ML20104A726

Technical Evaluation Rept of Detailed Control Room Design Review,South Texas Project

ML20104A726
Person / Time
Site:	South Texas
Issue date:	07/19/1984
From:	Savage J LAWRENCE LIVERMORE NATIONAL LABORATORY
To:	NRC
Shared Package
ML20104A591	List: ML20104A726
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8502010476
Download: ML20104A726 (58)

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• Enclosure 1 TECHNICAL EVALUATION REPORT OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR j HOUSTON LIGHTING AND POWER COMPANY'S

': SOUTH TEXAS PROJECT NUCLEAR POWER GENERATION STATION July 19, 1984 Jack W. Savage

' Lawrence Livermore National Laboratory for the United States Nuclear Regulatory Commission r

8502010476 850122 -'

PDR ADOCK 05000498 F PDR

TECHNICAL EVALUATION REPORT OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR HOUSTON LIGHTING AND POWER COMPANY'S SOUTH TEXAS PROJECT NUCLEAR POWER GENERATION STATION TABLE OF CONTENTS

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Section 1

1. B a c k g r ou n d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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2. Discussion............................................................

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3. R e vi ew Te am Sel e ct i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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4. Management Responsibility.............................................

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5. Re vi ew of Op e rati ng E xperi ence. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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6. Function and Task Analysis............................................

C o nt rol R oom I n v e nt o ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 7.

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8. C o nt rol R o om Su r v ey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

9. A s s e s s me nt o f HE D s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2

10. Sel ecti on of Desi gn Imp rovements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

11. Verification That Design Improvements Provide Necessary Correcti on and Do Not Int roduce New HE0s . . . . . . . . . . . . . . . . . . . . . . . . . . 49

12. Coordination of Control Room Improvements With 50 Other Programs....................................................

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13. Conclusions.........................................................

55 References...............................................................

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TECHNICAL EVALUATION REPORT OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR HOUSTON LIGHTING AND POWER COMPANY'S SOUTH TEXAS PROJECT NUCLEAR POWER GENERATION STATION

1. BACKGROUND Licensees and applicants for operating licenses shall conduct a Detailed Control Room Design Review (DCRDR). The objective is to "ipprove the ability of nuclear power plant control room operators to prevent accidents or cope with accidents if they occur by improving the information provided to them" Supplement I to NUREG-0737 requires each applicant or l (NUREG-0660 Item I.D).

licensee to conduct a DCRDR on a schedule negotiated with the Nuclear Regulatory Commission (NRC).

NUREG-0700 describes four phases of the DCRDR and provides applicants and licensees with guidelines for its conduct.

The phases are:

1. Planning

2. Review

3. . Assessment and Implementation 4 Reporting.

Criteria. for evaluating each phase are contained in draft NUREG-0801.

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A Program Plan is to be submitted within two months of the start of the DCRDR. Consistent with the requirements of Supplenent 1 to NUREG-0737, the Program Plan shall describe how the following elements of the DCRDR will be accomplished:

1. Establishment of a qualified multidisciplinary review team

2. Function and task analyses to identify control room operator tasks and information and control requirements during emergency operations

3. A comparison of display and control requirements with a control room inventory

4. A control room survey to identify deviations from accepted human factors principles

5. Assessment of human engineering discrepancies (HEDs) to determine which HEDs are significant and should be corrected

6. Selection of design improvements

7. Verification that selected design improvements will provide the necessary correction

8. Verification that improvements will not introduce new' HEDs

9. Coordination of control room improvements with changes from other programs such as SPDS, operator training, Reg. Guide 1.97 instrumentation, and upgraded emergency operating procedures.

A Summary Report is to be submitted at the end of the DCRDR. As a minimum it shall:

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. , 1 Ic Outline proposed control room changes

2. Outline proposed schedules for implementation

3. Provide summary justification for HEDs with safety significance to be left uncorrected or partially corrected.

The NRC will evaluate the organization, process, and results of the DCRDR. '

Evaluation will include review of required documentation (Program Plan and Summary Report) and ney also include reviews of additional documentation, briefings, discussio'ns, and on-site audits. In progress audits may be conducted after submission of the Program Plan but prior to submission of the

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Surmary Report. Preimplementation audits may be conducted after submission of the Summary Report. Evaluation will be in accordance with the requirements of Supplement 1 to NUREG-0737. Additional guidance for the evaluation is provided by NUREG-0700 and draft NUREG-0801. Results of the NRC evaluation of a DCRDR will be documented in a Safety Evaluation Report (SER) or SER Supplement.

Significant HEDs should be corrected. Improvements which can be accomplished with an enhancement program should be done prorptly.

2. DISCUSSION Houston Lighting and Power Company's (HL&P's) South Texas Project (STP) is under construction. Licensing cf Unit 1 is scheduled for December 1986. The STP DCRDR was initiated. in September,1982. HL&P briefed the NRC staff on its DCRDR Program Plan on October 5,1982, and formally submitted that Program Plan on October 20, 1982. Exceptions to the originally planned organization and process of the DCRDR were documented in a March 31, 1983 revision to the Program Plan. The Program Plan included review of the auxiliary shutdown panel within the scope of the DCRDR.

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O In a letter from J. H. Goldberg to T. M. Novak, dated April 7,1983, HL&P requested an in-progress audit of the STP DCRDR. The primary purpose of the request was to obtain NRC review of the STP main control board layout. The requested audit was conducted from May 2 through 6,1983, at the Bechtel Energy Corporation (STP architect-engineer) office in Houston. The NRC was assisted in the audit by its consultants from Lawrenr.e Livermore National Laboratory.

Available at the audit site were:

1. A full-size control room mock-up. )

2. A half-size color photo mosaic of the control room simulator.

3. A scale model showing control room layout.

4. Example controls and displays.

5. Examples of the labels and location aids being developed to assist control room operators. -

HL&P provided a number of documents by mail and at the audit site to support the in-progress audit. HL&P, Bechtel Energy Corporation, and Torrey Pines Technology (human factors consultant) personnel involved in the DCRDR were available on a daily basis during the audit,.

The in-progress audit of May 2 through 6,1983, consisted of walk-throughs, document reviews, briefings, and discussions. Major emphasis was on evaluation of the organization and process of the DCRDR. DCRDR results, particularly in areas which could affect main control board layout, were also evaluated. Evaluation of DCRDR results was limited because the DCRDR was incomplete at the time of the in-progress audit. An in-progress audit report, transmitted to HL&P on October 31, 1983 summarized staff findings, provided

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recommendati)ns, and indicated information needed to complete evaluation of the DCRDR.

HL&P addressed OCROR progress in a briefing on December 16, 1983. The briefing identifitd:

1. DCRDR activities completed since the in-progress audit

2. DCRDR activities remaining to be completed as of December 1983.

The f abrication status of control room panels CP-001 through CP-010 was also provided.

The Summary Report for the STP DCROR was submitted April 12, 1984, by letter from J. H. Goldberg to T. M. Novak. That report consisted of 15 documents.

Titles are provided in the Reference section of this report. Information in the Summary Report, along with information obtained earlier, was used to The NRC was evaluat.e the organization, process, and results of the DCRDR.

assisted in the evaluation by its consultants from Lawrence Livermore National Laboratory. Results of the evaluation are summarized below.

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3. REVIEW TEAM SELECTION Supplement 1 to NUREG-0737 requires the establishment of a qualified multidisciplinary review team. Guidelines in team selection are found in NUREG-0700 and NUREG-0801.

Houston Lighting and Power (HL&P) established a hierarchy of three teams, as illustrated in Fig. 2-2 of the Executive Summary Report, to manage and conduct the South Texas Plant' (STP) DCRDR. The Design Review and Technical Task Team That team includes is responsible for the technical aspects of the OCRDR.

HL&P, Bechtel, and Torrey Pines Technology personnel. Westinghouse personnel Team members (nuclear steam supply system vendor) are available as required.

represent a number of disciplines, including all those recommended in the NRC fiOUsTON CONTROL ROOM LIGHTING o gggg y g g yjg y E@ f0WER CO.

MANAGEMENT TE AM REVIEW AND APPROVE MAN A GE R. E N GIN E E RIN G e PROGRAM PLAN VICE PRES., OPERATIONS e CRITERIA e FINAL REPORTS BECHTEL e DESIGN !MPLEMENT ATIONS CHIEF ENGINEER CONTROLS f 4 PROJECT REVIEW TE AM ,

ML&P REVIEW PRE LIMIN ARY AND FIN AL LEAD ENGINEER INSTRUMENTATION & CONTROLS e PROGR AM PL AN REACTOR OPERATIONS SUPERINTENDENT e CRITERIA e DESIGN REVIEW FINDINGS BECHTEL e REPO RTS CONTROL SYSTEW ENGINEERING GROUP LEADER t I DESIGN REVIEW Ak0 '

TECHNIC AL TASK TE AM HL&P ENGINEERING. 0PERATIONS AND LICENSING PERSONNEL AS REQUIRED DEVELOP AND EVALUATE SECHTEL e PROGRAM PLAN e CRITERI A PRINCIP AL INVESTIG AT OR e CHECK LISTS ENGINEERING AS REQUIRED e SYSTEM FUNCTION AND TASK AN ALYSIS WESTINGHOUSE *

• SURVEYS e INVENTORY ENGINEERING AND TRAINING e WALK THROUGH AS REQUIRE 0 TALK THROUGH e PROCEDURES l CONSULTANTS

• OBSERVATIONS i PREPARE PROJE CT ENGINEER l ASST, PROJECT ENGINEE R e DESIGN !MP(EMENT ATION l TASK ANALYS13 LE ADER RECOMMENDATIONS l

OPERATING EXPERIENCE REVIEW LOR SYSTEMS SPECIALIST ANNUNCIATOR REVIEW LEADER INVENTORY

' HUMAN F ACTORS SPECIALIST l

OVERVIEW OF CONTROL ROOM DESIGN REVIEW ORGANIZATION l

I Figure 2 2 m

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guidelines. NUREG-0801 evaluation critoria for personnel qualifications and assignnents by discipline have r.ot always been fully met. However, DCr1DR performance to date does not appear to have suffered on this basis. lhe ability to supplement the team with needed expertise when required has been demonstrated.

The qualifications of the six Management Team nert)ers are described in Appendix A of the CRDR Program plan, and include the HL&P Vice President of Nuclear Plant Operations, the Principal Nuclear Engineer, the STP Engineering Manager, and Assistant Plant Superintendent. Bechtel Corporation mert)ers are ,

the STP Systems Project Engineer and the Chief Controls Engineer.

Tne qualifications of the 20 Project Review Team and Design Review and Technical Task Tean ment)ers are described in Appendix B of the HL&P CRDR Progran plan. The team mert)ers are affiliated as follows:

Torrey Pines Technology 9 1

Canyon Research Group Seville Research Corporation _

1 1

Westinghouse Bechtel Corporation - 4 4

HL&P 20

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The team mert)ership includes expertise in Hunan Factors; Instrumentation and Control; Licensing Plant Operations: Training; Systens Engineering; Psychology; Nuclear, Electrical, and Mechanical Engineering; and Plant Process Systems. Special assignments were made to lead the annunciator and process computer studies.

We conclude that the requirement in Supplement 1 to NUREG-0737 to establish a qualified multidisciplinary review team has been met.

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- 4 MANAGEMENT RESPONSIBILITY Merbersh.ip of th'e Project Review and Management Teams include both HLAP and Bechtel perse,nel. NRC guidelines recommend that overall management responsibil,;y for the DCRDR be invested in the applicant / licensee. Although it differed from the guidelines, the shared managenent arrangement was consistent with the plant's design and construction status. Shared management did not appear to cause any functional problems in conduct of the DCRDR.

5. REVIEW 0F OPERATING EXPERIENCE  :

HL&P conducted a very complete and well organized Operating Experience Review (OER). The Operating Experience Review Task Team (0ERT) reviewed pertinent operating experience documents (0ER Report, Section 2.1) and conducted a survey of control room operations personnel. In addition to typical human factors operator concerns, the OERT emphasized systens operability. It received valuable input for use by the other task groups, particularly the Systems Task Analysis Tean (STAT). Specific attention was placed on those normal plant procedures that experienced _ operators identified as having the greatest potential for hunan factors engineering enhancenents. This information was used in the selection . process for those events that were analyzed by the STAT. The methodology used in the preparation of operating procedures was reviewed and comments submitted to the operations department.

The stated purpose of the operating experience review (GER) was to assess all safety-related and efficiency-related f actors of the projected STP control

, room as identified by supervis' ors and operators. Its major objective was to

identify problems relative to operator performance, as well as potential solutions to those problems.

The OER determined that the CR contained all of the equipment necessary to operate the plant safety, but contained significant human factor

' i nadequaci es . These inadequacies ranged in severity from very minor to O 4

• e potentially severe, and the arrangement of components could create inconvenient sequences of RO movement about the contrc ) room and the potential for misinterpreting informatinn.

It is stated that the human f actors problems identified by operational personnel closely ~ corresponded with observations contained in the human f actors checklists. The OER Reports reconnended that CR modifications were necessary to optimize the final CR arrangenent for operator use.

The work is summarized in the Executive Summary Report, Section 2.3.2, with complete details of the original 0ER contained in the OER Report. Problem areas identified by operators in the original questionnaire (Appendix A of the OER Report) were used to guide control board modifications, and to develop an OER validation questionnaire (Appendix A of the OERV ' alidation Report).

Analysis of the results from the OER validation questionnaire indicated that no new observations were introduced as a result of the redesign of the control b oards. Four previous problems that did not receive operator consensus regarding validation of correction have been corrected.

6. FUNCTION AND TASK ANALYSIS Supplement 1 to NUREG-0737 requires the licensee to perform systems function and task analyses to identify control room operator tasks and information and control requirements during emergency' operations. Furthermore, Supplenent 1 to NUREG-0737 recommends the use of function and task analyses that had been used as the basis for developing emergency operating procedures technical guidelines and plant-specific emergency operating procedures to define these requi rement s.

The NRC memorandum of April 5,1984, from H. Brent Clayton to Dennis L.

Zienann, " Meeting Summary--Task Analysis Requirements of Supplement 1 to NUREG-0737, March 29, 1984 meeting with Westinghouse Owner's Group (WOG)

Procedures Subcommittee and Other Interested Persons", -tates that it appears that Revision 1 of the WOG Energency Response Guidelines (ERG) and background documents do provide an adequate basis for ger.erically identifying information and control needs.

The NRC memorandum of April 5,1984. states in Iten (2) that licensees and applicants must describe and report in the Procedure Generation Package (PGP) or DCRDR Program plan the process for using the generic guidelines and background documentation or other sources to identify the plant-specific characteristics of needed instrumentation and controls.

Iten (3) of the' memorandum states that saf ety-signficant, plant-specific deviations from the ERG instrumentation and controls must be reported and justified in the plant-specific technical guideline portion of the PGP, along with other technical deviations.

Item (4) of the memorandum states that for each instrument and control used to implement the E0Ps there should be an auditable record of how the needed characteristics were determined from the background documentation of Revision 1 of the ERG, or from plant-specific information.

The STP systens function and task analysis (SFTA) was performed through document reviews briefings, and walk-throughs of the mock-up. SFTA results identified main control board layout problems which could affect operator performance. Major revisions to main control board layout are currently reflected in the full-scale mock-up. An update of the SFTA using the revised mock-up is reported in the SFTA Validation Report. One NRC concern is that the SFTA was not based on finalized emergency operating procedures (per requirement in Supplenent 1 to NUREG-0737). Final energency operating procedures (EOPs) are not typically available at early stages of design and construction, but should be available prior to licensing. We recommend th:

HL&P confirn, after E0Ps are finalized, that information (parameter type, dynamic range, accuracy, f requency, feedback, etc.) and control functions (discrete / analog, precision, duration, criticality, etc.) needs have been adequately identified and are satisfied by available instrumentation and controls.

The applicant should describe specifically how it intends to accomplish Items 2, 3, and 4 of the April 5,1984 memorandum.

The HL&P SFTA was performed and reported in two steps. The SFTA, performed on the previous CR design, is reported in the SFTA report of March 25, 1983, and resulted in significant design modifications and improvenents which were incorporated into the CR nock-up. The revised mock-up was used to perform a validation of the original SFTA for the redesigned control panels. This is reported in the SFTA Validation Report of March 19. 1994, which supplenents the earlier report.

Both SFTAs were performed for the following six operational events (50Es):

A. Small break loss of coolant accident B. Steam line break C. Steam generator tube rupture ,

D. Loss of offsite power E. Turbine load rejection .

F. Plant startup The selection of these events was based on criteria chosen by HL&P to provide a good cross section of operator actions for the expected normal and emergency plant operating events. Those activities described in the earlier report which were not affected by the redesign were not repeated.

The-SFTA program as discussed in the original Program Plan included the following activities by Systems Task Analysis Tean mercers.

A. Review of pertinent plant documents such as: configuration drawings, FSAR, systems descriptions, operating procedures, and the Emergency Response Guidelines (ERG).

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l B. Attendance at a series of plant design and plant systems lectures conducted by Bechtel.

C. Identification of systems or subsystems and preparation of functional diagrans for these systems.

D. Preparation of a tabulation of emergency event sequences and background system information.

E. Preparation of event selection criteria and the selection of events to be analyzed by the Systems Task Analysis Tean (STAT). These events are defined as selected operational events (50Es).

F. Review of the.results of operating experience to help identify events 'as candidates for review.

G. - Performance of SFTA for each SOE considering the following:

1. Preparation of basic elements diagram.

2. Preparation of functional (decision-action) flow diagrans using the ERGS for reference.

3. Complete functional sequence tabulations.

4 Complete a hierarchial review process by identifying tasks associated with each function including equipment required.

5. List details about input and action / decisions using task--

oriented decision-action diagrams as required.

H. Preparation of panel interf ace equipment tabulation including data requirements suitable for use in verification process, as required.

I. Preparation of operational sequence diagrams and traffic link diagrams.

J. Evaluation of data and summary of observations.

The SFTA effort involved the preparation and recording of a large amount of information for each SOE. The following forms and diagrans were used as was appropriate for each SOE, and form a major part of the bulk of the SFTA report:

A. Control Panel Flow Diagrams, which show the major conponents and

. systems with the associated flow paths.

B. System Breakdown Form (Form A), which breaks each major system into its subsystems and components, and lists system designators and control panels. -

'C . Emergency Event Sequences (Form B), which shows the systems and subsystems involved with each emergency event; ,

D. Background System Information Form, which records the system functions, safety related manual controls needed, credible f ailures which may cause system failures, and other information useful to the analyses.

E. Basic Elements Diagrans, which show the operator involvement with the SOEs.

F. Functional Flow Diagram, which shows a visual representation of each SOE with decision-action points identified.

G. Systens status at onset of event (Form C). .

H. Functional sequence per SOE (Form D), which shows a list of the major functions for each SOE, systems /subsystens involved, who performs / monitors the function, identifies the principal control used for the function, and means of communication between operators.

I. Operator Task Identification and Analysis (Form E), which defines the tasks and task steps for each event.

J. Instru' ment Details (Forn F), which identifies for each task / step sequence nudaer, the instrument parameters being read or monitored, the device nun)er, panel nudaer, the estinated instrument range, and estimated initial value of the parameter.

K. Function Details (Form G), which describes detailed information about the. actions and equipment required to perform the task.

L. Operational Sequence Diagram, which shows the operator actions and steps for an individual control panel.

M. Traffic Link Diagram, which shows to approximate scale the relationships of the ten control panels, and the traffic flow between panels.

The original SFTA resulted in the significant relocation of nany of the panel The following devices, which altered the original reference database.

activities, which are reported in the SFTA Validation Report, were required to validate the original SFTA in terns of the design modifications incorporated into the CR and placed on the CR nock-up:

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A. Performance of the SFTA for each 50E.

1. Revise the panel and the panel f ace locations as required for the task steps on the Operator Task Identification and Analysis forns (Form E).

2. Reidentify or confirm the designated operator performing or monitoring the task steps on Form E.

B. Revise the traffic flow analysis to correspond to the latest panel layouts including revised operational sequence diagrams.

C. Revise the operational sequence analysis to corretpond to the latest panel' layouts including revised operational sequence diagrans.

D. Evaluate the analyses and sunnarize observations and reconnendations.

E. Perform a walk-through/ talk-thr_ough validation of two of the SOE studied in the SFTA.

F. Summarize and document the results and observations obtained from the SFTA validation.

The walk-through/ talk-thro' ugh validation effort of Plant Start-up and Stean Generator Tube Rupture showed that the control room crew could accomplish the allocated control room functions as defined in the normal and emergency operating procedures with one exception, i

The exception is that one case was found which did not satisfy the task grouping criteria. This involved task 9.10 of the LOCA event where the RCS is depressurized _using SI pump controls on panel 001 and pressurizer spray controls on panel 004 The devices for this task are not grouped to nininize L

operator movement. The layout of these systems with regard to all the events The NRC must be considered before identifying this observation as an HED.

should be advised of the re'aolution of this situation.

No additional observations of potential HEDs were identified during the walk-through/ talk-through.

From our evaluation of the Function and Task Analyses effort, we conclude that the part ,of the requirements of Supplement 1 to NUREG-0737 to identify CR operator tasks has been satisfied.

However, satisfaction of the part of the requirenents concerning identification of information and control needs is not as clear-cut.

We understand the current mock-up design is the result of an evolutionary process which began with a CRDR conducted on an earlier CR design, and that the current mock-up panels were derived f ron the mock-up which existed when the original SFTA was performed. A significant nunber of design changes were made to the original mock-up as a result _of the original SFTA.

The present design is understood to have developed at as follows:

1982 Mock-up (1) CRDR HEDs o Earlier Design SFTA HEDs o Design Changes Mock-up (2)

SFTA HEDs o Design Changes Mock-up (3) o SFTA 1984 Validation .

Part of the evolution included the redesign of the CR panels as described in the Implementation Plan Report. This description states in several places

.that Relayout Alternative 4 was planned to retain the existing or use the sane e:

type control / display devices that were used on the then existing panels (e.g.,

implementation Plan Report, Sections 5.0, 5.1.1, and 5.4).

Equipment, control, and instrument / display needs are tabulated in several places in the report (e.g., Forms D, E, F, G. C-12, 0-18, H-67, G-21) and each need is identified with certain specific mock-up panels.

The report 'also states that Westinghouse generic ERGS and the Westinghouse PIP were included in the documents reviewed and used as references for the SFTA The specification of characteristics for information and control requirements for emergency operations should be derived from an SFTA which is completely independent of existing designs or equipment (e.g., actual CRs or mock-ups).

An objective, independent determination of the operator information and control needs for each operator task should be done before instrunent and

. control specifications are developed. Review of the sample forns provided in the report does not indicate that an objective indentification of operator information and control needs was accomplished or adequately documented.

The 0RC staff has determined that the -current Revision 1 of WOG ERG and background documents provides an adequate basis for generically identifying (See pg. 4 information and control needs required for energency operations.

However, the CR this report which quotes NRC Memorandum of April 5,1984.)

design (mock-up) changes over the two year time span of the HP&L CRDR and SFTAs just described coincide with changes in the WOG ERGS during the same time span. It is not clear whether the existing mock-up information and control equipment requirements were truly determined independently or whether they were substantially influenced by a previous CR design for which the role of prior WOG ERGS is not explained. It is not clear what process was used to identify the operator information and control needs that are associated with each task.

We conclude that more information will be requ' ired before it can be determined that this part of Requirenent I to NUREG-0737 to identify CR operator information and control needs has been acceptably satisfied.

7. CONTROL ROOM INVENTORY Supplement 1 to NUREG-0737 requires the applicant to make a control room inventory and to compare the operator information and control needs determined f rom the task analyses with the control room inventory to determine missing controls and displays. ,

The control room inventory was not evaluated in detail, but descriptions of the inventory in HL&P's Program Plan and Implementation Plan and Executive Summary Reports were reviewed. Those descriptions indicated that the control roon inventory involved an automated system which is consistent with hRC guideli nes . The , inventory will be updated as the STP control room design evolves. .

The inventory of controls, displays, and-other CR equipment was perforned

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using the CR equ'ipment list at the tire of construction of the CR mock-up.

The equipment list was prepared on a panel-by-panel basis, categorized by equipment type, and is maintained as a database for ease of updating, revising, and sorting.

The inventory database was updated to reflect the additions and deletions of equipment, relocations between panels as work progressed in the SFTA, the revision of panel layouts, and verification. Devices identified by the control room survey as not complying with the control room criteria, such as wrong switch types, were also entered in the database. The listing contains a unique component identification code, the panel number where installed, the nameplate engraving, and certain cnaracteristics appropriate for the component. The results served as a reference database to verify that all the devices were properly represented on the control room nock-up. In addition, s

I the inventory provided a means to verify that all of the devices required by the SFTA (for those emergency events . analyzed) were available in the control room.

We conclude that the final updated HL&P inventory will be complete and adequate for use as a comparison reference to determine missing controls and displays.

However, we conclude that the applicant has not yet described that an objective comparison of independently determined display and control .

requirements, as determined by function and task analyses, has been made with the control room inventory to identify missing controls and displays.

Therefore, the requirenent of Supplement I to NUREG-0737 for comparison of operator information and control needs with the control room inventory has not been fully satisfied.

8. CONTROL ROOM SURVEY Supplement 1 to NUREG-0737 requires that _a control roor survey be conducted to The objective of identify deviations from _ accepted human factors principles.

the control room survey is to. identify. for assessnent and possible correction.

the characteristics of displays, controls, equipnent, panel 1ayout, annunciators and alarms, control roon layout, and control room actient conditions that do not conform to good human enginee' ring practices.

The control room survey was evaluated through document reviews, briefings, audits of HL&P identified HEDs, and an independent control room survey by the NRC. A key element of the STP control room survey is the Criterion Report.

Tne That document contains control room design criteria from several sources.

criteria have been tailored to the STP application, and all survey areas of NUREG-0700 are addressed. Observed deviations from the criteria (HEDs) are The Control Room Survey report is a logged in a computerized database.

T' hat report allows tracking of HEOs.

product of the computerized database.

their assigned priority, and proposed resolution. It also allows tracking of Design Review, Technical Task, Project Review, and Management Team decisions about HED resolutions. Information provided in review of the Criteria Report and Control Room Survey report indicated that, in general, the control roon

- survey was conducted in a manner consistent with NRC guidelines for objectives, approach, information sources, staffing, and results. A linited NRC audit of specific HEDs identified during the control room survey was nade possible through access to the mock-up, half-scale mosaic of the simulator, and examples of selected types of controls and displays. A limited independent control room survey of the CR mock-up by the NRC was also '

performed during the NRC audit of May 2 through 6,1983.

The Criteria Report is very complete and well organized. It contains guidelines for the following major areas:

o Control Room Layout and Facilities o Main Control Panels o - Auxiliary Shutdown Panel ,

o Human Factors o Communications _

o Annunciators o Post Accident Monitoring -

, o By-Passed and Inoperable Status o SPDS o Plant Computers Each major area is subdivided into more detailed subsections. The report is replete with tables, appendices, and figures to supplement the text, and _

includes a list of acronyms, abbreviations, and terms. Display equipnent

- guidelines include descriptions. to guide the selection of indicators, recorders, and annunciators. Computer systems will complement and/or - ~

duplicate panel-mounted hardwired displays. Uniform control switch selection is guided by Table 4.3-1 of_ the criteria, " Main Control Room Control Switch Types".

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In addition to addressing all areas of NUREG-0700, several supplementary These were:

special DCRDR studies were made and used by the Review Te .m.

o Anthroporetry Report o Labeling Study Report o Denarcation Study Report o Meter Scales e Recorder Survey o Knurled Knob Position Indicator o Distinguishing legend Pushbuttons from legend Lights .

o Annunciator Review Guide o Evaluation of Specified Parameters o Annunciator Report in each of these reports, HL&P addressed and resolved questions raised during the CRDR.

o Anthropometry Report - This report addresses the CR standing control panels. The sit-down design was incomplete and not addressed by this review. The NRC should be apprised of the present status of the sit-down design. Them. ost pertinar.t variables were identified as:

o Standing height o Eye height

- o Shoulder height o Functional reach n

o Extended functional reach The report states that th? stand-up panels satisfy the general visual field guidelines in Section 6.1.2:2 of NUREG-0700, but smaller operators rey experience difficulty in reading and interpreting annunciator tiles. It is stated that a more detailed c.

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The design adequacy is stated to be more questionable for functional operator reach. Using extended functional reach criteria, which HL&P considers to be more cperationally relevant, the panels will accommodate the 20th percentile female through 95th percentile male operators. The report suggests that further assessment be made using lower percentile subjects. The results and conclusions of this assessment should be reported to the NRC for review.

o labeling Study Report - The report states that the labeling study resulted in the correction of the control room survey discrepancies. Each panel received several levels of heirarchial labels that simplified the individual component labels. The study included significant operator participation.

The study produced a labeling guide that will become a permanent part iof the criteria report to guide future labeling. Over 1900 labels were formulated. They were formulated, with the objectives of consistency, conformance to human f actors recommendations for color contrast (change to light background and dark letters) and use of standard abbreviations consistent with quick recognition of the ,

label content.

o Demarcation Study Report - The demarcation study describes criteria and a technique for easy identification and differentiation of front panel surf ace counted devices that are associated with a particular system, subsystem, or functional activity. The study was made to correct - discrepancies noted in the CRDR. Three full scale front panel sections were used in the study.

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e Specific recommendations are made for brand and color of paints.

These recommendations have been applied to the twelve CR panels that will be used for plant operations.

o Meter Scale Study _ - This report pres'ents the results of the CROR study to determine uniforn meter paraneters and provides examples for use as guidance in applying meter markings. The study was The initiated as a result of the HEDs concerning reter paraneters.

study will assure that the HED resolutions are incorporated into the control room design, and that future meter additions conform to established and uniforn parameter guidelines.

The report includes criteria and recommendations in the following areas:

o Zone marking using color alone (e.g., red, anber, green) o Scale graduations per Section 6.5.1.5 of NUREG-0700 o Scale type style (Helvetica) o Recorder Function Study _ - This case-by-case study of nineteen main CR recorders was made as a r.esult of NRC audit comnents of May 2, 1983, concerning the suitability of using single speed recorders for real-time indications.

None Each recorder was reviewed for function by two operators.

required that the operator have the capability to run out the recent records to see the parameter values. Therefore, no revisions to the recorders were recommended, o

Knurled Knob position Indicator _ - This study was made as a result of NRC audit comments of May 2,1983. The study concluded that all 71 multiple detent position knurled knob' handle controls would be replaced with lever /bar type handles. This will solve the human f actors:

o Consistency

. o Rotary detent action o Obscuring the pointer position indication o Distinguishing Legend Pushbuttons from Legend Lights - Eighteen operators and design engineers were asked to state a preference among five different legend pushbutton shape patterns. The Closed

• Corner Octogon (CCO) pattern was clearly preferred, and is the reconnended shape to be used for distinguishing all legend pushbuttons, o Annunciator Review Guide - The Control Room Design Review Annunciator Review Guide establishes the basis criteria and methodology for completion of the review of the annunciator system, including the Bypassed and Inoperable Status Lights, and the writing of the final Annunciator Study Report.

The criteria and methodology set out in this guide will be used to determine the physical parameters, alarm message, and location of each alarmed point. The alarm printout and computer I/O will be revised to reflect changes made by this study.

The annunciator study was based on criteria developed by:

o STP CRDR Criteria Report Rev.1 o STP CRDR Labeling Guide o The contents of the Annunciator Review Guide, considering:

The _ list of points to be alarmed, including any new alarm points to be added. Corbining alarm inputs to reduce the total number of alarms in the control room to reduce' operator confusion. Where multiple inputs to a window are present, the computer is used to identify the source.

The Annunciator list will be reviewed for conformance with the list of acceptable atoreviations in the Criteria Report, Appendix L. This review will assure that wording is consistent, and that the chosen wording can be fitted onto the tiles.

Priorities shall be assigned within the three categories identified in the Criteria Report, Section 8. Physical locations will be determined based upon priority, and the review team's recommendations as to the relative inportance ,

of a particular alarm, with the more important alarms being located higher in the tile array, o Evaluation cf Specified Parameters - Historically, the panel layouts for the Pressurizer, Reactor Coolant, and Steam Generator Systems included a wide variety and nunter of parameter indications. The choice of variables to be displayed has sonetimes resulted in a conflict between human factors requirenents and the need for redundancy. -

The recent availability of, the Qualified Display Processing System (QDPS) permits the coordination of the panel layout with the SPDS and the renoval of extraneous meter indications to enhance operator ef fecti veness.

The evaluation encompassed 112 meters associated with the control and protection channels of 53 parameters. The evaluation process determined that 61 meters should be deleted and 10 meters should be added.

Each case is described in detail in the reconmendations in the report. The rationale for the deletions is explained, as are.the requirements for the additional meters. Where meters were deleted,

the signal was sent to the 00PS for cross channel checking and on-demand display.

The control panel mock-up was laid out based on the results of this evaluation. A walk-through of the startup procedures, from shutdown to power, was performed to verify that only the instrumentation required to operate the plant was there and that the additional recommended instrumentation was needed.

It was determined that the operator will be able to operate better, and respond quicker with fewer errors with the new control panel design.

o Annunciator Study Report - This very complete and detailed report documents the results of the review of the plant annunciator systems, the plant computer alarm functions, and the ESF bypassed and inoperable status monitoring ' systems. The review was perforned in two phases- on the full scale CR mock-up. The preliminary review was suspended because of the large nuM)er of changes projected for the controls. The review resumed when the control board revisions were completed, considering each window for appropriateness, desirability, message, priority, and location.

The objectives of the review were to determine the human ,f actors deviations in the STP control roon annunciator system, to provide recommended resolutions, and to accomplish a functional integration of all systers that provide annunciation. The review also supplied recommendations that provided human factors engineering guidance in the Bechtel engineering upgrading program.

The tasks included a review of design documents, NRC/EPRI studies, Each the development of criteria and the preparation of checklists.

window was examined for adequacy. Revisions were made to the tile size, character size and spacing, and message content. Tiles were relocated to be near the appropriate controls, and grouped by

..- e; function. Each window was assigned the proper priority.from a choice of three levels.

The existing design was reduced from 1055 active alarns to approximately 700 by combining alarms, moving alarns to the conputer or to other locations, etc. The original 8 by 12 and 8 by 8 window There boxes were changed to 6 by 8 alphanumeric identified arrays.

are two first-out window boxes containing the highest priority alarms. Five auditory alert sound sources will be used.

The rajor Control Room Survey Report is very detailed and very voluminous, but it is not always easily possible to uncover the answers to NRC reviewer questions because the report is not formatted to match the requirements of Supplement 1 to NUREG-0737.

It does, however, identify and summarize deviations from the human factors guidelines referenced in the criteria and the special studies reports.

The CR Survey Report is divided into four volumes.

Vol I_ states that the purpose of the control room survey was to identify items that do not conform to NUREG-0700 guidelines and/or criteria in the Criteria Report . It was the objective of the Design Review Tean to:

A. Identify characteristics of the control room instrumentation and physical arrangements that may impact operator performance.

B. -Determine whether the control room provides the system status information, _ control capabilities, feedback, and analytical aids necessary for effective plant operation.

C. Provide recommendations for correcting observations based on good human f actors principles.

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The tasks of the cantrol room survey inc.uded:

A$ Prepare checklists consisting of all criteria and applicable appendices from the Criteria Report.

B. Setup computer program for sorting and reporting checklist observations (CLO).

C. Perform control room survey on mock-up.

D. Visit STP sirulator for control panel hardware evaluation.

E. Visit Westinghouse for plant computer evaluation.

F. Put checklist observations (CLO) into computer systen.

G. Present CL0 to Project Review Team (PRT).

H. Update CLO to Human Engineering Discrepancy (HED) or re-evaluate CLO. .

I. Present HEDs to Management Tean (MT).

The nine checklists are identified and titled to match the nine sections of Chapter 6 of NUREG-0700. Each checklist criterion is contained in a single checklist form,. illustrated by Figs. 2-1 and 2-2 of the CR Survey Report. Tne filled-out forms were used as CL0 data input sheets for computer program ent ry . Checklists were evaluated on a panel-by-panel, system level, whole

' ' control room, or computer. basis, as was appropriate. The communication checklist must await evaluation in the completed CR and will be reported later.-

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' HEDs after screening and evaluation by the Project Review Team and Design Review and Technical Task Team. Checklist observations and HEDs which were

' converted to. computer printout sheets are included in Vols. II, III. and IV of B through Q. Vol.11 also includes, in the CR Survey Report as Appendi' Appendix A, eight sample HEDs of various categories with illustrative figures.

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o Checklist nu2er o Panel num er o Criterion numer o NUREG-0700 reference o Category nutter o Priority o Accept yes-no (the Observation and Design Review Team recommended action)

Summarized results from the HL&P CR survey are tabulated below.

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Vol. I, also includes a sunnary of HEDs and dispositions by NUREG-0700 section cat egory .

We conclude that, when completed, the applicant will satisfy the requirement of Supplement I to NUREG-0737 to conduct a Control Room Survey to identify deviations from accepted human factors principles.

9. ASSESSMENT OF HEDs Supplement 1 to NUREG-0737 requires that HEDs be assessed to determine which HEDs are significant and should be corrected.

HL&P's Program Plan indicated that their process for selecting HEDs to be analyzed for correction was simplified from that outlined in the NRC v

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I guidelines. HEDs with safety consequences are to be assigneo to a single Category ( A). Other HEDs will be assigned to categories linted to (B) availability improvements, (C) reliability improvenents, and (D) minor improvements. All Category A, B, and C HEDs will be selected to be analyzed for correction. The described process for selecting HEDs to be analyzed for correction appears adequate to satisfy assessment and inplementation phase objectives.

Two other categories used are (D) minor, which are nonnandatory and may or may not be corrected and (E) those which cannot be assessed using the mock-up or '

simulator, and kust be assessed later on the actual CR. The results of assessing the Category (E) HEDs should be reported to the NRC for evaluation.

All observations (potential HEDs) identified by the Review Tean were processed according to the methodology presented in Executive Sunnary Report, Figs. 3-1 and 3-2. These figures 'show that the observations and reconnendations documented by the Review Team on the preprinted Checklist Observation forms (CL0s) were assessed by the Project Review Tean (PRT), and either accepted or rejected (Fig. 3-1). -

The accepted CL0s were assessed and classified into Categories A, B, C, D, or E (Fig. 3-2). HEDs in Categories A, B, C, and certain Ds were referred to the Design Review and Technical Task Tean for analysis for correction.

Correction of Category E HEDs was deferred for assessnent until the actual control room is avai.lable for review. The assessnent process is stated by HL&P to accomplish the objectives of NUREG-0700 and NUREG-0801.

We conclude that, when completed, the described process will satisfy the requirenent of Supplement 1 to NUREG-0737 to assess HEDs to determine which are significant and should be corrected.

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10. SELECTION OF DESIGN IMPROVEMENTS Supplement 1 to NUREG-0737 requires selection of control room design improvements that will correct significant HEDs. It also states that inprovenents that can be accomplished with an enhancement program should be done promptly. In the STP report, the term "inplementation" encompasses the selection of CR design improvements.

The basic scheme for selection of design improvements described in the Program Plan was consistent with NRC guidelines. The selection of design improvements appears in the results of the several special studies included in the STP DCRDR Report. The described process for selection of design improvements appears adequate to satisfy assessnent and implenentation phase objectives.

The Program Plan states that all observations assigned Categories A, 8 or C and some Category D observations are planned to be identified as Human Engineering Discrepancies (HEDs) and will be analyzed for correction, (Fig. 4-3 of the Program Plan). The first step in this process is to identify those HEDs which can be corrected by enhancement. The renaining HEDs will be analyzed to identify design improvement alternatives and to select solutions. In addition, some HEDs may be corrected through training. An integral part of this step will be a reapplication of the control room review process as appropriate to ensure that:

o Other guidelines are not violated o Other corrections are not invalidated o Any resulting increase in significance of other findings is identified and accommodated Solutions which do not bring the discrepancies into full compliance with the guidelines will be identified and justified accordingly.

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. o The Project Review Taam will submit the processed CL0s and their recommended solutions to the management team for approval. Rejected CL0s and/or solutions will be returned to the Project Review Team for additional assessment.

Approved solutions will be returned to the Design Review and Technical Task Team for implementation planning.

The results of the control room survey, the operating experience review, the SFTA, the anrunciator study, and other special studies have been detailed in separate reports. The discrepancies identified in those reports were resolved -

by the methodology described in the Program Plan and the resulting changes were or will be incorporated into the control board during the redesign and inplementation efforts.

The 816 observations (potential HEDs) and their resolutions and/or recommendations are described in several places in the HL&P Sunnary Report.

which are summarized below.

1. Control Room Survey Report - Vol. I, Section 3.0 V'ol. II, Appendix A Vol . III

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-2. Control Room Survey Validation Report - Section 3.0, Appendix A, Appendix B

3. Annunciator Study Report - Section 4.0, Appendix C 4 Executive Surrery Report - Sections 3.1,' 3.2, 4.0 (NRC In-Progress Audit) Appendix A, Appendix B, Appendix C, Appendix 0 The following reports also discuss observations and recommendations /

resolutions in narrative format, but do not formally identify then by HED nunber.

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s o Special Studies Reports (see this report, pp. 21 through 27) o Implementation Plan Report, Section 3.9 o SFTA Report, Summary, Section 6.0 o Operating Experience Review (0ER) - Section 3.0 o OER Validation Report This report does not include a detailed evaluation of results of the HL&P A summary of the results of an exanination selections of design improvements.

of selected HED. related contents of the above HL&P reports is given below. .

HL&P assessed and categorized four hundred and thirty-one HEDs as follows:

TOTAL HEDs PER CATEGORY Category A - 45 Category B - 318 Category C - 20 Category D - 48 ~

431 Category E - 218 (Not evaluated)

The HL&P report includes a ' description of all Category A HEDs (45 items) identified during the DCRDR.

The paper trail of descriptive materials for a specific exanple HED (e.g.

Sheet 875) flows through seven locations in several volumes of the report.

The cultiplicity of documents described below was difficult to unscrarble.

- _39

(1) ryecutive Surrery Report, Section 3.1 3.1 Assessnert Results "A"

The following summarizes the status of the forty-five (45) Category HEDs identified in this program. Appendix A contains the detailed disposition of the Category "A" HEDs:

1. Relayout of panels for functional grouping of associated system or subsystem devices, or relocation on an appropriate panel to minimize operator movement or to f acilitate task sequence, or to acconnodate f requency of usage.

Sheet Nunbers - 511, 526, 530, 568, 569, 570, 572, 573, 574, 575, 576, 577, 578, 593, 594, 598, 599, 600, 603, 604, 605, 875 (2) Executive Summary Report, Appendix A Workspace HE'D Category A HF Area -

Sheet Nunber Observation or Disposition Reference Criteria Title Paragraph

1. Need AFW Flow Indication 1. AFW flow controller was 5-875 relocated on panel 006 P-6.1.1.1 related to flow controller near indicator Need ECW purp disch. flow 2. ECW Flow Data

2. in database for was incluceIl display o-indication QDPS plasma display

(3) Executive Summary Report, Appendix 0 Appendix D - List of CLO/HEOs vs. CRS Report Page No. Sheet No. Volume Page No.

Sheet No. Volume _

P9 872 II E67 822 IV G7 873 II E69 823 III P10 874 II E48 824 IV Pil 875 II 81 825 IV P12 876 III 166 826 IV P13 877 II E62 .-

827 IV P14 878 II E43 828 IV P15 879 II E44 829 IV (4) Control Room Survey Report, Vol . I, pg. 3-6, Section 3.3.1.2 3.3.1.2 Workspace HEDs The following is a sunmary of HEDs from the Workspace Checklist:

a. Observation: STP operators' identified the need for auxiliary feedwater flow indication to relate to the flow controller and a need for ECW pu@ disch5rge flow indication (sheet nutter 875 -

Appendix B, page 2).

Disposition: Relocate auxiliary feedwater flow indicator to panel CP-006 and provide ECW flow. (Category A)

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l. NEED AUE FEEO WATER FLOW IMOICATION TO RELATE TO FLOW CONTROLLER,

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(6) CR Survey Validation Report, Section 3.0 3.0' Conclusions 3.1 Category "A" HEDs The following Category "A" HEDs were resolved by the revised panel layouts as detailed in Main Control Panels - Equipment Layout Drawings 5-Z34-1-Z44501 through ~9-234-1-244508. Appendix A contains the data for the resolution of Category "A" HEDs.

Workspace - HED-875 (7) CR Survey Validation Report, Appendix A_

This Appendix A is a duplicate of Appendix A in the Executive Sumnary Report. (See (2) above.)

This kind of paper trail is typical of all HEDs.

These are: sheet nutter 367, Three Category A HEDs renain to be resolved.

which addresses the color green Rototellite indicator lights which cannot be distinguished when lit; sheet nurber 726, which identifies the bypass and inoperable status 1.ight legends as being unreadable due to narrow stroke width and inadequate character separation and line spacing; and sheet nurter 727_,

which states that legend messages contain more than three lines of text.

Resolutions of these unresolved Category A HEDs should be reported to the NRC for review and evaluation.

The Sumary Report includes a similar descriptive paper trail for a representative sampling (about 11 percent) of the total nurter of Category B HEDs.

6 The following Category B HEDs were stated to remain unresolved:

Sheet number 376_ concerning the scaling on the paper for recorder XR 6008 has not been resolved. Sheet number 6 concernino the lack of reter zone markings will be resolved through a technique that will be applied on a case-by-case basis in the field.

Since the above comments apply only to a sampling of Category B HEDs, it is When resolved, these assuned that other similar unresolved open iters exist.

unresolved HEDs should be reported to the NRC for review and evaluation.

Category C HEDs_ are mentioned in Fig. 3.2 of the Executive Summary and described as " Reliability Enhancenent" itens with corrections to be implemented at a convenient outage.

Category C HEDs and dispositions are described in the CR Survey Report, Vol. I, Section 3.3, but are interningled with and not separated fror other HEDs. .

In some cases, the dispositions are not specific (e.g., develop a color coding The CR Survey Report is not' dated, and an inplementation schedule scheme).

for corrective actions is not stated. The applicant should describe and schedule specific corrective actions for all HEDs for NRC review and evaluation.

Category 0 HEDs_ are described in the CR Summary Report, Vol. I, Section but are intermingled with and not separated from other HEDs.

Most of the dispositions reported are nonspecific (e.g , " provide enhancements within the existing computer system capability" or " upgrade within system I

capability if practical" or " Westinghouse will make changes within updated software") and are not listed for implementation on a stated tire schedule.

The applicant should describe and schedule specific corrective actions for all HEDs for NRC review and evaluation.

Category E Criteria (observations / potential HEDs) occur in areas that rust be These addressed when the CR is constructed and the panels are installed.

potential HEDs are distributed as follows:

Total Described in Checklist Category E CR Review Criteria Criteria Report Appendix Checklist  :

76 J 1 - Workspace 109 48 K 68 2 - Comnunications 14 L 3 - Annunciators 104 1 M 4 - Controls 62 33 N S - Visual Displays 112 63 3 0 6 - Labels 37 P 7 - Plant Computer 237 24 0 None 8 - Panel layout 37 6 0 9 - Control / Display Integration 816 - 218 237 None SPDS Corputer The observations are described in the HL&P CR Review Report ' Appendices listed There is no appendix listed for the SPDS computer. A in the table above.

narrative description of 18 Category E criteria that will be checked for compliance with the guidelines is listed in item 16 of Section 3.2 of the Executive Sunnary Report. The areas of concern, including the SPDS corputer, are listed in the CR Review Report, Vol. I, Section 3.3, but the HEDs and When the work is completed, the dispositions are not described in detail.

applicant should submit for NRC review and evaluation a description of the HEDs, dispositions, and the implementation schedule for corrective actions.

There is a discrepancy between the 218 Category E items above and the 55 mentioned in the Executive Summary Report, pg. xiii which should be explained to the NRC.

The Executive Summary Report. Appendix C describes and justifies three deviations from the Criteria Report guidelines. One of these concerns the need for inoperative panel instrunents to be apparent to the operators. The justification in Appendix C for use of non-off-scale indication type instruments is that (a) the 00PS systen performs cross-checking and can provide the operator with a quality tag for each output, or (b) that the ,

operator can cross channel check with redundant meters. However, in the CR Summary Report, Vol.1, Section 3.3.5.2e, a statement is made that failed meters will be made apparent by setting the indicating needle off-scale. The two differing statements should be reconciled and explained for the NRC for their review and evaluation.

The CRDR NRC In-Prooress Audit Review is discussed in the Executive Sunnary in Section 4.0.

HL&P requested an NRC in-progress audit of the STP CRDR in order to receive NRC review conments of the redesigned rain panel layouts prior to issuing a release to nanufacture panels 001 through 010. The audit was conducted from May 2 through May 6,1983 at '.he mock-up f acility in Bechtel's Houston engineering f acilities and consisted of walk-throughs, document reviews, briefings, and discussions. The results of this audit are reported in a letter f rom Knighton to Goldberg dated October 31, 1983 (Docket Nos. 50-498 a'nd 50-499).

In Section 4 of the Executive Summary, HL&P has acceptably addressed and responded in detail to the concerns expressed by the NRC during the in-progress audit and to HEDs generated by the limited independent CR survey conducted by the NRC.

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• These responses are related to and coordinated with HL&P DCROR HEOs and dispositions reported in other parts of the HL&P Summary Repor*., and connented on elsewhere in this report.

A sumary of 15 other items of remaining work which cannot be completed until the CR and/or simulator is operational is described in narrative forn in Section 3.2 of the Executive Summary Report. It is stated that seven of these items will be sample-checked to verify compliance with the guidelines and/or recommendations. The applicant should report the rationale and justification  :

for sample vs.100 percent checks for NRC review and evaluation.

The HL&P Schedule for completion of all planned CROR work is stated in general terms in Section 5 of the Executive Sumary Report. There is no schedule specifically identified with the implementation of HED corrective actions.

The schedule is stated in terms of four major plant milestones as follows:

"All items will be completed prior to fuel loading. HL&P will submit a supplementary executive summary report to conclude the CROR reporting within a period of three months foll'owing the completion of fuel loading.

5.1 COLD HYDR 0 o Random label checkout (including readability from nornal control roon positions).

o Check of vertical meter pointer painted red.

o Check if. demarcation painting conplies with the recommendations of the Denarcation Study.

o Verify the implementation of the use and control of tenporary labels.

o Validate the correct usage of lamp replacement legend raps.

o Check of labels to correct identifying meaning of some status lights when lit (Sheet No. 0792).

5.2 ENERGIZATIOR

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o Check of annunciator tiles for compliance with the annunciator 4  ; study results.

o Check of switch handles vs. readability of switch position.

!( o Check for compliance of meter scale markings.

o Random check of legend light engraving and " closed corner" markings.

5.3 HOT FUNCTIONAL o Resolve and validate correction of Rototellite color problen, and

( sample check of their engraving.

4 o Resolve and validate' correction of poor readability of the BYPASS / INOPERABLE status lights.

o Checkout the 0DPS plasma displays.

o Checkout-the effectiveness of annunciator horns.

o Resolve and validate correction of the problem for some meters to fail off-scale.

o Complete the review of the Human Engineering suitability and arrangenent of panel- dev' ices.

o Resolve and validate correction for the problem for those switches that.-are difficult to turn.

o Check of the inadvertant actuation and accessibility of controls to operators.

o Check of recorder paper and accessibility of supplies.

y 5.4 FUEL LOAD o Review and assessment of all Category E criteria (see Iten 16 of Section 3.2).

o Complete val.i'dation of E0Ps.

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, . 1 o Control Room Survey check of control room desk type stations used during plant operations."

The We question the adequacy of the random check of some items above.

applicant should report the rationale and justification of such checks to the NRC for review and evaluation.

We conclude that HL&P intends to meet the requirement of Supplement I to NUREG-0737 to select design improvenents that will correct significant HEDs.

However, the app.licant should supply the additional information as described earl.ier in this section so that the NRC can determine that this requirement has been met.

11. VERIFICATION THAT DESIGN IMPROVEMENTS PROVIDE NECESSAR NOT INTRODUCE NEW HEDs Supplement 1 to NUREG-0737 requires verification that selected design improvements will provide the necessary corrections of HEDs and will not introduce new HEDs into the CR. Information from the control roon inventory Those activities, as and SFTA are needed for the verification process.

planned and conducted, were capable of- providing the needed information.

The Executive Sumnary (Section 2.3.3.2) states that after the redesign of the I

main control board layout was completed, the SFTA was reviewed to verify that The the observations (HEDs) had been corrected and no new ones introduced.

operator task identification sheets for the six selected (operational) events were revised to show the new locations of devices, both within panels, and between panels. In some cases, devices had been removed or added, requiring The traffic l.

the revision of the instrument detail section of these forms.

link diagrans were then revised to reflect the movement of instruments from

panel-to-panel . The spatial operational sequence diagrams were revised to

. reflect the relocation of subsystens and of instruments within a subsystem.

The six sets of diagrams were then evaluated for efficiency of operator motion. ,

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The new layout resulted in significant improvement in the functional arrangement of the control boards. Operator travel between boards was reduced. The summary of this review in the SFTA Validation Report states that the walk-through/ talk-through validation effort showed that the control room crew could accomplish the allocated control room functions as defined in the nornal and emergency operating procedures. No additional observations of potential HEDs were identified during the walk-through/ talk-through.

We conclude that, for corrected and inplemented HEDs covered in the present report, HL&P has partially satisfied the requirement of Supplement I to NUREG-0737 to verify that selected design improvements will provide the necessary correction and will not introduce new HEDs. Open HEDs requiring further evaluation and implenentation should be reported to the NRC in the sane manner so that it can be determined if this requirement is fully satisfied.

12. COORDINATION OF CONTROL ROOM IMPROVEMENTS WITH OTHER PR Supplement 1 to NUREG-0737 requires that control room inprovements be coordinated with changes from other progr'ams; e.g., safety parameter display system (SPOS), operator training, Regulatory Guide 1.97 (RG-1.97), and emergency operating procedures (EOPs).

The Executive Summary Report states (pg. x, xi) that the CRDR Prograr was based on an overall HL&P plan to integrate (coordinate) the following pertinent TMI action plan (NUREG-0660) and NUREG-0737 Supplenent I related acti vities.

1. Inplenentation of a safety parameter display system (SPDS)

2. Implenentation of Regulatory Guide 1.97 instrunentation for minimizing risk to plant safety 4

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3. Implementation of instrumentation to monitor critical parameters following an accident ', post-accident monitors)

4. Training to enhance coping with emergencies

5. Development of symptom-based emergency operating procedures (E0Ps),

and

6. Design of emergency response f acilities. .

The Criteria Report specifically addressed post-accident monitoring (Section 9), bypassed and inoperable status (Section 10), safety paraneter display system (SPDS) (Section 11), and plant computer features (Section 12) in the control roor. In addition, the relayout of main control panels described in the Implementation Plan Report indicated specific examples of DCRDR The coordination with the post-accident monitoring and SPDS activities.

decision to proceed with the DCRDR prior to completion of operating procedures and training was noted in the Program Plan and provisions were made to assure proper consideration of the effects of DCRDR CR changes on future operating procedures and training. .

The Executive Summary Report (Sections 4.2.3 and 4.2.4) states that HL&P is committed to continuing to apply the benefits of the CRDR Progran as appropriate and that finalized E0Ps will be validated in accordance with NUREG-0737, using a staff that will provide continuity with the CRDR Design Review Team.

The Criteria Report, Appendix T, describes a rethodology to

! assure that good human factors principles will be applied to'all future changes.

The implementation Plan Report, Appendix A, presents the paraneter requirements related to Reg. Guide 1.97 which includes paraneter, range, category, and other detailed information on the displays and controls that

- must be added or are already on the panels. There were about 100 of these

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e changes, primarily for safety related systems. These are described in Section 4.0 of the Implementation Plan Report.

Based on our review, we conclude that when the coordination effort is complete, HL&P will meet the requirenent of Supplement I to NUREG-0737 to coordinate control room improvenents with changes from other prograns.

13. CONCLUSIONS The ruiti-volume South Texas Project summary report submitted by Houston It Lighting and Power Company is complete, voluminous, and of high quality.

is obvious that HL&P intends to meet the requirement of Supplement I to NUREG-0737. The report consists of the CRDR final reports identified in the References.

Our review of the STP Summary Report was oriented toward deternining if the requirements of Supplement 1 to NUREG-0737 will be met. We conclude that HL&P should be able to meet these requirements following the clarification by HL&P of exceptions which are noted below and -the submittal of presently incomplete information.

Areas needing clarification or additional information are listed below.

This Report Section Page Comment 6 11 Confirm that information and control needs were adequately identified and satisfied by available instruments and controls.

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6 11 Describe how it is intended to accomplish Itens 2, 3, 4 of the NRC April 5,1984 Memorandum.

6 16 Advise resolution of the single HF exception found during walk-/ talk-through validation.

6 18 Provide information which will substantiate chat information and control needs were determined by an independent, objective analysis.

- n This Report Section Djage Comment 8 21 Provide information concerning present status of the sit-down control station design.

8 22 Provide information and conclusions about supplementary assessment of use of smaller operat ors.

8 22 Provide results and conclusions of supplenentary assessment of use of extended functional reach criteria for narrower percentile subjects. .

8 29 Provide results and resolutions of the evaluation and assessnent of the computer checklist.

9 33 Provide results and resolutions of the asssssment of the Category E HEDs.

10 43 Provide results of the resolutions of the three Category A HEDs.

10 44 Provide results of the resolutions of all unresolved Category B HEDs.

10 44 Provide descriptions of specific corrective actions and implementation schedules for Category C HEDs.

10 45 Provide descriptions of specific corrective actions and implementation schedules for Category D HEDs.

l~ 10 45 Provide descriptions of the HEDs, dispositions, and implementation schedule for Category E HEDs.

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10 46 Reconcile the discrepancy between the stated number of Category E items.

I I 10 46 Reconcile the discrepancy between the two stated resolutions of th,e problem of alerting operators to the existence of inoperative panel instruments.

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! 10 47,49 Provide explanation of the rationale and I justification for random / sample vs. 100 percent checking of items.

10 47 Provide more specific HED inplementation schedule l

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- m, REFERENCES

1. NUREG-0660. "NRC Action Plan Developed as a Result of the TMI-2 Accident," May 1980; Revision 1, August 1980.

2. NUREG-0700, " Guidelines for Control Room Design Reviews," Septert)er 1981.

3. NUREG-0737, " Clarification of TMI Action Plan Requirements," Noverber 1980; Supplement 1, Decent >er 1982.

4 NUREG-0801, " Evaluation Criteria for Detailed Control Room Design Reviews," October 1981, draft report for comment.

5. NUREG-1000, " Generic Implications of ATWS Events at the Salen Nuclear Power Plant," April 1983.

6. Generic letter 83-28, " Required Actions Based on Generic Implications of Salen ATWS Events." July 8, 1983.

7. Menorandum from H. Brent Clayton, Section Leader, Procedures and Systens Review Branch,' Division of Human Factors Safety, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission to Dennis L. Ziemann, Chief, Procedures and Systems Review Branch. Subject

" Meeting Summary--Task Analysis Requirements of Supplement I to NUREG-0737--March 29,1984 Meeting with Westinghouse Owners Group Procedures Subcommittee and Other Interested Persons," April 5,1984

8. Letter to T. M. Novak, Assistant Director for Licensing, Division of Licensing, NRR, USNRC from J. H. Goldberg, Vice President--Nuclear Engineering and Construction, HL&P. Subject, " Control Roon Design Review 20, 1982.

Program Plan," for STP Units 1 and 2, dated October

?.

9. Letter to D. G. Eisenhut, Director, DOL, NRR, USNRC from J. H. Goldberg, HL&P. Subject, " Response to Supplement I to NUREG-0737 Requirenents for Energency Response Capability," for STP Units 1 and 2, dated April 14, 1983.

10. Meeting Summary by A. Vietti, Project Manager, Licensing Branch No. 3, D0L, NRR, USNRC. Subject, " Summary of Meeting - TMI Action Plan Requirements," dated February 13, 1984.

11. Letter to T. M. Novak, Assistant Director for Licensing, DOL, NRR, USNRC f rom J. H. Goldberg, HL&P. Subject, " Submittal of Control Roor Design Review Final Reports," for STP Units 1 and 2, dated April 12, 1954 References Provided as Control Room Design Review Final Reports

1. Progran Plan, Revision 1, March 31, 1983.

2. Criteria Report, Revision 2, March 27,1984

3. Operating Experience Review Report, Revision 0, March 25,1983.

4 Systen Function and Task Analysis Report, Revision 0, March 25,1983.

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5. Control Room Survey Report - Volume I, undated.

6. Control Room Survey Report - Volume II, Revision 0, March 30,1984

7. Control Room Survey Report - Volume III, Revision 0, March 30,1984 l

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8. Control Room Survey Report - Volume IV, undated.

j 9. Annunciator Study Report, Revision 0, March 29,1984 l

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10. Special Studies Report, Revision 0, March 30,1984

11. Imp 1'ementation Plan Report, Revision 0, March 26.1983.

12. System Function and Task Analysis Validation Report, Revision 0, March 19, 1984

13. Operating Experience Review Validation Report, Revision 0, March 7,1984 14 Control Room Survey Validation Report, Revision 0, March 19,1984

15. Executive Sunmary, Revision 0, February 27, 1984 6

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