ML18036B325

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Provides Notification of Completion of Safety Related Portion of NUREG-0737,Item I.D.1,CRDR,for Unit 2.Design Finalized,Equipment Installed,Procedures Issued & Necessary Training Completed.Heds & Corrective Actions Encl
ML18036B325
Person / Time
Site: Browns Ferry Tennessee Valley Authority icon.png
Issue date: 06/14/1993
From: Salas P
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.1, TASK-TM NUDOCS 9306180218
Download: ML18036B325 (92)


Text

A.CCELERAT+ DOCUMENT DISTRVTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9306180218 DOC.DATE: 93/06/14 NOTARIZED: NO DOCKET FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 AUTH. NAME SALAS,P.

RECIP.NAME AUTHOR AFFILIATION Tennessee Valley Authority RECIPIENT AFFILIATION 5~

ge.go <<-Z~ R Document Control Branch (Document Control Desk)

SUBJECT:

Provides notification of completion of safety related portion of NUREG-0737,Item I.D.l,CRDR,for Unit 2.Design finalized, equipment installed 6 procedures issued. D DISTRIBUTION CODE: D030D TITLE: TVA Facilities COPIES RECEIVED:LTR Routine

/ ENCL I SIZE: S3 Correspondence NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D

INTERNAL: ACRS 6 6 NRR/DSSA 1 1 OC~LF CB 1 0 OGC/HDS3 1 0 D BEG FILE 0'1 1 1 RES/DE/SSEB/SES 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D

D D

NOTE TO, ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTETH CONTACI'HE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO EUMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DONT NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 11

)l 4k t Ol

Tennessee Valley Autttotity. Post Otfice Box 2000. Decatur. Alabama 35609

""> ~4 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-260 Tennessee Valley Authority )

BROWNS FERRY NUCLEAR PLANT (BFN) COMPLETION OF NUREG-0737 (TMI ACTION PLAN)g ITEM I D 1~ CONTROL ROOM DESIGN REVIEWS (CRDR) FOR UNIT 2 This letter provides notification of the completion of the safety related portion of NUREG-0737, Item I.D.l, Control Room Design Reviews (CRDR), for BFN Unit 2. The design has been finalized, equipment installed, procedures issued, and the necessary training completed. TVA committed to provide this notification as part of the Unit 2 Cycle 6 outage completion letter (Reference 1).

TVA's corrective action plan for the resolution of each safety significant CRDR human engineering discrepancy (HED) was provided in References 2 and 3. TVA's commitment to complete the Unit 2 safety significant HEDs prior to restart from the Cycle 6 refueling outage was contained in Reference 4. In that letter, TVA also committed to implement Unit 2 non-safety significant HEDs prior to restart from the next refueling outage, if they are determined to have a positive cost/benefit ratio. In Reference 5, TVA informed NRC that the nine Unit 2 Cycle 6 restart HED commitments had been implemented.

3.70057 QQ I 93061802i8 9306i4 05000260 PDR *DOCK PDR

41 I I

2 U. S. Nuclear Regulatory Commission JUN i,4 1993 Since the issuance of References 1 and 2, signi.ficant refinements have been made in the designs used to correct the CRDR HEDs. Therefore, the remaining safety significant HEDs that TVA committed to complete during Unit 2 Cycle 6, the original corrective actions, and the implemented corrective actions are included in the enclosure to this letter.

Please update the Safety Issues Management System database to show this item being implemented on BFN Unit .2 as of the date of this letter. There are no additional commitments contained in this letter.

me at If (205) 729-2636.

you have any questions, please telephone Sincerely, Pedro Salas Manager of. Site Licensing Enclosure cc (Enclosure):

NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr. Thierry M. Ross,. Project Manager U.S. Nuclear Regulatory Commission One Nhite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 U.S. Nuclear Regulatory Commission Region 101 II Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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U.S. Nuclear Regulatory Commission JUN io i>m

References:

1) TVA letter to NRC, dated May 24, 1993, Completion of Commitments for Unit 2 Cycle 6 Outage and Response to Related Issues
2) TVA letter to NRC, dated December 30, 1986, Detailed Control Room Design Review (DCRDR)

NUREG-0737, Item I.D.1

3) TVA letter to NRC, dated November 9, 1988, Response to NRC Safety Evaluation for the BFN Detailed Control Room, Design Review (DCRDR)
4) TVA letter to NRC, dated December 28, 1989, Browns Ferry Nuclear Performance Plan, Attachment IV-4, Response to Request for Additional Information
5) TVA letter to NRC, dated March 14, 1991, Notification of NUREG-0737, Item I.D.1, Detailed Control Room Design Review (DCRDR) and II.K.3.27, Common Vessel Level Reference Implementation

0 II I A

I I

ENCLOSURE BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW BACKGROUND Pursuant to NUREG-0737 (TMI Action Plan) and Supplement 1, TVA provided its Control Room Design Review (CRDR) corrective action plan and commitments to NRC by letter, dated December supplemented by letter, dated November 9, 1988. Since the 30'986'nd issuance of these corrective action plans, significant refinements have been made in the designs used to correct the CRDR HEDs. Therefore, the remaining safety significant HEDs that TVA committed to complete during Unit 2 Cycle 6, the original corrective action, and the implemented corrective action are provided below. The corrective actions were excerpted from Appendices A and B of TVA's December 30, 1986 letter to NRC, unless otherwise noted.

t HEDs AND CORRECTIVE ACTIONS HED 003 Insufficient Shift Correction:

Operating crew Implementation:

will be Coverage increased from current level.

The "current level" referenced in the corrective action was one operator per unit. Present shift manning for Unit 2 provides for two licensed reactor operators, one licensed Assistant Shift Operations Supervisor (ASOS)/Senior Reactor Operator (SRO), and one licensed Shift Operations Supervisor (SOS)/SRO. Additionally, the daily shift manning schedule assigns one licensed operator for relief and tagging duties and an outside main control room ASOS for additional operational support and/or relief.

1 I I

ENCLOSURE (CONTINUED) Page 2 of $0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 004 Disconnected I&C No Longer in Use Correction:

Components that are identified in the HECs as disconnected and no longer in use will be removed and their holes will be covered.

Implementation:

The Unit 2 components that were identified in the HECs as disconnected and no longer in use were removed and their holes covered. This included the covering the hole for the old clock in Panel 2-9-5 and an alarm window on annunciator bank XA-55-3C was replaced with a blank.

HED 007 Insufficient Separation Between Panel 9-53 and Back of 9-54 and 9-55 (Units 1 and 2)

Correction:

Procedural control will be implemented to require caution for working in back of Panel 9-54/9-55 to avoid bumping into Panel 9-53.

Implementation:

Site Standard Practice 12.1, Conduct of Operations, now restricts control room access and access to the areas around the bench boards and between these panels to the on shift Unit Operators unless permission is obtained from the Operators to enter these areas. The Operator Ownership philosophy further requires that the Operator be aware of activities taking place in the control room.

ENCLOSURE (CONTINUED) Page 8 of SO BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 012 Safety Relief Valve Acoustical Monitors and Temperature Recorder Not Located in Horseshoe Area Correction:

TR-1-1 and PX-1-4 will be relocated to Panel 9-4.

Implementation:

Safety relief valve acoustical monitor PX-1-4 was moved to Panel 9-3. The temperature recorder was not moved.

However, it has been changed to a micro-processor based unit with digital display functions with inputs to the Integrated Computer System. Therefore, the information is now available in the main operating area.

HED 015 Main Control Room Prints Illegible and Easily Worn/Tom Correction:

Main Control Room prints will be reviewed periodically.

Poor quality or worn prints will be replaced. Main Control Room prints will be updated (i.e. red lined) after a ECN is field completed and system is turned back over to Operations.

Implementation:

Red lining of Main Control Room prints is no longer performed. Updated drawings must now be filed in the Main Control Room prior to returning a system to operation. Main Control Room prints are periodically reviewed by Document Control for legibility.

ENCLOSURE (CONTINUED) Pagc4of$ 0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 017 Control Room Supplies are Often Unavailable Correction:

A control room supplies list will be developed. Inventory level will be established and a supplies cabinet will be put within Main Control Room.

Implementation:

Supplies for operational needs are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day at the Customer Service Center, located within the plant.

Minimum inventory levels are maintained by automated reordering.

HED 041 Diesel Generator Controls/Lights Too Deep in Panel 9-23 (Units 1 and 2)

Correction:

Diesel Generator start switches, governor control, voltage regulator switches, and associated lights will be relocated to lower portion of the panel to within depth criteria.

Implementation:

The Diesel Generator start switches, governor control, voltage regulator switches, and associated lights were relocated to the lower portion of the panel. These new locations are within the depth criteria.

ENCLOSURE (CONTINUED) Pog4. S of $0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 059 Panel 9-25 Standby Gas Treatment Gauges Located Too High Correction:

Gauges will be relocated as per HED 251 correction to a lower position to facilitate operator viewing.

Implementation:

The Standby Gas Treatment System gauges discussed in this HED were applicable to Units 1 and 3; not Unit 2. However, Standby Gas Treatment System flow instrumentation was installed on Panel 2-9-20 at the proper height. In addition, other flow instruments on Panel 2-9-25 were relocated to be within proper viewing acceptance criteria.

HED 072 Inadvertent Controls Actuation Correction:

Guardrails will be installed on bench board panels 9-3, 9-4, partially on 9-5, 9-6, 9-7 and 9-8 for all three units and on Panel 9-23 for Unit. 1/Unit 2.

Implementation:

Guardrails were installed on Unit 2 benchboard Panels 2-9-3, 2-9-4, 2-9-5 (partial), 2-9-6, 2-9-7, 2-9-8, and common Panels 0-9-23-1 through -8.

HED 075 Panel 9-6 Drywell Pressure and Drywell/Torus Delta-pressure Gauges Located Too High Correction:

These indicators will be relocated to Panel 9-3 as per HED 241 correction. This new location will meet height criteria.

Implementation:

The Drywell Pressure and Drywell/Torus differential pressure gauges were relocated to Panel 9-3. These new locations are within the height criteria.

0'

ENCLOSURE (CONTINUED) Page 6of$ 0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 076 Diesel Generator Controls/Lights, Shutdown Board Backfeed and Voltmeter Switches Too Deep Correction:

Same as HED 41 correction. The shutdown board backfeed switches and the voltmeter selector switches will be relocated to the holes vacated by the diesel generator controls. The relocation of the shutdown board backfeed switches and voltmeter switches will improve the current condition but will not bring them to within the depth criteria.

Implementation:

The Diesel Generator control switches were relocated so as to conform to the depth criteria. The Diesel Generator mode select switch, mode select switch indicating lights, shutdown board backfeed switches, voltmeter switches, and shutdown bus/board automatic to manual transfer switches were not moved. Consideration was given to their frequency of use, the impact of misoperation, and the possibility of congestion if these items were moved to the lower surface area of the panel.

HED 081 Standby Gas Treatment Controls/Indicators Not Completely Available in All Control Rooms Correction:

Standby Gas Treatment fan status and outlet flow indicators will be installed in Unit 1 and Unit 3.

Implementation:

This HED is only applicable to Units 1 and 3. However, Standby Gas Treatment fan status (Trains A, B, and C) and outlet flow indications were added to Unit 2, Panel 9-20.

ENCLOSURE (CONTINUED) Page 7of$0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 084 Operator Protective Equipment Accessibility/Use Correction:

Emergency equipment (e.g. respirators, SCBA, etc.) will be stored in the Technical Support Center. Their use and control will be integrated into the Radiological Emergency Plan (REP) implementing procedures. BFN will evaluate available communication features/design for face masks and provide them as required.

Implementation:

Emergency Plan Implementing Procedure, EPIP-17, Emergency Equipment and Supplies includes a checklist of the necessary emergency equipment. The contents of each cabinet and storage area are inventoried, inspected, and checked for operations and/or material condition each calendar quarter.

The need for additional communication equipment was evaluated and it was determined that communications have been adequate and additional equipment is not required.

ENCLOSURE (CONTINUED) Page 8 of $0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 094 Operator Rest Room Accessibility Correction:

The additional manning as per HED 3 correction satisfactorily addresses this HED.

Implementation:

Refer to HED 003.

HED 104 Paging System Problems Correction:

A plant communication system study including the paging system is being performed by Acoustical Technology, Inc.

Their recommendations will be evaluated and implemented as required.

Implementation:

A plant communications study was performed. Communications upgrades were installed, including the addition of loud speakers, horns, bells, and sirens. In addition, plant operators routinely carry vibrating pagers and two way radios to improve communications.

HED 107 Annunciators that are No Longer in Use Correction:

Alarms not in use as referenced in the HECs will be disconnected and blank windows will be installed.

Implementation:

Alarms no longer in use were disconnected and blank windows installed (PA-1-4, Auto Blowdown Relief Valves Bellows Leak, and XA-47-84, ADS Emergency Assist).

0' ENCLOSURE (CONTINUED) Pago 9 ofSO BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 108 Annunciators Label Inadequacies Correction:

Incorrect or ambiguous legends will be revised. Temporary labels will be removed. Labeling of annunciator windows will be revised to adhere to the pending BFN labeling guidelines.

Implementation:

Control room annunciators were reviewed and incorrect and/or ambiguous legends were revised. The abbreviations are in accordance with Site Standard Practice 2.2, Writing Procedures. Temporary labels were removed in accordance with Site Standard Practice 12.53, Component Labeling, Signs, and Operator Aids. Engraved window numbers were added. In addition, annunciator response procedures were issued to aid the operator in determining the proper response to alarm conditions.

HED 111 Lack of Effective Prioritization System for Annunciators Correction:

An annunciator priority coding system by colors will be implemented.

Implementation:

An annunciator priority coding system by colors was implemented:

Red Critical Amber Urgent White Operational Magenta Process Radiation Monitoring

ENCLOSURE (CONTINUED) Page 10 of $0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 113 Annunciator with Multiple Input and No Reflash; Annunciators with Non-specific Legends Correction:

An annunciator study will be performed to identify required specific changes to annunciator window legends to eliminate ambiguous wording/descriptions. New window tiles will be generated with acronyms and abbreviations and component descriptions that are consistent with the labeling program results. The annunciator study will also provide the most cost-effective means to correct the reflash capability concerns.

Implementation:

Annunciator window legends were reviewed and revised as necessary to correct ambiguous wording, descriptions, acronyms, and abbreviations. An. annunciator study was performed to identify multiple input alarms that require reflash capability. The alarms were upgraded based on this study.

HED 117 Annunciator System Controls Correction:

An annunciator study will be performed to evaluate feasibility and cost-effectiveness of adding control features such as reflash, ringback, separate silence/acknowledge/reset/test controls, directional horns, etc.

Implementation:

An annunciator study was performed to address the feasibility and cost effectiveness of adding control features such as reflash, ringback, and separate silence, acknowledge, reset and test controls. As a result, separate control of alarm silence, acknowledge, reset, and test controls were provided for Panels 9-3, 9-4, 9-5, 9-6. 9-7, 9-20, and 9-53. It was determined that separate controls would not be feasible for Panels 9-8 and 9-23. It was also determined that directional horns would not be added since this revision would not provide a sufficient cost/benefit.

y,l d

ENCLOSURE (CONTINUED) Page llof SO BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 119 Nuisance Alarms Correction:

Nuisance alarms referenced in the HECs will be evaluated and corrected either by setpoint changes or by removal of the nuisance alarms, if required.

Implementation:

"Nuisance" and "Darkboard" alarm studies were performed to evaluate the identified alarms and to evaluate other potential nuisance alarms. Problems were corrected and setpoints were changed. In addition, O-OI-55, Annunciator System, provides instructions for disabling and tracking nuisance alarms until the condition clears or other t HED corrections are made.

141 EOI Procedure Correction:

Caution step Clarification will be added to the EOI's warning that activities carried out in the plant during an emergency in accordance with the controls specified in the be Radiological Emergency Plan Implementing Procedure.

Implementation:

Emergency Plan Implementing Procedure EPIP-14, Radiological Control Procedures, states that a Radcon Technician will accompany any personnel dispatched into areas of potential radiological hazard. It was determined that any additional cautions/step in the EOI flow,chart/appendices would be redundant.

ENCLOSURE (CONTINUED) Page 12 of $ 0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 144 Chlorine Storage Leak Annunciator No Longer in Use Correction:

Alarms will be disconnected and engraved windows replaced with blank white lens.

Implementation:

No implementation was required for Unit 2. This HED applies to Unit 3 only.

HED 145 Condensate Storage Tank Alarms are Only Available on Unit 1 Correction:

CST tank level alarms will be installed in Units 2 and 3 to alert the unit operator of CST conditions that affect their unit.

Implementation:

There were two Condensate Storage Tank alarms installed in the Unit 2 control room. One for Condensate Storage Tank 2 Level Abnormal and the other for Condensate Storage Tank 2 Level Low Low or High.

HED 146 Offgas System Adsorber Vault Radiation Alarms in Unit 1 Only Correction:

The two identified alarms have been determined as not needed for system operation by an earlier evaluation independent of CRDR. These alarms will be disconnected and removed from Unit 1.

Implementation:

These alarms are not available on Unit 1. They were available on Unit 2, have been disconnected, and the annunciator windows left blank.

ENCLOSURE (CONTINUED) Pago 13 of SO BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 147 Lacking EECW Alarms for Units 2 and 3 Correction:

The North EECW Header Low Level Alarm will be installed in Units 2 and 3.

Implementation:

The EECW System is common to Units 1, 2, and 3. The north header level alarm is provided to warn the operator of excess air or gases in the north header. It was subsequently determined that EECW north header low level alarm was not required in Unit 2 for the following reasons:

1) The system is now operated using a vacuum priming system. One EECW pump per header is in continuous operation to insure that the north and south headers are charged.
2) Each control room has north and south header pressure and flow alarms and system status indications.
3) Designated system pumps are aligned and automatically start on low system pressure to preclude system voids.
4) The Unit 1 control room is continuously manned and the alarm response is adequate to insure the headers stay full and charged. Therefore, duplication of this alarm on Units 2 and 3 is not needed.

ENCLOSURE (CONTINUED) Page 14 of $0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 148 Generic Labeling Concerns (Switches, etc.)

Correction:

Labels will be revised per the pending BFN labeling guidelines to improve contrast and consistency of abbreviations and acronyms.

Implementation:

Labeling guidelines were incorporated into TVA design drawing and Site Standard Practice 12.53, Component Labeling, Signs, and Operator Aids. Guidance regarding the consistent use of abbreviations and acronyms was incorporated into Site Standard Practice 2.2, Writing Procedures. Control Room low contrast labels were replaced with labels of higher contrast. Control Room nomenclature was revised to ensure consistency in the use of abbreviation and acronyms. Low torque switch plates were replaced with plates that are easier to read.

HED 150 Keylock Switch Convention Inconsistency Correction:

Keylock switches will be modified to establish the following convention: KEY INSERTED TEETH DOWN; KEY VERTICAL OFF OR SAFE.

Implementation:

Key locks were changed so that the teeth must be down for key insertion. Key positions are 135', 90', and 45~ for three position switches and 135'nd 454 for two position switches. These positions are consistent with other switch types in the control room and are adequate for control position distinction.

ENCLOSURE (CONTINUED) Page IS of $0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 151 Keys for Keylock Switches Not Always Available Correction:

A comprehensive plant key control program is under development. This program will address the control of keylock switch keys.

Implementation:

Operations Section Instruction Letter OSIL-16, Keys, identifies and controls radiation area, security area, and miscellaneous keys maintained by the Shift Operations Supervisor. Keys needed for quick access during transients are tagged and mounted on the control panel near the associated switch. Other keys are maintained in key cabinets mounted on the Shift Operations Supervisor and Unit Operator work stations.

HED 152 Lack of Switch Handle Shape Coding Correction:

Switch handles will be shaped coded to the extent practical as follows: Oval shape for pumps/fans/motors; Pistol grip handles for throttle valves will be labeled "throttle" and will have a white band around the handle. Extent of shape coding depends on availability of replacement handles for existing switches. Intent of this correction is to aid the operator in locating devices.

Implementation:

Switch handles were shape coded to the extent practical using the following convention:

Prime Movers (e.g., pumps, fans, etc.) use the large, high torque J handle.

Valves use the small, low torque J handle.

Select switches used the knurled handles.

Throttle valves have engraved characters and tactile coding.

ENCLOSURE (CONTINUED) Page 16of$ 0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOIVI DESIGN REVIEW HED 153 Control Switch Movement Convention Inconsistency Correction:

The following switch movement convention will be implemented: Clockwise Increase/Meter movement to right; Counterclockwise Decrease/Meter movement to left.

Implementation:

Switch position, movement, or associated indicator lights were replaced or moved and labeled, as appropriate, to make switch movements meet convention or match indicator light positions.

HED 155 Outboard MSIV Handswitch Location May Cause Misoperation Correction:

The system will be demarcated and hierarchically labeled.

In addition, the IIRedlt MSIV hand switches will be color coded Implementation:

MSIV switches were demarcated with color patching and hierarchical labels added. The switch handles were changed to red.

HED 156 Drywell Compressor/Air System Lights and Switches Not Grouped Correction:

Switches and indicators will be relocated from Panel 9-20 and Panel 9-6 to Panel 9-3 for functional grouping.

Implementation:

Switches and indicators were relocated from Panel 9-20 and Panel 9-6 to Panel 9-3 for functional grouping.

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CONTROL ROOM DESIGN REVIEW HED 157 Potential Inadvertent Controls Actuation on Panel 9-23 Due to Unit 3 Personnel Access Correction:

Traffic will be routed away from Panel 9-23 (Unit 3) via the use of a physical barrier (i.e. chains).

Implementation:

No implementation was required for Unit 2. This HED applies to Unit 3 only.

HED 158 Legend Push Buttons are Not Distinguished from Legend Indicators Correction:

Legend status lights will be coded per the BFN labeling standard to differentiate them from legend push buttons.

Implementation:

The identified legend status lights were coded using cross-hatched transparencies behind the legend push button lens.

ENCLOSURE (CONTINUED) Page 18 of SO BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 159 Lack of Operating Band Identification on Instruments Correction:

Evaluation of control room indicators will be performed to determine the need for banding on a case-by-case basis.

Color coding of operational bands will be used. Typical color coding is as follows: Green-normal; Yellow-Caution; Red-Danger; and Blue-Setpoints for auto-initiation.

Implementation:

Color banding was performed on selected meters, typically using the following convention:

Green Normal operating range Yellow Caution (starting at an alarms setpoint or operational limit)

Red Danger (starting at an initiation setpoint)

Unit 2 recorders were replaced with microprocessor based units having digital display and bargraph meters that do not support color banding.

HED 160 Generic Labeling Concerns (Displays and Status Panels)

Correction:

Labels will be revised per the pending BFN labeling guidelines to improve contrast and consistency of abbreviations and acronyms.

Implementation:

Guidelines were developed for labeling issues, such as color contrast, letter size, abbreviations and acronyms, label content (functional descriptions and information), label location, and meter/recorder scales. These guidelines were incorporated into design documents and plant procedures.

Control room labels for status panels and displays were revised or added, as practical, to correct partial, missing or incorrect labels.

ENCLOSURE (CONTINUED) Page l9of$0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 161 Missing/Unclear Labeling for Displays Correction:

Revision will be made to difficult-to-read or ambiguous meter/recorder scales and labels, and missing scales and labels will be added.

Implementation:

Guidelines for labeling issues, such as color contrast, letter size, abbreviations and acronyms, label content (functional descriptions and information), label location, and meter/recorder scales. These guidelines were incorporated into design documents and plant procedures.

Difficult to read, missing and ambiguous scales were replaced, added, or instruments were changed to correct these deficiencies.

Correction:

Labeling will be revised to correct misleading labels.

Implementation:

Controller labels were reviewed for possible misleading labels and corrections were implemented.

ENCLOSURE (CONTINUED) Page 20 of $0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 165 Main Control Room Control Bay HVAC Concerns Correction:

HVAC capacity will be evaluated and increased as required.

ECN P0697 is being implemented for that purpose. Automatic controls will be provided and adjusted such that a balanced, comfortable environment will result.

Implementation:

The adequacy of the Control Bay HVAC system was evaluated for both normal and post-Loss of Coolant Accident conditions. The capacity of the system, associated ducting, and its controls were upgraded. The system is now designed to automatically maintain control bay areas with comfort limits during normal operations and within design limits during abnormal events.

Correction:

Ineffective multi-point recorders will be replaced with recorders having the following desired features: easy identification of point being scanned; improved printing; capability to delete disabled or invalid points from scan; and auto tracking (lock in) of point(s) in alarm. Selection of commercially available multi-point recorders as replacements will be based on the above criteria. Priority for replacement will be based on each recorder's function.

Implementation:

Multi-point recorders were replaced with microprocessor based units. The new recorders provide, or can be programmed to provide, easy identification of the point being scanned, improved printing, the capability to delete or skip disabled or invalid points, and the ability to lock-in points in alarm.

ENCLOSURE (CONTINUED) Page 21 of $0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 179 Inconsistent Indicator/Status Light Color Code Correction:

Replace indicator and status light bulbs, lens, caps as needed to conform to established convention for color coding.

Implementation:

A guideline for color coding was established. Indicators and status light lens covers were replaced, as required.

HED 180 Ineffective Use of Color Coding of Switch Handles for System Demarcation Purposes Correction:

Switch handle color will be made black in general. System demarcation by permanent demarcation lines will be used.

Use of color switch handles will be on a selected basis when system demarcation and functional grouping by themselves do not provide sufficient/effective distinction.

Implementation:

Switch handles have been changed to black, with the exception of the Main Steam Isolation Valves, which are red (Also refer to HED 155).

ENCLOSURE (CONTINUED) Page 22 oj'$0 BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 182 Inconsistency of Recorder Pen Color Assignments Correction:

Convention will be established and implemented for assignment of color pens.

Implementation:

The following convention was established for small case recorder pen assignments:

Channel A Red pen, (For example: Inlet conditions, flow, and temperature)

Outlet t

Channel B Green pen, (For example:

conditions, pressure, and level)

HED 184 Reactor Vessel Temperature Recorder Precision Concerns Correction:

Recorder precision required for performance of procedure can be satisfied by the use of trend recorder and process computer console digital indicator. Operations will be trained on this aspect.

Implementation:

Reactor vessel temperature recorders 2-TR-68-2 and 2-TR-68-37 have been replaced with recorders that have digital value displays, enabling the operator to have adequate preci'sion for his procedural requirements.

ENCLOSURE (CONTINUED) Paga 23 ofSO BROWNS FERRY NUCLEAR PLANT (BFN)

CONTROL ROOM DESIGN REVIEW HED 185 Diesel Generator Cooling Water Temperature Indicator Lights Used as Annunciators Correction:

Annunciator window with reflash capability will be added to 9-20 on Unit 3. This annunciator in conjunction with the status lights will alert operator to cooling water of D/G cooling problems.

Implementation:

No implementation was required for Unit,2. This HED applies to Unit 3 only.

HED 188 Panel 9-47 Recorders Location Concerns Correction:

Critical points presently recorded on Panel 9-47 recorders will be input to the new plant computer. A format for suitable display of information (i.e. alarms, trending, etc.) to the operator will be developed on the new process computer.

Implementation:

Points recorded, on Panel 9-47 recorders, are input to the new plant computer and suitably displayed.

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CONTROL ROOM DESIGN REVIEW HED 189 PCIS Status Difficult for Operator to Determine Correction:

PCIS Group Status lights will be installed on Panel 9-3.

EOI Appendix will include tabulation of PCIS groups/valves.

Label will be added to Panel 9-3 containment mimic tabulating PCIS groups. All PCIS control valves on control panels will be provided with unique labels. Containment mimic labels will identify PCIS groups.

Implementation:

A new Containment Isolation Status System was added to Panel 9-4. Panel 9-3 was not used due to a lack of space.

The PCIS control valves are identified with a special label, denoting the valve's PCIS group. The containment mimic valve symbols contain the associated group number on each valve symbol.

Revision 3 of the Emergency Operating Instructions included a tabulation of Primary Containment Isolation System (PCIS) valves as an appendix. This appendix was deleted as part of Revision 4 since the number of verifications were reduced to Groups 1, 2 and 3. These verifications can be performed using the new status system.

HED 190 Group 6 Primary Containment Isolation Status on Panels 9-54 and 9-55 is Not Based on Actual Valve Status Correction:

Present PCIS Group 6 valves indications on Panel 9-54 and 9-55 are valve power supply lights. They will be evaluated for adequacy to provide indirect indication of PCIS Group 6 status. Direct valve position will be provided for these valves in the Main Control Room evaluation results.

if dictated by engineering Implementation:

The issue of primary containment isolation valve position indication was addressed under Regulatory Guide 1.97. TVA's justification for not providing containment isolation valve position indication for the HzOz monitoring system was submitted by TVA letter to NRC, dated May 7, 1985. NRC approved this deviation in its February 8, 1990 letter.

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CONTROL ROOM DESIGN REVIEW HED 191 Inadequate Standby Gas Treatment and Reactor Building Ventilation Indication on Front Panels Correction:

Standby Gas Treatment fan status and outlet flow indicators will be installed in Unit 1 (visible to Unit 1 and Unit 2 Reactor Operator) and Unit 3.

Implementation:

Standby Gas Treatment fan status (Trains A, B, and C) and outlet flow indications were added to Unit 2, Panel 9-20.

HED 192 EOI-related Reactor Level Instruments Concerns Correction:

A hot-calibrated and a cold-calibrated digital, wide-range reactor water level instrument will be installed. Yarway gauges on Panels 9-3 and 9-5 have been replaced by gauges with better precision.

Implementation:

In response to NUREG-0737 (TMI Action Plan), Item II.F.2 Instrumentation for Detection of Inadequate Core Cooling, and Generic Letter 84-23, Inadequate Core Cooling Instrumentation, TVA previously rerouted the reactor water level reference legs to minimize the routing of the reference legs inside the drywell. This eliminated the need for both hot and cold calibrated reactor water level nomenclature. Two new digital level indicators were added to Panel 9-5.

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CONTROL ROOM DESIGN REVIEW HED 193 EOI-related Reactor Level Instrument Concerns Correction:

Same as HED 192:

Implementation:

Same as HED 192.

HED 194 - EOI-related Reactor Pressure Instruments Concerns Correction:

A digital pressure instrument will be installed.

Implementation:

A wide range digital meter was installed to monitor reactor pressure.

HED 196 HzOz Sample Valve Handswitch Position Not Precisely Labeled Correction:

Hand switches with switch position labeled "normal" will be evaluated to determine the meaning of "normal". Where "Normal" means on/off, open/closed, the label will be revised to reflect the actual meaning. Where "Normal" means there is an automatic system function associated with the component, a label of "Auto" will be added.

Implementation:

The H>O> Sample Valve handswitch plate was labeled "CLOSE" instead of "NORMAL". Other switch plates were changed to ensure consistent use for "NORMAL" position. Normal is no longer used to denote open, close, or automatic system function.

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CONTROL ROOM DESIGN REVIEW HED 199 EOI-related Torus Level Instrument Concern Correction:

Requirement to read torus level at .25" increments will be evaluated. Procedure or instrument will be changed accordingly. LI-64-54A and LI-64-66 will be provided identical scales.

Implementation:

The EOIs were revised to reflect controlling suppression pool level between -1 and -6 inches, which is easily determined from LI-64-54A and LI-64-66. LI-64-54A and LI-64-66 were replaced with new meters with duplicate t

scales.

HED 200 Lack of Automatic Depressurization System Logic Inhibit Feature in Main Control Room Correction:

ADS logic inhibit switches will be installed.

Implementation:

ADS logic inhibit switches were installed in response to TMI Action Item II.K.3.18. TVA notified NRC of the completion of this item in its January 18, 1991 letter. Verification of the completion of this item was included in Inspection Report 91-16, dated June 5, 1991.

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CONTROL ROOM DESIGN REVIEW HED 201 EOI-related Drywell Pressure Instrument Concerns Correction:

Required torus pressure instruments will be expanded to 0-60 psig range. Psia gauges will be converted to psig gauges. Scales will be revised or marked to enable the operator to read 2.45 psig.

Implementation:

During the Unit 2 Cycle 5 outage, TVA revised the drywell pressure gauge from a 0 40 psig range to a 0 60 psig range. During the Unit 2 Cycle 6 outage, the remaining drywell pressure gauges were converted from psia to psig and the scales revised to enable the operator to read 2.45 psig.

HED 203 EOI-related Drywell Temperature Instrument Concerns Correction:

Procedures have been changed to address the precision concern.

Implementation:

Requirements in the EOIs to read 212'F and 281'F were changed to 200'F and 280'F, respectively.

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CONTROL ROOM DESIGN REVIEW HED 204 EOI Training Reactor Water Cleanup System Correction:

This was determined to be an invalid HED during the corrective action development phase. No correction is required.

Implementation:

In addition,'t was determined that Operating Instruction 2-OI-69 provides for the return to service of the Reactor Water Cleanup System following an isolation. In addition, EOI Appendix 11E, Alternate RPV Pressure Control Systems RWCU System Recirc/Blowdown, addresses placing the Reactor Water Cleanup System in the Recirculation mode for t HED alternate reactor pressure vessel pressure control.

205 Inconsistent Correction:

The reason only) will be consistent.

Instrumentation Between Units for the inconsistency (i.e. PI-64-39 in Unit determined and the units will be made 1

Implementation:

Drywell pressure information is adequately provided on Unit 2 and no additional Unit 2 action was required.

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CONTROL ROOM DESIGN REVIEW HED 206 EOI-related Torus Level Instrument Concerns Correction:

EOIs have been changed to address the torus level instrument precision concern.

Implementation:

A requirement for Suppression Pool Level in EOI-2 was revised from 17 feet 2 inches to 18 feet, which is more readily determined from LI-64-159A. Another requirement for Suppression Pool Level in EOI-2 was revised from 20 feet to at or above 18 feet. Additionally, EOI Appendix 9 provides alternate means for determining Suppression Pool Level when the level exceeds 18 feet.

HED 207 EOI-related Drywell Temperature Instrument Range Concerns Correction:

EOIs have been changed to address instrument precision concern.

Implementation:

The concern was that the "RX SATURATION TEMP" chart had a temperature axis of 200 550 4F while the range of the instrument used to measure this value was 0 400 F. The name for this chart was changed to "RPV SATURATION TEMP" and the axis was changed to 200 400 'F.

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CONTROL ROOM DESIGN REVIEW HED 208 Hot Rod Scrams Correction:

Control rod pull sheet will be redesigned to provide a consistent method of identifying hot rods for both Engineering and Operations.

Implementation:

<<Hot rods" are no longer used in the same manner for changes in criticality. The current startup procedures incorporate the Reduced Notch Worth Procedure (RNWP) and Banked Position Withdrawal Sequence (BPWS) recommended by General Electric in Service Information Letter 316. The BPWS prevents excessive fuel pellet enthalpy during the worst case control rod drop accident. The RNWP is used during startup to prevent high notch worth that might result in short period scrams.

HED 209 DC Lighting Concern Correction:

A DC lighting survey will be performed to evaluate lighting condition. Correction to lighting system will be made to ensure minimum light levels are obtained and shadows are not a problem due to placement of lamps behind operator.

Implementation:

DC light illumination levels were evaluated and approved.

Lights are now directed toward control panels instead of across the room (behind the operator). This reduces the affects of shadows.

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CONTROL ROOM DESIGN REVIEW HED 210 Lack of Offgas Isolation Indication Within Horseshoe Area Correction:

An offgas isolation valve closure annunciator will be installed on Panel 9-8 or 9-53.

Implementation:

An offgas isolation valve (FCV-66-28) "closed" alarm was installed on Panel 9-7.

HED 213 Placement of Labels Correction:

(I Use of hierarchical labeling and label placement will be implemented per the pending BFN labeling guidelines to facilitate easier viewing.

Implementation:

Guidelines were developed for labeling issues, such as color contrast, letter size, abbreviations and acronyms, label content (functional descriptions and information), label location, and meter/recorder scales. These guidelines were incorporated into design documents and plant procedures.

Label changes were implemented.

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CONTROL ROOM DESIGN REVIEW HED 214 Labels Letter Sizes Correction:

Labels will be revised or added to obtain consistent abbreviations and acronyms, label size, contrast and font as per the pending BFN labeling guidelines.

Implementation:

Guidelines were developed for labeling issues, such as color contrast, letter size, abbreviations and acronyms, label content (functional descriptions and information), label location, and meter/recorder scales. These guidelines were incorporated into design documents and plant procedures.

t Label changes were implemented.

HED 215 Labels Functional Description Correction:

Functional descriptions on labels will be verified. Labels will be revised as required to obtain consistent abbreviations or acronyms.

Implementation:

Guidelines were developed for labeling issues, such as color contrast, letter size, abbreviations and acronyms, label content (functional descriptions and information), label location, and meter/recorder scales. These guidelines were incorporated into design documents and plant procedures.

Label functional descriptions and consistency in abbreviations and acronyms were implemented.

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CONTROL ROOM DESIGN REVIEW HED 216 Temporary Labels Correction:

All existing temporary labels will be removed.

Administrative controls will be initiated to control use, removal, and installation of temporary labels.

Implementation:

The temporary labels were removed from the control room panels and the backup control room panel. Site Standard Practice 12.53, Component Labeling, Signs and Operator Aids, was implemented to control placement and quality of labels, signs, and operator aids.

HED 218 Mimic and Demarcation Convention Correction:

Permanent demarcation and mimic lines will be installed on control boards. Characteristics for demarcation and mimic lines will be as described by the pending BFN labeling guidelines.

Implementation:

Demarcation and mimic lines were installed on the Main Control Room panels and backup control panel.

Characteristics for demarcation and mimic lines are described in the panel layout drawings.

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CONTROL ROOM DESIGN REVIEW HED 220 Operator/Computer Dialogue Correction:

Abbreviations and descriptions used by computer will be revised to be consistent with BFN standard abbreviations and acronyms.

Implementation:

The new Integrated Computer System uses the standard acronyms and abbreviations specified in Appendix H of Site Standard Practice 2.2, Writing Procedures.

HED 225 Panel 9-5 Poor Reactor Level Gauge Location Correction:

Digital level and pressure indicators will be installed on Panel 9-5.

Implementation:

Digital level and pressure indicators were installed on Panel 9-5.

HED 237 Fire Protection Controls Not Grouped Correction:

HS-26-98 and HS-26-104 (sprinkler switches) will be moved to Panel 9-20 from 9-2 (Unit 1 only) and grouped with other fire protection controls.

Implementation:

No implementation was required for Unit 2. This HED applies to Unit 1 only.

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CONTROL ROOM DESIGN REVIEW HED 238 Lack of Functional Grouping, Demarcation, Color Coding Panel 9-3 Correction:

Switches for the HPCI, RCIC, CS, RHR, RHRSW, Containment, and MS Drain Systems will be rearranged to enhance functional grouping and reduce the complexity of flow path mimics. Flow paths will generally be top to bottom and left to right. Hierarchial labeling and system demarcation will be implemented.

Implementation:

The switches for the High Pressure Coolant Injection, Reactor Core Isolation Cooling, Core Spray, Residual Heat Removal, Residual Heat Removal Service Water, Containment Ventilation, and Main Steam Drain Systems were functionally grouped, demarcated, and labeled. Reducing the complexity of flow path mimics took precedence over the top to bottom and left to right convention.

HED 239 Panel 9-4 Layout Confusing Correction:

Switches for fuel pool cooling, reactor water cleanup, and drywell sump systems will be rearranged to provide functional grouping and to conform to left-right and top-down flow conventions as much as possible. System and subsystems will be demarcated and hierarchically labeled.

Implementation:

Switches for fuel pool cooling, reactor water cleanup, and drywell sump systems were rearranged to provide functional grouping and to conform to left-right and top-down flow conventions, as desired. System and subsystems were demarcated and hierarchically labeled.

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CONTROL ROOM DESIGN REVIEW HED 240 Panel 9-5 Lack of Demarcation Correction:

Switches for CRD system will be rearranged to conform to left-right and top-down flow conventions as much as possible. Systems and subsystems will be demarcated and hierarchically labeled.

Implementation:

Switches for the CRD system were rearranged to improve system grouping and conform to left-right and top-down flow conventions, as much as practical. Systems and subsystems were demarcated and hierarchically labeled.

HED 241 Panel 9-6 Layout Confusing Correction:

Switches for Feedwater, Condensate, and Extraction Steam systems will be rearranged to provide functional grouping and to conform to left-right and top-down flow conventions as much as possible. Systems and subsystems will be demarcated and hierarchically labeled. Drywell pressure control switches and indicators will be moved to 9-3 (same as HED 156 correction).

Implementation:

Switches for the Feedwater, Condensate, and Extraction Steam systems were rearranged to provide functional grouping and to conform to left-right and top-down flow conventions, as much as practical. Systems and subsystems were demarcated and hierarchically labeled. Drywell pressure control switches and indicators were moved to Panel 9-3.

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CONTROL ROOM DESIGN REVIEW HED 242 Panel 9-7 Layout Confusing Correction:

Switches for Main Steam, Heater Drains/Vents, and EHC systems will be rearranged to conform to left-right and top-down flow conventions as much as possible. Systems and subsystems will be demarcated and hierarchically labeled.

Implementation:

Switches for the Main Steam, Heater Drains/Vents, and EHC systems were rearranged to conform to left-right and top-down flow conventions, as much as practical. Systems and subsystems were demarcated and hierarchically labeled.

HED 243 Panel 9-8 Layout Confusing Correction:

Offgas system switches will be rearranged to conform to left-right and top-down flow conventions as much as possible. System and subsystems will be demarcated and hierarchically labeled.

Implementation:

Offgas system switches were rearranged to conform to left-right and top-down flow conventions, as much as possible. System and subsystems were demarcated and hierarchically labeled.

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CONTROL ROOM DESIGN REVIEW HED 248 Panel 9-20 Poor Grouping, Demarcation, Confusing Layout Correction:

Condensate storage tank controls and indications will be relocated to the blank panel next to 9-20 (Unit 1) to alleviate congestion on 9-20. With additional space made available, switches for CCW, RCW, EECW, Service Water, Fire Protection systems will be rearranged to enhance functional grouping. Hierarchial labeling and system demarcation will be implemented.

Implementation:

Unit 2 Condensate Storage Tank indications were added to Panel 9-6. Controls and indications for the Condenser Cooling Water, Raw Cooling Water, Emergency Equipment Cooling Water, Service Water, Control Air, and Fire Protection Systems were relocated to enhance functional grouping.

HED 250 Electrical Board (9-23) Mimic Lines Confusing; Diesel Generator Displays Not Demarcated Correction:

Hierarchical labeling and functional demarcation will be used. Additional synchroscope(s) will be added for Unit 3 Diesel Generators or the existing one will be mounted on a swivel base to facilitate operator viewing.

Implementation:

The diesel generator panel was revised to improve display and control layout, functional demarcation, and labeling.

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CONTROL ROOM DESIGN REVIEW HED 251 Panel 9-25 Layout. Confusing Correction:

Switches for Reactor Building Ventilation and Drywell Ventilation System and Standby Gas Treatment instruments will be rearranged to conform to left-right and top-down flow conventions as much as possible. Systems and subsystems will be demarcated and hierarchically labeled.

Implementation:

Switches for the Reactor Building and Drywell Ventilation Systems and the Standby Gas Treatment instruments were rearranged to conform to flow conventions. The systems and subsystems were demarcated and hierarchically labeled.

HED 253 Offgas System (Panel 9-53) Layout and Mimic Confusing Correction:

System switches will be rearranged to conform to left-right and top-down flow conventions as much as possible and to enhance the ease of mimic. Subsystems will be demarcated and hierarchically labeled.

Implementation:

System switches were rearranged to conform to left-right and top-down flow conventions. Improved mimics, demarcations and hierarchical labels were added to enhance system comprehension.

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CONTROL ROOM DESIGN REVIEW HED 259 Drywell and Torus Displays and Controls Not Functionally Grouped Correction:

Affected control and indicators will be rearranged on Panel 9-3 for functional grouping. Affected switches and displays from 9-6 will be moved to 9-3 (this is also addressed by HED 156 correction).

Implementation:

The affected control and indicators were rearranged on Panel 9-3 for functional grouping. Drywell compressor switches and drywell pressure instrumentation were moved from Panel 9-6 to Panel 9-3.

HED 267 Cooling Tower Temperature Monitoring System Not Used Correction:

Instrument will be removed from panel and cover provided over the hole.

Implementation:

The instrument was removed from the panel and a cover was provided over the hole.

HED 268 Suppression Chamber Water Temperature Transfer Switch No Longer Being Used Correction:

Suppression chamber water temperature transfer switch will be removed from Unit 2, Panel 25-32 and cover provided over the hole.

Implementation:

The suppression chamber water temperature transfer switch was removed from the panel and a flush plate was provided over the hole.

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CONTROL ROOM DESIGN REVIEW HED 271 Procedure Concerns Correction:

~ Operator training of EOIs will include understanding the basis of the EOIs.

Implementation:

The bases for the EOIs are taught in initial and requalification training.

Correction:

~ The present system of using required monthly operator reading as the mechanism to convey procedure revision information will be evaluated and changed as required to increase the effectiveness of conveying procedure revision information to the operator.

Implementation:

BFTI-410.01, Operator Required Reading Program, addresses the timely review of procedure changes.

Classroom time is scheduled during requalification training to review these changes.

Correction:

~ An index will be provided in each volume (book) located in the Main Control Room.

Implementation:

Operating Instructions were separated into one volume per instruction to eliminate confusion as to which procedures were in what volume. For other plant procedures, the first volume in the series contains the index. Each volume in the series has information in the spine relating to the type of procedure and which procedures are contained in that volume.

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CONTROL ROOM DESIGN REVIEW HED 272 Procedure Revisions/Plant Modification Training Concerns Correction:

BFN Standard Practice 8.3 will be implemented. Per this standard practice, Training is notified of all modifications and will identify training requirements. Procedure revision training is accomplished via the required reading training mechanism.

Implementation:

Site Standard Practice 9.3, Plant Modification and Design Change Control, prescribes the review and evaluation of modifications for impact on procedures and training. Site Standard Practice 12.1, Conduct of Operation, describes the requirements and responsibilities for required reading.

Selected plant modifications are included as part of operator requalification classroom training and on the simulator, where applicable.

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CONTROL ROOM DESIGN REVIEW HED 273 PCIS Reset Status Correction:

A caution step will be provided in Surveillance Instruction 4.1.A-10 to warn operators of possible consequences if MSIV power available lights in Aux.

Instrument Room are not checked during surveillance test.

Implementation:

Surveillance Instruction 4.1.A-10 was superseded by two other Surveillance Instructions; 2-SI-4.1.B-10(A), Main Steam Line Radiation Monitor Channel Alignment and Functional Test 2-RM-90-136 (Channel A) and 2-SI-4.1.B-10(B), Main Steam Line Radiation Monitor Channel Alignment and Functional Test 2-RM-90-136 (Channel B) . Each Surveillance Instruction has a sign off for verification that the Reactor Protection System and Primary Containment Isolation System indicating lights are illuminated prior to performing the surveillance. Each Surveillance Instruction contains a precaution that states that this test should be completed prior to performing a calibration of any other Main Steam Line radiation monitor in order to prevent a scram. Prerequisites for the Surveillance Instructions include verifying that no other tests or maintenance are in progress that could provide a half scram or containment isolation signals.

HED 275 No Visual Relief From Arrays of Instrumentation Correction:

No specific fix. Individual demarcation fixes for all control room panels will alleviate the concern of this HED.

Implementation:

Demarcation and color patching was provided for the control room panels. The changes implemented for each panel relocated components provided additional vi'sual relief from arrays of instrumentation.

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CONTROL ROOM DESIGN REVIEW HED 280 Diesel Generator Trip Due to Misalignment of Mode Switch Correction:

Cautionary label will be added.

Implementation:

Instead of a cautionary label, Operating Instruction O-OI-82, Standby Diesel Generator System, was revised to include the following caution statement:

Failure of the PARALLEL SYSTEM light to illuminate in the following step could indicate that the DG is still in SINGLE UNIT operation and result in overload when t HED 282 the DG output breaker is closed.

Steam Packing Exhauster Blower and Discharge Valve Do Not Operate Per Drawings Correction:

Maintenance will investigate discrepancy. The functional design of controls will be incorporated into the operator training program.

Implementation:

No discrepancies between system function and logic were identified. Operating Instruction 2-0I-47C, Seal Steam System, was revised to include operational instructions.

HED 284 Control Bay Ventilation Annunciator that Affects All Units But Only Alarms in Unit 1 Correction:

Annunciator for Control Ventilation Isolation will be installed on Unit 2 and Unit 3.

Implementation:

Control room high radiation isolation and control room isolation radiation monitor downscale or inoperable alarms were added to Panel 9-6B in the control room.

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CONTROL ROOM DESIGN REVIEW HED 288 EOI-related Reactor Water Level Instrument Concerns Correction:

This issue is covered by HEDs 192, 296, and 297.

Implementation:

Two digital reactor water level instruments were provided on Panel 9-5. These digital level indicators parallel the Emergency Range Indicators and have a range of -155 to +60 inches with a resolution of 0.1 inches.

HED 289 EOI-related Steam Tunnel Temperature Instrument Concerns Correction:

The instrument setpoint will be marked on the meter.

Implementation:

The steam tunnel temperature indicator was replaced with an indicator that alarms when the high temperature setpoint is exceeded. The temperature is indicated in both analog and digital format.

HED 291 Main Steam Acoustic Monitor Power Indication Is Not Clearly Labeled Correction:

The power switch positions will be clearly labeled.

Implementation:

The power switch positions were labeled "ON" and "OFF".

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CONTROL ROOM DESIGN REVIEW HED 293 Drywell Temperature and Pressure Recorder has Poor Scales for Readability Correction:

Scales will be replaced with ones that have conventional divisions and markings. Psig will be used instead of psia for pressure.

Imp lementat ion:

The drywell temperature and pressure recorders were replaced with recorders that have digital displays. The units for the pressure indicator were changed from 0 80 psia to

-15 to +65 psig. The change in units was reflected in proposed Technical Specification Amendment No. 327, dated August 25, 1992, which was approved on April 22, 1993.

HED 296 EOI/Regulatory Guide 1.97 Integration Concerns Correction:

This is outside the scope of will evaluate and implement additional integration, if TVA DCRDR.

required.

Implementation:

TVA's August 22, 1991 described the formal process for coordinating the CRDR program with the Safety Parameter Display System and Regulatory Guide 1.97 modifications. The NRC closed this CRDR program requirement in their October 29, 1991 Safety Evaluation. Design Procedure PI 89-06 requires a human factors review of designs that could impact the control room operator. Site Standard Practice 9.3 requires operations and training departmental coordination during each phase of design package development.

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CONTROL ROOM DESIGN REVIEW HED 297 Integration of DCRDR with Control Room Modifications Correction:

This is outside the scope of will evaluate and implement additional integration, if TVA DCRDR.

required.

Implementation:

TVA's August 22, 1991 described the formal process for coordinating the CRDR program with the Safety Parameter Display System and Regulatory Guide 1.97 modifications. The NRC closed this CRDR program requirement in their October 29, 1991 Safety Evaluation. The EOI Program Manual states that qualified Post-Accident Monitoring instrument utilized as much as practical and that the t

should be operator should observe as many of the multiple readouts as practical for verification of the values being observed.

HED 302 EOI-3 Procedure Entry Condition Correction: "

The difference between setpoints and procedure values will be analyzed. Setpoints or procedure will be revised to correct problem as needed.

Implementation:

The entry conditions for EOI-3, from Secondary Containment area temperatures exceeding maximum normal values, has been established at the alarm setpoints.

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CONTROL ROOM DESIGN REVIEW HED 305 EOI-3 Tabulation of Area Radiation Levels Correction:

The difference between normal and safe setpoints will be evaluated. Procedures will be revised to correct problem.

Implementation:

The maximum normal value for the Transverse In-core Probe Room was revised to match the alarm setpoint. Conditions that may cause entry into EOI-3 must be evaluated by the SRO on a case by case basis. Entry and exit from EOI-3 is based on the actual unit conditions.

HED 306 Tabulation of Maximum Safe Operating Water Levels (EOI-3)

Correction:

Permanent markings will be provided locally to indicate maximum safe operating water levels.

Implementation:

Permanent scales were painted on two Reactor Building walls, at Elevation 519, to indicate the maximum safe operating water levels. These markings are viewable from the stairwells.

Corrective action excerpted from TVA's November 9, 1988 letter to NRC.

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CONTROL ROOM DESIGN REVIEW HED 308 TI-75-69B Scale Range Does Not Support EOI-3 Parameters Correction:

difference between setpoint. and procedure value will be

'he evaluated. Deficiency will be corrected by instrument modification and/or procedure revision.

Implementation:

The table in EOI-3, which contains the maximum normal operating temperatures for Secondary Containment Temperatures, now corresponds to the scale provided for the applicable temperature instruments.

HED 311 EOI-1, Appendix 12 Procedure Clarification Correction: "

The EOI setpoint will be evaluated. If valid, indication will be added to the Main Control procedure will be revised.

Room, if not, the Implementation:

The setpoint was evaluated and it was determined that the caution for monitoring the RBCCW outlet temperature could be removed. Operating Instruction 2-OI-69 and EOI Appendix 12 were revised to remove this caution.

Corrective action excerpted from TVA's November 9, 1988 letter to NRC.