ML20141C701

Suppl to Technical Evaluation Rept, Dcrdr for Salem Generating Station,Units 1 & 2

ML20141C701
Person / Time
Site:	Salem
Issue date:	12/02/1985
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML18092A988	List: ML20141C701
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8512270493
Download: ML20141C701 (30)

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ENCLOSURE l1- ,

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SUPPLEMENT TO THE

! TECHNICAL EVALUATION REPORT 0F THE DETAILED CONTROL ROOM DESIGN REVIEW i FOR THE SALEM GENERATING STATION, UNITS 1 AND 2 December 2,1985 l

Prepared for:

) U.S. Nuclear Regulatory Commission

. Washington, D.C. 20555 i

i Prepared by:

Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102

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l TABLE OF CONTENTS Section , Pale 1

1. Qualifications and Structure of the DCRDR Team . . . . . .

2. Function and Task Analysis, and

3. Comparison of the Display and Control Requirements With a Control Room Inventory . . . . . . . . . . . . . . . . 1 4 Control Room Survey. . . . . . . . . . . . . . . . . . . . 4

5. Assessment of HEDs . . . . . . . . . . . . . . . . . . . . 8

6. Selection of Design Improvements . . . . . . . . . . . . . 10

! 7. 8. Verification That Improvements Will Provide the Necessary l Corrections Without Introducing New HEDs . . . . . . . . . 16

9. Coordination of the DCRDR With Other Improvement Programs. 16 ,

Summary and Conclusions. . . . . . . . . . . . . . . . . . 17 References . . . . . . . . . . . . . . . . . . . . . . . . 20 Appendix A: HEDs from Section 6.1 of the SSR in which resolutions j were proposed and were found to be adequate or to be l insufficiently described or resolved. . . . . . .. . . 22 Appendix 8: HEDs from Sections 6.2 and 6.3 of the 55R in which resolutions were proposed and were found to be adequate or to be insufficiently described or resolved; and dis-cussion on the cumulative and interactive effects of I HEDs was provided but found to be insuf ficient to resolve these concerns. . . . . . . . . . . . . . . . . 23 Appendix C: HEDs from Section 6.3 of the SSR in which rationale for the assessment was provided and found to be

acceptable, unacceptable, or was not provided at all. . 27 t

Appendix D: HEDs from Section 6 of the $$R which are associated t with labeling discrepancies and should be addressed by the application of satisfactory standards or guidelines. . . . . . . . . . . . . . . . . . . . . . . 28 i

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SUPPLEMENT TO THE i TECHNICAL EVALUATION REPORT ,

0F THE DETAILED CONTROL ROOK DESIGN REVIEW

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FOR THE SALEM GENERATING STATION UNITS 1 AND 2 This report documents the findings froa a review of Public Service Electric and Gas (PSE&G) Company's Supplementary Summary Report for the DCRDR being conducted at its Salem Generating Station. Ur.its 1 and 2. Based upon the findings of a pre-implementation audit .:caducted the week of j November 26,1984. (Reference 7), the NRC staff concluded in its Supplemen-tal Safety Evaluation Report (SSER) that PSE&G had satisfied some but not all of the requirements of Supplement 3 to. NUREG-0737 and that a satisfac-tory Supplemental Summary Report (SSR) should be submitted for review by the NRC staf f. PSE&G submitted its SSR to,the NRC attached to a letter dated September 16, 1985 (Reference 8). The findings of the review of the $$R are presented below according to each DCRDR requirement of Supplement I tc I NUREG-0737. (HED numbers used refer to actual HED nu:,bers, not document page numbers.) These findings reflect the conclusions of the NRC and SAIC.

1. Qualifications and Structure of the DCRDR Team i '

As stated in the SSER, PSEAG has satisfied this requirement of Supplement 1 to NUREG-0737.

2. Function and Task Analysis, and

3. Comparison of the Display and Control Requirements With a Control Room Inventory

Based upon the findings of the pre-implementation audit, the NRC audit

! teen, concluded that PSEAG should submit the following documentation in order l to resolve the NRC's remaining concerns regarding the acceptability of 4

PSEAG's Systems Function Review and Task Analysis (SFR&TA) and verification of Task Performance Capabilities in meeting the requirements of Supplement 1 to NUREG-0737:

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l l 1. A description of how the E0P upgrade methodology and findings will j supplement the Systems Function Review and Task Analysis and the

. Verification of Task Performance Capabilities.

! 2. A description of what further work needs to be done tn the Sys'tems Function Review and Task Analysis and Verification of Task

! Performance Capabilities that hasn't been accomplished by the i DCRDR and the E0P upgrade program. Since the qualifications of -

! the E0P upgrade consultants apparently do not reflect the level of l human factors expertise normally needed to ensure a comprehensive i analysis of tasks for information an_d control requirements, addi-tional analysis may be necessary. '

( PSEAG describes in Section 4 of the SSR the task analysis activities l that address the first item above. The task analysis activities were i l performed under the DCRDR and the E0P development program. During the pre-l implementation audit, the NRC audit team found that although the information l and control requirements were apparently derived independently of the exist-l ing control room instruments and controls, the identification and listing of information and control requirements were not comprehensive of needed characteristics of information and controls. The information and control requirements listed in the " System Responses" column of the pre-filled task analysis forms were generally limited to parameters and control functions.

I Needed characteristics of information such as units of measurement, range, reading accuracy or precision, etc., were not identified. Needed character.

istics of controls such as the type of control capability required (e.g.,

discrete versus continuous); the type of control operation required if the l control capability needed is discrete (e.g., detented versus spring-loaded, momentary contact positioning); control positions; rate, gain, and response characteristics; etc., were not identified. However, based upon a review of the E0P development program, the NRC audit team found that the SFRATA should satisfy the requirements of Supplement 1 to NUREG-0737 when supplemented with the results of the development, verification, and validation of E0Ps.

The NRC audit team found that the E0P upgrade consultants were determining the availability and suitability of instruments and controls in the control room for performing the procedures. However, the NRC audit team determined that the qualifications of the E0P upgrade consultants do not reflect the level of human factors expertise normally needed to ensure a comprehensive 2

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analysis of tasks for information and control requirements, and that addi-tional analysis may be necessary. In order to demonstrate that a compre-hensive analysis of tasks for information and control requirements was performed, the NRC stated that PSE&G aust provide a description of how the current E0P development methodology and findings will supplement the DCRDR SFR&TA and what further human factors effort must be accomplished.

A review of the E0P development program as described in the SSR found that the suitability of 1.istruments and controls in the control room for performing the procedures was evaluated to a limited extent. The suita-bility of instruments and controls in supporting the performance of the procedures was evaluated in the E0P verification and validation activities.

The bas,is of the evaluation of instrument and control suitability in the i verification activity appeared to censist of operations feedback and engi-neering (nput as documented in the setpoint study and the E0P/ ERG Comparison Record. PSE1G states that the setpoint study provided documentation of plant-specific information requirements, and the E0P/ ERG Comparison Record provided documentation of necessary deviations from the ERGS based on an i analysis of plant-specific characteristics.

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PSE&G states that "information and control capabili ,es required for each rolei caetion, and step in the Salem E0P were identifled by performing a setpoirt study and by systematically evaluating the instrumentation needs associated with performing the emergency tasks." In addition, PSE&G states ,,

that "the E0P/ ERG Comparison Record ... provides documentation of necessary deviations based on unique Salem design characteristics" (p. 4-14 of the SSR). PSE8G continues by stating that "the setpoint study provided documen-tation of plant-specift: information requirements. ;" that "setpoint infor-mation included the required parameter, units, and any allowances for accuracy of information"; and that "although readability error was not included in tLe setpoint study, this factor was independently evaluated by the Procedures Development Team." The basis of the evaluation of instrument and control suitsbility in the validation activity appeared to consist of operations feedback from the E0P walk-throughs as documented in the Devia-tion Log and from training sessions. In its discussion of the implications ,

l of the ECP development program in satisfactorily supplementing the SFR&TA, l PSElG states that "the E0P review ir.cluded an analysis of means, units, reading accuracy and acceptable tolerances s:Sociated with instrumentation.

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i This effort can provide additional documentation of the relevant characteristics of information required in response to emergencies" (p. 4-15 of the SSR). PSESG also states that "although relevant control characteris-tics were not formally listed, the suitability of controls was analyzed via engineering evaluations and in feedback obtained from operators." '

Based on the statements PSE&G has made concerning the evaluation of availability and suitability in the E0P development program and the samples provided of the EOP/ ERG Comparison Record and the Deviation Log (no sample forms were provided of the setpoint study), it appears that an evaluation of ,

instrcments and, to a lesser extent, controls was performed. However, there does not appear to be sufficient evidence in the forms provided that demon-strates a systematic and comprehensive analysis of tasks and information end control requirements was performed which identified and listed needed characteristics of instruments and controls for subsequent verification in the control room. PSE&G states that " issues of acceptability and/cr suita-bility have been noted, subjected to engineering esaluation, and resolved."

In order to perform a more complete and conclusive review of the E0P development program in supplementing the SFR&TA, PSE&G nesds to provide documentation of the noted, evaluated, and resolved issues of acceptability and/or suitability which demonstrates the problems identifled and the reso-lutions determined as required by Supplement I to NURES-0737. In addition, PSE&G should provide any other forms which would support its discussian (e.g., from the setpoint study).

4. Control Room Survey Based upon the findings of the pre-implementation audit, the NRC audit team concluded that PSEAG should submit the following ecumentation in order to resolve the NRC's remaining concerr.s regarding the acceptability of the control room survey in meeting the requirements of Supplement I to NUREG-0737:

1. A description of all the environmental survey methodologies.

2. A description Df the approach taken to establish and apply color ,

coding and labeling standards in the control rooms and hot shetdown panels.

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Section 2 of the SSR includes a description of the environmental survey method >1ogies and findings. A review of this documentation has found the methodologies and findings of the illumination, luminance, sov .3 and te'aperature and humidity surveys to be adequate. The resolution of the HEDs generated from these surveys has been addressed previously in'the SAIC'TER and in the Selection of Design Improvements ser*R$ 9' this report.

Section 3 of the SSR describes the Salem design conventions and stan- i dards for the following aspects of the control room: abbreviations, color coding, and hierarchical labeling and demarcation. A review of Appendix A l of the SSR, which contains the " Standard Abbreviations List " has found this list to be inadequate as a standard. It appears to be merely a compilation of abbreviations and acronyms used in the control room and other contexts within the plant. PSE&G states that some instances remain where a single word or phrase has more than one abbreviation, or that more than one word or phrase has the same (or very similar) abbreviation. No fewer than 99 instances of such inconsistencies were found in the " Standard Abbreviations L i s t." PSE&G states that this list will be followed during future design changes. This statement appears to indicate that no corrective action or standardization of abbreviations and acronyms will be performed in the present control room or for the present procedures. The present use of abbreviations and acronyms in the control room is inadequate due to the existence of at least as many inconsistencies as were found in the " Standard Abbreviations List." Overall, the concerns that exist regarding the abbre-viations list are (1) the numerous inconsistencies, and (2) its limited application to future design changes and apparently n.ot to the present control room and procedures.

A review of the Salem color-coding convention provided in Table 12 of the SSR has found it to be inadequate. There are a large number of differ-  :

ent meanings associated with each color (e.g., 14 meanings for red) dimin-l 1shing its usefulness as a discriminator and increasing the potential for -

l operator error. Furthermore, there is a redundancy of colors for the same meanings or similar functions (e.g., trip, reset, etc.). The color-coding l conventions listed in this table do not appear to be comprehensive of all colors used or to be used in the control room and provide no indication of the context (e.g., CRT, indicator lights, mimics, etc.) in which they appear. HED 57 indicates that the indicators powered by instrument buses A.

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.s B, C, and D will be coded by the colors green, gray, blue, and brown, respectively. The color-coding conventions do not include the colors gray and brown. The color-coding conventions do not account for some of the colors and meanings used in the simic color coding in the . control , room (Figure 11 of the SSR). PSE&G states that these conventions will be refer-enced during future design changes. This statement appears to indicate that no corrective action or standardization of color usage will be performed in the present control room. The present color coding in the control room is inadequate due to the existence of at least as many inconsistencies as were found in the color coding conventions. Overall, the following concerns exist regarding the color coding convention: (1) the redundancies in colors used for the same meaning or similar functions; (2) the large number of different meanings associated with each color; (3) the lack of comprehen-siveness of color application in the control room; (4) its limited applica-tion to future design changes and apprently not to the present control room; and (5) the lack of discussion concerning application of a color-coding standard across the display cent !xts (e.g., SPDS, indicator lights, mimics , etc.).

A review of the discussion in Section 3.3 of the SSR concerning the hierarchical labeling and demarcation at Salem produced several concerns.

HED 658 describes the inconsistent letter height on labels within the hier-archical level. PSE&G states that DCR 1EC-1092 has implemented new labels for Unit 1 that meet the intent of the human factors guidelines and that through 2EC-1093, the same will be done for Unit 2. PSE8G's statement i suggests that the new labels may not meet the letter of the human factors guidelines. Any such deviations need to be identified by PSE&G. PSE&G made no mention of developing a standard for the application of mimics in the control room (other than color usage). Also, no mention was made of apply-ing standards or criteria for hierarchical labeling, demarcation, and mimics in the SPDS.

PSE&G's discussion on demarcation addressed HED 477 and panel layout philosophy. HED 477 (page 407 of the SR) concerns the lack of demarcation of the AFW controls in the Hot Shutdown Panel (Panel 213). PSE&G is intend-ing to provide demarcation to correct this HED. PSE&G presently does not intend to make any corrections to the control t oom panels using demarcation.

PSE&G states, "With respect to both hierarchical labeling and demarcation, 6

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Salem has chosen to be conservative since the panels are already ci:sely packed with instrumentation and controls (!&C) due to the miniaturized module nature of design and backfits over the many years of plant operation.

(The modularized design of the boards does provide effective spatial enhancement.) The trade-off between enhanced operator identification of I&C and creation of additional HEDs by cluttering the boards was given serious attention by the DCRDR tsam. In future design changes, this trade-off will be given equally serious :onsideration."

i The necessity of developing a standard for demarcation depends upon whether improvements to panel layout will be performed. As discussed by PSE&G in sectf ons 6.2.2.1 and 6.2.2.2 of the SSR and in the Selection of Design Improvements section of this report, minimal improvements to the control panel layout are planned. The final resolution of this issue may or may not have an impact upon the necessity of demarcaticn and other panel enhancement applications. If such enhancemer.ts are needed, then standards for demarcation, hierarchical labeling and those enhancements involved

should be developed.

PSE&G states that it has developed lettering guidelines "for use in specifying characteristics of labels, annunciator tiles and control /

l display / alarm pushbutton/ indicators" and that the annunciator specification was implemented on an experimental basis in the control room to ensure reada bil i ty." PSE&G did not clarify the basis of these guidelines and its application to the remainder of the control room. HEDs 152 and 621 indicate that a human factors standard will be used to specify lettering requirements as some legend pushbuttons and legend indicators in the control room are repl a ced. The relabeling of these controls and displays is a positive action toward improving the overall readability of information in the con-trol room. However, many other instances of discrepant labels and lettering exist in the control room for which PSE&G does not intend to take corrective action. These include legend pushbuttons and indicators as well as other component types. These HEDs are listed in Appendix D. The need for PSESG to apply an adequate standard abbreviations list to the present control room will involve most or all of these HEDs. The labels associated with these i

HEDs, and those located elsewhere, should be corrected if the standard l abbreviation list, hierarchical labeling, and lettering guidelines are applied to the present control room and hot shutdown panel.

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t In summary, the environmental surveys have been found to be adequately performed. PSE&G has developed standards for application to future design changes. However, there is a need for application of such standards to the i present control room as demonstrated by numerous inconsistencies in labeling and color coding. Before this can be performed, these standards need to be considerably improved to meet established human engineering principles for labeling and color coding. PSE&G needs to describe the lettering guidelines it has developed. Its application to annunciator tiles and some components is a positive action to improving the readability of information in the control room. However, its application should be widespread, as should an

{ upgraded standard abbreviations list and a color coding convention, in the control room, hot shutdown panel SPDS, procedures, and wherever the opera-tor interfaces with the plant. In order for these concerns to be satisfied, additional discussions with and commitments from PSE&G are necessary.

5. Assessment of HEDs Based upon the findings of the pre-implementation audit, the NRC audit team concluded that PSE&G should submit the following documentation in order to resolve the NRC's remaining concerns regarding the acceptability of the assessment of HEDs in meeting the requirements of Supplement I to NUREG-0737:

1. A description of its consideration of the cumulative and interactive effects of the HEDs listed in Appendix B, section 2 for assessment and resolution.

2. A description of the rationale used for assessing each HED listed in Appendix C.

PSE&G indicates that three HEDs have been upgraded due to the existence of cumulative effects of annunciator HEDs (p. 6-177 of the SSR). However, this appears to be the only discussion in the SSR concerning cumulative and interactive effects upon the assessment of HEDs. Section 6.2.2 of the SSR appears to address only cumulative and interactive effects upon the l resolution of HEDs. Although the upgrading of the assessment of three I

annunciator HEDs indicates that PSE&G has considered cumulative and interactive effects upon HED assessment to some extent, there is no 8

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1 discussion pertaining to this consideration for the other HEDs listed in Appendix B, item 2 of the TER. The discussion provided in Section 6.2.2 of the SSR should not pertain to the assessment of HEDs since HED assessment should be independent and unbiased from intended resolutions. Further '

discussion with PSE&G is necessary to resolve this NRC concern.- ,

A review of the assessment of HEDs in the Summary Report found 3D HEDs

' that were assessed as Category IV findings (i.e., HEDs which neither increased the potential for causing or contributing to an operator error nor had adverse safety consequences) but which the staff determined should have been assessed at least as Category III HEDs (NEDs found to have the potential to cause operator errors of low probability which could result in adverse plant conditions). The NRC required further response to the assess-ment of these HEDs. Section 6.3 of the SSR contains the HEDs for which documentation of the rationale for the Category IV assessment was required.

A review of these 30 HEDs in the SSR has found that 8 HEDs have been upgraded to Category !!! and the remaining 22 HEDs have retained their l

Category IV assessment. Of these 22 HEDs, nn rationale was provided for the i

Category IV assessment of 16 HEDs. In addition, the rationale given in the S,SR for 4 other HEDs appeared to contradict the Category IV assessment that still remained. In the comments given for these HEDs, the association of the discrepant components with emergency operations is mentioned. Explicit with the fact that a human engineering discrepancy exists is the probability of operator error. Since some probability of operator error must exist and the discrepant components have an association with emergency operations, the consequence of the operator error occurring could have,an adverse impact upon plant conditions. HEDs of th's significance should be at least Category III HEDs, not Category IV HEDs. These 4 HEDs and the 16 for which no rationale for assessment was provided need to be further addressed by PSE&G. In addition, the assessment of four other HEDs which appear to be related to emergency operations need to be addressed. These four HEDs were identified due to additional information provided in the SSR which leads NRC to believe these HEDs are safety-related but ware assessed as Category IV HEDs. All these HEDs are listed in Appendix C of this report.

a In summary, PSE&G has not sufficiently addressed the NRC's remaining concerns regarding the assessment of HEDs. Further discussion with PSE8G is necessary to progress toward a resolution of these concerns. Further l

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discussion with PSE&G should also address the independence with which the HEDs associated with these concerns were assessed from the resolutions proposed.

6. Selection of Design Improvements The NRC audit team found the methodology for selecting design improve-ments to be satisfactory. However, a significant portion of the HEDs identified had resolutions that were inadequate or inadequately documented or resolved. In addition, no calendar dates for the implementation schedule of HED corrections were given.

Section 6 of the SSR includes documentation of those HEDs found during the pre-implementation audit to be inadequately documented and resolved.

Section 6.1 includes documentation of those HEDs listed in Appendix A, section 1 of the SAIC TER in which the proposed corrective action described by PSE&G during the audit appeared to be adequate but needed to be docu-mented for NRC review. Of the 26 HED resolutions described, 9 were found to be adequate. The other proposed resolutions (not always corrections) were found to be inadequate or to require further clarification. Appendix A of this report contains the complete list of HEDs from section 6.1 (by HED number) in which resolutions were proposed and were found to be adequate or to be insufficiently described or resolved.

Section 6.2.1 of the SSR includes documentation of those HEDs listed in Appendix B, section 1 of the SAIC TER in which justifications for HEDs le'ft uncorrected or partially corrected were found to be inadequate and to require further consideration and documentation for NRC review. Of the 133 HED resolutions described (some were corrections), 37 were found to be adequate. The other proposed resolutions were found to be inadequate or to Included in Appendix B, sections 1 and 2 of require further clarification.

this report is the complete list of HEDs from section 6.2.1 (by HED number) in which +esolutions were proposed and were found to be adequate or to be insufficiently described or resolved.

Section 6.2.2 of the SSR includes responses to the NRC audit team's findings that the justifications for not correcting the HEDs in Appendix B, i 10

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e section 2 did not consider the cumulative and interactive effects of  ;

individual HEDs.

Section 6.2.2.1 includes responses to the NRC concern that panels CC-1, CC-2, and CC-3 have layout problems documented in 29 HE'Ds. psf 8G's ,

responses to each HED were either that no corrective action would be taken i or that the discrepancy will be handled by training. The NRC audit team ,

found these responses to be inadequate in light of the number and signifi-cance of the panel layout problems. The NRC audit team concluded that due to the cumulative and interactive effects these HEDs have upon each other and the layout of the pancis, PSE8G should provide an operational and behavioral justification or resolution that takes these effects into account. A review of PSE&G's response to this concern found that it did not address cumulative and interactive effects of these HEDs and the type of

layout problems the HEDs are associated with upon the layout of the panels.

PSE&G addressed the types of layout problems on an individual basis. In addition, PSE8G's response to individual layout problems does not have an empirical and objective basis such as that characteristic of NUREG-0700.

Grouping of controls and displays by system through the use of bezels occurs in some of the control room. However, the layout problems the 29 HEDs represent involve safety-related components and occur across and within bezel groupings. The sum or product of these cumulative and interactive HEDs and its potential effect upon operator perforciance and plant safety transcends training as the sole source of corrective reasures. Due to the serious nature of this issue and its implications upon the DCRDR, the NRC and PSE&G should meet to discuss alternative means to resolve this issue' .

The 29 HEDs concerned with this issue plus one other (f142) are listed in  :

Appendix B, section 3.a of this report.

Section 6.2.2.2 of the SSR addresses the NRC audit team's concern over the interactive effect between the relatively narrow clearance between panels and the high and low location of components on r3nels RP-1, RP-3, RP-4, and RP-6. The concern was for the compounding effect of the close proximity of these panels to the back of the consoles upon (1) the  ;

readability of displays located higher or lower than the height recommended by the guidelines, and (2) the operability and potential for. accidental '

activation of controls located below the height recommended by the guidelines. A review of PSE&G's response to this concern found that it 11 4, . _ . , , _ , - . . _ _ _ _ _ . _ . . _ . _ _ . _ . . ~

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satisfactorily resolved some but not all of the HEDs involved. The part of PSE&G's response which addressed the interaction of HEDs 9,177, and 178 with HED 1 was found to be satisfactory. More information from PSE&G is needed to resolve concerns over the interaction of HEDs 6,180, and 13 with HED 1 in order to resolve all four of these HEDs. Relative to'HEDs 6 a'n 13, PSEAG needs to provide the details of its approach to and results of the j review of all meters on these panels for visibility and readability. PSE&G states that the indicator lights associated with HED 180 are safety-related and that there are annunciators to alert the operators depending on the reason for the electrical failure. PSESG needs to describe what the annun-ciators are and where they are located relative to these indicator lights.

The resolution of HED 1 is dependent upon the resolution of these other

! remaining HEDs. The HEDs associated with this concern are listed in l Appendix B, section 3.b of this report.

Section 6.2.2.3 of the SSR addresses the NRC audit team's concern regarding the availability and accessibility of aids for operating the process computer system. PSE1G states that it presently has a study program for the purpose of upgrading the process computer system at Salem. It will ,

specify and procure a new system with human factors guidelines, including NUREG-0700 and others (e.g., MIL-STD-14728). PSEAG appears to satisfy the concerns of the NRC audit team in that the upgrading of the process computer system will include hardware and peripherals, software, and documentation.

However, PSE&G needs to describe how the upgrading of the process computer l

! system will resolve in specific each of the following HEDs once the design of the new system is finalized: 18 9, 190. 191. 196. 199, a nd 555. In addition, PSE&G needs to indicate its schedule for implementing the new coraputer system. These HEDs are listed again in Appendix 8, section 3.c of this report.

Section 6.2.2.4 of the SSR addresses the NRC audit team's concern regarding the readability of labels and displays in the following areas:

e Illumination / contrast 1

o El 300' and 33' wind speed and direction recorders -

( o Fire protection legend indicators i 12

i e Mimic color coding

! e Annunciators  !

.i In general, the concerns regarding the cumulative and'interac'tive effects of HEDs within each of these areas have not been satisfactorily addressed. PSESG has stated that it will use the results of the lighting survey and will modify lighting levels to be as close to the guideline range as possible. PSE&G needs to document its finalized corrective action as it j affects HEDs 625 and 626. Although backlit pushbuttons do provide a source of light to read the engraved, backlit labels, backlit pushbuttons are not

. an adequate source to supplement emergency lighting for other labels and

! displays (e.g., meters). Backlit pushbuttons in such lighting contexts i could possibly degrade readability of adjacent labels and displays due to -

! increased glare and excessive luminance contrast. The HEDs associated with

) this concern are listed in Appendix 8. section 3.d of this report.

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PSE&G states that although the elevation 300' and 33' wind speed and direction recorders do not conform to all human factors guidelines, the DCRDR team concluded that the recorders were adequate in terms of readability. PSE&G needs to provide the basis of its rationale for this determination as it relates to the associated HEDs. The HEDs associated with this concern are listed in Appendix B, section 3.d of this report.

The NRC audit team had a concern regarding the cumulative and inter-active effects of the HEDs associated with the readability and visibility of the fire protection legend indicators. Although PSE&G addresses the fire alarm capability and the enhancement of the search process for fire protec-l tion legend indicators through panel arrangement, it does not address the l

cumulative and interactive effects of the HEDs upon readability of the indicators. The HEDs associated with this concern are listed in Appendix B, section 3.d of this report.

The NRC audit team's concern about the inconsistent use of simic colors and the effect of illumination problems upon the discernability of colors used was indirectly addressed in PSE&G's discussion on improving lighting levels and consistency throughout the control room. PSE&G also presented the mimic color-coding scheme (Figure 11 in the SSR) in the Salem control 13 r, a.-_-.--.--- - - - _ - . - . ---- _. -.

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room in response to the concern about inconsistent color-coding across mimics in the control room. A review of the mimic color-coding scheme found that there were inconsistencies across panels (although not within panels) and that the mimic color coding was inconsistent with the, color-coding '

convention (Table 12) to be applied elsewhere in the control room. The HEDs l

associated with this concern are listed in Appendix B, section 3.d of this report.

l l Section 6.2.2.5 o f the SSR lists those HEDs associated with i annunciators. The NRC audit team's concern here was for the cumulative

( effect of these HEDs upon the auditory environment in the control room.

l With the exception of one HED, PSE&G's previous response was that no corrective action was going to be taken. In the SSR. PSE!.G has ctw ged its position to that of addressing all but one of the annunciator HEDs in one annunciator system design change package. PSE8G states that "in the l procurement of an upgraded annunciator system, Salem will review these concerns and take advantage of recent guidance on the design .of alarm systems (i.e., NUREG/CR-3217) to supplement the Guidelines for Control Room Reviews (NUREG-0700)." In order for these particular annunciator HEDs to be resolved, JSE&G needs to document for NRC review how the upgraded annunciator system has corrected these HEDs and the schedule for implementing the new annunciator system. For HED 635 in particular, the adequacy of the justification for not correcting this HED cannot be ascer-tained untti the final resolution of the other annunciator HEDs has been submitted by PSE1G. The HEDs associated with this concern are listed in Appendix B, section 3.e of this report.

The Assessment of HEDs section of this report previously discussed the review of the assessments given for the HEDs in Section 6.3 of the SSR.

Some but not all of these HEDs were duplicated in Section 6.2.1 of the SSR.

These were HEDs 19, 41,123,133, 204, 397, and 599. The review findings for these seven HEDs are indicated in Appendix B, sections 1 and 2.

Overall, a significant number of HEDs contributing to cumulative and interactive effects have not been adequately addressed. Although some of the HEDs were apparently addressed or corrected, especially those related to l the process computer system and annunciator system, a large number of HEDs remain to be addressed in the context of their involvement in cumulative and l

l 14

1 interactive effects. Those HEDs that were found to be adequately addressed but need to have specific final resolutions documented and those needing further discussion and resolution are listed in Appendix B, section 3 of this report. HED 625 was not addressed at all in the SSR and was listed in Appendix B, section 3 of the SAIC TER. This HED needs to be addresse'd by PSE&G.

PSE&G did not include in the SSR a schedule for implementation of HED corrections. In its cover letter to the SSR, PSE8G justifies this as follows:

"Our letter of September 18, 1984 indicated that design changes to correct human engineering discrepancies (HEDs) identified in the DCRDR would be implemented during the 1986 refueling outages for the Salem units. However, as a result of your November 1984 pre-implementation audit, the scope of these design changes has increased substantially, as can be seen on the attached summary listing of additional . changes.

In as much as it is our policy to implement major design changes in a coordinated fashion, our overall approach for implementation of HED corrections will be re-evaluated. We will provide our implementation l schedule upon receipt of your written approval of our proposed HED corrections."

However, NRC approval of PSE&G's proposed corrections cannot be complete a until PSE&G provides satisfactory HED documentation necessary to allow the NRC to finalize -its review. The NRC and PSE&G should negotiate a schedule for the submittal of the necessary HED documentation and a schedule, including calendar dates, for the implementation of HED corrections.

In summary, many HEDs requiring further documentation c1 proposed corrections and justifications for not correcting HEDs were found to be adequately resolved. However, a significant number of HEDs have not been adequately resolved. All of these HEDs have been listed in appendices A and B of this report according to NRC findings from its review of the HED documentation in the SSR. A schedule for the resolution'of the remaining, unresolved HEDs needs to be established in order to determine a schedule for the implementation of HED corrections.

15

) -

7. and 8. Verification That Improvements Will Provide the Necessary l Corrections Without Introducing New HEDs I

l Based upon the findings of the pre-implementation audit, the NRC audit ,

team concluded that PSE&G should submit a description of how it will ensure adequate human factors review, prior to sign-off, of DCRs and EDDs l originating from the DCRDR in order to resolve the NRC's remaining concerns regarding the acceptability of the HED correction verification process in meeting the requirements of Supplement I to NUREG-0737. PSE&G responds to this concern in Section 5 of the SSR entitled " Human Factors in Future Design Changes." A review of the general design change request (DCR) i development process has found that PSE&G intends to incorporate a human factors review in the initial design memorandum and after the design change package has been developed. Both activities occur prior to the DCR sign-off .

which currently includes a signature for the human factors review.

The basis of the human factors review will be a Salem-specific set of human factors guidelines that have not yet been developed. PSE&G states that in the interim, NUREG-0700 and Salem-specific DCRDR documentation (such as color-coding guidelines) will be used. Except for the use of certain Salem-specific DCRDR documentation (e.g., color-coding guidelines, standard I

abbreviations list), the approach and criteria for verifying HED corrections in the DCR process appears to be adequate. As discussed in the Control Room Survey section of this report, those Salem-specific documents are not adequate. In order for PSEAG to meet the Supplement I to NUREG-0737 requirements for the verification of HED corrections, the basis of this proc,ess (i.e., the guidelines, standards, and conventiens) must conform to established human factors principles.- This will involve upgrading the Salem-specific standaras and conventions and providing documentation of this. In addition, documentation of the as yet to be developed Salem-specific set. of human factors guidelines which demor.strates conformance to established human factors principles, and is comprehensive of these principles for its use, should be submitted to the NRC fo seview.

9. Coordination of the DCRDR With Other Improvement Programs Based upon the findings of the pre-implementation audit, the NRC audit .

team concluded that PSE&G should submit a description of hot it will ensure 1

1 1

16

r. ._

i

) that the results and remaining methodologies of the DCRDR will be coordinated and integrated among all emergency response capability (ERC) programs. The only portion of the SSR which appears to address this concern is found in Section 1.2. In this section. PSE8G's discussion is limited to the personnel involved in the DCRDR and some of the other ERC programs.

PSE&G's basis for ensuring that the DCRDR is coordinated with other improvement programs appears to be limited to the continuity of personnel among the DCRDR SPDS, EOFs, and upgraded E0Ps. As found during the pre-implementation audit, continuity of personnel cannot be relied upon as the sole provision for coordinating and integrating the DCRDR with the other improvement programi (including Reg. Guide 1.97 and training). This was particularly apparent in the lack of coordination found by the NRC audit team between the E0P upgrade program and the DCRDR SFR&TA. PSE&G apparently has not established or documented a system, schedule, or program which will ensure that the appropriate coordination and integration occurs. Until documentation of such a capability is provided to the NRC, PSE&G has not met this requirement of Supplement I to NUREG-0737.

SUMMARY

AND CONCLUSIONS Based on its findings during the pre-implementation audit, the NRC audit team concluded that PSE&G had satisfied some but not all of the

{ requirements of Supplement I to NUREG-0737. Based on the review of the Supplemental Summary Report (SSR), we conclude that PSE&G has satisfied some but not all of these concerns remaining from the pre-implementation audit.

The documentation provided in the SSR has satisfactorily addressed and resolved the concern regarding the methodologies for performing the environ-mental surveys. However, the documentation provided in the SSR has not satisfactorily addressed and resolved the following areas of concern from the pre-implementation audit:

e Function and Task Analysis, and Comparison of the Display and Control Requirements With a Control Room Inventory

- The adequacy of the E0P develop'nent program in supplementing the SFR&TA.

i 17

1. w~---_,, ,..-,..--~,,w,_._.__.._.--,-- . . - - , . - , , . . . _ , . . - . . _ _ , - _ . . _ _ - . . ~ _ - .

o Control Room Survey

- The adequacy and application of the standardized abbreviation list, color-coding convention, and lettering g.idelines.

e Assessment of HEDs

- The consideration of cumulative and interactive effects of t'he HEDs listed in Appendix 8. Section 2 of this report.

- The rationale used for assessing the HEDs listed in Appendix C, Sections 2 and 3 of this report.

e Selection of Design Improvements

- The resolution of the HEDs listed in Appendix A. Section 2 of this report.

l

- The resolution of the HEDs listed in Appendix B. Sections 1 and 2 of this report.

- The resolution of the HEDs affected by the procurement of new process computer and annunciator systems (listed in Appendix B.

Section 2) and the implementation schedule for these systems.

- The consideration of cumulative and interactive effects and the resolution of the HEDs listed in Appendix 8. Section 2.

- The calendar dates for the implementation schedule of HED corrections.

e Verification That Improvements Will Provide the Necessary Corrections Without Introducing New HEDs 1

- The adequacy and application of the Salem-specific set of human

factors guidelines and other documents (i.e., the standard abbreviation list, color-coding conventions, and lettering guidelines).

18

o Coordination of the DCRDR With Other Improvement Programs

- The schedule and system / program for ensuring that emergency response programs are coordinated and integrated. ,

i In summary, PSE&G has improved upon the resolution of HEDs since the pre-implementation audit. However, there remains a significant number of HEDs that have not been adequately resolved. According to the cover letter for the SSR. PSE&G will not provide an implementation schedule for HED corrections until it receives approval of its proposed HED corrections (and proposed justifications for not taking corrective actions) from the NRC. In order to provide a forum for discussion of these issues and to progress toward the resolution of the NRC's remaining concerns regarding the Salem DCRDR, a meeting should be held with Salem DCRDR representatives by the NRC.

I 19 x - .. . . .

REFERENCES

1. " Salem Generating Station Units 1 and 2 Control Room Design Review Program Plan," Public Service Electric and Gas Company, November,1982.

2. ' etter from E.A. Liden, PSE&G, to S.A. Varga, USNRC, dated February 14, 1983, submitting Control Room Design Review Program Plan for Sal.em Generating Station Units 1 and 2.

3. "NRC Review Comments on Salem DCRDR Program Plan," attachment to Memorandum from W.T. Russell, USNRC, to G.C. Lainas USNRC, dated October 7, 1983.

4. " Detailed Control Room Design Review Report for the Public Service Electric and Gas Compsny, Salem Station Units 1 and 2, Volume 1:

Review Plan and Summary, Volume 2: HED Docu.nentation," December 30, 1983.

5. "SER INPUT for the Salem Generating Station Detailed Control Room Design Review," attachment to Memorandum from W.T. Russell, USNRC, to G.C. Lainas USNRC, dated March 21, 1984.

6. " Supplemental Information Detailed Control Room Design Review "

included in and attached te a letter from E.A. Liden, PSE&G, to S.A.

Varga, USNRC, dated September 18, 1984.

7. " Human Factors Engineering Branch Detailed Control Room Design Review Supplemental Safety Evaluation Report For Salem Generating Station, Units 1 and 2 " attachment to Memorandum from D.H. Beckham, USNRC, to G.C. Lainas. USNRC, dated April 5,1985.

8. " Detailed Control Room Design Review Report for the Public Service Electric and Gas Salem Station Units 1 and 2. Addendum " attachment to

, letter from C.A. McNeill, Jr., PSE&G to S.A. Varga, USNRC, dated September 16, 1985.

9. NUREG-0660, Vol.1. "NRC Action Plan Developed as a Result of the THI-2 Accident," USNRC, Washington, D.C., May 1980; Rev.1 August 1980.

20 7 _ __ - _ . - _ _ - _ . _ . _ . _

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

l .-

1

10. NUREG-0737, " Requirements for Emergency Response Capability, " USNRC, l

Washington, D.C., November 1980.

11. NUREG-0737, Supplement 1 " Requirements for Emergency Response Capability," USNRC, Washington, D.C., December 1982, tr'ansmitte'd to reactor licensees via Generic Letter 82-33, December 17, 1982.

l 12. NUREG-0700, " Guidelines for Control Roora Design Reviews," USNRC, Washington, D.C., September 1981.

13. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 18.1, Rev. O, USNRC, Washington, D.C., September 1984.

a -

Salem 1 and 2 TAC Nos. 51298 and 51299 SAIC 1-263-07-557-61/62 NRC-03-82-096 21 T. ._

APPEND!X A HEDs (by HED number) from Saction 6.1 of the SSR in which resolutions were proposed and were found to be (1) adequate or (2) insufficiently described or resolved.

1. The proposed corrective actions and justifications for not taking corrective actions were found to be adequate for the following HEDs:

. 55, 90, 130, 164, 399, 550, 627, 721, and 722

2. The proposed corrective actions and justifications for not taking corrective actions were found to be insufficiently described or ,

resolved as follows:

a. The description of the proposeo corrective action, justifica-tion for not taking corrective action, or discrepancy was ambiguous or in need of further clarification in order for an evaluation to be completed.

58, 280, 380, 542, 583, 649, 658, 720, and 725

b. The proposed correction was not finalized.

l 25, 97, 98, 306, and 667, .

c. The proposed correction will not correct the discrepancy.

60 and 372

d. The proposed corrective action only partially corrects the discrepancy.

l 57 22

a APPENDIX B HEDs (by HED number) from Sections 6.2 and 6.3 of the SSR in which resolutions were proposed and were found to be (1) adequate or (2) insuffi-ciently described or resolved; and (3) discussion on the cu.mulative and interactive effects of HEDs was provided but found to be insufficient to resolve these concerns.

1. The proposed corrective actions and justifications for not taking corrective actions were found to be adequate for the following HEDs:

10 132 216 259 437 31 142 234 283 479 37 171 245 333 480 81 178 247 338 532 l

110 181 251 372 560

115 206 255 373 562 i

116 214 256 397 563 432 622

2. The proposed corrective actions and justifications for not taking corrective actions were found to be insufficiently described or resolved as follows:

a. The description of the proposed corrective action, justifi-cation for not taking corrective action, or discrepancy w'as ambiguous or in need of further clarification or discussion in order for an evaluation to be completed:

2 41 126 282 402 521 534 6 80 133 313 405 522 538 13 114 152 320 430 523 625 19 121 204 358 478 533 635 l

l b. The proposed correction was not finalized:

549 and 621 23

. o

c. The proposed correction will not correct the discrepancy:

3 and 5

d. The proposed corrective action only partially. correct % the discrepancy:

39, 134, 141, and 680

e. The resolution is not consistent with previous, similar com-mitments for corrective action:

14 (relative to 13)

f. The basis of the justification is not adequate (i.e., it does not address operational or behavioral factors):

139

g. The justification insufficiently addresses the discrepancy:

12 140 242 343 38 146 243 429 65 166 308 599 111 203 341 610 664 l

l

h. The justification of individual HEDs does not consider the cumulative or interactive effect of other HEDs.

l

- Interaction between 295 and 310 on readability

- Cumulative effects of bulb testing and maintenance problems (260, 262, 308, and 342) on reliability of " Dark Board Concept" (349) 24

~ ~ ~

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

3. HEDs from Section 6.2.2 of the SSR in which discussion on the cumulative and interactive effects of HEDs was provided but found to be insufficient to resolve these concerns,

a. HEDs from Section 6;.2.2.1 of the SSR in which the discussion of the cumulative and interactive effects of HEDs upon the layout of panels CC-1. CC-2, and CC-3 was found to be insuf-ficient.

CC-1: 132, 134, 139, 140, 141, 145, 146, 523 and 672 CC-2: 37, 39, 41, 109, 111, 113, 114, 119, 120, 121, 122, 133, 521, and 522 CC-3: 133, 204, 205, 206, 211, 214, and 216

b. HEDs from Section 6.2.2.2 of the SSR in which discussion of the cumulative and interactive effects of HEDs associated with pane? clearance and panel location of components was found to be adequate or found to be insufficient.

Adequately resolved

9, 177, and 178 Insufficiently resolved: 1, 6, 13. and 180 l .

c. PEDS from Section 6.2.2.3 of the SSR in which discussion of the cumulative and interactive effects of HEDs associated with '

( availability and accessibility of aids 'for operating the process computer system was found to be satisfactory. How-j ever, PSE&G will need to provide further information of how the upgrading of the process computer system will resolvt each I of the following HEDs and the schedule for implementing the new computer system:

189, 190. 191, 196. 199, and 555 l d. HEDs from Section 6.2.2.4 of the SSR in which discussion of the cumulative and interactive effects of HEDs associated with 25

1. . , - , , .. ._ . - . _. , .-- . . _ - - - _- - - . . - - - - - . . . - -

e illumination / contrast with those HEDs associated with the other areas listed below was fnund to be insufficient.

Illumination / contrast: 21, 625, 626, and 631 El 300' and 33' wind speed and direction recorders: 250, 444, 450, and 458.

Fire protection legt.nd indicators: 324, 325, 328, 331, 332, 349, 354, and 551.

Mimic Color coding: 54

e. HEDs from Section 6.2.2.5 of the SSR in which discussion of the cumulative and interactive effects of HEDs associated with the annunciator system was found to be satisfactory. However, PSE&G will need to provide further information of how the upgrading of the annunciator system will resolve each of the following HEDs and the schedule for implementing the new annunciator system:

492 530 540 635 712 716 502 531 541 710 714 718 507 535 543 711 715 i -

26

~

'~

.=

APPENDIX C HEDs (by HED number) from Section 6.3 of the SSR in which rationale for the assessment was provided and found to be (1) acceptable. (2) unaccepta-ble, or (3) was not provided at all. ,

1. HEDs in which the assessment was found to be satisfactorily upgraded or sufficiently justified for not upgrading.

3, 5, 13, 14, 37, 41, 540, 541, 599, and 716

2. HEDs in which the rationale for not upgrading the assessment was insufficient.

38, 111, 139, and 242

3. HEDs in which rationale for the assessment needs to be provided.

19. 39, 114, 116, 123, 133, 134, 141, 146, 204, 397, 480, 532, 533, 534, and 538; o -

Also 180, 415, 444 and 450 (identified from the SSR review).

G

/

27

APPENDIX D HEDs from Section 6 of the SSR which are associated with labeling discrepancies and should be addressed by the application of satisfactory standards or guidelines. ~

123 360 408 444 453 153 361 409 445 454 212 362 410 446 455 225 363 411 447 456 244 364 412 448 457 289 365 414 449 459 328 367 415 450 463 329 368 416 451 464 345 369 443 452 465 512 l

l l

28 7 .- . - . .

.