ML20138C767

Addresses Concerns Expressed in Crdr Onsite in-progress Audit & .Attachment 1 Delineates Program.Nrc Evaluation of INPO 83-042 W/Respect to NUREG-0700 Detailed in Attachment 2.CRDR Survey Scope Addressed in Attachment 3

ML20138C767
Person / Time
Site:	Vogtle
Issue date:	12/09/1985
From:	Bailey J GEORGIA POWER CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0700, RTR-NUREG-700 GN-755, NUDOCS 8512130088
Download: ML20138C767 (19)

Text

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. Georgia Power Ccmpany

. Route 2. Box 299A Waynesboro. Georgia 30830 Telephone 404 554 9961 4C4 7244114 Southern Company Services, Inc.

Post Office Box 2625 ' g, Birmingham, Nabama 35202 Tele @one 205 8n>G3tt Vogtle Proj.ect 4.

December 9, 1985 Director of Nuclear Reactor Regulation File: X7BC35

• Attention: Mr. B. J. Youngblood Log: GN-755 {

PWR Project Directorate #4 Division of PWR Licensing A U. S. Nuclear Regulatory Commission Washington, D.C. 20555 s

REF: ADENSAM TO FOSTER DATED 9/26/85 NRC DOCKET NUMBERS 50-424 AND 50-425 CONSTRUCTION PERMIT NUMBERS CPPR-108 AND CPPR-109 V0GTLE ELECTRIC GENERATING PIANT - UNITS 1 AND 2 i OPEN 11EM 14: CONTROL ROOM DESIGN REVIEW (CRDR)

Dear Mr. . Denton:

During the CRDR on-site in-progress audit, which was documented in the above reference, your staff expressed certain concerns. Among these concerns were:

(1) personnel resources devoted to the CADR, (2) the use of system function and task analysis (SFTA) to identify instrument and control (I & C) needs, (3) comparison of identified I & C needs with the I & C control room inventory, and (4) guidelines used to conduct the control room survey.

To address these concerns, GPC has assigned the CRDR as the primary responsibility of the team leader. As such approximately 80% of the team leader's time is devoted to the CRDR. In addition, the team has been augmented by one full-time and one part-time employee. The SFTA process has been expanded to identify I & C needs based upon generic guidelines and background documentation. The I & C needs identified will then be compared with a control room inventory survey. This program is more fully delineated in ' Attachment 1. The concerns expressed by your staff on the survey 1 guidelines stem from GPC's use of INPO 83-042 rather than the NRC-approved '

guidelines as presented in NUREG-0700. An evaluation of INPO 83-042 with respect to NUREG-0700 was undertaken by the NRC and is included in

-Attachment 2. Attachment 3 provides a point-by-point GPC position on the NRC evaluation. As indicated in Attachment 3, GPC has expanded the CRDR survey scope to specifically address your staff's concerns.

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File: X7BC35

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4 s The impienentation of these com'aitments discussed herein will be documented in the VEGP-CRDR Summary Report. 'Tne CRDR is an ongoing process; and should your staff require additional information, it is requested that your staff contact GPC as soon as'possible, y ,

./ Sincerely, >

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7 J. A.'Badley ,

Project Licensing Manager

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i Attachment xc: R. E. Conway G. Bockhold, Jr.-

It. A. Thomas ,

T. Johnson J. E. Joiner, Esquire  ! D. C. Teper B. W. Churchill, Esquire L. Fowler M. A. Miller (2) W. C.sRamsey B. Jones Vogtle' Project File' L. T. Gucwa ..

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ATTACILTTr 1 VOGTLE ELECTRIC GEbERATING PLANT, UNITS 1 abo 2 Instrumentation and Control Characteristics Review The Instrumentation and Control Characteristics Review program will identify and justify the instrumentation and control characteristics that are necessary for proper operator response to emergency transients. This program addresses item 2 (development of a process), item 3 (identification of generic instrumentation and control characteristics and plant specific deviations) and item 4 (development and justification of instrumentation and control characteristics based on operator information and control needs) of the March 29,1985 WOC /NRC meeting.

Process The program will first identify generic characteristics based ca the WOC high-pressure reference plant design, follovced by the identification of plant specitic deviations (i.e.,

differences and detail) and their characteristics. Characteristics will be justified through development of or reference to appropriate generic or plant specific basis documentation.

The process to be used is as follows:

1. The appropriate generic Emergency Response Guidelines (ERCS) and generic ERG background documentation (Step Description Tables) will be reviewed to identify:

All operator tasks necessary to support the operator functions.

Operator information and control needs necessary to support the operator functions and major actions.

Plant systems i.wessary to provide information and control needs.

Plant instrumentation and controls necessary to provide informatian and control needs.

2. For the required plant instrumentation and controls identified in item (1) above, generic characteristcs will be identified based on the required information and control needs.

a. Characteristics for instrumentation will include:

Setpoints Units Range Resolution Response Time Type of Display (e.g., continuous or trending)

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b. Characteristics for controls will include: f l

Positions Response Time

- Type of Control (e.g., variable)

3. From the information gathered in items (1) and (2) above, a Required Characteristics Justification Table will be developed for required instrumentation. This table will identify operator action categories and associated operator information needs, criteria (e.g., specific values for instrumentation) and characteristics (e.g., range, resolution, accuracy, etc.).

The basis for each action category or information need will be described or a reference to other documentation will be given.

4. Following identification of the required generic characeristics in item (3),

the required Vogtle specific characteristics will be identified. The plant specific characteristics will consist of applicable generic characteristics

! and plant specific deviations (i.e., characteristics that differ from generic due to design differences and characteristics for plant specific design features beyond the scope of the generic design).

To identify plant specific instrumentation and controls and their associated required characteristics, the plant specific EOPs will be reviewed to identify deviations from the generic ERCS. These deviations will be evaluated with respect to process items (1) and (2) above. Characteristics for deviations will be identifed consistent with process item (3) above. These plant specific characteristics (consisting of identified deviations and applicable generic characteristics) will then be entered on the Required Characteristics Justification Tables.

5. Generic and plant specific required characteristics will be reviewed and the limiting required characteristics will be summarized in Characteristics Requirements Tables.

6. An inventory of plant specific control board equipment and chara teristics will be developed.

7. The inventory will be compared to the Characteristics Requirements Tables and any requirement which is not met by inventory equipment will be identified as a Human Engineering Discrepancy and treated in accordance with our program plan.

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VOGTLE CRDR PROGRAM PLAN MODIFICATIONS TO ADDRESS NRC

. AUDIT CONCERNS ON NUTAC VICE NUREG 0700 SURVEY USAGE

REFERENCE:

NRC REVIEW OF NUTAC 03-042 BY R.W. Froelich, APRIL 5,1984 A. NUTAC SECTION 2 DEFINITIONS: THE DEFINITIONS SECTION WAS NOT INCORPORATED IN OUR PROGRAM B. NUTAC SECTION 3 SURVEY DEVELOPMENT METHODOLOGY

1. THE HUMAN FACTOR SPECIALIST ON THE CRDR TEAM HAS PERSONNALLY INSPECTED ALL EQUIPMENT COVERED BY THE SURVEYS,AND REVIEWED ALL SURVEY REPORTS. WE HAVE ALSO PROVIDED A MECHANISM FOR OPERATOR INPUT TO SUPPLEMENT, NOT SUBSTITUTE FOR, REVIEW AGAINST HUMAN FACTORS BENCHMARKS.

2. THE EXPERIENCE LEVEL OF OUR CRDR TEAM WAS EVALUATED AS SATISFACTORY DURING OUR IN PROGRESS AUDIT.

3,4,5,6,7,8,. ITEMS NOT INCLUDED IN THE NUTAC SURVEYS, LISTED IN APPENDIX 8-H WILL DE REVIEWED AGAINST THE VOGTLE DESIGN AS AN ADDITIONAL SURVEY.

C. NRC COMMENTS ON APPENDIX A:

1. ENGINEERING DEPARTMENT QUESTIONAIRE NO NRC COMMENTS

2. OPERATOR QUESTIONAIRE.

THESE ARE USED TO SUPPLEMENT, NOT SUBSTITUTE FOR. THE SPECIFIC GUIDELINE CHECKS USED IN OTHER SURVEYS. WE FEEL THAT OPERATOR CONCERNS ARE A VALIO INPUT TO THE DESIGN REVIEW PROCESS.

3. OVERVIEW CHECKLIST OC-1. MIRROR IMAGING IS NOT USED IN THE MAIN CONTROL BOARD OR ANY PART OF OUR PANELS. LEFT-RIGHT RELATIONSHIPS ARE PRESERVED IN DUPLICATION OF EQUIPMENT, SUCH AS TRAIN A/B.

i OC-4. THE SHIFT SUPERVISOR WORK STATION IS LOCATED IN THE MAIN CONTROL ROOM, IN VIEW OF THE CONTROL PANELS, SO "NEAR" WAS NOT OTHERWISE DEFINED.

4. OPERATOR ASSISTED CHECKLIST NO NRC COMMENTS

5. LABELING, MINICS, AND DEMARACATICN THIS AREA WILL BE SUPPLEMENTED BY AN ADDITIONAL SURVEY USING NUREG 0700, SECTION 6.6.

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. 6. GENERAL PANEL CHECKLIST NO NRC COMMENTS

7. CONTROL ROOM COMPUTER CHECKLIST NO NRC COMMENTS-----HOWEVER, THIS IS AND THE CONTROL ROOM COMPUTER SURVEY WILL BE REPLACED BY NUREG 0700.

SECTION 6.7, PROCESS COMPUTERS.

8. DESIGN CONVENTION SURVEY NO ACTION PLANNED. THE INTENT OF THIS SURVEY IS NOT TO IDENTIFY ALL CONVENTIONS, BUT TO SERVE AS AN AID IN IDENTIFYING DESIGN CONVENTION VIOLATIONS ON THE COMPONENTS COVERED.

9. LIGHTING SURVEY THIS SURVEY WILL BE REPLACED BY NUREG 0700 APPENDIX E-2.

10. NOISE SURVEY THIS SURVEY WILL BE REPLACED BY NUREG 0700-E1.

11. ANTTHROPOMETRIC SURVEY THIS AREA WILL BE SUPPLEMENTED BY AN ADDITIONAL SURVEY USING NUREG 0700, SECTION 6.1.2.

12. ANNUNICATOR SURVEY THIS SURVEY WILL BE REPLACED BY NUREG - 0700 SECTION 6.3

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13. COMMUNICATIONS SURVEY THIS SURVEY WILL BE REPLACED BY NUREG - 0700 SECTION 6.2 14 AB8REVIATIONS AND ACRONYMS SURVEY NO NEGATIVE NRC COMMENTS

15. COLOR CODING SURVEY NO NRC COMMENTS

16. CONTROL ROOM COMPUTER SURVEY THIS SURVEY AND THE COMPUTER CHECKLIST WILL BE REPLACED BY NUREG -0700 SECTION 6.7, PROCESS -

COMPUTERS.

D. APPENDIX 8-H ITEMS NOT INCLUDED IN THE NUTAC SURVEYS, LISTED IN APPENDIX 8-H OF NUTAC 83-042 WILL BE REVIEWED AGAINST THE VOGTLE DESIGN AS AN ADDITIONAL SURVEY.

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ATTACRMENT 2 i

COMMENTS ON INPO 83-042 (NUTAC)

CONTROL ROOM DESIGN REVIEW i SURVEY DEVELOPMENT GUIDELINES The subject document was prepared to assist individual utilities in developing their detailed control room design review (DCRDR) program plans and in developing the seterial to be used in performing the survey portion of the DCRDR. Related NUTAC documents associated with the DCRDR are: ,

Control Room Design Review Implementation Guideline.

INPO83-026(NUTAC)

Control Room Design Review Task Analysis Guideline (Draft)

Human Engineering Principles for Control Room Design Review, INPO83-036(NUTAC). -

The Survey Development Guideline (SDG) consists of 3 major parts:

1. An introductory portion describing the document's purpose and scope, defining terms, and describing methodology.

2. An appendix providing an example set of surveys, checklists and questionnaires.

3. A set of appendices listing NUREG-0700 Section 6 guideline items not included in the examp1.e set of surveys, checklists and

. . questionnaires, or modified.

In addition, the SDG provides appendices cross-referencing the NUREG-0700 Section 6 guidelines with the example set of surveys, checklists and questionnaires.

The SDG outlines a method for generating checklists, surveys and questionnaires by " screening any existing set of human facters design items .

according to criteria related to their measurability and objectiveness."

Items that can be assessed objectively are retained in checklist form. Items of a subjective nature o- that are not easily measured must be addressec elsewhere in the DCRDR. Although the claim is made that this methodology can be applied to any set of human factors design items, the guidelines have in fact been developed on the basis of a critique of the control qpon human engineering guidelines presented in Section 6 of NUREG-0700. As such, the SDG appears to suggest that utilities intending to base their GRDR on the guidance of NUREG-0700 can use the questionnaires, checklists and surveys contained in SDG Appendix A without further modification.

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2-In comenting on the SDG, it should be noted that the Section 6 Guidelines of NUREG-0700'were not intended to be applied to a control room survey only. As noted in the Introduction to Section 6

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"This section contains detailed guidelines for reviewing the human engineering suitability of control room features. Most of these guidelines will be used in the control room survey discussed in

' Section 3 Subsection 3.6. Application of some of the guidelines, especially those concerning panel layout and control-display integration, involves consideration of individual task performance Those requirements and integrated function performance requirements.

guidelines will need to be applied in conjunction with task descriptive data and control room procedures data as discussed in Section 3.

Subsections 3.7 and 3.8." .

The Section 6 guidelines were presented in a checklist fashion to facilitate their systematic application. A general concern with the SDG, then, is that their screening approach to the full set of NUREG-0700 guidelines does not '

appear to ensure a systematic approach to a control room survey. One eddence of this can be seen in SDG Appendix I which cross-indexes Section 6 gu'idelines to the SDG Appendix A survey items. Frequently, more than one survey, checklist or questionnaire is referenced, or a number of survey items / questions are referenced as applying to a single NUREG-0700 guideline.

And in the other direction, many NUREG-0700 guidelines can evidently be reviewed through application of a single SDG guideline item. Also, frequent references are made to a " systems review" which is expected to address those NUREG-0700 guidelines which are believed not appropriate for a control room j

survey. We are unable to determine that a NUTAC addressing all of these j

items has been prepared. Suming up our general coments, we are concerned j that the SDG is not structured to ensure the identification of human engineering deficiencies (HEDs) which are "A departure ham some benchmark of system design suitability for the roles and capabilities of the human operator." (From Section 1.5 of NUREG-0700.) Despite its claims of objectivity, the SDG in too many instances replaces tht objective measurement guidelines of NUREG-0700 with subjective opinions with no foundation in human factors values. Citing only one example, Operator Questionnaire Item OQ-4 asks the operator "Are any controls too large, too small, or too close together to operate easily." This question replaces over 30 NUREG-0700 guicelines, many of which contain specific dimensional standards of control design and placement based on well-founded human factors principles.

Our coments on specific sections of the SDG follow:

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A. Section 2 Definitions ,.

1. The control room survey is defined as a " static verification" of the control room. Verification is hardly appropriate, and some survey items must be dynamic. ,

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2. The concept of a " review team" responsible for directinc the control room design review is of significant concern. The ,

multidisciplinary review team described in Supplement J to NUREG-0737 is expected to conduct the review, not direct it. The danger here is that the actual review can be done by inexperienced persons who may not identify HEDs that would be immediately '

apparent to, e.g., a human factors specialist. This comment applies specifically to the survey team.

3. Task analysis should not be expected to verify and validate the ,

untch of infonnation available in the control room to the infonnation requirements of the emergency operating tasks. These are separate activities.

4. The definition of verification should add (to the first sentence)

"as identified by task analyses." And the second sentence should be deleted - this status check of instrumentation describes the control room survey. .

8. Section 3 Survey Development Method

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Section 3.1.1, Definition of Control Room Survey -

1.

It is stated that "Other activities conducted as part of the

- overall CRDR can be used to gather subjective information

- concerning control room design adequacy and operational characteristics." Over and above the concern that there may not be another CRDR activity that will accomplish this, the fact remains that such subjective information will need to be collected by a trained human factors specialist. And, since such a specialist should participate in the control room survey, there is no reason why this information should not be a part of the survey. We are concerned that the survey is not structured to require human factors specialists, since the final sentence of this section suggests that human factors experts may not be involved in a number of CRDR survey activities. This last sentence suggests, for example, that operator judgment will be substituted for the application of human factors benchmarks, or for the judgment of persons trained in human factors.

2. Section 3.1.2, Survey Team Composition The assumption is made that survey team members will,)e inexperienced, (presumably, both in plant operation .and human factors), and the survey guidelines were structured with this limitation in mind. We do not agree. Restructuring the survey to only those items amenable to a yes-no answer will probably overlook many HEDs. For example Annunciator Survey Guideline AS-19 directs the inexperienced survey member to verify that " Displays including I

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annunciator tiles are located and oriented so they can be read by operators." Without any specifics of character height / viewing distance, and faced with a requirement to provide a yes-no response '

to this statement, the response would almost have to be "yes" in all cases. ,

3. Section 3.2.1, Non-Measurable Items

- This and the following Section 3.2 items list the screening criteria used by the NUTAC to remove items from the control room survey. The basic thrust of Section 3.2.1 is to eliminate non-measurable guidelines. Those NUREG-0700 items eliminated on this basis are listed in Appendix 8 of the SDG. In general, we find that the screening criteria have been misapplied. The principal screening criteria appears to be based on the use of inexperienced team members to conduct the survey. If qualified human factors experts participated in the survey, most of these guidelines could be applied. Further consnents are contained in our review of the material found in Appendix 8. .

, , 4. Section 3.2.2, Redesign Versus Review Items cn

- This section describes a NUTAC rationale to eliminate from the survey process all of those guidelines which they believe suggest a preferred design or a design specification. The argument is made that such guidelines do not refer to any given human factors principles, (their example is the concept of a "greenboard" color-coding scheme), or are only applicable in the design process.

We do not agree. Regardless of how the NUTAC describes them, the infomation presented in these guidelines represents the benchmark l

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of design suitability for the roles and capabilities of the human ,

operator, and existing control room design features should be i

compared to these benchmarks. We would further point out the NUREG-0700 does not hold up the concept of a,"greenboard" color coding scheme. TfIe NUTAC has misinterpreted that guideline.

5. Section 3.2.3, Uncharacteristic Items ,

We have no conenents on this section. However, considering the small number of items in Appendix E, and the possibility that the NUTAC could be in error (e.g., " items that -- everyone complies with") we suggest that these items be retained in the survey.

6. Section 3.2.4, Items That Might Degrade Performance '

The items listed in Appendix F as design characteristics that might f degrade operator performance nave been misinterpreted by the NUTAC.

These items should be retained in the control room survey. See Section D. 4 of this review for further consnents. .

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7. Section 3.2.5, Redundant Items .

The redundancy objected to by the NUTAC (often, a NUREG-0700 guideline that references another NUREG-0700 guideline) is in many cases an intentional inclusion in the guidelines to improve the conduct of the control room survey. Eliminating these guicelines represents a risk of not evaluating some control room components and/or design . features.

8. Section 3.2.6, Guidelines Using Inappropr.f ate Criteria Appendix H lists items where the NUTAC believes that while the guideline intent was proper, the criterion used (i.e., the .

benchmark of design suitability) was unsuitable. In general, we do not agree with the revisions proposed by the NUTAC. To cite one

-example, NUREG-0700 Guidelines 6.5.1.1.f reads: " DISPLAY FAILURE -

When panel instruments, such as meters, fail or become inoperative, the failure should be apparent to the operator, (e.g., through off-scale indication)." The NUTAC has taken this guideline to*

• require off-scale indication, and bases its objection / revision on that ttem. Their proposed revision reads " Panel instruments do not fail -- in their normal operating ranges." We observe that this guideline is not measurable (particularly by an inexperienced survey team member) without additional assistance and interpretation. In particular, the term " normal operatinp range" must be further specified before the guideline can be applied.

C. Coments on the Appendix A NUTAC Questionnaires, Survey and Checklists Note: We have not conducted a detailed review of all of the material found in this Appendix. The following comments represent

. . spot-checks of some of the NUTAC material.

1. Engineering Department Questionnaire Me have no coaments. .

2. Operator Questionnaire As a substitute for the specific guidelines of NUREG-0700, these questions appear to be far too general. The following examples are cited:

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00-1. Are controls and displays too far apart?. (Howfar is "too far?")

00-3. Are controls "too large, too small, or too close together? (How close is "too close?") ,

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4 Also, some items (e.g., emergency gear) that could have been '

applied to this questionaire seem to be missing.

We would be concerned that completed questionantres would seldom provide the. kinds of responses that would trigger a specific and detailed review of control room design features.

3. Overview Checklist We note that mirror-imaging seems to have been applied only at the multi-unit level. (OC-1.) Also, how is "near" assessed in terms of location of the shift supervis r's office? (OC-4.)

4. Operator Assisted Checklist We have no comments.

5. Labeling, Mimics, and Demarcation Checklist .

From a brief review of this checklist, it appears that a large

. . -- amount of NUREG-0700 guideline data has been omitted. We would note that the NUTAC checklists also appear to suffer from recundancy. For example. 0AC-36 gives "-- clearly visible title labels identify specific documents " and LMD-15 has "- Documents should be labeled clearly so they are easily distinguished from one another."

6. General Panel Checklist

- - We have no comments.

7. Control Room Computer Checklist j

We have no comments.

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8. Design Convention Survey i' The intent of this survey is to be commended. However, restricting the scope of the survey to controls, meters and repetitive groups l

' does not seem to be enough to identify all control room design conventions.

9. Lighting Survey .

Only minimal instructions are provided. The number of measurements 7 may be inadequate to determine, on an objective basis, the l

' suitability of control room lighting.

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10. Noise Survey The survey calls for recording data only by exception (e.g., " note readings higher than 65 dbA.") This may be inadequate to identify all noise problems in the control room. ,

11. Anthropometric Survey

- We are not in agreement with the NUTAC proposed relaxation of anthropometric standards as given in NUREG-0700. We also note that the generality of some survey items, as well as their subjectivity,

, may preclude the identification of significant HEDs. For example, AS-19 states " Displays including annunciator tiles are located and oriented so they can be read by operators."

- 12. Annunciator Survey This survey lists only four questions. We believe that this survey is inadequate to properly 2 valuate control room annunciators, even with the other MUTAC item that might involve these systems. ,

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13. Communications Survey The survey does not appear to have the depth necessary to cover all

.- of the communications items addressed in NUREG-0700.

14. Abbreviations and Acronyms Survey This is a very good addition to the control room survey process.

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15. Color-Coding Survey

We have no coments.

16. Control Room Computer Survey l

The survey appears to be incomplete. For example, we find no survey items addressing computer printers.

t D. Coments on SDG Appendixes B through H ,

1. Appendix 8 Non Measurable Items

a. The NUTAC lack of objectivity argument agafhst the guidelines listed in this appendix appears to be related more to their planned procedures for the control room survey than to these guidelines. Many of the guidelines

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listed in this appendix can be reviewed and evaluated during the survey jf, a human factors professional is a member of the survey team.

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b. A number of guidelines listed here are to be reviewed "during the systems review" portion of the DCRDR. We have no information to assure us that there will be a systems review procedure that will include these guidelines. .

c. " Splitting" guidelines between two or more review  ;

activities can be expected to lead to overlooking HEDs.

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Exam' p les are NUREG-0700 guidelines 6.1.2.5.(a)(2) and i

y 6.1.2.5.b.(2) for control and display height. These two l guidelines address the height limits for controls and l displays requiring precise or frequent operation, or for '

emergency controls. By splitting these guidelines between a survey procedure and an operator questionnaire question, the determination that controls and displays are within this range is lost. The survey activity will only determine general control and display height limits

- which are a wider rance - and the operator questionnaire is completely subjective - e.g., "Are any -

controls difficult to adjust as precisely as needed?"

- - 5- The outcome of these activities will almost certainly be to miss any controls or displays for emergency or i

~ precise / frequent use that are located out of the recomended height range.

d. Some objective, measurable guidelines (e.g., 7.1.5.1.b) have been replaced with a subjective opinion-type of question. This appears to be a direct contradiction of the intent of this appendix.

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e. Some NUREG-0700 guidelines have been replaced with NUTAC items which do not appear to be valid substitutes.

Examples would include the NUTAC replacements for guidelines 6.2.1.8.c.(2), and 6.2.2.1.c.(1) and (2).

f. Some NUREG-0700 guidelines have been eliminated as a result of the NUTAC treatment of these guidelines. For >

example, Guideline 6.3.1.5, dealing with cleared annunciator alams, states that individual " cleared" tiles should have one of the following visual indications:

(1) A special flash rate w ,

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(3) A special color.

Appendix 8 notes that these are only suggestions, and that there are many more ways to signal a cleared alam.

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Whether the NUTAC can in fact identify many more human-factored ways to visually signal a cleared alarm is questionable, but insignificant. What is of great concern here is that this item, on the basis of the NUTAC

' comment, has been dropped from the controi room survey.

2. Appendix C and D " Redesign" Items Comments on these two appendices are provided in Item 8.4 of this review.

3. Appendix E Uncharacteristic Items See Item 8.5 of this review.

4. Appendix F Items That Might Degrade Performance The NUTAC has evidently misinterpreted these guidelines. We do not agree that any of them '"

could degrade operator performance.

a. Guideline 6.2.2.1.a states that systers used to transmit non-verbal auditory signals should be used only

l. - for that purpose. The NUTAC comment

, that this guideline prohibits alerting pignals for public address systems or walkie-talkie use does not follow.

- - b. Guideline 6.5.4.1.b states that in princiole, graphic recorders wh1Ei must be verified and attended by operators

. should be in the primary operating a rea. We are not fully in disagreement with the NUTAC concern that there may be too many recorders in the primary operating area, but remain convinced that those recorders which the operators must verify and attend to should be in the primary operating area. The NUTAC suggestion that this be limited to recorders used "to control the plant" approaches our intentions, but we are concerned that this perticular definit 1no might be a difficult one to agree on for some recorders.

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c. Guideline 6.9.3.1.c.(2) calls for intermediate feedback indications of processes and direction of parameter change when there is a time lag between control actuation and ultimate system state. We do not believe that the NUTAC interpretation (that this calls for a predictor or quickened

' display that conflicts with the direct

- ' indication requirement) is a valid argument. We believe this to be a 4

significant "important to safety" item, and the guideline should be retained.

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d. Guideline 6.8.3.2.d.(1)callsfor coordinate axis labeling for large matrices of similar components. An exhibit (6.8-6) in NUREG-0700 .

Illustrates this point. The NUTAC response does not address this

-' guideline.

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5. Appendix' G Redundant Items

-- See Item B.7 of this review.

6. Appendix H. Items Using Inappropriate Criteria See Item B.8 of this review.

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In conclusion, while there are some positive factors of the NUTAC Survey Development Guidelines, we believe that too many of the NUREG-0700 guidelines

- have either been dropped, relaxed, or put off to other unspecified pertions of the DCRDR. We are particularly concerned that the survey as envisioned by the NUTAC will not involve the participation of a human factors professional.

We cannot conclude that control room surveys made on the basis of this l

guideline will meet the requirements of Section 5.1.b.(iv) of Supplement 1 to NUREG-0737, which calls for "A control room survey to identify deviations from accepted human factors principles.

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ATTACHMENT 3 V0GTIE CRDR PROGRAM PIAN MODIFICATIONS TO ADDRESS NRC AUDIT CONCERNS ON NUTAC 83-042 RATHER THAN NUREG 0700 SURVEY tJ3 AGE

REFERENCE:

NRC review of NUIAC 83-042 by R. W. Froelich, April 5, 1984 (Attachment 2)

A. NUTAC Section 2 Definitions: The definitions section was not incorporated in our program.

B. NUTAC Section 3 survey development methodology:

1. The human factor specialist on the CRDR team has personally inspected all equipment covered by the surveys and reviewed all survey reports. We have also provided a mechanism for operator input to supplement, not substitute for, review against human factors benchmarks.

2. The experience level of our CRDR team was evaluated as satisfactory during our in progress audit.

3,4,5,6,7,8. Items not included in the NUTAC surveys, listed in Appendix B-H will be reviewed against the Vogtle design as an '

additional survey.

C. NRC Comments on Appendix A:

1. Engineering Department Questionnaire:No NRC Comments  ;

2. Operator Questionnaire These are used to supplement, not substitute for, the specific guideline checks used in other surveys. We feel that operator concerns are a valid input to the design review process. [

3. Overview Checklist OC-1. Mirror imaging is not used in the main control board or any part of our panels. Lef t-Right relationships are preserved in duplication of equipment, such as Train A/B.

-0C-4. The shift supervisor work station is located in the main control room, in view of the control panels, so "near" was not -

otherwise defined.

4. Operator Assisted Checklist No NRC Comments 4

5. Labeling, Minics, and Demaracation This area will be supplemented by an additional survey using NUREG 0700, Section 6.6.

6. Geceral Panel Checklist No NRC Comments

7. Control Room Computer Checklist No NRC Comments--however, this is and the control room computer survey will be replaced by NUREG 0700, Lection 6.7, process computers.

8. Design Convention Survey No action planned. The intent of this survey is not to identify all conventions, but to serve as an aid in identifying design convention violations on the components covered.

9. Lighting Survey This survey will be replaced by NUREG 0700 Section 6.1.5.3/4.

10. Noise Survey This survey will be replaced by NUREG 0700-El.

11. Anthropometric Survey This area will be supplemented by an additional survey using NUREG 0700, Section 6.1.2.

12. Annunicator Survey This survey will be supplemented by NUREG 0700 Section 6.3

13. Communications Survey This survey will be replaced by NUREG 0700 Section 6.2

14. Abbreviations and Acronyms Survey No negative NRC comments

15. Color Coding Survey No NRC Comments

16. - Control Room Computer Survey This survey and the computer checklist will be replaced by NUREG 0700 Section 6.7, process computers.

r 1 D. Appendix B-H Items not included in the tiUTAC surveys, listed in Appendix B-H of NUTAC 83-042 will be reviewed against the Vogtle design as an additional survey.

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