ML20100N143
| ML20100N143 | |
| Person / Time | |
|---|---|
| Site: | Limerick |
| Issue date: | 04/12/1985 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| CON-#285-578 OL, NUDOCS 8504180377 | |
| Download: ML20100N143 (14) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 1215) 841-4 5o 2 VIC E fR ESID E NT Emeseste nene ano massancee
-Mr. A. Schwencer, Chief Docket No.: 50-352 Licensing Branch No. 2 50-353 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 FOL No.: NPF-27 APR 121985
SUBJECT:
Limerick Generating Station Control Room Design Review
REFERENCES:
- 1) Letter, D. G. Eisenhut to E. G. Bauer, Jr.
dated October 26, 1984
- 2) Letter, J. S. Kemper to A. Schwencer, dated April 4, 1985
- 3) Teleconference between Leo Beltracchi of the NRC and T. J. Cabrey and D. F. Ciarlone of PECo dated April 9, 1985 on the same subject.
- 4) Letter, J. S. Kemper to A. Schwencer, dated November 2, 1984 FILE:
GOVT 1-1 (NRC)
The purpose of this letter is to provide the information required to close Limerick License Condition 2.C.8(a) part 2, as contained in the reference 1 letter, and to complete the information submitted in our reference 2 letter.
LIMERICK LICENSE CONDITIONS 2.C. (8) (a) DETAILED CONTROL ROOM DESIGN REVIEW Part 2: Control Room Survey The licensee shall satisfactorily complete the control room survey, evaluate all human engineerina discrepancies defined by the survey, including those ' defined by the staff's audit team during the In-Progress Audit, and correct human engineering
. discrepancies which have been categorized as Priority 1 (High Safety Significance) prior to operation at a power level greater than five percent of rated power.
The results from the effort are to be documented in an addendum to the Final Report and submitted for staff review.
hph 8504180377 850412 PDR ADOCK 05000352
Response
F PDR
,y The control' room survey is complete with the exception of the review of the Safety Parameter Display System (SPDS) which is not operational at this time. The delay in the completion of this part of the survey is acceptable for the following reasons:
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1
. 1)
The SPDS itself will not be operable until its validation and testing program is complete.
2)
General Electric, the system designer of the SPDS, has hired a human factors consultant to assist in the man-machine interface development. The NRC has performed a Design Verification Audit of the General Electric design effort and reported the results of their review in Supplement No. 3 of the Limerick SER. (Section 18.2.5) 3)
During the Limerick CRDR validation effort a hardcopy of the SPDS displays were used to verify their coordination with the CRDR.
Based on the above, there is a very low probability that the completion of the SPDS survey will identify any priority 1 or priority 2 human engineering discrepancies (HEDs).
A human factors survey of the SPDS will be performed prior to the turnover of the SPC3 to Limerick for use. by the control room operators.
This survey will use the applicable portions of the BWR Owners' Group Control Room Survey Checklist. The portions of the survey used will include a review of the SPDS keyboard and CRT displays, (Computer console sections.-D1 & SDl, Computer capability sectior.s-D2 & SD2, and Computer CRT sections-D3 & SD3 of the BWR Owners' Group Checklist).
. All the other items that are part of this License condition (i.e., all HEDs assessed for safety impact and/or corrected prior to exceeding 5% power) have been completed.
All HEDsi identified have been corrected or assessed with no new priority 1 HEDs.
This includes the 8 NRC Audit Team HEDs which were discussed in the reference 2 letter and is further discussed below in the response to item 1 of the request for additional information.
REQUEST FOR ADDITION INFORMATION Item #1 - Control Room Survey The licensee shall assess and report on the results of the essessment of all of the HEDs defined by the NRC Audit Team during the In-Progress Audit.
gsponse:
The CRDR review team has assessed the 8 open NRC Audit Team HEDs (see reference 2).
This assessment identified no priority 1 (high safety significance) HEDs and only one priority 2 (low safety significance) !!ED. - This priority 2 HED ' (NPl-01) was identified during construction and was corrected prior to system turnover.
The remaining seven.HEDs were all assessed as priority 4 (no safety significance or reliability concern).
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-. The HED. assessment ' sheets for these 8 HEDs are enclosed in
' attachment #1.
-Item #3 - Assessment of HED's, Re-assessment of HED SPV-07 I.
The licensee shall report results on the reassessment of HED SPV-07.
j
Response
l L
The correction.of HED SPV-07 (T-200 Series Procedures) has been l
completed.. All T-200 series procedures have been revised and approved by-the Plant Operations Review Committee (PORC) to properly: reflect the enhanced hierarchical labeled control room.
Item #5: Coordination of NUREG-0737 Supplement 1 items.
l During the reference 3 teleconference the NRC requested f-additional information on the coordination of the NUREG-0737 I
Supplement 1 items. These include the following:
.l.
. Emergency Operating Procedures 2.
Accident Monitoring Instrumentation - R.G.-l.97 3.-
Safety Parameter Display System (SPDS)
-4.
Emergency Response Facilities 5.
Detailed Control Room Design Review
= Response:
During the final validation' effort the coordination of the above i
systems / facilities was completed. 'The actual' validation was a l
. walkthrough/talkthrough -. of the Emergency Operating Procedures j
using hardcopy' displays for SPDS on'a full-scale enhanced mockup of the Limerick unit #1 control room. This walkthrough/talkthrough l
identified areas where a. control room operator would require p
. comununicationc-with the Emergency Response. Facilities-and the i
operator.discribed what 1 control room consnunications equipment would be utilized to complete this task. In addition HED SIl-06, l
(Reg. Guide 1.97* instrument enhancements) was implemented on the full scale mockup prior to this walkthrough/talkthrough.
The-operators could quickly identify..these ' environmentally qualified l
instruments during these walkthrough/talkthroughs.
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This final validation was an effective method of' coordinating the
~
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' integration of the NUREG-0737. Supplement 1 ' items..
.Any I
. discrepancies identified during these' walkthrough/talkthroughs were ~ classified as. a ~HED and assessed in the Final ~ Report l
Supplement No.1-. (reference 4,page 8 and Appendix A). -
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- Should you require any further information, please do not hesitate
..to call.
Sincerely,'
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SF41085M1040-Attachment (1)
Copy to:- (See attached service ' list) i-U I
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- cc! Judge Helen F. 'Hoyt (w/ enclosure)
Judge Jerry Harbour (w/ enclosure)
Judge. Richard F. Cole (w/ enclosure)
Troy B. Conner,' Jr., Esq.
(w/ enclosure)
Ann P.:Hodgdon, Esq.
(w/ enclosure)
Mr. Frank R. Romano..
(w/ enclosure)
Mr. Robert L. Anthony
.(w/ enclosure)
Ms._Phylits'ZItzer (w/ enclosure)
Charles W.'Elliot, Esq.
(w/ enclosure)
Zort G. Ferkin,,Esq.
(w/ enclosure)
'Mr. Thomas Gerusky (w/ enclosure)
Director,' Penna. Emergency (w/ enclosure)
Management Agency Angus R. Love,'-Esq.-
(w/ enclosure)
David Wersan, Esq.
(w/ enclosure)
Robert J. Sugarmen, Esq.
(w/ enclosure) 9 Martha W. Bush, Esq.
(w/ enclosure)
Spence W. Perry, Esq.
(w/ enclosure)
Jay M. Gutierrez, Esq.
(w/ enclosure)
Atanic Safety & Licensing (w/ enclosure)
Appeal Board Atomic Safety & Licensing (w/ enclosure)
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. Board Panel Docket & Service Section (w/ enclosure)
Mr. James;Wiggins (w/ enclosure)
'Mr.' Timothy-.R. S. Campbell (w/ enclosure) 4 1
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-S-ATTACHMENT #1 HED ASSESSMENTS OF NRC AUDIT TEAM HED's NOT PREVIOUSLY ASSESSED
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i HED ASSESSMENT HED No.
NPl-01 EP =
N/A TITLE:
Procedure Storage COMMENT:
No. storage space for procedures located at Remote Shutdown panel.
Item:
B110 -
Ref.:
El.5 Source:
NRC Audit IDENTIFICATION:
Panel:
Remote Shutdown Panel Component Name:
Procedures ID or Number:
N/A DESCRIPTION:
There is no apparent storage or laydown space at the Remote Shutdown Panel for procedures.
RESOLUTION:
(Code:
A)
(Priority:
2)
(Sched:
Complete
)
Work-Station shelves have been installed -which provide both storage and laydown space for procedures located at this panel.
NoLlonger a discrepancy.
TRAINING REQUIREMENTS:
PROCEDURE REQUIREMENTS:
Approval Signature:
Date:
4/5/85
(') Additional page(s)~
attached
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HED ASSESSMENT HED No.
NA2-01 EP =
N/A TITLE:
Audible Alarm COMMENT:
Alarm bells not distinguished from each other.
Item:
Bill Ref.:
F2.1 Source:
NRC Audit IDENTIFICATION:
PaneE:
N/A.
Component Name:
Annunciator Alarms ID or Number:
Audible tones DESCRIPTION:
Audible annunciator alarms do not distinguish alarm location.
Different annunciators use the same bell.
RESOLUTION:
(Code: A)
(Priority:
4)
(Sched:
N/A
)
The audible bell is used to alert the operator of an alarm.
The bell ' must be silenced at each respective station.
The flashing annunciator window provides alarm location.
~Also, electrical alarms use a different tone.
TRAINING REQUIREMENTS:
PROCEDURE REQUIREMENTS:
i' Approval Signature:
1 1 Date:
4/5/85
(- ) Additional page (s) attached C
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4-l HED ASSESSMENT HED No.
NC5-01
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EP =
N/A j
l TITLE:
Lettering Contrast.
COMMENT:
Lettering is not visually distinctive.
Item:
B202 Ref.:
AS.8 Source:
NRC Audit IDENTIFICATION:
Panel:
Process Computer Component Name:
Keyboard ID or Number:
N/A DESCRIPTION:
The contrast of engraved printing on.the keyboard keys is not very good (white on grey).
Dirt tends
'to-collect in the engraving and. obscure the letters.
RESOLUTION:
(Code:
D)
(Priority:
4)
(Sched:.N/A
)
The keyboard -is used during-normal operations.
During an emergency, the keyboard is used as'a-backup.
The primary source of information during-an emergency is the control room instrumentation and -ERFDS.
Note the ERFDS keyboard provides adequate _ contrast and_ minimal' glare.
TRAINING REQUIREMENTS:
-PROCEDURE REQUIREMENTS:
(Approval' Signature:
Date: 4/5/85 i
( ) Additional page(s) attached
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HED ASSESSMENT HED No.
NC4-03 EP =
N/A TITLE:
Printer Paper Accessibility COMMENT:
_ Paper in printer is not easily accessible.
Item:
7205 Ref.:
D4.7 Source:
NRC
' Audit-IDENTIFICATION:
Panel:
Process Computer Component Name:
Printer ID or Number:
N/A DESCRIPTION:
Physical' access to printer copy.is difficult, especially inside
'the bottom compartment in the front of the printer.
RESOLUTION:
(Code: -A)
(Priority:
4)
(Sched:
N/A
)
When -the main printer goes down, or runs out of paper,.the computer automatically -switches to the backup printer.-
This allows sufficient time for a technician to replace the paper.
' TRAINING REQUIREMENTS:
PROCEDURE REQUIREMENTS:
I Approval Signature:
Date: 4/5/85 s
.(
) Additional page(s) attached E
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HED ASSESSMENT HED No.
NC4-02 9
EP =
N/A TITLE:
Printout Redability
. COMMENT:
Printouts not easily read white in printer.
Item:
B204
-Ref.:
D4.8 Source:
NRC Audit IDENTIFICATION:. Panel:
Process Computer Component.Name:
Printer ID or Number:
N/A DESCRIPTION:
The printer dust cover collects dust and inhibits the readability 4
of printouts while they are in the printer.
4 RESOLUTION:
(Code: D)
(Priority:
4)
(Sched:
N/A
)
4 Printouts.are backups and are not immediately. time sensitive.
A page advance pushbutton=and a line advance pushbutton are located on the' keyboard,Lshould-the operator require information quickly.
Information oon - the printer is available to the; operator on the CRT as well.
TRAINING REQUIREMENTS:
PROCEDURE REQUIREMENTS:
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Approval Signature: '
Date: 4/5/85
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(') Additional page(s) attached r
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HED ASSESSMENT HED No.
NC4-01 EP =
N/A TITLE:
Printout Readability COMMENT:
-Computer printout is difficult to read.
Item:
B203 Ref.:
D4.8 Source:
NRC Audit' IDENTIFICATION:
Panel:
Process Computer Component Name:
Printer ID or Number:
N/A DESCRIPTION:
Printouts still in the printer are difficult to read as the paper drive guide covers four or five characters on about 16 lines of the printout.
RESOLUTION:
(Code:
D)
(Priority:
4)
(Sched:
N/A
)
Printouts _are backups and are not immediately time sensitive.
A-page advance pushbutton and a line advance pushbutton are located on the keyboard, should the operator require information quickly.
Information on the printer is available to the operator on the CRT as well.
TRAINING REQUIREMENTS:
PROCEDURE REQUIREMENTS:
Approval Signature:
Date: 4/5/85 j
( ) Additional page (s) attached i
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HED ASSESSMENT HED No.
ND3-01 EP =
N/A TITLE:
. Control Layout Consistency COMMENT:
Controls not organized in a consistent manner.
Item:' B106 Ref.:
A3.2 Source:
NRC Audit IDENTIFICATION:
Panel:
648 Component Name:
RCIC Div. 1 and Div. 3 ID or Number:
N/A DESCP.IPTION:
The Div.
1 and Div. 3 RCIC controls located on 648 panel are not laid out'in an identical manner.
RESOLUTION:
(Code:
B) (Priority:
4)
(Sched:
N/A
)'
.These are' status displays which provide backup information for an annunciator alarm.
The label associated with each light must be read.
This' then dictates the' action support personnel must take to _ troubleshoot.the problem..
There is no distinction 1necessary between DIV l-and.DIV 3.
With a status light illuminated. the control room operators shift to another injection mode.
This is not-a discrepancy.
TRAINING REQUIREMENTS:
i l
q PROCEDURE REQUIREMENTS:
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' Approval-Signature:
Date: 4/5/85
( )' Additional page(s) attach,ed
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HED ASSESSMENT HED No.
ND3-02 EP =
N/A TITLE:
-Control Layout Consistency COMMENT:
Components are not in expected order.
Item:
B105 Ref.:
A3.2 Source:
NRC Audit' IDENTIFICATION:- Panel:
648 Component Name:
RCIC Div. 1 and Div. 3 Controls ID or Number:
N/A DESCRIPTION:
The Div.
1 and Div.
3 RCIC status lights are not ordered identically.
This could lead to a misinterpretation in emergency situations.
RESOLUTION:
(Code: B)
(Priority:
4)
(Sched:
N/A
)
These are status lights and are not primary displays during.
emergencies.
RCIC status is primarily determined using_the "RCIC Out of Service" alarm.
Upon iden'tifying this alarm, operators will activate a different injection system without observing RCIC status lights.
No other immediate action is required.. Once a
different injection system has been. selected, then the status light label will be read and support personnel will'be-sent to investigate.
TRAINING REQUIREMENTS:
PROC.EDURE-REQUIREMENTS:
.)
Approval 1 Signature:
Date: 4/5/85
( ^)
Additional page(s) attached i
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