ML20101T359

Forwards Implementation Schedule for Detailed Control Room Design Review,In Response to Generic Ltr 82-33,Suppl 1 to NUREG-0737.Safety Significance Rankings of Human Engineering Deficiencies & short-term Corrective Actions Encl

ML20101T359
Person / Time
Site:	Davis Besse
Issue date:	01/31/1985
From:	Crouse R TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 1121, GL-82-33, TAC-56116, TAC-65255, NUDOCS 8502060117
Download: ML20101T359 (13)

Text

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Docket No. 50-346 votsoo License No. NPF-3 Serial No.1121 January 31, 1985 Director of Nuclear Reactor Regulation

' Attention:

Mr. John F. Stolz Operating Reactor Branch No. 4 Division of Licensing United States Nuclear Regulatory Commission sWashington,.D. C.

20555

Dear Mr. Stolz:

On December 17, 1982, the Nuclear Regulatory Commission (NRC) issued Supplement 1 to NUREG 0737, " Requirements for Ev rgency Response Capabil-ity", (Generic Letter 82-33) (Log No. 1168).

On June 29,1984 (Serial 1057), Toledo Edison submitted a summary report for the Detailed Control Room Design Review (DCRDR)'. Additionally, Toledo Edison committed to provide a proposed schedule for implementation in ac-cordance.with Commission Order dated February 21, 1984, as revised June 5, 1984 (Log No.-1527).

Section 7 of the DCRDR Summary Report described two different approaches to the dispositioning of Human Engineering Discrepancies (HED's); those for which short term corrective actions.could be identified, and those which required additional consideration to~ assure an integrated approach to their* resolution. Those HED's requiring additional consideration were

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9 further divided into a number of special studies described in the report.

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In planning these additional--studies, Toledo Edison has determined that not all of the studies _need be conducted in parallel, i.e., they need not all be completed in the same time-frame to assure proper' resolution'of all HED's.

We further determined'that.the most safety-significant HED's were included.in only half of?the identified ^ studies.

To help establish the schedule for the conduct of these studies,-we decided to re-examine the most safety significant HED's /to further prioritize them and thus determine which of the studies would provide the most significant benefits. The result of,this effort is a clearer understanding of the safety'signficance of these_HED's and a more definitive schedule for the

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conduct of these special studies.

4 8502060117 850131 PDR ADOCK 05000346 F

PDR h0 THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652

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Dockst No. 50-346 License No.NPF-3 3

- Serial No. 1121 January 31, 1985 Page 2 f '.

Att'achment'l,contains a completion schedule for the resolution of those LHED's for~which short: term corrective-actions were identified.

It further provides 'a proposed ' chedule for the implementation of the individual s

special' studies and a dispositioning of associated HED's.

Also identified L

is the anticipated schedule-for resolution of the most safety significant

.HED's.

Very.truly yours,

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-cc: DB-1 i;EC Resident Inspector

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Dockit No. 50-3461

-License No. NPF-3 iSerial No. 1121 January 31,.1985

. Attachment 1 Page 1 of 4 SUPPLEMENT 1 TO NUREG 0737 DETAILED CONTROL ROOM DESIGN REVIEW IMPLEMENTATION SCHEDULE 4 ~

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. SCHEDULE FOR RESOLUTION OF HEDS WITH SHORT TERM CORRECTIVE ACTIONS The expected completion date for the resolution of each HED with an identified short term corrective action, is provided in Table 2, to-gether.with a very brief description of the planned disposition. HED

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P.9.2-7, which was included in this list in the DCRDR Summary Report,

.was not included in Table 2.

The short term corrective action originally identified was ' determined to be inappropriate, and this HED has instead'been included for consideration in the display study.

The completion date referenced in the table is the date on which the

-identified disposition was or will be accomplished.

In wome cases, the identified disposition may be the initiation of some other Leorrective action mechanism such as the Toledo Edison Facility

,hodification Program..~ Corrective-action by this program is initiated when a Facility Change-Request- (FCR) ' form is prepared. >This process then tracks the requested project / modification through completion.and includes a method of prioritizing the project / modification with~

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' respect: toj all Lother :proj ects.1 The completion of these projects is

.in.accordance with'the-Toledo. Edison Integrated Living: Schedule

-Program,LToledo Edison Serial No.' 1043, submitted' July.-16,-1984.-

~-RE-EVALU' TION OF HUMAN ENGINEERING DESCREPANCIES A

II.

As. mentioned previously, the re-evaluation of'the most' safety signifi-cant HEDs was undertaken to: help identify which special studies.would

. provide the most safety-significant improvements'to the Davis-Besse

. Control-Roon. The HEDs reviewed were those originally prioritized as "A" or;"B" in the DCRDR Summary Report.

.The review of[these HEDs was'further prompted bysthe recognition that'

--the safety significance of these HEDs varied ' considerably. - Section :

16;1'of.the'DCRDR Summary. Report identified"the process used--to priori-L tize HEDs. L A very strict and conservative interpretation.of1the terms

',' plant safety _ functions", " mitigate the consequences of 'an accident",-

-and " unsafe. operations or plant conditions" was used in this evaluation.-

J This'resulted in.HEDs'being prioritized as "A" or "B" if it.was even

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1 remotely - significant.--

Tofmore: appropriately assess the safety. significance of these HEDs,-

- the ' review team -was' assembled ;(with the - exception of: the human factors' specialists)' and each HED was -given a high/ medium / low safety;

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? significance ranking..The definition of'these rankings are'as

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"follows:

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? License No. NPF-3 Serial No. 1121

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' Attachment 1-Page 2.of 4

.High

. - The hypothesized error will prevent or degrade a safety function Medium

- The hypothesized error will challenge a safety system or could potentially degrade a safety function Low

- The hypothesized error could potentially challenge a safety system The'results of this review are given in Table 1 which presents the significance ranking for each HED along with a brief description of

-proposed corrective action. Of the 29 HEDs evaluated, only one was

-determined to have high safety significance.

Eight HEDs were evaluated as_having medium safety significance, and the remaining twenty were categorized as having low safety significance.

Of the high and' medium' safety significant HEDs, four were originally to = be dispositioned by the. Steam and Feedwater Rupture Control System

~(SFRCS) SpecialiStudy. Three of these HEDs were to be dispositioned by the Display l Study and the remaining two were'to be evaluated in

-the Label and Location Aids Study.' Additionally, of the three HEDS originally to be dispositioned in the Display Study, one HED was-specifically related'to the SFRCS..

- With these results and an understanding of_the. magnitude of effort

involved'in all of the studies, we determined that~the SFRCS Study

=would provide the most significant benefits. Of'the. remaining 1

studies, the Label!and Location Aids Study and the Display Study.

-provide:the most benefit to the operator. The remaining studies'will-.

l provide thefleast significant Control Room improvements.

III.,-SFRCS'SPECIAL STUDY Because-of the safety significance of the HEDs: associated with.the

Steam'and' Feed'wat'er Rupture Control System, Toledo. Edison has placed

.special attention upon their resolution. Those'HEDs to be dispositioned

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einfthe SFRCS Study along with.related HEDs from other studies, have:

mbeen-reviewed by Toledo Edison' Operations and' Engineering pereonnel.

including. individuals from the-DCRDR Review Team.

Of the'HEDs, reviewed,'one (9.2-54) was given a High safety _ significance Jas described in Section~II. This HED:is:actually~ composed of three

individual parts, ~only;one of which was. determined to be of 'high!

tsignificance'. This problem is' associated with:the SFRCS mandal' y

> initiation switches'.,.The~ arrangement of'two.of.the' switches is

reversed from.what>the operator would logically expect to'see.

With-the existing: arrangement, an operator attempting to manually initiate SFRCSfon'aitherla: low steam pressure on Steam Generator 1 or-low steam. pressure on Steam Generator.2 may inadvertently block'any SFRCS~

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Dockst~No.-50-346

! License No.-NPF-3 Serial No.1121

' January 31,'1985'

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' Attachment 1

.Page 3 of.4 actuation. The automatic actuation of SFRCS on either of these two conditions would not be affected by this switch arrangement unless the operator chose to manually initiate SFRCS end made an error in 1the selection of the switches used.

Control Room operators have already been trained on this potential aproblem.and procedures have been modified to clearly explain the; condition. 'An FCR has already been initiated to modify this switch arrangement..We anticipate that this problem will be resolved no later than.the end of the fifth refueling outage.

The review of the remaining HEDs resulted in the development of additional' modification proposals.

Included in these proposals are the addition of selected Control Room indications for parameters used as. inputs. to the SFRCS, the1 addition' of computer inputs from the SFRCS to indicate various SFRCS trip conditions, and the addition and

' rearrangement of selected SFRCS related annunciators. These proposals L are currently being evaluated for feasibility. - These proposed.

modifications'should effectively resolve the HEDs given a medium safety significance classification. We anticipate resolution of L these HEDs no later than the end of the ~ sixth refueling outage.

- The ' remaining HEDs.which were tfo be covered by the. SFRCS Study, as

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described'in Section 7 of~the DCRDR Summary Report, will be disposi-

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tioned no.later'than the' seventh refueling outage.,

IlV.."SCHEDULEFORCOMPLET10NOFSPECIALSTUDIES Although'the SFRCS Study has-received the most significant attention -

. progress;has been nede on some of the other studies.

A.-

Label and Location Aids-

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.Two HEDs,.to:be resolved as a part of the1 Label and Location

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Aids Study, were'given a' medium safety significance classification as' described in Section II.-

These two HEDS were involved with..

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the Safety Features Actuation System mimic panel and the' lack o'f-a mimic-on the Auxiliary Feedwater System controls and displays.-

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Additionally, one:of the HEDs originally to be evaluated in the.

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' Displays Study was.given a medium safety significance ^classifica-.

tion 'and will-be - reviewed ' for.possible corrective ' action :as a.

9 jpartLof-the Label and Location Aids' Study.

J Planning for;thefLabel and Location Aids Studyzand the review;

~ _.and update'of some,of'the documentation basic;to-this study has already been! initiated.. We anticipate that control panel modifications resulting~from this study will be'made'during the

!following three refueling' outages (fifth,' sixth, and seventh).

While.the three HEDs identified as having medium safety signifi-

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Dockst Ni.:50-346-

-License.No. NPF-3 Serial No.J 1121 '

l January 31, 1985-l

' Attachment 1 Pagef4 of.4f cance-will receive the top priority in this study, their final resolution may not be complete until the sixth refueling outage depending upon the type of corrective action selected.

.B.-

Diiplay Study Planning.for the Display-Study activities has been initiated. A

--preliminary review of the HEDs to be dispositioned in the U

Display. Study has indicated a number of minor problems with the displays on:the post-accident monitoring panels. The one HED in

.this group given a medium safety significance classification was nin regards to these displays. Since the post-accident monitoring a

. panel is physically separated from the remaining Control Room panels, we have initiated an independent review of these displays e

Jand have developed preliminary modification proposals'to resolve these deficiencies. We anticipate that the.HED given the medium

-safety' significance classification and probably all other HEDs

associated with post-accident monitoring panels will be resolved no later than the. sixth refueling outage.

'All HEDs associated with the Display Study will be dispositioned by the seventh refueling outage.

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Other Special Studies Of the.HEDs in the remaining studies, none were determined to have any serious safety significance. Various levels of activi--

ties'have been initiated on the remaining studies. We anticipate-

' that all HEDs will be'dispositioned by the seventh refueling

outage.

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Docket'No.50-346/LicensiNo.fNPF-3

-Serial No. 1121-

.Pcg2 1-Table 1

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HED SAFETY SIGNIFICANCE RANKING NUMBER l'

II PROPOSED DISPOSITION l

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P.I.7-10 No lamp test, dual bulbs or' dual filament L

Evaluate affected displays to assure all have some bulbs form of redundant information.

P.1.7-11 Pushbuttons or indicator lights that have L

Procedural / training problem - procedures modified -

shorted out while bulbs were being-training requirements identified, replaced:

P.3.1-37 Annunciators with inputs from more than L

Review in annunciator study.

-one parameter is not avoided P.4.1-4~

Controls positioned too close together-L_

Actual problem is ambiguous labeling - to be that' adjacent controls were accidentally corrected in Label and Location Aids Study.

activated P.5.1-2 Indicator lights that indicate system /

L Evaluate affected displays to assure all have equipment status when light is off some form of redundant indication.

P.S.1-6.

Scales where the' maximum values are too-M Change request initiated to incorporate new large.for the scale indication.

P.5.1-7 Pointers on meters do not fail off scale L

Look at possibility of new display device.

P.5.1-9 Hulti-scale meters that are confusing to M

Correct with labeling in Label and Location Aids read Study or replace meter.

P.5.1-29 Meters with pointers that have parallax L

Change request to modify indicators initiated.

problems

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~ Table 1-2

~HED SAFETY SIGNIFICANCE RANKING TI n PROPOSED DISPOSITION NUMBER

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P.6.1 Labels that are not placed above the panel L

Correct in' Label and Location Aids' Study.

elements they describe

-P.G.1-15 Temporary labels and magnetic' labels and-L Procedural problem to be corrected.

information tags obscure components / labels a.

-9.2-1

-SFRCS Display. Arrangement does not support M

Change request initiated to add and rearrange

. operations tasks' indications.

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9.2 Related controls and displays not collo-L Procedure problem only - modify procedure.

cated 9.2 Misleading Panel Arrangements (ICS)

L Correct in Label and Location Aids Study.

9.2-6 Violation of operator. expectancy (control L

Correct in Label and Location Aids Study - trip type) switches to be covered.

9.2-7 Insufficient display accuracy (AW) -

L Initiate change request to replace indicator.

reliability 9.2-18 Availability / consistency of information M

Change request initiated to add and rearrange

.(SFRCS) indication, 9.2-20 Incident isolation groups are not consis -

L Initiate change request to relocate switches or tent (SFAS) correct with Label and Location Aids Study.

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' Serial No. 1121

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Table 1 -

HED SAFETY SIGNIFICANCE RANKING' i-1 SI F

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PROPOSED DISPOSITION 9.2-28

. Misleading FW flow indication L-Initiate change' request to modify input to flow recorders.

9.2-30

. Critical displays.not visible.from bench-

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SPDS consolidates information.

. board (T and T )'

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i 9.2-33 Lack of mimics'(AFW).

M Correct in Label and Location Aids Study.

i 29.2-42 Logic system SG level control inputs and M

Evaluate calibration procedures and resolve.

l' indications have different compensations

-(ICS, SFRCS)-

.9.2-43 Control.not available in CR (startup L

Immediate feedback available - extremely low valve SFRCS block)-

probability event requiring use of control -

no action.

9.2 Unclear mimic relationships (decay heat-M Correct in Label and Location Aids Study.

Pump /HPI-pump)-

t 9.2 Controls not located / arranged Part 1 H

Procedural clarification made, change request

_ Par. I to support emergency task initiated.

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-sequence Part 2 M

Change request initiated.

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Consider in Label and Location Aids Study.

9.2-65 Inadequate.information-(main L

Displays available but unreliable - required l

. turbine) maintenance to be determined.

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Serial No'. 1121

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HED SAFETY SIGNIFICANCE RANKING' SIGNIF CE

- PROPOSED DISPOSITION' TITLE g

,g 9.2-83 Inadequate info --ICS_

L Initiate change request to add alarm - consider

- Track mode in annunciator study.

9,2-84 Inadequate info - Deaerator-L Initiate change request'to add indicator.

- Level control valve position P.9.8 Displays ~that do not provide the' precision M

Change request to modify indicators initiated.

or accuracy required O

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Docket Noa 50-346/ License No. NFF Serial No. 1121-Page,1:

Tabla 2-

. LIST OF lEDs FOR WICH SHORT TERM CORRECTIVE ' ACTIONS HAVE BEEN IDENTIFIED 4

SCHEDULED IED NO.

DESCRIPTION CORREC"T.VE ACTION

. COMPLETION DATE 4

-P;1.1-3.

Work Space - Reference Document Storage in Additional shelving was added in the Control Room to make more

. Completed

Control Room usable space available.. A review of all the books'and reference material on the shelves was made, and the books were rearranged-E so the important documents (those used most during normal opera-g tion and those most vital during an accident) were in the most desirable locations.,The new book arrangement was approved by

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Operations management. In addition, new binders were purchased to replace any old, defective binders.

P.1.1-5 Work Space - Dedicated cr=-mication Links,-

An intercom has been added between the Control Room and the Shif t Completed Reactor Operator to Shift Supervisor Supervisor's office to provide a direct link. This, in conjunction with the numerous Cai-Tronics stations and phone stations, provides excellent communication between the Shift Supervisor's office and the Control Room.

Also, an SRO is now required to be in the Control Room area, reducing the need for communication with the Shift Supervisor's of fice.

P.1.6-6 Noise - Signal discriminability, fire alarm FCR 79-189 will provide an annunciator for the' fire alarm panel. This Completed annunciator will eliminate the problem of the noise to signal discriminability on the fire alarm system.

P.1.7-1 Maintainability - Recorder supplies I6C support is now available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week, eliminating Completed this concern. Also, a set of keys to the supply cabinets was provided to the Shift Supervisor to provide access to the material at all times.

P.1.7-5 Identifying bulbs and recorder supplies An index was made of _ the control' switches in the Control Room to indicate Completed the identifying number of each control switch light. Therefore, if a bulb cannot be identified by removal, the index can be used for identification.

Since 16C now is on shift around the clock, recorders are serviced by the I&C Department.

P.1.7-6 Maintainability - Spare bulbs, recorder

~ Station administrative procedures were modified to identify that the Control Completed paper Room operators are responsible for maintaining an adequate bulb supply in the Control Room. A note was added to the supply drawer t) remind the opera-tors to reorder bulbs as soon as the supply begins to get tw.

Spare recorder paper is inventoried and maintained by the I6C group.

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.Page 2-Tabla 2 3

' LIST OF HEDs FOR 1EICH SHORT TERM CORRECTIVE ACTIONS HAVE BEEN IDENTIFIED SCHEDULED

- HED NO ?

DESCRIPTION CORRECTIVE ACTION 1 COMPLETION 5

DATE

-P.1.7-7 Maintainability - Paper and ink replenishment 16C personnel now perform the paper and ink replenishments on the Control Room Completed on recorders recorders..On a daily basis, a petiodic check of the Control Roon strip charts is performed. This has eliminated the need for the operators to per-form this function.

= P.1.7-9 Maintainability - Bulb replacement, operators-The main cause of the shocking was a metal bulb extractor which would cause the Completed being shocked bulb contacts to short. This metal bulb extractor has been eliminated and a plastic bulb extractor is now being used.

P.1.7-11 Maintainability - Lights shorted out in Switch-Although the main cause of this is probably the metal bulb extractor which has -

Completed yard Panel

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now been removed, the Switchyard Panel is powered by 120 volts AC, making it susceptible to arcing during bulb changing. The Control Room operators have been instructed to leave the replacement of these bulbs to the electricians, eliminating this concern for the Control Room operators.

P.2.1-2 Communication - Gai-Tronics cords in traffic It appears the cords on several of the Cai-Tronics stations had been Completed paths stretched and did not recoil to take them out of the traffic path when they were not in use. All affected cords were replaced.

P.3.1-29 Alarm typer failures-A service contract with DEC has now been initiated which includes routine Completed preventative maintenance. This appears to be increasing the reliability of the typer. Further reduction of the nuisance alarms per the Nuisance Alarm Reduction Program will reduce the loading on the alarm typer. Since the alarms can be viewed on the CRTs and the line printer can be used to print out any rapid sequence of alarms, no specific human factor problems remain.

P.3.1-35 Annunciators - Coordinate Designators Although the annunciators at Davis-Besse do not have a letter and number Completed P.3.1-36 descriptor, the numeric labeling is suitable for the layout of the Station procedures. The digit before the decimal identifies the panel number and the digits after the decimal identify the numeric order of the panel. Most Control Room operators do not have problems with identifying the proper procedure for a tile with the present labeling. The item has been referred to the Training Department for review to determine if any additional train-ing is required.

. P.4.1-1 Controls. Critical control guard.

FCR 84-132 has been written to add flip covers, cylinders, or extension Completed guards on critical controls inside and outside the Control Room.

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LIST OF HEDs FOR 1411CH SHOltT TERM 00ltRECTIVE ACTIONS HAVE BEEN IDENTIFIED

! SCHEDULED

.IED NO.

DESCRIPTION CORRECTIVE ACTION COMPLETION, DATE s

P.4.1-7 Controls.- Interlocks

'A permanent warning label has been added to the prime interlock control

. Completed

' concern on the Control Rod Drive Panel. Other controls on interlocks -

are' covered during the. operator training program, i

r areas of the CoHtrol R8ce,d i large I*I8hancements have been made by the

.P.9.2-30' V&V - Walk-through - Display Visibility Although both T and T an meter are visible in numerous Completed w

additional y.

installation of the Safety Parameter Display System (SPDS). The P/T displays have been installed on the SPDS screens making T and T visible h

e in all required areas of the Control Room

-P.9.2-37'

.V&V - Walk-through - Display Accuracy ^

.The problems identifed in the emergency procedures have been corrected Completed to ensure meter accuracy required is not more than half of an increment.

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.P.9.2-88 V&V - Walk-through - Timers An electronic timer has been purchased for review and provided to the Completed Control Room operators. This provides a more accurate timing device than the mechanical timers previously provided. Additional electronic timers will be provided if the Control Room workload requires.

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