ML20129C386

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Control Room Design Review Supplemental Rept 2 to Final Rept of June 1984
ML20129C386
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/30/1985
From:
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20129C367 List:
References
NUDOCS 8507160177
Download: ML20129C386 (108)


Text

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< Q .. , ,,4 PHILADELPHIA ELECTRIC COMPANY'S LIMERICK GENERATING STATION CONTROL ROOM DESIGN REVIEW SUPPLEMENTAL REPORT 2 TO THE FINAL REPORT OF JUNE 1984 JUNE 1985 8507160177 850628 hDR ADDCK 05000352 PDR

TABLE OF CONTENTS SECTION TITLE PAGE Introduction 1 I Methodology 3 II General Findings / Implementation 8 III Modified HEDs/ Assessment of 14 Outstanding HEDs LIST OF APPENDICES APPENDIX TITLE PAGE A Limerick Task Analysis A-1 Worksheet B Team Brief for Task B-1 Analysis C Key to Task Analysis C-1 Worksheet D Task Analysis Guidelines D-1 E Resume of Task Analysis E-1 Expert F Limerick Task Analysis F-1 HEDs (Human Engineering Discrepancies)

G Modified HED Resolutions G-1 H Assessment of Outstanding H-1 HEDs i

LIMERICK GENERATING STATION CONTROL ROOM DESIGN REVIEW SUPPLEMENTAL REPORT 2 INTRODUCTION This is Philadelphia Electric Company's (PECo) Detailed Control Room Design Review (DCRDR) Supplemental Report 2 for the Limerick Unit 1 Nuclear Generating Station. This report documents the results of the formal task analysis conducted as part of the overall DCRDR effort. On November 2, 1984, PECo submitted to the Nuclear Regulatory Commission (NRC) the DCRDR Supplement 1 of the Final Report, which documented results of DCRDR activities that had been completed subsequent to the submittal of the DCRDR Final Report of June 25, 1984.

Plant-specific emergency operating procedures (EOPs) were pre-pared and implemented for Limerick in accordance with a Procedure Generation Package sent to the NRC with a June 19, 1984 letter from S.L. Daltroff to A. Schwencer. This procedure generation package was found to be acceptable by the NRC in the Limerick SER, Supplement 2, Section 13.5.2.3.

The process by which these plant-specific EOPs were developed and proofed was described in the Limerick DCRDR Program Plan, dated August 1983. These procedures form the Transient Response Implementation Plan (TRIP). There are 11 TRIP procedures that cover the symptom-oriented EOPs for the Limerick plant. The DCRDR Supplement 1 of the Final Report of November, 1984, described the validation walkthrough conducted using the TRIP 1

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o procedures. PECO committed to perform a Task Analysis to com-plete the DCRDR in a letter from J.S. Kemper to A. Schwencer, dated August 16, 1984.

This document consists of three major sections: Methodology, Findings and Implementation, and Modified HEDs/ Assessment of Outstanding HEDs.

Section 1, Methadology, discusses the specific methods used in performing the actual task analysis and verification, including the use of the control room mockup.

Section 2, Findings and Implementations, delineates the types of Human Engineering Discrepancies (HEDs) identified during the task analysis process and discusses the actual resolution of the HEDs identified. Copies of HED Assessment sheets from the task analysis appear as Appendix F.

Section 3, Modified HEDs/ Assessment of Outstanding HEDs, contains two subsections, Modified HED Resolutions, and Assessment of Outstanding HEDs. The Modified HED Resolution section deals with HEDs that have had resolution modifications based on engineering and design considerations. These 22 HEDs appear as Appendix G. The Assessment of Outstanding HEDs section discusses those HEDs that remained unresolved when the Limerick Plant CRDR Final Report was submitted. These four HEDs have been assessed and appear as Appendix H.

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SECTION I METHODOLOGY The task analysis process used the approved TRIP procedures as the functional analysis. The plant specific procedures developed from the BWROG EPGs are satisfactory for use as a functional analysis per the BWROG meeting with the NRC on May 4, 1984.

These procedures provided the definition of functions from which the task analysis was conducted. The task analysis was performed in accordance with NUREG 0700, paragraph 3.4.2.4., and SRP 18.1, Appendix A, Sections 2.2 and 2.3. The analysis commenced on March 12, 1985 and was completed on April 16, 1985. The analysis was performed by a team consisting of a nuclear /I&C engineer (Thomas Cabrey) ; two human factors specialists (Richard Morrison and Ralph Chidley), and two licensed operators on Limerick Unit 1 (Rick Cendrella; Joe Coyle). The Task Analysis Expert's resume appears as Appendix E. The analysis team had ready acce,ss to, and used, other licensed operators and engineering personnel for support as required.

The process was performed in two separate steps. The first was to determine the display and control requirements for the control room instruments. In order to do this, an analysis of tasks required to accomplish the functions was performed. These tasks included defining the parameters necessary for the operators to determine the need to perform an action, performing the action as directed by the TRIP procedure, and defining the parameters 3

o necessary to determine that the action had been performed successfully. The second step was to conduct a verification that the control room inventory met the stated display and control requirements that resulted from the analysis of tasks to identify missing displays and controls. The form.used to record the information generated from these two steps is enclosed in Appendix A.

In the first step, the analysis was conducted in a location where the team would be less likely to think about the existing controls and displays on the control panels. A written briefing of task analysis was provided to the team by the Task Analysis Expert to educate the team on what was to be done and how it was to be'done. This briefing is enclosed as Appendix B. The team then discussed the written briefing. All questions and key points were explained. During this step of the analysis, only the left half of the Task Analysis Worksheet, labeled Task and Requirements, was completed. The information was recorded in accordance with the Key to Task Analysis Work Sheet, which is enclosed in Appendix C. All 11 TRIP procedures were talked through in this manner.

TRIP Procedures: T-100's T-99 Post Scram Restoration T-130 Scram T-101 RPV-Control T-102 Containment Control T-lll Level Restoration T-ll2 Emergency Blowdown T-ll3 Blowdown Cooling T-ll4 Spray Cooling T-ll5 Alternate Shutdown Cooling T-ll6 RPV Flooding T-ll7 Level / Power Control 4

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o After the completion of the requirements section of the Task Analysis, the team reconvened in the control room of Limerick, Unit 1. The control room itself was used for the control room inventory. The team reviewed the verification procedure provided in the written briefing, and the key points were discussed. Using the task steps and the display and control requirements, the-availability section of the form was completed by talking through each step, having the operators indicate which instruments and controls would be used to accomplish the steps, and recording the characteristics of the designated existing instruments. The team then performed a comparison of the designated instrument with the display and control requirements of the task analysis. Any verification entry that did not meet the display and control requirements section was documented a's a note at the bottom of the Task Analysis form and subsequently written as a HED.

During this verification process, the team also addressed the suitability of those designated instruments. This included a consideration of.the relationship of control and displays. To aid the team in assessing human factors considerations for the suitability of the instruments, each team member was provided with a copy of the Task Analysis Guidelines during the briefing for the Verification phase. A copy of the Guidelines is included in Appendix D. The final overall suitability of each entry was then determined by the team to be either satisfactory, or to require preparation of a Human Engineering Discrepancy (HED) 5

o Assessment sheet. Where necessary, information and corroboration from other licensed operators available in the were sought control room during the verification. Information was recorded on Key the form in accordance with the Verification section of the to Task Analysis Work Sheet (Appendix C).

This process for the determination of the control and display requirements, HED assessment, and verification is the same as used at the Peach Bottom plant, which was reviewed by the that NRC during the In-Progress Audit for Peach Bottom on February 19 to 22, 1985. The NRC Audit Report, transmitted in the April 19, 1985 letter from J.F. Stolz to E.G. Bauer, Jr . , found this process to be satisfactory.

The T-200 procedure series supports the TRIP Procedures. The T-procedures were reviewed and found to contain mostly system 200 lineup instructions for both control room and floor operators.

Since the lineup instructions called for specific controls in the control room, the availability of these controls was verified.

(These procedures were used during the validation walkthroughs in the Limerick Supplement Number 1 Re7 ort of November reported that pertain to 2, 1984.) For each of the T-200 Procedures control room operators, a task analysis similar to that conducted identify information needed, on the TRIPS was performed to actions required, and feedback information required to determine the action was performed successfully. These actions that involved only one or two steps after a system lineup typically 6

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identified and the verification section' was completed as previously described.

i During the analysis of TRIP p'rocedure tasks described above, there were certain system lineups for, specific operations that were lengthy and werefrequired ~in'several procedures. These involved merely providing controls with appropriate feedback for accomplishing these system lineups. These sections were referred to a separate lineup analysis for the specified operations. The analysis consisted of using existing lineup sheets also used for Limerick Unit 1, and identifying those controls that were re-quired.to be in the control room. Availability of these controls in the control room was verified as having appropriate indicat-ing lights, which provide appropriate feedback to the operator.

This completed the task analysis of_ emergency proced'ures and supporting procedures.

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6 SECTION II FINDINGS AND IMPLEMENTATION This section delineates the findings resulting from the task analysis portion of the Detailed Control Room Design Review (DCRDR) effort and the solutions implemented in each case. In

< summary, 36 HEDs were identified during the course of the task y analysis process. The HEDs have been classified, and assigned 5'

i' ' a safety significance as follows:

Panel Design: 2 Priority 2: 18

, Instrumentation: Priority 4: 1 Suitability 15 Acceptable, or 1 Not a

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, Resolution 19 Discrepancy 17

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'd Total 36 Panel Design Because of the high density of components in the control room, controls and associated instrumentation were found to conform to human factors distance guidelines. In certain instances, the lateral distance between related components was felt to be exces-1 sive, but still within guidelines; this was the case on panel 10C-653, where the " Bypass Jack Control" (HED TA-05) was separ-ated from the " Reactor Pressure" indication by a distance of 6 feet. A related " Steam Line Pressure" gauge was located 8

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D immediately above the jack control. This provided the operator with immediate feedback regarding jack operation and reduced necessity for immediate operator movement to view the the

" Reactor Pressure" indicator.

indicators used for The selection of similar scales for

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E control room operations was very comparative reading during effective. The narrow range Reactor Pressure recorder XR01-IR609 located on the 10C-603 panel however, was found to. use a different multiplier (x10) than other reactor pressure indicators (HED TA-03). It was determined by the team that the use (x100) of a 100 multiplier on the narrow range Reactor Pressure recorder would be unsatisfactory, as it would require a pressure reading of 8.5 and 10.5 PSIG on the scale and the decimal could cause operator error during time-sensitive operations. The team resolved the problem by recommending that the scale not use a multiplier at all. This resolution will allow personnel to more easily determine pressure on the scale without the potential problems of a decimal. The remaining reactor pressure scales all use a 0-12 or 0-14 PSIG scale with a x100 multiplier and were considered adequate for their purpose.

Instrumentation The majority of discrepancies identified during the task analysis involved panel instrumentation and fell within two categories:

instrument suitability and instrument resolution.

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a Instrument Suitability -

In almost all operational situations, the proper instrumentation was readily available to personnel in the control room. In several cases, however, the team identified instrumentation that was not convenient for operator use. This was especially noted with regard to a summary of containment isolations. In situations where containment isolations would occur, no summary of isolations exist (HEDs TA-01, TA-02, TA-15, TA-16). Operators currently have to review the various system valve position indications in order to properly determine if isolation has occurred. This will be remedied upon the completion and turnover of the Safety Parameter Display System (SPDS), which will provide a summary of all isolations to the operators. Control panel enhancements reported in the Final Report enable operators to more clearly identify system and containment isolations, on two occasions, the team identified where additional alarms appeared to be needed in the control room. Upon more detailed investigation, the team recommended that " Suppression Pool . Low Level" (HED TA-20) and "Drywell High Temperature" (HED TA-22) annunciator alarms be added to the appropriate panels.

i The Boron Injection instrumentation lacks.a flow meter for direct determination of system flow. This was not considered a discrepancy because the addition of a flow meter would not add to or alter the process of performing the TRIP function (HED TA-17).

In addition, no direct instrumentation for the determination of 10-

the amount of boron injected was identified. However, the procedures describe in detail the calculation required for .the operators to determine the amount of boron injacted. The operators are not subject to time pressure when they pe;*orm this calculation because the system is not shut down until the calculation is completed. Consequently, this was not considered to be a discrepancy. Similarly, HEDs TA-9 4, 07, . 06, 12, 19, 21, 23, ' 24, 25, 26, 28, 32, 35, and 36 were not determined to be HEDs as discussed on HED assessment sheets in Appendix F.

The ADS Timer does not provide the operator with sufficient feedback to indicate that the logic has been reset (HED TA-09).

This problem has been temporarily resolved by placing the internal switch on the " ADS Timer Initiated" system annunciator in the auto-reset mode to allow the' annunciator to automatically clear when the timer reset button is depressed, the annunciator will annunciate when the reset button is released. This will provide the operator with sufficient feedback to indicate that the logic has bee'n reset. The final resolution will revis# the TRIP procedure prior to the completion of the first refueling outage to use newly installed auto-inhibit switches that defeat auto-initiation of ADS. All oth'er instrumentation in -the control room was sufficient.

44 Instrument Resolution - As discussed in the previous section, appropriate instrumentation required by procedures was available in the control room, however, several procedures required operators to identify values that were not readily available on 11

the associated indicator display scales. For example, the reactor' level indicator LI42-lR604 uses a scale of +60 to -150 inches with increments of five inches. Procedure T-101 RC/Q requires the operator to identify a value of -38 inches (HED TA-13). Clearly this level cannot be easily determined by operations personnel. Discrepancies such as this (HEDs TA-06, 10, 11, 27, 29, 30, 31) were resolved through the development of an enhancement philosophy which uses a combination of zone markings to modify necessary meter faces to provide the operator with the appropriate information. Care was taken to ensure that colors used for zones conformed to the overall control room enhancement philosophy delineated in the Limerick CRDR Final Report.

Reactor power recorders C51-R603A, B, C, and D use a 0-125 percent scale accurate to +2.5 percent. Several procedures require operators to identify a power level of 3 percent (HEDs TA-14, TA-18). While this is not identifiable on the existing scale, no modification was considered necessary since all APRM downscale indicator lights are energized at less than 3 percent power, IRM's selected to range 10 will provide an adequate scale

! resolution at 3 percent power, and accurate information provided by the plant-process computer.

.In one instance, the team determined that modifying the display scale would violate human factors guidelines and the availability of computer backup was not felt to be sufficient (HED TA-33).

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RPV ' Pressure recorder LR42-lR623A, B uses a scale of 0-1500 PSIG and can be read to a resolution of +10 PSIG. Procedures T-115 and T-ll7 require operator identification of 154 and 255 PSIG pressures. These scales will be revised and enhanced to clearly identify these pressures. Similarly, the drywell reference leg temperature must be read to determine saturation at 212 degrees, but can be read only to an accuracy of 10 degrees F (HED TA-34).

The SPDS will provide more convenient identification of these points when operational.

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SECTION III MODIFIED HEDs/ ASSESSMENT of OUTSTANDING HEDs Modified HEDs This section discusses previously submitted HEDs that have since had minor changes. These HEDs appear as Appendix G. These modifications in no way change the intent of the original resolutions.

e Eight.HEDs were updated with regard to the schedule for implementation of their resolutions:

- Al-03 - SA2-02

- Al-06 - SDV-03

- Al-07 - SPV-06

- Al-08

- A l- 0 9 e HEDs changed for the purpose of clarification:

- HED SD4-02: revised in order to clarify color conven.-

tions.

- HED SIl-03: revised to specifically address human

, engineering discrepancy as listed.

- HED SIl-06: ID or Number was changed to reference an FSAR table to clarify exact instruments involved. The original attachment deleted.

- HED Al-01: revised to clarify intended numbering se-I quence.

- HED D2-13: revised 2nd paragraph of attachment to say l "...recombiner inlet valve" instead of ...recombiner cooling water inlet valve."

- HED I2-ll: minor changes in wording to clarify intent.

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- HED D3-09: reference added to clarify intent.

- HED SD4-02: revised to clarify color conventions.

l - HED D2-10: provides for interim resolution until the final resolution is implemented.

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- HED D5-02: corrected typographical error in ID.

- HED SPV-02: clarify identification of opening sequence.

e Three HEDs were modified so as to prevent occurence of a new HED:

HED 12-03d and 12-14: original resolution clarified so as to prevent creation of a new HED.

HED. SI5-05: operators to be supplied with a portable adapter instead of a mushroom handle, which would have caused another HED.

Outstanding HEDs At the time of submittal of the Limerick DCRDR Final Report, four HEDs' remained outstanding. These HEDs, with final Resolutions, appear as Appendix H.

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Appendix A Limerick Task Analysis Worksheet i

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Appendix B Team Brief for Task Analysis l

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Appendix B TEAM BRIEF FOR TASK ANALYSIS The task analysis will be performed by the Limerick team using the Transient Response Information Plan (TRIP)

The analysis is divided into two distinct phases. procedures.

phase determines the REQUIREMENTS for panel The first controls to support the TRIP. instruments and the available panel instruments The and second controlsis meet a VERIFICATION that the require-ments of the first phase.

REQUIREMENTS PHASE In this phase of the analysis, the team must establish the requirements team for control room panels to support TRIP. To do this, ments members that existare asked not to think of the controls and instru-in the control room, but to concentrate on systems requirements and actions.

Think in terms of what the systems are doing and what is required to be done in the systems.

operators will find it difficult not to think of the control room components, with which they are familiar, but should understood that the existing components might not be exactly what is needed for a specific step. Not all indications'provided are used for a particular operation, and sometimes additional help in controlling the plant. Do not limit your contributionindications could to what is available.

The team should realize that what is said during the task analysis is not final. Although the analysis lists a not now provided on the panels, requirement that it will be provided later. this does not necessarily mean listed requirement is not needed. Further study may show that a On the other hand, not specifying the need for an instrument on a particular does not mean operation that an existing instrument will be removed. This analysis must be a best attempt to specify the CHARACTERISTICS of instruments required for each specific step, based upon the team's combined experience and expertise. This analysis phase must be independent of what already exists.

VERIFICATION In this phase the team is asked to reverse its previous approach, phase, and think of what exists in the control room. For this the team will have contro) panel prints and other informa-tion and listings for reference. The team may have access to the control room for this phase. The intent in the VERIFICATION phase is to ensure that what does exist in the control room meets all the REQUIREMENTS specified in the first phase of the analysis. By comparing problems with what exists with what is required, we can identify any the control room instrumentation and controls in support of performing the TRIP procedures.

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PROCEDURE FOR ANALYSIS The method to be used in the firnt phase of the task analysis will consist of reading each step of the TRIP and then specifying what actions must be taken to carry out the step. Where the opera-tor will need information, the team will specify the characteris-tics of the information needed. For example, each TRIP sequenca has initiating cues, all of which must be specified. Each action consists of two parts: taking the action that alters the system, and receiving the feedback indication that lets the operator know that the action was successful. Both parts must be discussed for each action.

Because the TRIP procedur's e give only general direction, the team must fil1 in the specific actions to be taken in performing eachJ TRIP step. This will involve recording each valve that must be manipulated, each pump that must be controlled, and each indication that must be read in order to perform the operation specified in'the TRIP sequence. Any other procedures referred to in the TRIP will be reviewed to determine if they must also be included in the analysis.

As each step is listed on the form, the team will assume there are only two types of activities for the operator: either he must obtain information, or he must take action. Decision points usually require the operator to obtain information. Also, the word " verify" will be assumed to mean action, since any verifica-tion process that reveals a control or parameter not in the

' correct state, then requires the' operator take the action that will put it in the correct state. For an item verified not correct, the action to be taken must be stated.

In general, decision points in the flow diagram will take the NO option. In some cases, there will be a short branch where an action is required under the YES and NO options. In order to be thorough, the team will first assume a YES and take that action, then backtrack and assume a NO to continue the worst case flow path.

When specifying the range required for meters, the team should address only the range of readings expected for that specific step, not the whole range of the meter. The term

" resolution" refers to how accurately the operator must be able to read the scale. Generally, if a fairly wide range of readings are acceptable, the scale will not require high resolution. In other cases, a fine resolution may be required. The scale should provide enough resolution to allow the operator to perform the specific step under consideration. The resolution is usually given in + or - numbers. If an absolute limit is involved so that the operator must know when that limit is reached, it must be made clear in our response.

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During the verification, the team will determine the availa-bility of specific controls and instruments in the control room that meet defined requirements. In addition, the team will consider the suitability of the component identified. The component must be suitable in location, type, and arrangement. For example, some controls might be separated from the necessary feedback display so that the operator cannot reasonably observe the results of his actions. Or, because of angle of view, it may be difficult to read some displays. In some cases the needed information may be widely dispersed making the operation difficult. To aid the team in recognizing some of these suitability considerations, Task Analysis Guidelines are attached.

These guidelines are intended for frequent reference by team members during the verification phase.

After the team considers the availability and suitability of control room components for each requirement esta$lished in the first phase, a final judgement will be made. Either the selected component will be marked as satisfactory, or a human engineering discrepancy (HED) will be written. The HED will then be investi-gated and processed in the same manner as all other HEDs generated during the Control Room Design Review.

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Appendix C Key to Task Analysis Worksheet P

1 KEY TO TASK ANALYSIS WORK SHEET TASK The task being analyzed will be identified at the top left of the worksheet (TASK: ) using the procedure titles.

The Step Number (STEP NO.), and DESIRED ACTION for each task being analyzed will also be taken from the actual Limerick procedure. The team will first list the step numbers under STEP NO., and the primary actions in the Desired Action column. The team will then fill in any secondary actions, or substeps, that are required to perform the step.

A sample entry for this section, with "a" and "b" indicating substeps is:

STEP DESIRED NO. ACTION 1 Entry condition for T-101 detected?

(No) 2 Verify Scram

a. verify control rod insertion
b. verify power decreasing This section might also include such information as:

e Regulate feed flow to reactor e Obtair level between 12" & 54" e Stop pump; Start pump e Initiate flow; Stop flow e De-energize bus; Energize bus REQUIREMENTS CHARACTERISTICS:

This section lists the characteristics of actions or infor-mation for each task item. The headings and example entries are listed below:

CODE will be one of'the following:

I - Information the operator must have to determine the need to perform the task step.

A - Action taken by operator to control the systems.

F - Feedback information the operator must have to verify the step was performed successfully.

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TYPE ACTION or PARAMETER: (select one as appropriate)

Action: Discrete, Continuous, Adjust, Set Parameter: Level, Flow, Pressure, Temperature, Position, etc.

STATE or DYNAMIC characteristics of parameters or actions:

(select one as appropriate)

Action State: Closed, Open, Trip, Run, Stop Parameters: Fast Increase, Slow Decrease, Steady, Long Term Trend, Monitor INDICATION of POSITION or RANGE refers to the immediate action indication or parameter range of readings required:

(select one as appropriate)

Action Indication: Open, Closed, On, Off, etc.

Parameters: Range between which the parameter may vary for this specific step.

SCALE RESOLUTION (SCALE RESOL. ) refers only to the parameter reading resolution of the scale, usually expressed in +/-

units.

RESPONSE refers to the speed of response required of the operator in determining the parameter or taking the action:

Rapid - Under time pressure Deliberate - Considered but timely action or reading required Analyze - No time constraints to consider reading or action NOTES:

  • Notes will be numbered consecutively for each page and filled in below.

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VERIFICATION This phase of the task analysis is used to verify that the requirement characteristics defined in the first phase have corresponding instruments in the control room, and that the' instruments are suitable for use by the operator. This phase continues the entries on the form under the headings Availability and Suitability. The following entries are made on this form.

AVAILABILITY:

COMPONENT TYPE (COMP. TYPE) will identify the kind of instrument that has been selected from the control room inventory, such as:

Meter, analog Meter, digital Control switch Control pushbutton Annunciator alarm Light INDICATION POSITION-or RANGE lists the actual position indi-cation or meter range on the panel.

SCALE RESOLUTION (SCALE RESOL.) indicates the actual resolu-tion available on the existing scale.

ID # will list the component identification number.

PNL # will list the panel on which the instrument is loca-ted.

SUITABILITY:

In the Suitability section, the team will record its judgement on the suitability of the instrument for use by the operator. Location and relationship to other instruments and between controls and associated indication. If coordination o~f control room team members is required, the review will determine if that interaction is consistent with control room organization and mode of operation. (such information is appropriately noted in the Comments and Note sections.) The attached guidelines will be referred to by the team to aid them in performing the suitability deliberations.- The team will reach a conclusion on each item and the last column will be checked either Satisfactory or indicate the need for a HED. If any aspect of suitability is considered not acceptable, a HED must be prepared.

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'k A -check in the satisfactory column will also indicate that the . availability is considered to be satisfactory. Therefore, this column indicates overall verification for each line entry.

Comments will be entered- if appropriate. Numbers in parenthesis will refer to notes below. A note is mandatory for all entries requiring a HED.

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) Appendix D Task Analysis Guidelines 4

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TASK ANALYSIS GUIDELINES The primary purpose of the task analysis is to ensure that 6111ab all controls and displays needed to perform the Emergency 6511bc Operating Procedures are present and suitable. 6512ab The word " suitable" means:

e They facilitate operator actions by location, arrangement, and identifiability, and design.

e The operators are not overloaded by the requirements of controls and indications in performing the procedures under stressful conditions.

A secondary purpose of the task analysis is to analyze certain minor operational sequences that require operator and engineering judgement to determine their suitability for either normal or emergency operations. ,

(The numbers in the right hand column are NUREG 0700 references.)

GUIDANCE The following general guidance is provided for reference by the team during the task analysis.

GENERAL PANEL PRINCIPLES e The controls and displays minimize operator movement by 6811 appropriate grouping. 6821 6921a e No redundancy unless required for backup or to avoid 6511d excess movement, o Controls and displays are in the primary work area if 6111b required for continuous monitoring or critical timing.

  • Manning provides timely coverage of'co'ntrols during emer- 6112 gency operations - no extra personnel needed.
  • Procedures terminology should be consistent with panel 6514e labels. 6633c General dimensions of work station:

e lateral viewing angle 45 deg. 6122e2 e lateral spread no more than 6 ft. 6122f e Vertical panels - instruments frequently used or require precise reading or setting:

Controls 53 inches above floor 6125a2 Displays 65 inches above floor 6125b2 D-1

CONTROL'/ DISPLAY RELATIONSHIPS e The arrangement of controls and related displays is 6911c clearly identifiable.

e Controls and displays that are normally used together are 6911a located in close proximity.

e Control movement should have apparent display feedback in 6932a sufficient time under expected dynamic conditions.

e Controls that have a display response lag should have an 6931c immediate feedback of the process and direction of para-meter change.

e Annunciator windows are located above related controls 6331a and indications.

CONTROL PRIt!CIPLES e Provides sufficient range of control. 6422a e Provides sufficient precision (but not excess precision) 6932ac within limits of dexterity, coordination, and reaction time.

o Multiple controls related to the same function grouped 6921a together.

e Controls used in the blind are identifiable visually and 6422d tactually and have separation. 6441c DISPLAY PRINCIPLES e Scales consistent with accuracy needed. 6512a e Operator does not have to convert readings. 6512b e Scales cover the range needed. 6512d e Multipliers should be avoided if possible. 6512e e Multiple displays related to the same general function 6921a should be grouped together, e Displays to be compared should have compatible numerical 6515d progression and organization.

e Recorders:

e Generally should show trends or provide information for 65419 later reference.

e Channels clearly identified. 6542b2 6638a e Located in operating area if required. 6541h D-2

Appendix E Resume of Task Analysis Expert

RALPH E. CHIDLEY - TASK ANAYLSIS RESUME EXPERIENCE: 1954 - Present Directly involved in human factors and training for twenty-nine years. Broad experience in operating and design of control systems with hands-on application of human factors in systems design. Work has covered workspace design and environmental conditions analysis, panel design, operational computer display concepts and design, procedures development, and training.

Thoroughly familiar with commercial nuclear plant systems and operating procedures for both PWRs and BWRs. Extensive experience in nuclear plant operation. Specific experience listed below.

Task Analysis e Directed the conduct of CRDR task analysis for four power plants, three of which have been audited by the NRC.

e Conducted Position / Activity Analysis for various job cate-gories for a major utility.

e Developed innovative techniques in " top-down" systems analysis and task analysis performed for Navy submarine training.

e Conducted task analysis to define requirements for curricu-lum and simulators at the U. S. Coast Guard Academy.

e Developed detailed team training task analysis in military and commercial contexts.

Procedures and Training e Developed procedure writing guidelines for the preparation of normal and emergency operating procedures as part of a DCRDR project.

e Directed the systems analysis design and integration of Navy training simulators into the Trident training facility.

  • Directed development of entire Trident training system including curricula for 140 courses representing 22,000 class hours.

e Designed team training curriculum development strategies and techniques.

E-1

R.E. Chidley (continued) e Developed a team training curriculum for submarine sonar crews.

e Member of evaluation team specifying simulator training requirements for Coast Guard Academy cadets in shiphandling.

Panel Design e Designed control panel improvements as part of CRDRs.

e Designed Trident SSBN control room layout.

e Designed Polaris SSBN ship control ballast control panels.

e Designed an integrated CRT operation concept and display content as part of CRDR.

e Designed and integrated CRT displays for submarine fire control systems and associated training systems, e Contributed to the design layout for the 680 Class SSN.

o Designed and integrated CRT displays for submarine fire control systems and associated training systems.

8 E-2

Appendix F Limerick Task Analysis HEDs (Human Engineering Discrepancies)

HED ASSESSMENT HED No. TA-01 EP = N/A TITLE: Isolation Alarm COMMENT: There is no alarm to indicate a group II isolation.

Item: STEP 2 Ref.: T-100 Source: TA IDENTIFICATION: Panel: 1CC801 Component Name: Annunciator ID or Number: N/A DESCRIPTION:

No single, definitive alarm indicating a group II isolation exists. Operators must observe "RHR Out of Service" alarms and system indicating lights to verify an isolation. Response:

Rapid.

RESOLUTION: (Code A) (Priority 2) (Sched: When PECo notifies )

the NRC that SPDS is opera-tional.

The SPDS system will be used.

TRAINING REQUIREMENTS:

Provide training to operators on SPDS displays.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: dg Date: 6 28-BI F-1

s 1

i HED ASSESSMENT .

HED No. TA-02 EP = N/A TITLE: Isolation Indication i

COMMENT: No convenient indication of group II trip (isolation).

Item: STEP 2 Ref.: T-100 Source: TA IDENTIFICATION: Panel: 601, 602 Component Name: Valve position indication ID or Number: See attached.

DESCRIPTION:

Operators must observe all appropriate valve position indications to verify a group II trip has occurred. No single indication exists. Response: Rapid.

RESOLUTION: (Code A) (Priority 2) (Sched: When PECo notifies the NRC that SPDS is opera-tional.

The SPDS system will be used.

  • TRAINING REQUIREMENTS:

Provide training to operators on SPDS displays. ,

PROCEDURE REQUIREMENTS: None. ,

Team Approval Signature:  ;

hbr (

Date: 6 Z8-W (1) Additional page (s) attached 1

F-2

i TA-02 f T.

Attachment ID or Number:

HV-51-lF009 HV-51-lF008 HV-51-lF015A~

HV-51-lF015B HV-51-151A HV-51-151B HV-51-lF050A HV-51-lF022 HV-51-lF023 HV-51-lF079A i HV-51-lF079B HV-51-lF080A HV-51-lF080B HV-51-lF049 HV-51-lF040 s

4 ',

F-3

HED ASSESSMENT HED No. TA-03 EP = N/A TITLE: Reacror Pressure Scale Multipliers {

COMMENT: Scales use different multipliers.

Item: STEP 9 Ref.: T-100 Source: TA j IDENTIFICATION: Panel: 603 l Component Name: Analog Ind/ Recorder l

ID or Number: PI42-IR605, XR01-IR609 DESCRIPTION:

I These scales measure Reactor Pressure over different ranges (0-1200 PSIG, 850-1050 PSIG), however, they use different multipliers (100, 10). This does not facilitate comparative reading. Response: Rapid.

MITIGATING CONSIDERATIONS:

Most scales use 0-12 or 0-14 PSIG times 100.

RESOLUTION: (Code: B) (Priority 2 ) (Sched: 2nd Refuel )

Modify the 250-1050 PSIG face to use no multiplier to allow direct reading. Leave 0-12 scale as times 100 to be consistent with other reactor pressure scales.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Ch Date: 6 Sf'

( ) Additional page (s) attached F-4

HED ASSESSMENT HED No. TA-04 EP = N/A TITLE: Missing Alarm COMMENT: No alarm to indicate Containment Instrument Gas isolated.

Item: STEP 10 Ref.: T-100 Source: TA IDENTIFICATION: Panel: 601 Component Name: Ind. Light ID or Number: HV59-101, HV59-102 DESCRIPTION:

No discrete alarm exists to indicate Containment Instrument Gas Isolated. Oper e. tor s must look at the system control valve position indications to determine system status. Response:

Rapid.

MITIGATING CONSIDERATIONS:

The ERFDS will provide a summary display of this isolation.

RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

The location of the Instrument Gas Suction Valve controls are side by side in clear view of the operator. He can tell at a glance whether or not the system is isolated. It is a procedural step in the T-100 Scram procedure to check these control indica-tions. The panel has been enhanced to aid the operator in loca-ting these controls. This is not a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: b-UY

( ) Additional page (s) attached F-5

HED ASSESSMENT HED No. TA-05 EP = N/A TITLE: Viewing Distance COMMENT: Difficult to view indications from control location.

Item: STEP llB Ref.: T-100 Source: TA IDENTIFICATION: Panel: 653 Component Name: Bypass Control, Rx Pressure Ind.

ID or Number: N/A DESCRIPTION:

The distance and viewing angle between the Bypass Jack Control and .the necessary Reactor Pressure indication make it difficult to monitor pressure while operating the bypass. Response:

Rapid.

MITIGATING CONSIDERATIONS:

There is a Steam Line Pressure gauge immediately above the jack control.

RESOLUTION: (Code D) (Priority 4 ) (Sched: N/A )

The Steam Line Pressure gauge gives the operator immediate feedback on bypass jack operation. The operator has time to check the Reactor Pressure guage which is approximately 6' away.

Human Factors guidelines allow a lateral span of controls up to 6'. This arrangement is considered to be satisfactory since the two consoles meet at an angle that aids the operator in reading the Reactor Pressure gauge.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: h hg Date: 648-8[

( ) Additional page (s) attached i

F-6

HED ASSESSMENT HED No. TA-06 EP = N/A TITLE: Reactor Level Indication COMMENT: No discrete identification of Reactor Low Level.

Item: CAUTION 5 Ref.: T-100 Source: TA IDENTIFICATION: Panel: 601 Component Name: Analog Ind/ Recorder ID or Number: LI42-lR610, LR42-lR615 DESCRIPTION:

Procedures require identification of a reactor level of -167".

Both indicator and recorder scales have a range of -100" to

-300" but there exists no identification of the -167" level.

Response: Deliberate.

RESOLUTION: (Code: A) (Priority: 2 ) (Sched: 1st Refuel )

This scale will be enhanced by the use of specific zone markings to identify safe and unsafe parameters.

TRAINING REQUIREMENTS: Modification Package (MP)

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: h Date: 6-78-8 [

( ) Additional page (s) attached F-7

. o HED ASSESSMENT HED No. TA-07 EP = N/A TITLE: Flow Indication COMMENT: No Circulating Water Flow indication exists.

Item: STEP 16 Ref.: T-100 Source: TA IDENTIFICATION: Panel: 652 Component Name: Flow Indication ID or Number: N/A DESCRIPTION:

Circulating Water System Flow cannot be determined directly.

Operators must observe pump amperes and pump discharge pressure to infer operation status. Response: Deliberate.

RESOLUTION: (Code: C) (Priority N/A) (Sched: N/A )

This step requires the operator to maintain Condenser Vacuum.

Circulating water flow is necessary to maintain a steady condenser vacuum. The primary indication for maintaining condenser vacuum is the Condenser Vacuum gauge which was found to meet requirements. Circulating Water System operation can be verified by pump breaker position, suction and discharge valve position, and pump discharge header pressure. Indications for these are available and adequate. This is not considered a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: b -IS #15' l- ( ) Additional page (s) attached l

1

, F-8 L_

HED ASSESSMENT HED No. TA-08 EP = N/A TITLE: Rod Drive Flow Increments COMMENT:. Scale increments are missing between some major divisions.

Item: STEP 4 Ref.: T-101 RC/L Source: TA IDENTIFICATION: Panel: 602 Component Name: Square Root Analog Indicator ID or Number: FC46-lR600 DESCRIPTION:

The Control Rod Drive System Flow Indicator uses a 0-100 gpm scale that has no intermediate graduations between 0-20 gpm.

This makes it difficult to read accurately. Response:

Deliberate.

RESOLUTION
(Code A) (Priority N/A) (Sched: N/A )

This is a square root scale. The reading accuracy is + 2 gpm between 40 and 100 gpm. The minimum flow is 50 gpm so teat the scale meets all operational requirements. Not considered to be a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: i - Date: 6 -7 8 -VI

(

( ) Additional page (s) attached l

1 l

F-9

4 1

i HED ASSESSMENT HED No. TA-09 EP = N/A TITLE: ADS Timer Control Feedback COMMENT: No feedback involved with ADS Timer Reset.

Item: STEP 7 Ref.: T-lOl RC/L Source: TA IDENTIFICATION: Panel: 626 Component Name: Annunciator Panel 110, Div I (A-4), Div III (C-4)

ID or Number: B21C-53A,C l DESCRIPTION:

The procedure requires that ADS be defeated by resetting timer logic. When the ADS Timer is reseh, the operator receives no direct . feedback indicating that the reset has been completed.

I Response: Rapid.

RESOLUTION: (Code A) (Priority 2) (Sched: Interim: Complete)

  • Final: 1st Refuel)

Interim Solution: Keep the internal switch on this annunciator alarm in the auto-r'eset mode. This will cause the annunciator to automatically reset when the pushbutton is depressed and it will i

annunciate when the button is released.

Final Solution:- Revise procedure to use the newly installed auto-inhibit switches that defeat auto-initia~ tion of ADS.

TRAINING REQUIREMENTS:

l Train personnel in new procedures.

PROCEDURE REQUIREMENTS:

Revise appropriate procedures for use of auto-inhibit switch.

Team Approval Signature: ) h Date: 6- Z& 8

( ) Additional page (s) attached j

i I

- F-10 L

HED ASSESSMENT HED No. TA-10 EP = N/A TITLE: Drywell Pressure Scale Resolution COMMENT: Cannot read required discrete value on scale.

Item: NOTE 21 Ref.: T-lOl RC/L Source: TA IDENTIFICATION: Panel: 601 Component Name: Drywell Pressure Indicator ID or Number: PI57-121 DESCRIPTION:

The Drywell Pressure. Indicator uses a -5 to +5 scale with a +.1 PSIG level of accuracy. Procedures require the operator to read a pressure of 1.68 PSIG which is too specific for the current scale. Response: Deliberate.

MITIGATING CONSIDERATIONS:

Many annunciator alarms initiate at 1.68 PSIG Drywell Pressure.

RESOLUTION: (Code: A) (Priority: 2) (Sched: 1st Refuel )

This indicator is sufficient for all other tasks. The meter face will be enhanced to allow operators to better identify normal, abnormal, and unsafe parameters.

TRAINING REQUIREMENTS: MP PROCEDURE REQUIREMENTS: None.

Team Approval Signature: ( Date: 6 -Eg -L'5'

( ) Additional page (s) attached F-11

HED ASSESSMENT HED No. TA-ll EP = N/A TITLE: RPV Pressure Scale Resolution COMMENT: The indicator scale is not accurate for requirements.

Item: STEP 9 Ref.: T-101 RC/P Source: TA IDENTIFICATION: Panel: 603 Component Name: RPV Pressure Indicator ID or Number: PI42-lR605 DESCRIPTION:

Procedures require a reading of 1115 PSIG. The scale has a range of 0-1200 PSIG, but can only be read to + 10 PSIG. This is not accurate enough to determine 1115 PSIG. Response: Rapid.

RESOLUTION: (Code: A) (Priority 2 ) (Sched: 1st Refuel )

The scale will be enhanced by the use of specific zone markings to identify safe and unsafe parameters.

TRAINING REQUIREMENTS: MP PROCEDURE REQUIREMENTS: NO3e.

Team Approval Signature: hd Date: 6 4$ Y

( ) Additional page (s) attached F-12

HED ASSESSMENT HED No. TA-12 EP = .N/A TITLE: RPV Level Alarm COMMENT: No Reactor Vessel low level alarm exists.

Item: STEP 0 .Ref.: T-101 RC/Q Source: TA.

IDENTIFICATION: Panel: N/A Component Name: Alarm ID or Number: N/A DESCRIPTION:

There is no alarm to alert operators to a low-low level in the reactor vessel. Operators must observe the RPV Level indication to identify a low-low level (less than -38"). Response: Rapid.

RESOLUTION: (Code: A) (Priority N/A) (Sched: N/A .)

A reactor low-low level alarm exists -(panel 114, window C-2),

which alarms at -38 inches. This is not a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: [o-19-95'

( ) Additional page (s) attached F-13

HED ASSESSMENT HED No. TA-13 EP = N/A TITLE: RPV Level Scale Resolution COMMENT: Operators must interpolate scale to determine low level.

Item: STEP 0 Ref.: T-101 RC/Q Source: TA IDENTIFICATION: Panel: 603 Component Name: RPV Level Indication ID or Number: LI42-lR604 DESCRIPTION:

Procedure requires operator to identify RPV level less than -38" to determine RPV low level. The scale range is 60"'to -150" but uses increments of + 2.5 inches.

The -38" level cannot be read directly from the indicator and operators must approximate the level. Response: Rapid.

MITIGATING CONSIDERATIONS:

There is an annunciator which alarms at this level.

RESOLUTION: (Code: A) (Priority 2 ) (Sched: 1st Refuel )

This scale will be enhanced by the use of specific zone. markings to identify safe and unsafe parameters.

TRAINING REQUIREMENTS: MP PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: b 49"

( ) Additional page (s) attached F-14 i

HED ASSESSMENT HED No. TA-14 EP = N/A TITLE: Reactor Power Scale Resolution CCMMENT: Scale not accurate enough for procedural require-ments.

Item: STEP 0 Ref.: T-101 RC/Q Source: TA IDENTIFICATION: Panel: 603 Component Name: Reactor Power Indications ID or Number: C51-R603A,B DESCRIPTION:

Procedures require a discrete reading of 3% power. 'The two recorders use a range of 0 to 125% power but can only. be read accurately to + 2.5%. This is not accurate enough to meet procedural requirements. Response: Rapid.

MITIGATING CONSIDERATIONS: The plant computer displays reactor power within .1% and is available for operator use. IRM's on range 10 can identify 3%_ power.

RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

APRM Down Scale lights (6) on Panel LOC 603 are energized when less than 3%' power. Consequently this is not a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: b-ES-S I

( ) Additional page (s) attached F-15

. l 4

HED ASSESSMENT HED No. TA-15 EP = N/A TITLE: Isolation Indication COMMENT: No distinct indication signaling group isolations 4

exist.

Item: STEP 1 Ref.: T-101 RC/Q Source: TA IDENTIFICATION: Panel: N/A Component Name: Isolation Signal ID or Number: N/A DESCRIPTION:

l Operators have no simple means of identifying group isolations (other than group I). Personnel must observe specific groups of indicating lights to determine if isolation has occurred.

Response: Rapid.

RESOLUTION: (Code A) (Priority 2) (Sched: When PECo notifies the NRC that SPDS is opera-4 tional.)

The SPDS system will be used.

TRAINING REQUIREMENTS: 4 Provide training to operator or SPDS display.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: , Date: b-18-8[

( ) Additional page (s) attached i

t F-16

I l

l HED ASSESSMENT HED No. TA-16 EP = N/A TITLE: Isolation Indication COMMENT: No summary of isolations exists.

Item: STEP 1 Ref.: T-101 RC/Q Source: TA IDENTIFICATION: Panel: N/A Component Name: Isolation Signal ID or Number: N/A DESCRIPTION:

No alarm or summary of group isolations is available for operators to use to identify group isolations. Personnel must scan valve position indications and various annunciators- to determine which isolations have taken place. Response: Rapid.

RESOLUTION: (Code A) (Priority 2) (Sched: When PECo notifies the NRC that SPDS is opera-tional.)

The SPDS system will be used.

TRAINING REQUIREMENTS:

Provide training to operators on SPDS displays.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: ) h Date: lo-28,9[

l ( ) Additional page (s) attached l

l 1

F-17

i l

HED ASSESSMENT HED No. TA-17 EP = N/A TITLE: Boron Injection Flow Instrumentation COMMENT: No flow indication exists for Standby Liquid Control.

Item: STEP 1, 15, 19, 30 Ref.: T-101 RC/Q Source: TA IDENTIFICATION: Panel: 603 Component Name: Flow Indication ID or Number: LI48-lR601 DESCRIPTION:

Boron injection flow cannot be determined directly. Operators must infer flow by checking Standby Liquid Control tank level indication and pump status lights. Response: Rapid.

RESOLUTION: (Code C) (Priority N/A) (Sched: N/A )

This step requires the operator to inject boron. He can determine that boron is injecting by pump breaker position, squib valve continuity, and pump discharge pressure greater than reactor pressure but less than 1400 PSIG (setpoint for relief valve lift indicating no flow path). Concurrent with this step, the operators are attempting to insert any control rods that have failed to insert. Both of these operations must continue until all rods are in or sufficient boron has injected as determined by boron tank level and appropriate calculations. A flow meter would not add to or alter this process. This is not considered to be a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: b -ES -8I

( ) Additional page (s) attached F-18

HED ASSESSMENT HED No. TA-18 EP = N/A TITLE: Reactor Power Scale Resolution COMMENT: Reactor power indicator scale not accurate enough.

Item: STEP RC/Q 2 Ref.: T-101 RC/Q Source: TA IDENTIFICATION: Panel: 603

' Component Name: Reactor Power Indication l ID or Number: 651-R603A,B

! DESCRIPTION:

Same as HED TA-14. Response: Rapid.

RESOLUTION: (Code A) (Priority N/A ) (Sched: N/A )

APRM Down Scale lights (6) on Panel LOC 603 are energized when less than 3% power. Consequently this is not a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

i Team Approval Signature: p Date: h 48-W

( ) Additional page (s) attached i

F-19

-. .- - _ _ _ .-. .. ~_,

1 HED ASSESSMENT HED No. TA-19 EP = N/A TITLE: Boron Injection Instrumentation COMMENT: Not possible to determine amount of boron injected.

Item: STEP 56 Ref.: T-101 RC/O Source: TA IDENTIFICATION: Panel: 603.

Component Name: N/A ID or Number: N/A DESCRIPTION:

Operators must observe Standby Liquid Control tank level and ST boron concentration to determine the amount of boron injected.

No simple means of determining pounds of boron exists. Response:

Analyze.

RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

Immediate operator action is not required. Time permits the calculation of the pounds of boron injected. Trip procedures provide the calculation format. This is not considered to be a discrepancy.

TRAINING REQUIREMENTS: None.

l PROCEDURE REQUIREMENTS: None.

Team Approval Signature: ) ,

Date: lo -2S-8[

d

( ) Additional page (s) attached F-20

HED ASSESSMENT HED No. TA-20 EP = N/A TITLE: Suppression Pool Low Level Alarm COMMENT: No Suppress. ion Pool Low Level Alarm present.

Item: STEP O Ref.: T-102 SP/T Source: TA IDENTIFICATION: Panel: LAC 847 Component Name: Annunciator ID or Number: A4 DESCRIPTION:

Procedures require operations personnel to quickly determine if Suppression Pool level is outside its normal range. While a Suppression Pool High Level alarm is present, no low level alarm exists. The operator must use the Suppression Pool Level indicator to check level outside normal range. Response: Rapid.

RESOLUTION: (Code A) (Priority 2) (Sched: 2nd Refuel )

6 Add a " Suppression Pool Low Level" annunciator to the appropriate' panel.

TRAINING REQUIREMENTS: None. ,

PROCEDURE REQUIREMENTS:

Add annunciator response procedure.

Team Approval Signature: Date: b I

! ( ) Additional page (s) attached i

I i

F-21 L

HED ASSESSMENT HED No. TA-21 EP = N/A TITLE: Suppression Pool Level Scale Resolution COMMENT: Scale cannot be read to level of accuracy required by procedures.

Item: STEP 0 Ref.: T-102 SP/T Source: TA IDENTIFICATION: Panel: 626 ,

Component'Name: Analog. Indicator ID or Number: LI 51-14 0s. , B DESCRIPTION:

The Suppression Pool Level indicator uses a 0-50 feet range and can be read accurately to +.5 feet. Procedures require the operator to~ identify a discrete level of 24.25 feet. This level cannot be identified on the present scale. Response: Rapid.

RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

Panel 10C648 LI55-ll5 has a range of 20-26 feet + .05 ft.

Therefore this is not a discrepancy.

TRAINING REQUIREMENTS:

Although not a discrepancy, operators will be trained on the availability of LI55-ll5. The training will be scheduled during the next annual requalification program.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature:

k ( Date: ( 40- I0

( ) Additional page (s) attached F-22

HED ASSESSMENT HED No. TA-22 EP = N/A TITLE: Drywell Temperature Alarm Indication COMMENT: No Drywell High Temperature alarm exists.

Item: STEP 0 Ref.: T-102 SP/T Source: TA IDENTIFICATION: Panel: N/A Component Name: Alarm ID or Number: Drywell High Temperature DESCRIPTION:

Operators must observe the specific Drywell Temperature recorder to determine if Drywell Temperature is above its upper limit.

No discrete alarm exists to warn operators of this condition.

Response: Rapid.

MITIGATING CONSIDERATIONS:

Computer provides Drywell Cooler Input Temperature alarm (TISH-77-101, A-H) .

RESOLUTION: (Code A) (Priority 2 ) (Sched: 2nd Refuel )

Add an annunciator alarm indicating "Drywell High Temperature" to alarm when Drywell Temperature reaches 145 degrees F.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS:

Add annunciator response procedure.

Team Approval Signature: Date: b -lS $[

( ) Additional page (s) attached F-23

HED ASSESSMENT HED No. TA-23 EP = N/A TITLE: Drywell Temperature Scale Resolution COMMENT: Drywell Temperature recorder scale not accurate enough for procedural requirements.

Item

  • STEP 0 Ref.: T-102 SP/T Source: TA IDENTIFICATION: Panel: 601 Component Name: Recorder ID or Number: TR57-122 DESCRIPTION:

The Drywell Temperature Recorder has a range of 40-440 degrees F, and is readable to +5 degrees F. Procedures require opera-tors to identify a discrete temperature of 145 degrees. While the scale can be read to this level of detail, a discrete mark at the 145 degrees does not exist. Response: Rapid.

RESOLUTION: (Code: A) (Priority N/A) (Sched: N/A )

The scale is readable to + 5 degrees. Therefore it is accurate enough for procedural requTrements. This is not a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: g ( Date: 6-L9- 8[

( ) Additional page (s) attached l

F-24

HED ASSESSMENT HED No. TA-24 EP = N/A TITLE: Temperature Indication COMMENT: No discrete indication exists for Steam Dome Coolant to Bottom Head Drain Coolant Temperature.

Ite,m: STEP llA-3 Ref.: T-99 PSR Source: TA IDENTIFICATION: Panel: 602 Component Name: Temperature Indication ID or Number: TR43-lR650, TI44-lR607 DESCRIPTION:

The procedure requires restart of a recire, cump during plant recovery. This restart requires operators to observe steam dome to bottom head drain coolant Temperature. In order to accomplish this, operators must observe steam pressure, steam tables, and Bottom Head Drain temperature and then calculate the Steam Dome to Bottom Head Drain Coolant Temperature. No discrete Temperature indication exists. Response: Analyze.

RESOLUTION: (Code: A) (Priority: N/A) (Sched: N/A )

There exists no time constraints on the operator in performing this task. As the information to do the calculation exists in the control room, and procedures do not require an immediate operator response, this is not considered a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: j hk. Date: b-M W

( ) Additional page (s) attached F-25

I l

a HED ASSESSMENT HED No. TA-25 EP = N/A TITLE: Drywell Temperature Scale Resolution COMMENT: Drywell Temperature recorder scale not accurate enough for procedural requirements.

Item: STEP 2 Ref.: T-102 DW/T Source: TA IDENTIFICATION: Panel: 601 Component Name: Temperature Recorder ID or Number: TR57-122 DESCRIPTION:

Procedures require a scale range of 100 to 145 degrees F. The recorder has a range of 40 to 440 degrees, but can only be read to +10 degrees F. This is not accurate enough to read to the level of detail required by procedures. Response: Deliberate.

-RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

Upon re-examination of the display, the scale was found readable to + 5 degrees. Therefere it is accurate enough for procedural requirements. This is'not a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: [n/ Date: 6 19--85

( ) Additional page (s) attached r

F-26

HED ASSESSMENT HED No. TA-26 EP = N/A TITLE: Reference Leg Temperature Qualifications r

COMMENT: Reference Leg. Temperature recorder is not environmentally qualified.

Item: STEP 4 Ref.: T-102 DW/T Source: TA IDENTIFICATION:. Panel: 601 Component Name: Temperature Recorder ID or Number: TR57-110 (Red Pen)

DESCRIPTION:

The recorder meets procedural requirements for range and accuracy, but is not a Reg. Guide 1.97 instrument. The recorder next to it (TR57-122) is identical and is a Reg. Guide 1.97 instrument. Response: Deliberate.

RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

This recorder is specified because the sensor is close to the reference leg, the other is not. The recorder is not required to be a Reg. Guide 1.97 instrument. This is not a discrepancy.

TRAINING REQUIREMENTS: -None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: b 8 [

( ) Additional page (s) attached F-27

HED ASSESSMENT HED No. TA-27 EP = N/A TITLE: Suppression Scale Resolution COMMENT: Scale not accurate enough for procedural requirements.

Item: STEP 5, 10, 12, 14 Ref.: T-102 DW/P Source: TA IDENTIFICATION: Panel: 601 Component Name: Pressure Recorder ID or Number: PR57-101 DESCRIPTION:

Procedures require discrete readings of 22, 38, 53, and 128 PSIG to determine if Suppression Pool Cooling should continue. The recorder has a range of -5 to 165 PSIG, but can only be read to

+2.5 PSIG. This is not accurate enough for procedural require-ments. Response:~ Deliberate.

RESOLUTION: (Code: A) (Priority: 2) (Sched: 1st Refuel )

This scale will be enhanced by the use of specific zone markings to identify safe and unsafe parameters.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: .

Date: b78-8[

( ) A ditional page (s) attached F-28

1

=

HED ASSESSMENT HED No. TA-28 s

EP = N/A TITLE: Suppression Pool Level Resolution COMMENT: Scale cannot be read to level of accuracy required by procedures.

Item: STEP 2 Ref.: T-102 SP/L Source: TA STEP 16 IDENTIFICATION: Panel: 626

, Component Name: Level Indication ID or Number: LI51-140A,B DESCRIPTION:

See HED TA-21. Response: Deliberate.

4 RESOLUTION: (Cede A) (Priority N/A) (Sched: N/A )

Panel 10C648 LI-55-ll5 has a range of 20-26 feet +- .05 feet.

Therefore this is not a discrepancy.

TRAINING REQUIREMENTS:

Although not a discrepancy, operators will be trained on the '

availability of LI-55-ll5. The training will be scheduled during the next annual requalification program.

  • PROCEDURE REQUIREMENTS: None.

i j

Team Approval Signature: Date: lo -194[

( ) Additional page (s) attached

[

A F-29

i HED ASSESSMENT ,

HED No. TA-29 EP = N/A TITLE: Suppression Pool Level Resolution COMMENT: Scale not accurate enough to be read to_ level required by procedures.

Item: STEP 9 Ref.: T-102 SP/L Source: TA STEP 17 IDENTIFICATION: Panel: 626 Component Name: Level Indicator ID'or Number: LI52-140A,B DESCRIPTION:

Operators must read a discrete suppression pool level of 16.9' and 24.6'. The meter has a range of 0-50', but can only be read to 1 5'. This is not accurate enough for procedural require-ments. Response: Deliberate.

MITIGATING CONSIDERATIONS: The computer provides backup _ data and can be read 1.l'.

RESOLUTION: (Code A) (Priority 2 ) (Sched: 1st Refuel- )

The meter face will be enhanced to allow operators to better

, identify normal, abnormal, and unsafe parameters.

TRAINING REQUIREMENTS:

1 Personnel have been trained in meaning of enhancements.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: b Date: b-ZS-SS

( ) Additional page (s) attached l

l l F-30

HED ASSESSMENT HED No. TA-30 EP = N/A TITLE: RPV Pressure Scale Resolution COMMENT: Scale not accurate enough for procedural requirements.

Item: STEP 5 Ref.: T-lll LR Source: TA IDENTIFICATION: Panel: 601 Component Name: Pressure Recorder ID or Number: XR42-lR623A,B DESCRIPTION:

Procedures require a discrete reading of 330 PSIG. While the scale has a range of 0-1400 PSIG and can be read to an accuracy of +10 PSIG, there exists no graticule at 330 PSIG.

Operators can only approximate 330 PSIG currently. Response:

Deliberate.

RESOLUTION: (Code A) (Priority 2 ) (Sched: 1st Refuel )

The meter face will be enhanced to allow operators to better identify normal, abnormal, and unsafe parameters.

TRAINING REQUIREMENTS:

Personnel have been ;&ained in meaning of enhancements.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: #

< (^/ Date: b-17 d$

( ) Additional page (s) attached F-31

HED ASSESSMENT HED No. TA-31 EP = N/A TITLE: RPV Level Scale Resolution COMMENT: Scale not accurate enough for procedural requirements.

Item: STEP 6 Ref.: T-lli LR Source: TA IDENTIFICATION: Panel: 601 Component Name: Level Recorder ID or Number: XR42-lR623A,B DESCRIPTION:

Procedures require a discrete reading of -129" level. The recorder has a range of -150" to +60", but can only_be read to

+2.5". This is not specific enough for procedural requirements.

Response: Deliberate.

RESOLUTION: (Code A) (Priority 2 ) (Sched: 1st Refuel )

This scale will be enhanced by the use of specific zone markings to identify safe and unsafe parameters.

TRAINING REQUIREhENTS: MP PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: G-T 9 -0 [

( ) Additional page (s) attached F-32 I,

HED ASSESSMENT HED No. TA-32 EP = N/A TITLE: RPV Pressure Scale Range COMMENT: No narrow range indicator of Reactor Pressure.

Item: STEP S Ref.: T-112 EB Source: TA IDENTIFICATION: Panel: 603 Component Name: Reactor Pressure Indicator ID or Number: PI42-lR605 DESCRIPTION:

A narrow range Reactor Pressure indicator is recommended for use in Emergency Blowdown (0-300 PSIG). Current scales have a range of 0-1200 PSIG. Response: Deliberate.

MITIGATING CONSIDERATIONS: The current scale is readable from 0-300 PSIG +10 PSIG.

RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

The existing scale meets all procedural requirements except for the range, which exceeds that which is suggested. As the scale resolution has not been reduced, this is not considered a discrepancy.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: (o-22-95 F-33

}

HED ASSESSMENT HED No. TA-33 EP = N/A I

TITLE: RPV Pressure Scale Resolution COMMENT: Scale not accurate enough for procedural requirements.

Item: STEP 11 Ref.: T-ll5 AK Source: TA

. STEP 9 T-ll7 LQ IDENTIFICATION: Panel: 601 i Component Name: Reactor Pressure

ID or Number
LR42-lR623A,B DESCRIPTION:

2 Procedures require a discrete reading of less than 154 PSIG and less than 255 PSIG. The. scale has a range of 0-1500 PSIG, but can only be read to +10 PSIG. This is not accurate enough for procedural requirements. Response: Deliberate.

MITIGATING CONSIDERATIONS: The computer provides backup and can-be read to +1 PSIG.

2 l RESOLUTION: (Code A) (Priority 2 ) (Sched: Enhancement -

1st Refuel.

SPDS - When PECo notifies the NRC that SPDS is operational.)

scales will be enhanced to clearly identify 154 PSIG and j These

,; 255 PSIG. The SPDS will provide more convenient identification of these.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None,

)

i Team Approval Signature:

Date: 6 -ZS -I i F-34c

o l

l l

\

l HED ASSESSMENT HED No. TA-34 EP = N/A i TITLE: Drywell Temperature Scale Resolution COMMENT: Scale not accurate enough for procedural requirements.

Ite,m: STEP 17 Ref.: T-ll6 RF Source: TA IDENTIFICATION: Panel: 601 Component Name: Temperature Recorder ID or Number: TR57-110 DESCRIPTION:

Drywell reference Leg Temperature is required to be read at a discrete temperature of 212 degrees F. The scale has a range of 40 degrees F to 440 degrees F, but can only be read to +10 degrees F. This is not accurate enough for procedural requirements. Response: Deliberate.

MITIGATING CONSIDERATIONS:

Computer backup provided.- Reads to +1 degrees F.

RESOLUTION: (Code A) (Priority 2) (Sched: When PECo notifies the NRC that SPDS is oper-tional.)

The ERFDS will provide an accurate saturation curve and the operation point.

TRAINING REQUIREMENTS: MP EROCEDURE REQUIREMENTS: None.

Team Approval Signature: b Date: lo -2.9 -b [

( ) Additional page (s) attached F-35

f,

/

/, .

/

HED ASSESSMENT HED No. TA-35 EP = N/A TITLE: Reactor Power Scale Resolution COMMENT: Scale not accurate enough for procedural requirements.

Item: STEP 1 Ref.: T-ll7 LQ Source: TA IDENTIFICATION: Panel: 603 Component Name: Reactor Power Indication ID or Number: C51-R603 A,B,C,D DESCRIPTION:

Procedures require a trend reading accuracy of 11%. The scale has a range of 0-125%, but is only readable to +2.5%. This is not accurate enough for procedural requirements. Response:

Deliberate.

MITIGATING CONSIDERATIONS: Computer provides backup and is read 11%.

RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

Operator actions require a discrete trend indication at 8% power.

This is provided by APRM indicator scales which provide a scale resolution of 2.5 percent; and the team determined this to be an adequate scale resolution to determine trends around the 8% power level.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None. 1 Team Approval Signature: {. kc Date: (-18-@[

F-36

l t

l HED ASSESSMENT HED No. TA-36 EP = N/A TITLE: Boron Injection _ Instrumentation COMMENT: See HED TA-19.

Item: STEP 56 Ref.: T-101 RC/Q Source: TA IDENTIFICATION: Panel: 603 Component Name: See HED TA-19.

ID or Number: See HED TA-19.

DESCRIPTION:

See HED TA-19. Response: Analyze.

RESOLUTION: (Code A) (Priority N/A) (Sched: N/A )

Immediate operator action is not required. . Time permits the calculation of the pounds of boron injected. Trip procedures provide the calculation format. This is not considered to be a discrepancy.

TRAINING REQUIREMENTS: None.

l PROCEDURE REQUIREMENTS: None.

l Team Approval Signature: -

Date: (, 19 -9[

( ) Additional page (s) attached l-F-37

Appendix G Modified HED Resolutions l

t I

I r

i

\

l l

l

HED ASSESSMENT HED No. Al-03 EP = 4 TITLE: Annunciator Abbreviations COMMENT: Inconsistent use of abbreviations Item: 5.3 Ref.: C2.1 Source: CRS

5.4 IDENTIFICATION

Panel: Various Component Name Annunciator System ID or Number: N/A DESCRIPTION OF PROBLEM:

Annunciator abbreviations were not consistent with each other or with overall control room abbreviation conventions. HTX/HX, REACTOR 20 LEVEL / REACTOR LEVEL 3, D/G versus D-G, CONT used'for both " containment" and " control".

RESOLUTION: (Code: A ) (Priority: 3 ) (Sched: Will coordinate with all plant modifications that involve annunciator window tile changes.)

Alarms to be relabeled using terminology consistent with related control panels. (See general discussion of annunciator improvements.)

TRAINING REQUIREMENTS: MP PROCEDURE REQUIREMENTS: MP Team Approval Signature:

f Date: ( Lsgi' Revised 6/6/85 per telecon. ( .) Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-1

5 HED ASSESSMENT HED No. Al-06 EP = 6 TITLE: Excessive Annunciator Wording COMMENT: Many annunciator windows contain excessive wording.

Item: 5.7 Ref.: C2.5 Source: CRS IDENTIFICATION: Panel: See attached Component Name: Annunciator System ID or Number: N/A DESCRIPTION OF PROBLEM:

Insuccinct wording was found on many annunciator legends. (See attached sheet for examples.)

RESOLUTION: (Code: A) (Priority: 2) (Sched: Will coordinate with all plant modifica-tions that involve annun-ciator window tile changes.)

Alarms to be reworded using hierarchal labeling to reduce the number of words on window labels. (See general discussion of annunciator improvements.)

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: _

b Date: S4'6C Revised 6/6/85 per telecon. (2) Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-2

IDENTIFICATION HED Al-06 attachment Page 1 GENERATOR HYDROGEN COOLERS H2 OUTLET HI/LO TEMP, panel 1BC870, window 34 EHC EMERGENCY TRIP PRESS LO PRESS TRIP, panel 1AC870 window 46' CONT ENCL ST FLDNG DMPR PNL 00C729 TROUBLE, panel 00C881, window 20 A REFUELING FLOOR ISOLATION SIGNAL INITIATED, panel 10C881 window 23 1A CRD WATER PUMP TRIP panel 1BC803, window 31 UNIT 1 REAC BLDG EL 352 NORTHWEST AIRLOCK SEAL BROKEN, panel 10C889, window 1 CIRC WATER PUMP COOLING WATER BASKET STRAINER FAILURE, panel 10C855, window 43 1 GEN BKRS 452-535/635 POSITION MONITOR CKT CONTROL PWR FAILURE, panel 1BC854, window 5 Dll D-G DIESEL OIL STORAGE TANK HI/LO LEVEL, panel 1AC861, window 19 DIV 1 ADS MANUAL INITIATION SW ARMED / RELAYS SEALED IN, panel 10C826, window 2 G-3

. 'e HED Al-06 attachment Page 2 DIV 2 LO REACTOR PRESSURE RHR PERMISSIVE TO START, panel 1CC801, window 25 CONTROL RM EMER FRESH AIR SUPPLY CHARCOAL FILTER A FIRE, panel BBC850, window 26 EMER COOLING SUPPLY FROM CONDENSATE STORAGE TANK

.MOV OVLD LOSS OF PWR, panel 10C847, window 21 G-4

+

HED ASSESSMENT HED No. Al-07 EP = 6 TITLE: Annunciator System Identification COMMENT: Annunciators do not fully identify systems.

Item: 5.8 Ref.: C2.5 Source: CRS IDENTIFICATION: Panel: 800,801 Component Name: Annunciator System ID or Number: N/A DESCRIPTION OF PROBLEM:

Some annunciator legends were not specific enough to fully identify the system referred to.

- SUPPRESSION ATMOSPHERIC ANALYZER TROUBLE (panel 10C800, window 28)

- TRAIN A PIPING FILL PUMP AP256 LO PMP DISCH (panel' 18C801, window 14)

MITIGATING CIRCUMSTANCES:

Annunciator response cards define the meaning of each window.

RESOLUTION: (Code: A ) (Priority: 2 ) (Sched: Will coordinate with all plant modifica-tions that involve annun-ciator window tile changes.)

Alarms to be reworded using hierarchal labeling and system colors to completely identify the system. (See general discussion of annunciator improvements.)

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: G-L9['

Revised 6/6/85 per telecon. ( ) Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-S

HED ASSESSMENT HED No. Al-08

a d 5 i

COMMENT: Annunciators have incomplete, sometimes incorrect

! legends.

4 Item: 5.9 Ref.: C2.5 Source: CRS

, 5.10 5.11

< IDENTIFICATION: Panel: LAC-870, LAC-801

Component Name
Annunciator System 1

ID or Number: N/A ,

DESCRIPTION OF. PROBLEM:

- No process variable specified on windows 43 and 50, panel LAC 870

- DIV 1 SHUTDOWN COOLING & MIN FLOW VALVES OPEN should read RHR A not DIV 1 (LAC 801)

- CORE SPRAY LINE INTERNAL BREAK is not literally correct l

(LAC 801)

RESOLUTION
(Code: A) (Priority: 2) (Sched: Will coordinate i

with all plant modifications j that involve annunciator window tile changes.)

Alarms to be relabeled to provide complete and correct labels.

{ (See general discussion of annunciator improvements.)

TRAINING REQUIREMENTS: None.

J-i PROCEDURE REQUIREMENTS: None.

J 4

Team Approval Signature: ,, Date: l. -L- f (

j Revised 6/6/85 per telecon. ( ) Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-6

HED ASSESSMENT HED No. Al-09 EP = 4 TITLE: Multiple Trip Levels, Clarity COMMENT: Annunciators legends with multiple trip levels do not differentiate levels.

Item: 5.12 Ref.: C2.6 Source: CRS IDENTIFICATION: Panel: Various Component Name: Annunciator System ID or Number: N/A DESCRIPTION OF PROBLEM:

Some alarm windows use terminology that does not refer clearly to varying setpoints for parameters with multiple trip levels. An example would be " REACTOR LO LEVEL TRIP" versus REACTOR HI/LO LEVEL and REACTOR HI LEVEL TURBINE /RFPT TRIP RESOLUTION: (Code: A ) (Priority: 2 ) (Sched: Will coordinate with all plant modifica-tions that involve annun-clator window tile changes.)

.These alarms to be made clear with better terminology. They ~

represent specific set , points. (See general discussion of annunciator improvements.)

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: j Date: (p4-Sf Revised 6/6/85 per telecon. ( ) Additional page(s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-7

HED ASSESSMENT HED No. SA2-02 EP = 6 TITLE: Excessive Annunciator Wording COMMENT: Annunciator windows contain excessive wording.

Item: N/A Ref.: C2.5 Source: SCRS IDENTIFICATION: Panel: 673 (See attached)

Component Name: Annunciator System ID or Number: N/A DESCRIPTION:

Insufficient wording was found on many annunciator legends.

(See attached sheet.)

RESOLUTION: (Code A ) (Priority: 3 ) (Sched: Will coordinate with all plant modifica-tions that involve annun-ciator window tile changes.)

Alarms to be reworded using hierarchal labeling to reduce the number of words on window labels. (See general discussion of annunciator improvements.)

TRAINING REQUIREMENTS: None

' PROCEDURE REQUIREMENTS: None.

Team Approval Signature: ,

[ Date: (o-C- W Revised 6/6/85 per telecon. ( ) Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-8

HED ASSESSMENT HED No. SD4-02 EP = 9 TITLE: Pushbutton Colors COMMENT: Colors used for pushbuttons are not consistent.

Item: N/A Ref.: A4.2 Source: SCRS TDA IDENTIFICATION: Panel: All Component Name: Guarded and Unguarded Circular Pushbuttons ID or Number: N/A DESCRIPTION:

Pushbuttons use colors of red, yellow, green and black throughout the control room. The use of color is not consistent with function.

RESOLUTION: (Code: A) (Priority: N/A) (Sched: Fuel Load )

See attached.

TRAINING REQUIREMENTS: None.

. PROCEDURE REQUIREMENTS: None.

Approval Signature: Date: C 4-B[

(1) Additional page (s) attached Revised 6/6 /85.

G-9

=

SD4-02 RESOLUTION Pushbutton Color Codes Pushbuttons throughout the control room will be colored using the-following color-codes: (NOTE 1)

FUNCTION COLOR 1.. Emergency Trip, RED Emergency Actuation.

2. Reset LIGHT GRAY
3. Acknowledge Alarm, YELLOW Bypass, Block

.4. Non-Emergency (Start /Stop/ Auto, GREEN Open/Close, etc.)

5. Test BLACK NOTE 1 Does not apply to NSSSS isolation logic resets (inboard and outboard) or the North Stack Hi-Rad isolation ~re-set.

NOTE 2 Does not apply to annunciator reset pushbuttons. *

(See HED SD2-04.)

Revised 6/6/85 per telecon.

Between Interlock (R. Morrison) and PECo (T.J. Cabrey) 9 G-10

HED ASSESSMENT HED No. I2-03 EP = 6 TITLE: Indicator Scales COMMENT: Indicators are not scaled properly.

Item: 4.2.3 Ref.: B2.3 Source: CRS IDENTIFICATION: Panel: 647,648,670,602,653,696 Component Name: Indicating devices ID or Number: See below DESCRIPTION OF PROBLEM: ,

Indicating devices are not scaled in units that relate to the operation of the system:

a. Pump suction pressure indicators (panels 647,648)
b. Main generator rotor temp (panel 670)
c. Recirc pump speed and demand speed (panel 602)
d. Low pressure turbine exit pressure indicators (panel 653)
e. Turbine speed (panel 653)
f. Reaction chamber temperature control indicator (Recombiner 696)

RESOLUTION: (Code: See Below) (Priority: N/A) (Sched: Fuel Load)

a. Scale will be renumbered in standard increments. Correct RCIC indicator to be consistent with HPCI indicator. Code A
b. Enhancements will emphasize the centigrade scale. System measures degrees Centigrade, therefore indicator is scaled properly. See general discussion of enhancements. Code A
c. The minimum speed of this pump is 28% and is indicated by a red line. The scale covers the range of 18% to 102% and is considered to be satisfactory. Code B
d. The engineering units will be positioned across from their designated portion of the scale with clear separation between engineering units. Code B
e. Turbine speed recorder indicates RPM; it should be percent.

Will be changed. Code A

f. Not included in CRDR.

TRAINING PROCEDURES: None.

PROCEDURE REQUIREMENTS: None.

Date: GAST Team Approval Signature:

Team revised 6/6/85 per telecon.

Q() Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-11

HED ASSESSMENT HED No. I2-14 EP = 4 TITLE: Scale Differentiation COMMENT: There is no differentiation between psi and vacuum scales.

Item: 4.2.17 Ref.: B2.18 Source: CRS IDENTIFICATION: Panel: 647, 648 Component Name: Pump Suction Pressure Indicators ID or Number: PI 1R604 and PI 1R606 DESCRIPTION OF PROBLEM:

There is no clear differentiation between psi and vacuum scales on the pump suction pressure indicators.

RESOLUTION: (Code: A) (Priority: N/A) (Sched: Fuel Load )

The engineering units will be positioned across from their designated portion of the scale with clear separation between engineering units. (See HED 12-03.)

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: [w Date: G 4-Y Revised 6/6/85 per telecon. ( ) Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey).

G-12

HED ASSESSMENT HED No. SIl-03 EP = 6 TITLE: Scale Units COMMENT: Process units not specified.

Item: N/A Ref.: SBl.4 Source: SCRS

. IDENTIFICATION: Panel: 602 Component Name: Chart recorder ID or Number: CRSH23-lR601/lR603 DESCRIPTION OF PROBLEM:

The cleanup inlet and outlet conductivity scales have no process units specified. (These recorders appear not to be installed completely.)

RESOLUTION:- (Code: A) (Priority: N/A) (Sched: Fuel Load )

Process- units for these recorders have been specified and will be verified.

o INFLUENT. IR601 .05-10 umhos o EFFLUENT IR603 .0-1.0 umhos TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: 4A.,9f Revised 6/6/85 per telecon. ( ) Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-13

HED ASSESSMENT HED No. SIl-06 EP = 12 1

TITLE: Regulation Guide 1.97 Instruments COMMENT: Post accident monitoring indication not clearly identified.

Item: N/A Ref.: B6.1 and Source: SCRS Reg. Guide 1.97 IDENTIFICATION: Panel: 652,670,603,600,602,626,601,647,667,624 &

648 Component Name: Post Accident Monitoring Instrumentation ID or Number: Ref. FSAR Table 7.5-3 Cat.1 and 2 instru-ments DESCRIPTION OF PROBLEM:

i

! Instruments that meet Reg. Guide 1.97 requirements are spreai throughout the control room. They should be distinctly marked sa that the operator can quickly identify them in post accident

, conditions.

RESOLUTION: (Code: A) (Priority: N/A) (Sched: Fuel Load )

Reg. Guide 1.97 indicators will be highlighted as part of the overall control panel enhancement effort. (See general discussion of enhancements.)

TRAINING REQUIREMENTS: None.

7 PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: 6 4.g Revised 6/6/85 per telecon. ( ) Additional page (s) attached Between Interlock (R. Morrison) and PECo (T.J. Cabrey)

G-14

.3, s,-.__,._.s - . _ . . . . _ _ . . , . , , , c

m. ,,-,_r . . - , . . - _ _ . . _ . . _ . , . . , _ _ _ _ . _ . _ . _ _ - , , _ , . , - _

HED SIl-06 attachment Replace pages A-161 through A-164 with this page.

s G-15 4

HED ASSESSMENT HED No. Al-01 EP = 4 TITLE: System Grouping COMMENT: Annunciators not above related controls and displays Item: 5.1 Ref.: C1.2 Source: CRS IDENTIFICATION: Panel: 661,00C-656,616, ADS,602,668,669,00C-650 Component Name: Annunciator System.

ID or Number: N/A DESCRIPTION OF PROBLEM:

While annunciators are grouped within panels by system, they are not always above the related controls and displays. See attached sheet for examples.

RESOLUTION: (Code: D ) (Priority: N/A) (Sched: Fuel Load )

All annunciator panels will be assigned a hierarchal name that relates them to their associated panel or console. Each will be numbered beginning with 101 for identification in procedures.

Appropriate demarcation will also be used between annunciator panels. (See general discussion of Annunciator Improvements.)

TRAINING REQUIREMENTS: None PROCEDURE REQUIREMENTS:

Modify' alarm response card numbers to conform to new panel number.

Team Approval Signature: k Date: b Ao -SC (1) Additional page (s) attached Revised 6/10/85 G-16

HED' Al-01 attachment Page 1 Relating to panel 661, the Dll alarms are above the D13 controls, the D13 alarms are above the D12 controls, and the D12 and D14 alarms are above panel 00C-656.

The location of ADS and MSIV leakage control alarms in alarm panel 10C826 is the reverse of the location of related controls on panel 626.

The reactor isolation system alarms of alarm panel LAC 802 are above the ADS panel.

Excess flow check valve and fuel pool alarms of alarm panel 1BC802 are located with the recirculation and RWCU alarms related to panel 602.

Radiation monitoring alarms in alarm panel 00C824 are above panel 668.

Feedwater alarm panel 1BC868 is located above panel 669.

Fire protection alarm panel OBC 850 is located above the control room entrance, to the left of fire protection panel 00C-650.

G-17

4 .

HED ASSESSMENT HED No. D2-13 EP = 12 TITLE: Mimic Flow Path Arrangement COMMENT: Flow paths and arrangements are not orderly or easily recognized.

Item: 3.2.9 Ref.: A2.7 Source: CRS IDENT:~~~ATION: Panel: See attached Component Name: See attached

'D or Number: See attached DESCRIPTION OF PROBLEM:

Flow paths are confusing, often appearing to connect where they should not, and sometimes incorrect. See attached.

RESOLUTION: (Code: A) (Priority: N/A) (Sched: Fuel Load )

Resclved through improvement of mimic lines as part of panel enhar. cements . (See general discussion of enhancements.)

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: h/ Date: L -to 4 (

(1) Additional page(s) attached G-18

HED D2-13 attachment Page 1 RHR 1A mimic lines for minimum flow bypass and suppression pool sparger flow appear to connect, but should not - 601.

Some flow arrows are misplaced, such as that to the A containment hydrogen recombiner inlet valve - 601.

RHR servicing water crosstie mimic flow arrow is pointing to an end point labeled "from RHR switch system" - 601.

Core spray B suppression pool return lines for test and minimum flow bypass are very close and congested with the main turbine stop valve and demarcation line. Congestion is also evident in the mimic lines from the pumps to the bypass valve - 601.

I t

l l

[

Revised 6/10/85

{

i G-19 t

HED ASSESSMENT HED No. S!5-05 EP = 12 TITLE: Control :tanipulation Fatiguing COMMENT: Pushbuttons induce excessive fatigue.

Item: N/A Ref.: B5.5 Source: SCRS IDENTIFICATION: Panel: 603 Component Name: Control rod insert, withdrawal, continuous insert and continuous withdrawal buttons.

ID or Number: N/A DESCRIPTION:

Pushbuttons require single finger operation for extended periods of time inducing excessive fatigue.

RESOLUTION: (Code: A) (Priority: N/A) (Sched: Fuel Load )

Supply the operators with a portable adapter.

TelAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: j, Date: lo \0df'

( ) Additional page (s) attached Revised 6/10/85.

O G-20

HED ASSESSMENT HED No. I2-11 EP = 3 TITLE: Scale Subdivisions COMMENT: Indicators are scaled with incorrect- decimal multiples.

Item: 4.2.13 Ref.: B2.13 Source: CRS IDENTIFICATION: Panel: See attached Component Name: See attached ID or Number:~See attached DESCRIPTION OF PROBLEM:

The following indicating devices are scaled with subdivisions in decimal multiples other than the recomended 1, 2, or 5. (See attached sheet)

RESOLUTION: (Code: A) Priority: N/A) (Sched: Fuel Load )

A guideline for analog indicator gauge faces has been developed and will be used throughout the control room to correct indicators as appropriate.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: / Date: 6 -\0-ST (1) Additional page (s) attached Revised 6/10/85.

c G-21

l l HED ASSESSMENT l

HED No. D3-09 EP = 9

(

TITLE: Coding Consistency COMMENT: There appears to be no coding convention applied. .

Item: 3.3.8 Ref.: A3.5 Source: CRS IDENTIFICATION: Panel: 651,652 Component Name: N/A ID or Number: N/A DESCRIPTION OF PROBLEM:

Coding methods such as demarcation lines, shading, spacing and switch shape are not used consistently between panels; variations in these occur on both panels.

RESOLUTION: (Code A) (Priority: N/A) (Sched: Fuel Load )

overall enhancement design rectifies these discrepancies. (See general discussion of enhancements. Shape coding; see HED 15-10.)

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: ,

Date: C, \ L -W

( ) Additional page (s) attached Revised 6/10/85.

I G-22

HED ASSESSMENT HED No. SD4-02 EP = 9 TITLE: Pushbutton Colors COMMENT: Colors used for pushbuttons are not consistent.

Item: N/A Ref.: A4.2 Source: SCRS TDA IDENTIFICATION: Panel: All Component Name: Guarded and Unguarded Circular Pushbuttons ID or Number: N/A DESCRIPTION:

Pushbuttons use colors of red, yellow, green and black throughout the control room. The use of color is not consistent with function.

RESOLUTION: (Code: A) (Priority: N/A) (Sched: Fuel Load )

See attached.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Approval Signature: Date: b-to ,9[

(1) Additional page (s) attached Revised 6/10/85.

G-23

4 J

SD4-02 RESOLUTION Pushbutton Color Codes Pushbuttons throughout the control room will be colored using the following color codes:

FUNCTION COLOR

1. Emergency Trip, RED Emetgency Actuation
2. Reset LIGHT GRAY
3. Acknowledgs Alarm, YELLOW Bypass, Block
4. Non-Emergency (Start /Stop/ Auto, GREEN Open/Close, etc.)
5. Test BLACK NOTE 1: Does not apply to NSSSS isolation logic resets (inboard, and outboard) or the North Stack Hi-Rad isolation reset.

NOTE 2: Does not apply to annunciator reset pushbuttons.

(See HED SD2-04.)

NOTE 3: The color code is determined by the color of the pushbutton collar unless collar is silver in which case the color of the pushbutton determines the code. j f

f Revised 6/10/85 G-24

HED ASSESSMENT HED No. D2-10 EP = 8 4

. TITLE: Mimic Quality COMMENT: Some mimics appear poorly made and installed.

- Item: 3.2.7 Ref.: A2.6 Source: CRS i

IDENTIFICATION: Panel: 601, 647, 648 Component Name: Mimic lines ID or Number: N/A DESCRIPTION OF PROBLEM:

Mimics appear to be of low quality and have been installed

! without proper care.

f RESOLUTION: ~(Code: A) (Priority: N/A ) (Sched: Fuel Load )

will be either painted or be of an acceptable adhesive i

Mimics i colored taping to ensure proper installation. The mimic has been re-designed and uill be checked periodically to ensure proper installation until the 1st refuel outage when the mimic will be J

replaced with a durable material. (See general discussion of enhancements.)

}

" TRAINING REQUIREMENTS: None.

! PROCEDURE REQUIREMENTS: None.

4

, r I

Team Approval Signature: ) Date: 6 -40 /% $f

( ) Additional page (s) attached Revised 6/10/85.

G-25

.-. . . - _ - -- - -. =_ . .

e HED ASSESSMENT HED No. D5-02 EP = 6 TITLE: Label Location COMMENT: Labels have been switched.

t Item: 3.5.2 Ref.: A5.1 Source: CRS IDENTIFICATION: Panel: 603 Component Name: Recorder Labels ID or Number: XRM-IR623, XR01-IR609 DESCRIPTION OF PROBLEM:

The labels on these two recorders have been inadvertently reversed.

s RESOLUTION: (Code: A) (Priority: N/A) (Sched: Fuel Load )

Resolved through reversing labels associated with hierarchal labeling. (See general discussion of enhancements.)

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: b - to-g[

( ) Additional page(s) attached Revised 6/10/85.

G-26

- _ .- -- --_.~ _. __ __

c e v

HED ASSESSMENT 4

HED No. SPV-02 EP = N/A a

TITLE: SRV Opening Sequence l

COMMENT: SRV opening sequence not specified.

I Item: Run 7 Ref.: R.E.C./A.C.M. Source: Val-idation IDENTIFICATION: Panel: 626 Component-Name: Safety relief valve controls

. ID or Number: N/A DESCRIPTION:

r TRIP procedure T-lW1 Step RC/P-9 and note 24 specify using SRV opening sequence. The proper sequence is not specified in the TRIP procedure or on the panel, i

RESOLUTION: (Code: A) (Priority: 2) (Sched: 5% Power )

List appropriate SRV sequence of operation on hierarchal labeling. This is considered to be adequate and is not required in the procedure.

TRAINING REQUIREMENTS: None.

4 PROCEDURE REQUIREMENTS: None.

s Team Approval Signature: L/ Date: 6,A B S [

( ) Additional page (s) attached l

Revised 6/18/85.

G-27


w - . -- - - - -

, e,,--4,-9-m . - + , - - . - ,-=w-- ._, emu ,<r , ,-.-,%#- , , ,- - - - - - - , - - - - - - - - - - - - - - - -

HED ASSESSMENT HED No. SDV-03 EP = N/A TITLE: ERFDS Locations COMMENT: An ERFDS display is not conveniently located for use by the shift supervisor.

Item: Run 2 Ref.: R.E.C. Source: Val-idation IDENTIFICATION: Panel: Supervisor Station while using TRIP procedures Component Name: ERFDS Display and Control ID or Number: N/A DESCRIPTION:

The shift supervisor is responsible for directing the execution of TRIP procedures. This includes determining plant conditions and making decisions. The manual plots required to be used by him are 'on the TRIP procedures and are also automated on the ERFDS, yet the ERFDS cannot be observed from his station.

MITIGATING CONSIDERATIONS:

TRIP procedures are based upon communications between operators (team) whether it's information from control panel indications or ERFDS display.

RESOLUTION: (Code: ) (Priority: 2 ) (Sched: When PECO notifies the NRC that SPDS is oper-ational.)

The SPDS system will be used.

TRAINING REQUIREMENTS:

Provide training to operator on SPDS display.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: Date: 64Y W

( ) Additional page (s) attached Revised 6/24/85.

G-28

HED ASSESSMENT HED No. SPV-06 EP = N/A TITLE: Procedure /ERFDS Correlation COMMENT: ERFDS should be appropriately referenced within procedures to indicate display formats as backups.

Item: Run 10 Ref.: A.C.M. Source: Val-idation IDENTIFICATION: Panel: N/A Component Name: ERFDS ID or Number: N/A DESCRIPTION:

The TRIPS provide plots of various parameters to determine " safe

& unsafe" regions. The parameter values must be determined from panel instrumentation. ERFDS provides the same plots via CRT displays. These displays are not referenced within the procedure and would be valuable to the ACO to confirm actual readings.

Appropriate ERFDS display numbers should be referenced in the TRIPS.

RESOLUTION: (Code: A ) (Priority: 2) (Sched: When PECo noti-fies the NRC that SPDS is operational.)

The SPDS system will be used.

~

TRAINING REQUIREMENTS:

Provide training to operators on SPDS displays.

PROCEDURE REQUIREMENTS:

Procedure; will be revised during the first refuel outage to refE'rence the ERFDS.

Team Approval' Signature: L Date: (,444 i

( ) Additional page (s) attached Revised 6/24/85.

G-29

l, . o HED ASSESSMENT j i ______________

l HED No. SIl-03 l

' EP = 6 TITLE: Scale Units  ;

COMMENT: Process units not specified.

Item: N/A Ref.: SBl.4 Source: SCRS

IDENTIFICATION
Panel: 602 Component Name: Chart recorder ID or Number: CRSH23-lR601/lR603 DESCRIPTION OF PROBLEM:

The cleanup inlet and outlet conductivity scales have no process units specified. (These recorders appear not to be installed completely.) ,

4 RESOLUTION: (Code: A) (Priority: N/A) (Sched: Fuel Load )

Process units for these recorders have been specified and will be verified.

e INFLUENT IR601 umhos e EFFLUENT IR603 umhos i

l TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Team Approval Signature: , ( Date: Mo-ST Revised 6/10/85. ( ) Additional page (s) attached 1

G-30

Appendix H Assessment of Outstanding HEDs e

HED ASSESSMENT HED No. Al-ll EP = 3 TITLE: Annunciator Tile Color Contrast COMMENT: Low contrast between amber and white tiles (bulbs)

Item: 5.14 Ref.: C2.8 Source: CRS C3 IDENTIFICATION: Panel: All Component Narae: Annunciator System ID or Number: N/A DESCRIPTION OF PROBLEM:

Alarms have been prioritized through the use of red and amber bulbs. There appears to be little contrast between the amber and white tiles when illuminated.

RESOLUTION: (Code: C) (Priority: 4 ) (Sched: N/A )

The annunciators are being relocated within their panels to enhance the distinction of red, amber, and white windows (see HED Al-02). Amber signifies cautionary alarms only. Since operators will acknowledge these alarms when they occur, and since all cautionary alarms are supported by emergency alarms which will annunciate if a cautionary alarm is ignored, the existing contrast is sufficient.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

Teata Approval Signature: Date: C- 78 I

( ) Additional page (s) attached H-1 k

1 HED ASSESSMENT HED No. I5-04 EP = 9 .

TITLE: Emergency Switch Position Markings COMMENT: Emergency pushbutton switches have no obvious position markings for disarmed / armed position.

i Item: 4.5.3 Ref.: B5.2 Source: CRS

'l IDENTIFICATION: Panel: Various Component Name: Emergency pushbutton switches i ID or Number: N/A DESCRIPTION OF PROBLEM:

Emergency pushbutton switches have a small red line on side of collars indicating position; this line is not readily apparent to the operator.

RESOLUTION: (Code: F (Priority: 4 ) (Sched: N/A )

The red position- line is not essential to operation. These pushbutton collars are normally disarmed. They are alarmed so that when they are armed, an annunciator activates to alert the operator. No change necessary.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

I Team Approval Signature: ). k Date: (o 9\'

( ) Additional page (s) attached s

H-2

s .

HED ASSESSMENT HED No. SD3-15 EP = 9 TITLE: Control Location COMMENT: Manual Initiation pushbutton is not located near signal lock-in control.

Item: N/A Ref.: A3.1 Source: SCRS TDA IDENTIFICATION: Panel: 647,548 Component Name: Manual Initiation, Signal Lock-in ID or Number: 464,463,(647): 426,459,(648)

DESCRIPTION OF PROBLEM:

a These controls appear to be related in the initiation of HPCI and Reactor Core Isolation Cooling, but they are separated and grouped with isolation and turbine trip controls.

RESOLUTION: (Code: D) (Priority: 4 ) (Sched: N/A )

The panels have been enhanced to demonstrate control / display relationships. These enhancements are adequate.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

t 1

Team Approval Signature: Date: b-d-9[

( ) Additional page (s) attached H-3

HED ASSESSMEdT HED No. SI2-04 EP = 6 TITLE: Indicator Glare COMMENT: Glare from ambient lighting exists on higher indicators.

' Item: N/A Ref.: B2.2 Sourca: SCRS IDENTIFICATION: Panel: RSP Component Name: Linear Analog Indicators ID or Number: See attached print.

DESCRIPTION OF PROBLEM:

See Comment above.

RESOLUTION: (Code: A ) (Priority: 4 ) (Sched: 1st Refuel )

Permanent lighting has been installed since the time of survey-ing. Light covers will be installed in order to diffuse lighting and reduce glare.

TRAINING REQUIREMENTS: None.

PROCEDURE REQUIREMENTS: None.

i Team Approval Signature: Date: (o-LS-S[

( ) Additional page (s) attached H-4