are not oriented horizontally and svitch position labels are obscured by the control handle.

Example:

a.) AKKTER CONTROLS FOR BUS 2Al

RESPONSE

24. The control handle will be modified or changed so that switch position labels are not obscured.

Svitch position label orient:ation vill be further evaluated per the requirements of NUREG-0700.

This item vill be completed prior to fuel loading.

Page 39 of 59 6~ LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDING 25.'ntrendPanel 205, there is no indication on two-color recorders as to which color represents an

'actual reading and which represents the set point.

RESPONSE

25.. Labels will be provided that identify the pen color meanings. This item will be implemented prior to issuance of an operating license.

PRIORITY FINDING 26 'he REACTOR CHANNEL labeled as to function.

TRIP BUTTONS on Panel 204 are The buttons should be not labeled "TRIP" .

RESPONSE

26. The content of these labels will be reviewed and improved labels provided. This item will be implemented prior to issuance of an operatin'g license.

PRXORXTY FINDING 3l 27; Hoot of the component labels on the FEEDWATER REGULATXNG RACK do not contain component identif ication numbers ~

RESPONSE

27. Permanent labels will be provided prior to fuel loading.

PRXORITY FXNDING 31 28. mbels on Panels 205 and 206 aie very similar and can be confusing..

Examples:

a.) BORIC ACID GRAVITY FEED VALVE V-2508 and BORIC ACID GRAVXTY FEED VALVE V<<2509.

b.) HPSI TO HOT LEG 2B VALVE V-3551 and HPSX TO HOT LEG 2B VALVE V-3523

'ESPONSE

28. Similar labels will be resolved as part of the relabeling effort. This item will be implemented prior to fuel loading .

Page 40 of 59

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6~ LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDING

29. On Panel 206, there is an error on the HPSI HDR B TO LOOP 2B2 label. It should read LPSI instead of HPSI.

RESPONSE

29. Errors in labeling will be corrected as part of the relabeling effort. This item will be corrected prior to issuance of an operating license.

PRIORITY FINDING

30. Abbreviations are not used consistently in labels'xamples:

a.) Panel 206: CCU pUMP 26 (CCM ~cow onent cooling water) b.) Panel 203: CCW FRO'1 RCP 2A1 PLOW (FIA-1158)

(CCM ~ core cooling water component.

c.) Panel 205: CO."P COOL'G MATER.

, RESPONSE

30. Standardized 'abbreviations are to be employed during St. Lucie Unit No. 2 relabeling. Presently this item is scheduled for -implementation prior to issuance of an operating license.

PRIORITY . FINDING 31 31. Labeling of units on scales of trend recorders, counters, and process controllers on Panel 202 is inconsistent and often is redundant with the control label.

Example:

- a.) FEEDMATER TO SG 2A REG VALVE BYPASS LIC-9005 RESPONSE .

31. This item will be addressed as part of the St. Lucie Unit No. 2 relabeling effort. This effort is scheduled for implementation prior to fuel loading.

a

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Page 4 1 of 59 6~ LABELS AND LOCATION AIDS (Cont. )

PRXORITY -

FINDING 2 32 ~, Pushbut tons on Panels 201 and 203 have two labels which present redundant information.

Examples:

a.) Panel 201: TURBINE TRXP and TRIP b ~ ) Panel 203: RCP 2A1,VIBRATION RESET and RESET.

RESPONSE

32 ~ Redundan t labels will be removed ~ This item will be implemented prior to issuance of an operating license.

PRXORXTY 33 'n FINDING

~

Panel 203, two PRESSURXZER LEVEL controllers that are labeled CONTROL have different functions'ESPONSE 33 'oth selector controllers provide the same function, with a switch determining which controller is in service. No further action is required on this item.

FINDING 34 'ome labels are difficult to read due to color contrast between label surface and insufficient lettering'ESPONSE

34. Figure background contrast will be improved as part of relabeling. This item is scheduled to be

. implemented prior to issuance of an operating license.

PRIORITY FINDING 35.' Eng rav ed labels on al 1 panels in the control room

~

have become obscured by grime.

RESPONSE

35. Relabeling will use black characters on a white background, reducing obscuration by grime. This effort is scheduled to be implemented prior to issuance of an operating license.

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k Page 42 of 59

6. LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDING

'n

) 36. the Plant Auxiliary Panel, the annunciator control button labels are illegible and the ACKNOWLEDGE buttons are not labeled.

RESPONSE

36. These controls will be appropriately labeled as part of the ongoing labeling, study which is scheduled for implementation prior to issurance of an operating license.

PRXORITY FINDXNG 31 37. Panels 203 and 206 have labels whose characters are separated by less than the minimum recommended space (1/6 character height) .

RESPONSE

37 ~ During St. Lucie Unit No ~ 2 relabeling, character spacing will conform to the requirements of NUREG-0700. This item is scheduled as part of the relabeling effort to be implemented prior to fuel loading.

PRXORITY FXNDING

38. Line spacing is less than 1/2 character height on almost all labels in the control room.

RESPONSE

38. During St. Lucie Unit No. 2 relabeling, line spacing will be 1/2 character'eight or greater. Line spacing will conform to the requirements of NUREG-0700 and will be implemented prior to fuel loading.

PRIORITY FINDING

/

31 39 ~ Several controls on Panel 201 have temporary labels to indicate associated circuit bre'akers.

RESPONSE

39. A review of existing labels (permanent and temporary) vill be conducted. During St. Lucie Unit No 2 ~

relabeling all information will appear on permanent labels. This effort is scheduled for implementation prior to fuel loading.

Page 43 of 59 6~ LABELS AHD LOCATION AIDS (Cont.)

PRIORITY FINDING 31 40. The permanent label for the STATION BATTERY 28 VOLTS meter is incorrect and has been replaced by a temporary label. However, both labels are still in place'ESPONSE

40. This will be corrected with correct, permanent labels. This labeling effort is scheduled for completion prior to fuel loading ~

PRIORITY FINDING 31 41. On Panel 201, the label for the 480V BUS TIE SMITCH 2AB-2 is handwritten in ink on the panel surface.

RESPONSE

41. A permanent label will be provided'his item is scheduled to be implementated prior to fuel loading.

PRIORITY FINDING

42. Tag outs on Panel .,201 obscure displays located below them on the control panel.

RESPONSE

42. A method of tagging which does not obscure adjacent switches vill be implemented prior to issuance of an operating license.

PRIORITY FINDING 31 43. On Panel 201, summary labels and demarcation lines are not used to identify and separate systems surrounding mimics. Labels do not always appear above mimic areas.

Example:

a.) , Electrical distribution buses

RESPONSE

43 ~ Summary labeling and demarcation lines will be used to more clearly identify and separate those specific controls which are nOt associated with the surrounding mimic areas. This item will be completed prior to fuel loading'

Page 44 of 59

6. LABELS AND LOCATION AIDS (Cont ~ )

PRIORITY "FINDING 1 44 ~ TRIP A and C pushbuttons on Panel 201 are adjacent, to the TURBINE TRIP pushbutton. REACTOR TRIP is a safety function and its controls should be rea'dily distinguishable from the TURBINE TRIP

'ESPONSE'EACTOR control. 0

44. Reactor Trip pushbuttons will be conspicuously demarcated and labeled. This item is scheduled for implementation prior to issuance of an operating license.

PRIORITY FINDING

45. The color coding and shading of control labels on the HVAC Panel is inconsistent with the rest of room. the'ontrol

RESPONSE

45, Any color coding of labels during the relabeling study will offer consistent color meanings. This item is scheduled for implementation prior to .

issuance of an operating license.

PRIORITY FINDING

46. Mimics in general are not consistently color coded.

For example, there is an inconsistent use of color in the Power Distribution Mimic on Panel 201. The colors yellow and blue are used for voltages of 6.9KV and 4.16KV and yellow and blue are also used for protective channels B and D.

RESPONSE

46. Consistent mimic color and codings means will be provided. This will be implemented prior to issuance of an operating licence.

Page 45 of 59 6~ LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDING

47. On Panel 205, the annunciator TEST control is color c'oded red, which is inconsistent with coding of other annunciator controls.

RESPONSE

47.. This control will be changed to black. This backfit will be implementd prior to issuance of an operating license.

PRIORITY FINDING

48. The Line Repeat Panel Mimic has incomplete mimic lines and arrows.

RESPONSE

48. The mimic will be completed. This item will be completed prior to fuel loading.

PRIORITY FINDING

49. Color codes of labels are generally based upon the power supply for the component instead of the component function. This color code scheme is helpful for maintenance but 'is not a useful aid for the operator.

RESPONSE

4

49. The present labels are scheduled to be replaced with black on white labels; however, a small color dot indictor will be used to denote power train.

Presently this item is scheduled to be completed prior to issuance of an operating license.

PRIORITY FINDING

50. On Panel 201, the 480V BUS BREAYXR controls are interspersed with controls which are part of a system mimic. This tends to confuse the mimic arrangement.

RESPONSE

50. The purpose of interspersing the Bus Breaker controls in the mimic arrangement is to minimize the potential for an improper Bus line up or intertie. A more detailed review of this section of the control board will be made and reported on as required by NUREG-0700.

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Page- 46'f 59 6~ LABELS AND LOCATION AIDS (Cont.)

PRIORITY FINDING

51. 'here is a lack of grouping of Diesel Generator.

controls on Panel 201.

RESPONSE

51. The Diesel Generator controls are grouped in accordance with the associated distribution system as depicted by the board mimic. Displays are located directly above associated controls.

Summary labeling and demarcation lines will be used to more clearly define grouping of associated diesel generator controls. This item will be implemented prior to issuance of an operating license.

Page 47 of 59 7~ PROCESS COMPUTERS THE PROCESS CO>fPUTER INSTALLATION FOR UNIT 2 HAS NOT INSTALLED AND COULD NOT BE EVALUATED.

There will be significant differences between the Unit 2 Process Computer and the Process Computer system now operating in Unit l.

RESPONSE

This item will be addressed with the other (systems which could not be eva3.uated) items at the end of the audit report.

Page 48 of 59 So PANEL LAYOUT PRIORITY FINDING Controls that are used together are not functionally

=

grouped on Panel 206, Example:

a.) CSAS CHANNEL SA, SIAS CHANNEL SA, AND RAS CHANNEL SA

RESPONSE

These controls are oriented to comply with present fire separation requirements. All "8" train components are located together and all "A" train components are located together. Florida Power and Light will prepare a more detailed Justification as part of the detailed control room design review per NUREG-0700.

PRIORITY FINDING 2~ On Panel 203,the Pressurizer Relief Line Temperature and the Safety Valve Discharge Temperature meters are installed in unconventional left to right order (1107, 1108, 1109, 1106).

RESPONSE

2~ Florida Power and Light feels that this is not a valid finding since the safety valves discharge to the relief line and function is depictd in order of event (e.g. safety valve discharge through relief line). Additionally,

- the three safety valves are installed in left to right order, V1200 being on the left, V1201 being in the middle, and V1202 being on the right.

PRIORITY FINDING 3~ On Panel 206 unrelated displays have been placed between related displays 'for CCW FROM SHUTDOWN, CCW FRVf FUEL POOL, and CONTAINMENT SPRAY.

RESPONSE

3~ Florida Power and Light will review this item as part of the detailed control room design review and it wi11 be reported on in accordance with NUREG-0700.

k Page 49 of 59

~ ~

8~ 'ANEL LAYOUT (Cont.)

PRIORITY FINDING 4~ The VOLUME CONTROL TANK DISCH VALVE V-2501 and the REFUELING WATER TO CHARGING PUMPS VALVE V-2504 on Panel 205 are spacially separated by other letdown, charging; and VCT controls. There is a general lack of logical layout of charging, letdown, and VCT controls on this panel for task oriented optimization.

RESPONSE

4~ This item will be incorporated into the long term review and reported in accordance with NUREG-0700.

PRIORITY NINDING 31 5~ On Panel 203, there is a lack of consistency in the column alignment of similar displays.. For example, UPPER CAVITY PRESSURE indicators are not aligned vertically in the same column.

RESPONSE

5~ This is a labeling problem and not a lack of consistancy. The span of the gauges indicates they are installed in a consistant manner. The labeling will be corrected prior to fuel loading.

3here PRIORITY FINDING 202.

is Examples:

a general lack of system grouping on Panel a.) The Primary Water lfakeup Pump controls and PRDfARX WATER STORAGE TANK LEVEL displays are located on Panel 202. The remainder of the makeup controls and displays are located on Panel 205.

RESPONSE

6.a. The prhnary water storage tank level display, as well

.as the pump controls, are associated with a number of systems in addition to the charging system and displays located on Panel 205. Relocation of these controls and displays would not change or improve present operator effectiveness. Florida Power and Light feels these items are properly located'his item will be evaluated as part of the long term review and reported on in accordance with NUREG-0700.

Page SO of S9 8~ PANPL LAYOUT (Cont.)

PRXORXTY PXNDING 7~ On Panels 205 and 206 it is difficult to locate and identify specific con'trois located in large matrices of controls Qxich are identical in appearance. The control arrays do not have aids such as system functional grouping, functional color coding, or demarcation to facilitate operator actions'ESPONSE 7.. These control arrays will incorporate system functional grouping and demarcation to facilitate operator actions. This item will be .implemented prior to issuance of an operating license.

PRIORITY FINDING

8. The CONDENSATF. STORAGE TANK HIGH LEVEL and LOW LEVEL annunciator tiles on annunciator Panel Q are not near or above associated system displays'ESPONSE

'8. The CONDENSATF. STORAGE TANK HIGH LEVEL and LOP LEVEL annunciator tiles are located on Panel G not on Panel Panel G is located on Control Board 202 and the displays are located 4 feet, to the right and- are readable from the associated control location. The annunciator display relationship will be addressed as part of'ong term review in accordance with NUREG-0700.

PRXORITY FINDING

2. 9. The indicator lights for DIESEL GEN. 2A LOADING status on Panel 201 are not arranged in the conventional operational loading sequence.

RESPONSE

9~ '"'oading sequence on Panel 201 will be arranged in a consistent manner prior to issuance of an operating license ~

Page 51 of 59 8~ PANEL LAYOUT (Cont.)

PRXORITY FINDING 31 10 On Panel 203, some controls are not arranged by importance or frequency of use.

Examples:

a ~ ) ANNUNCIATOR controls b.) REACTOR COOLANT PEfP controls

RESPONSE

10. Presently the ANNUNCXATOR controls located on Panel 203 are scheduled to be moved to the lower right-hand corner of Control Board 204. These controls are scheduled for relocation prior to receiving an operating license.

PRIORITY FINDING ll, There is a poor grouping of indicator lights in several places on Panel 206.

Examples:

a.) CSAS CHANNEL SB bo) SXAS CIQNNEL SB c.) RAS CHANNEL SB

RESPONSE

These controls and associated indicating lights will be demarcated to improve control/display relationships. This item is scheduled for implementation prior to issuance of an operating license, PRIORITY FINDING

12. On Panel 203, several controls/displays are arranged horizontally on the upright panel while related controls/displays are arranged vertically on the benchboard.

Example:

a.) Reactor Coolant Pumps 2A1, 2A2, 2B1, and 2B2.

RESPONSE

12. These controls and displays will incorporate demarcation, hierarchical labeling, and summary labeling to better define these control/display relationships, This'tem is scheduled for implementation prior to fuel loading.

Page 52 of 59

8. PANEL LAYOUT (Cont.)

PRIORITY FINDING 2 13. There is a reversal from normal left-to-right convention of the indicator lights for the LPSX HDR A

'O LOOP 2Al VALVE and the LPSI HDR A TO LOOP 2A2 VALVE on Panel 206.

RESPONSE

13. The arrangement of the HIPSI and LIPSX control displays will be reviewed 'and rearranged to complement the control/display demarcation effort.

This item is scheduled for implementation prior to

,issuance of an operating license.

PRXORITY FINDING

14. Columns of similar control switches on Panel 206 are separated by two columns of miscellaneous controls.

Examples: .

a,) Control switches V3612 and V3622 b .) Control switches V3613 and V3623

RESPONSE

14 ~ 'his item will be incorporated into the long term review and reported in accordance with NUREG-0700.

PRXORXTY FXNDXNG 31 15. The AUX FEEDWATFR HEADER FLOW trend recorders on Panel 202 are arranged in BCA left-to-right sequence instead of ABC.

RESPONSE

15'hese recorders will be "rearranged to conform to the control grouping. This item is scheduled for implementation prior to fuel loading.

page 53 of 59

8. PANEL LAYOUT (Cont.i PRIORITY PINDING I

2 16. There are many locations in the control room where components are not arranged left-to-right and/or top-to-bottom and are not identified in alphabetical or numerical sequence.

Examples:

a.) The HOLDUP TANK LEVEL INDICATORS on Panel 205 are arranged from right to left.

b.) On Panel 206, the HDR B ISOL VALVE is above the HDR A ISOL VALVE.

c.) The Line- Repeat Panel MEGAVAR meters are numbered from right to left.

RESPONSE

16.a. The HOLDUP TANK LEVEL INDICATORS will be rearranged to agree with left to right convention.

16,b. 'he HDR B and HDR A ISOL VALVE key operated switches and indicating lights will be rearranged to agree with top 'to bottom convention. These will be implemented prior to issuance of an operating license.

16.c. The NEGAVAR meters are a mimic of the lines in the switchyard with No. 1 being to the North, No. 2 in the middle, and No. 3 to the South. No further action will be taken on this item.

PRIORITY PINDING

17. The locations'of LIQUID HASTE FLOH VALVL'S PCV-6627Y an'd PCV-6627X status indicator displays and valve control switch positions violate the upper/left-lover/right layout convention for associated controls and displays in a mixed horizontal and vertical layout. The upper set of indicator lights for valve Y is associated with the right position of the valve control. The lower set of indicator lights for valve X is associated uith the left position of the control.

RESPONSE

17. The light positions will be reversed to agree with left/right - top/bottom convention. This item will be implemented prior to issuan'ce of an operating license.

1

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Page 54 of 59 8~ PANEL LAYOUT (Cont.)

PRIORITY FINDING 18.'nnarrow Panel 206 the meter for SI TANK 2A2 LEVEL is range instrument. It should be a wide range meter to be consistent with similar level displays on the panel'ESPONSE

18. SI TANK 2A2,LEVEL instrument LIA-3311 will be replaced with the proper wide range indicator. This item will be implemented prior to fuel loading.

PRXORXTY FINDING

19. The controls for the REACTOR REGULATOR SYSTEM "1" and "2" on Backpanel 204 and the continuous rotary selectors on the LOOSE PARTS MONITOR panel do not meet minimum separation guidelines for controls'

RESPONSE

19. 'he above mentioned items are not controls, but test switches and pushbuttons. These will be operated by procedure and any error would be self evid~nt.

PRIORXTY FINDING

20. There are excessively long meter strings of more than five vertical meters p'er string on Panels 201 and 203'xamples:

a.) EXPANSION STEAN AREA b~) CONDENSER STEAM AREA

RESPONSE

20. Labels (summary and component) and demarcations will be provided to provide visual anchors breaking up strings into smaller groups. This item will be implemented prior to issuance of an operating license.

U ~ Page 55 of 59 8~ PANEL LAYOUT (Cont.)

PRIORITY FINDING 2 21. There is string of 10 J-handles on Panel 203. It is difficult to readily distinguish individual controls in the string.

RESPONSE

21 ~ Labels (summary and component) and denarcation will be provided to provide visual anchors breaking up strings into smaller groups. This item will be implemented prior to issuance of an operating license.

PRIORXTX FINDING 22 ~ The REACTOR COOLANT PUMP 282 control on Panel 203 is located in cluster with the PRESSURIZER BACKUP HEATER BANK controls. The pressurizer heater controls are ,

used frequently. This location of the reactor coolant pump control among frequently operated controls increases the likelihood of accidental shutoff of the reactor coolant pump.

RESPONSE

22. Finding to be resolved via demarcating and summary labeling of RCP controls, pressurizer relief controls, pressurizer heaters,and shape coding of RCP handles. This item to be implemented prior to issuance of an operating license.

PRIORXTX pzzmnG

23. The CRT display on Panel 204 is difficult to view" from the operator's position at the ROD POSXTION CONTROLS because of the poor viewing angle,

RESPONSE

t

23. The analog display is in close enough proximity to the CEA control panel to eliminate any viewing problem. This will be verified utilizing guidelines of NUREG-0700 prior to issuance of an operating license.

Page 56 of 59

8. PANEL LAYOUT (Cont.)

PRIORITY FINDING 31 24. Electrical test points for Reactor Coolant Temperature are included in front panel. If they are used only for calibration, they should be placed in other than prime control areas. If they are used for operations, they should be replaced by an appropriate display.

RESPONSE

24. These test points vi11 be relocated to another area prior to fuel loading.

Page 57 of 59 9~ CONTROL/DISPLAY INTEGRATION PRXORITY FINDING 3 1~ There is little system functional logic to the layout of Panel 205. For example, a normal blending operation would involve the use of the BORIC ACID MAKEUP PEP 2A, the BORIC ACID MAKEUP FLOW VALVE, the REACTOR MAKEUP WATFR STOP VALVE, and the REACTOR MAKEUP FLOW VALVE controls and the indicators for BORXC ACID FLOW, REACTOR MAKEUP WATER FLOW and VOLUME CONTROL TANK LEVEL. These controls and displays are not logically grouped to perform this operation.

RESPONSE

This item will be incorporated into the long term review and reported in accordance 'with NUREG-0700.

PRIORITY FINDING 2 2~ Panel 202 benchboard controls are mirror imaged while corresponding vertical displays are not.

RESPONSE

2~ The displays associated with the Aux Feedwater controls on Panel 202 will be arranged to be consistent with the associated controls. This effort will be combined with the upgrade requirements of the Aux Feed system and.is scheduled for implementation prior to issuance of an operating license.

PRIORITY FINDING 3~ On Panel 203, there is a poor layout of Pressurizer Level and Pressurizer Pressure controls and displays. Pressure controls are to the left of Level controls, while pressure displays are to the right of Level displays. Furthermore, the LOOP,2A/28 HOT LEG TEMPERATURE display is located between the Level and Pressure displays.

RESPONSE

3~ This item will be reviewed as part of the long term review in accordance with NUREG-0700.

r

Page 58 of 59

9. CONTROL/DISPLAY INTEGRATION (Cont.)

PRXORXTY FZNDXNG 3 4, The SHUTDOWN COOLING HX OUTLETS 2A and 2B (TEMP-TI-3303X and TBP-TI-3303Y) displays are located at the opposite end of the panel from the SHUTDONN HX CC VALVES (HCV-14-3A and HCV-14-38) controls, These controls and displays are used together during a failed pump condition.

RESPONSE

4~ HCV-14-3A and 38 are either full open or full close valves. RCS temperature is controlled by varying the amount of RCS flow through the heat exchangers. The controller for this function is adjacent to the temperature indicators. This item will be evaluated as part of the long term design review and reported on in accordance with NUREG-0700.

PRIORITY FINDING The right portion of Panel'02 contains five di,fferent subsystems (circulating water, condensate, primary makeup, intake, and screen wash) which are not arranged in a logical layout.

h

RESPONSE

54 Demarcation will be implemented as an interim measure prior to issuance of an operating license. This item will bc reviewed as part of the long term design review in accordance with NUREG-0700.

Page 59 of 59 9~ CONTROL/DISPLAY INTEGRATION (Cont.)

PRIORXTY FXNDING 6., Fisher-Porter controllers are inconsistent with each other. Some are fixed scale/moving pointer, while others are moving scale/fixed pointer. This requires operator to move the set point rotary wheel up to increase on some controls and down to increase on others.

'xamples: (Panel 205) a.) REACTOR MAKEUP FLOW (FRC-2210X) bo) FLASH TANK LEVEL (FCV-6627Y)

RESPONSE

6.a.) Prior to issuance of an operating license "increase arrows" will be placed to clarify operation of those movable scale controllers.

b.) These controllers will be incorporated in the detail Control Room design review and reported on in accordance with NUREG-0700.

PRIORITY FINDING 7t The FEEDWATER TO STEAM GENERATOR ISOLATION VALVES (HCV-09-1A, 2A, 13, 2B) on Panel 206 are widely separated from the FEEDWATER PUMP 2A FLOW (FI-09-1A, lB) and FEEDWATER AND STEAM FLOW SG2A/SG2B displays found on Panel 202.

RESPONSE

7~ These isolation valves are grouped with others required for isolation in the event of an accident.

Isolation can be verified in one quick glance, which would not be the case if the valves were spread around the board. This item will be 'evaluated as part of the long term design .review and will be reported on in accordance with NUREG-0700.

PRXORXTY ~ FINDING

8. The COND PIT SUMP/YARD SUMP HIGH LEVEL annunciator tile on Panel 205 should be associated with the CONDENSATE PUMP 2A and 2B controls on Panel 202.

RESPONSE

8~ These are two separate, sump systems and this annunciator would not necessarily be associated with the condensate pumps. There are no controls in the control room associated with these sumps. The annunciator was located in the waste management system which monitors all sump status ~ Florida Power and Light plans no change to the present configuration. This item will be reviewed as part of the long term design review in accordance with NUREG-0700.

Audit Report Saint Lucie 2 ll SYSTEMS WHICH COULD NOT BE EVALUATED of the state of completion, it was not possible to evaluate r

• 'ecause the following General Layout aspects of the Control Room:

Furniture and Equipment Layout Document Organization and Storage Spare Parts, Operating Expendables and Tools Supervisor Access Nonessential Personnel'ccess Operator consoles were represented by cardboard mock-ups which were only approximate replicas of the consoles to be installed. Thus, no studies of the operator consoles or any associated equipment were possible, preventing evaluation of such items as:'nthropometrics Console Dimensions Desk Dimensions Operator Chairs

• Unit Integration and Interference between the Unit 2 and the Unit, 1 Control Rooms under operational conditions could not be fully evaluated. It was observed that, if present plans are implement'ed, there will be differences between the two control rooms that may have significant human factors implications.

Emergency equipment was not present for evaluation of:

Operator Protective Equipment Fire, Radiation, and Rescue Equipment Emergency Equipment Storage The Control Room environment was not in its final state. The following environment topics could not be evaluated:

Temperature and Humidity Ventilation Illumination ~

Emergency Lighting Auditory Environment

~

Personal Storage Ambience and Comfort The following Voice Communication System items were not available for'valuation under operating conditions:

Conventional-Powered Telephone Systems Sound'owered Telephone Systems Walkie-Talkie Radio Tranceivers Fixed-Base UHF Transceivers Announcing Systems Point-to-Point Intercom Systems Emergency Communications

Audit Report Saint Lucie 2 No evaluation could be made-of the Auditory Signal System including:

Use of Auditory Signals'ignal Meanings Auditory Coding Techniques "Signal Propagration Signal Frequency Signal Intensity System Reliability Numerous controls and displays throughout the control room were

. missing or represented by photo mock-ups and could not be evaluated completely.

The Plant Process. Computer was not installed in Unit 2 and could not be evaluated from the Unit l computer installation. Items which need to be addressed include:

Computer Access Cathode Ray Tube (CRT) Displays Hard Copy Printers

h I

"k~