ML20147G557

Suppl 1 to Summary Rept LaSalle County Station,Units 1 & 2 Dcrdr

ML20147G557
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Site:	LaSalle
Issue date:	12/31/1987
From:	COMMONWEALTH EDISON CO.
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Download: ML20147G557 (163)

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December 11, 1987

'% J TO: Mr. L. D. Butterfield Nuc Lic A Site Rev 34 FNE

SUBJECT:

Commonwealth Edison Company's (CECO) response to the Nuclear Regulatory Commission's (NRC) September 9, 1987 Safety Evaluation (SE) Report of the LaSalle County Nuclear Station.

Dear Mr. Butterfield:

Enclosed is the LaSalle County Station's Units 1 and 2 Detailed Control Room Design Review (DCRDR) Supplement i Summary Report. This is CECO's response t.o the NRC's September 9, 1987 SE Report of LaSalle County Station's Units 1 and 2 DCRDR Final Summary Report dated October 1985. It is scheduled to be transmitted to the NRC by December 16, 1987.

Sincerely yours, g E. /MI Robert E. Howard Human Factors Engineering Coordinator Production Services Dept.

i ces J. S. Abel W. R. Huntington C. M. Allen N. N. Kaushal J. C. Blomgren J. J. Krass T. M. Chow H. L. Massin G. J. Diederich J. P. Peters T. A. Hammerich R. Ryback i

K. A. Hesse G. P. Wagner File

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Detailed Control Room Design Review i j

Supplement 1 - Summary Report  ;

December 1987 ,

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TABLE OF CONTENTS j,/ k

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. LaSalle County Station. Unitar i and 2 DCRDR Supplement 1 - Summary Report December 1987 '

r Ew2 Introduction 1 Index of Modified _s 24 Implementation' Dates t .

Enclosure 1 SER Encl. 1- 1

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Enclos0re.A SER Encl. A- 1 Enclosure B TER Append. Al- 1 TER Appendix A1 TER Append. Al- 1 TER Appendix A2 TER Append. A2- 1 TER Appendix A3 TER Append. A3- 1 1

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~e .' COMMUNWEALTH EDISON COMPANY'S RESPONSE TO THE NRC'S SAFETY EVALUATION REPORT OF THE LASALLE COUNTY RTATION, UNITS 1 AND 2 t i DETAILED CONTRtt ROOM DESIGN REVIEW l pu s ..i

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Commonwedith Cdison Company (CECO) submitted the Summary Report for the LaSaile Coupt) Station, Units L and 2 Detailed Control Room Design Review AECRD7),to the NRC October 29, 1985, as required by Supplement 1 to NUPEG-0737. The NRC staf", sosisted by consultants from Science Appli^dtions ryternational Corporation (SAIC) and COMEX Corporation re'qi9v.3d the Summary Report (!,R ) and conducted a Pre'bplementationl Audit (PIA) at LaSa115 Station from June 3 to June 6,iiSGd. In e,ietter to t',e NRC dated April 21, 1987 CECO substq0ently modif tad' the schedt i for complesion of the Human Engineering Discrepancies (HEDs) listed in the SR. Review of Ceco's LaSalle County Station DCRDR activities by SAIC is documented in their Technical, Evaluation (TF) Report dated August 21, 1987. The NRC staff endormea$the evaluations, recommendations and conclusions I, f as presented in the TER and included it in their Safety Evaluation y .

(SE) Report dated September 9, 1967. This LaSalle County Station, Units 1 and 2 DCRDR Supplement 1 Report is CECO's response to that SER.

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Cgmmonwealth Edison Companv'o Response to the NRC's Enclosure 1 o.C the SER NRC Sub3ect: A control room survey to identify deviations from accepted human factors principles

, NRC Concerns CECO should document the asurce and i.dentification of the guidelines it used to conduct the ce ntrol room survey as discussed during the audit.

CECO Response: The human factors guidelines used curing the LaSalle Station DCRDR to identify contrcl room deviations from accepted human factors principles were reconfigured and reapplied to be identical to those used during the Zion, Quad Cities, Byron and Draidwood control room surveys. These guidelines were derived from tNase in NUREG-0700. NRC staff concerns reinted to differences between these CECO guidelines and NUREG-0700 were rettolved as reported in the "Safety Evaulation By The Office of Nuclear Reactor Regulation Related to Detailed Control Room Design Review Coemonwealth Edison

, Compar;r Zion Nuclear Power Station, Units 1 and 2, Docket Nos. 50-295 and 50-304,* section 4, page 3, dated March 10 1997.

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o Pcgo: 2 NRC Sub3ect: Assessment of human engineering discrepancies (HEDs) to determine which are significant and should be corrected NRC Concern #1: CECO should provide assurance that, during the assessment phase of the DCRDR, it had considered, (1) the combined effects of HEDs on operator performance, and (2) the cumulative or interactive effects of other HEDs.

CECO Response #1: The combined effects of HEDs on operator performance and the cumulative or interactive effects of HEDs vere considered throughout the review and assessment process. During the review process each HED was related to a checklist guideline number, regardless of where in the review process it was identified. This served to identify how often a particular problem was identified, which helped direct our attention during the assessment.

As a function of the assessment process, the cumulative and interactive effects were considered and assessments modified to address these concerns. Als7, several CRDR systems design recommendations and their interactive effects were reviewed in great detail on CAD drawings. These revealed both the cumulative strengths and weaknesses of our design recommendations and facilitated the final design specifications.

O NRC Concern #2: HED 162 should be changed to category 1 and the schedule for correcting it should be advanced as appropriate.

CECO Response #2: Per the discussions conducted during the PIA, HED index number 162 was upgraded in category status to category 1.

Since the potential consequences from an operator error due to this discrepancy did not change, the Level, 'B', remained the same (see page SER Encl. 1-13 of this Supplement). The corrective action for this HED however entails a change to components on the PM13J panel, the Containment Monitoring panel. That panel is scheduled to undergo complete redesign in response to other HEDs associated with it. CECO intends to implement corrective actions in a rigorous, integrated and coordinated fashion so as to preclude the introduction of additional HEDs and ensure as well a human engineered control room ac is retrospectively possible. The engineering and manufacturing lead time necessary to redesign it necessitates a second refueling outage implementation date.

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e Page: 3 O NRC Sub1ect: Selection of design improvements NRC Concern 1: CECO should review all annunciator windows against the standard and propose improvements / corrections for HEDs identified.

CECO Response 1: The HEDAT has reevaluated the HEDs associated with the Station's annunciator system. As a result, a comprehensive and integrated program will be implemented to review the content of each onnunciator tile to ensure that it corresponds to the Station's cceepted Abbreviation Standard. Legend content will be modified as necessary and the tile will be reengraved in accordance with accepted Human Factors Engineering design criteria. Concurrently, the tile's content will be evaluated by an operations Subject Matter Expert (SME) and a Human Factors Specialist (HFS) to determine which are time-critical and therefore of a relatively higher priority. Those co designated will have a red border placed around the perimeter of the tile to indicate to the operator that these alarms require immediate attention. Given the magnitude of this program it has been ccheduled for completion by the end of the second refueling outage.

g-s NRC Concern 2: CECO's plan to use 23 colors for background shading

( )cncontrolpanelsindicatesanoveruseofthismethodofcorrecting certain HEDs. This could lead to a reduction in the effectiveness of this technique to resolve HEDs. Because of the increased operator comory burden, the potential confusion, and the increased error cusceptibility, the operators' ability to cope with plant emergencies may be affected.

CECO Response 2: A primary technique for allowing the operator to cort out the immediately relevant stimuli is the enhancement of displays and controls. Effective enhancement permits timely ccquisition of meaningful information, facilitates correct identification of relevant control options, and allows the operator to taaintain effective cognizance over system status.

Surface techniques such as using demarcation and mimic lines, color shading, and other cues are primary techniques for layout onhancement. Color enhancement is used in nuclear power plant control rooms to help clarify component identification and functional relationships among various components. Many problems, such as matrices of undifferentiated componenta, physically displaced controle j and their associated displays, can be remedied through color shading.

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o Pcgo: 4 O Background shading also improves the efficiency of information t ransfer to the operator and assists his decision-making process by organizing desired associations between panel elements, and standardizing information presentation. Color enhancements also can facilitate learning and retention where components and controls are located, especially for new operators. Components having a common color also are seen as forming a group.

Since the goal of shading is to provide operator aids, if the operator does not agree with or approve the enhancement, it probably will not be successful. Operator participation is a requirement throughout the color shading process and was integral during the selection of color enhancements at LaSalle County Station.

SAIC makes reference that the number of colors used for coding should not exceed eleven and should be kept to the minimum needed to provide sufficient information as identified on page 6.5-11 in NUREG-0700. We reiterate that LaSalle County uses only six colors for coding purposes. The color shading does not represent system status or state. It is merely a perceptual aid designed to facilitate system identification. There is no meaning assigned to the shading and the shading should not be conceived of as coding.

Another factor in determining the utility of background shading is the area of the surface to which vm are applying background shading. A control room the size of LaSalle County's board can O afford to use a greater number of color enhancements than control rooms with lesser area, provided it has been systematically applied using sound human engineering and operating principles. Several industry documents recognize the utility of using a number of background shading colors. One EPRI document advocated and provided an example which included eight colors for one sample panel. In addition, there are precedents set throughout the industry which clearly demonstrates the effectiveness of using over twenty colors for enhancement to support system identification.

A total of six colors were chosen to be applied across the main control boards at LaSalle County for background shading during the Preliminary Design Assessment. Principles for color use, outlined in sections 6.5 and 6.6 of NUREG-0700, guided the selection of colors to be used on the control panels. Colors were selected from a pool of high contrast and matte finish shades used at other stations applied against a "Kewanee Beige" board color. As an engineered retrofit, their application extends from a total-board design evaluation that followed a system-by-system approach.

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Pagan 5 O In general, controls and displays at LaSalle County were found to be grouped by function with few "extraneous" or "maverick" components.

However, in these cases, background shading affords a means to functionally group theme components. Both the main component group and their "maverick" components in a system were colored identically.

Safety-related component groups were background shaded. For I example, engineered safeguards monitor lights and manual activation

' controls are located primarily on the engineered safeguards panel.

However, these controls and displays also appear on panels across the total benchboard area. Similarity of function, in these cases, served as the basis for their grouping by common background shade.

Background shading was also applied to systems nested among

! others. In the few cases in which this technique was applied, a high contrast background shade was applied to the centrally positioned group, thereby enhancing the separation of the adjacent system.

On the whole, the selection and use of background shading is designed to work in concert with other perceptual aids and the placement design of instruments. The total-board design evaluation holds in check the potential overuse of one or more perceptual aids.

Thus, where background shading in applied, the use is conservative, necessary and meaningful for operator performance. ,

In addition, lines of demarcation will be used, where possible,

! to enhance system grouping. Demarcation will be used between closely-spaced but functionally distinct systems that do not have individual componante placed within other system groupings. The use of demarcation instead of background shading, in these instances, will prevent the overuse of color. The proposed demarcation consists of circumscribing functional or selected groups with a contrasting line in areas where physical space or panel edges do not already ,

visually set apart the related components.

l NRC Concern 3: The licensee should analyze the need for guardrails, provide the results of the analysis, and provide a description of the guardrails to be installed, if needed. ,

l L l CECO Response 3: The need for guardrails was established prior to l their implementation on the benchboards and prior to the recommendation for the vertical panels. The analysis focused on the vulnerability of controls at or near the area frequented by the operators.  !

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Pcgo: 6 gmg The analysis revealed that the J-handle and OT-2 switches

( j located in proximity to traffic areas are susceptible to possible inadvertent actuation. The potential for this problem was borne out at other plants which experienced inadvertent actuations and subsequently mitigated the problem with guardrails. The guardrails to be installed will be round steel of a 5/8" diameter. They will protrude a maximum of 4" from the panel. All angles will be curved and they will connect to the panel at varying intervals. The guardrails on the vertical boards will serve two purposes:

1) they will direct personnel away from the boards when they are passing by, and 2) act as a barrier for equipment, such as procedure carts, from damaging the panels.

NRC Concern 4: The use of stepladders to read instruments or manipulate controls which are installed above the recommended height could introduce new problems without correcting the original problem.

CECO should determine which controls and dispinys must be manipulated and read in time-critical situations and develop appropriate HED corrective actions, or provide substantial Justification for utilizing a stepladder as a required piece of control room operating equipment.

CECO Response 4: In response to this concern a comprehensive review of the control room panels was performed by a Human Factors Specialist (HFS) and a operations Subject Matter Expert (SME) to

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\s, identify all the controls and displays outside the acceptable height envelope specified in the CECO checklist (items 1.2.5.a(1) and 1.2.5.b(1)). Those controls and displays were compared to the DCRDR Task Analysis database to determine whether any were identified as required to mitigate a transient event. For those that were, the relevant tasks were extracted from the database and evaluated by a HFS and SME to ascertain which instruments might be used in a time-critical fashion, given the constraints of the task action steps they were associated with.

No controls with a time-critical function were discerned in this review. Given that guardrails exist that will prevent inadvertent actuation of controls in the case where an operator must lean over the panel slightly in order to manipulate a control, none of the non time-critical controls will be relocated.

Some displays were identified in the review that may have to be read in a time-critical fashion. In all cases these displays were edgewise meters and were above the maximum recommended display height. All ,

recorders were within the recommended envelope. To address this problem, these time-critical displays will be zone banded so that operators can determine at a glance whether a parameter is in normal or abnormal range.

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d The HEDAT feels that the use of the ergonomically designed stepladder was misconstrued. That stepladder was never intended for operator l use to manipulate or read instrumentation in a time-critical

- cituation.- Rather, it was intended to be used to facilitate operator Job. performance and promote personal safety in non time-critical ,

cituations, such as when replacing annunciator light bulbs.  !

Consequently, it is the company's intention to provide that aid to  !

our operators in the control room.  ;

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, NRC Concern 5: Many of the solutions to correct HEDs proposed in the l Ceco SR for LaSalle County appear to be conceptual-level solutions and i cre not presented as specific solutions to specific HEDs. Therefore,

. CECO should reevaluate and propose specific actions for correcting cpecific HEDs in sufficient detail to permit NRC evaluation.

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CECO Response 5: The LaSalle County Station SR summarizes proposed  :

! corrective solutions to specific HEDs. Some of those solutions (MODS)  !

j cre in various stages of engineering, which require long lead times. l t Some of those solutions, such as the background shading, labeling, etc., t require iterative human factors engineering reviews. Solutions for i which it is not possible to provide the degree of detail desired at  !

this time, are and will continue to be verified by the Human Factors l Engineering Review team. This team is involved in the conceptual  !

I design stage, the MOD review stage and the post implementation stage l to assure that each MOD has corrected the HED problem and did not [

introduce new HEDs. Some of the solutions cite ' standards'. These  !

ctandards were developed from the checklist used in the DCRDR, as t

! voll as other accepted Human Facters reference sources, to provide

{ 'otandard' guidance to team members designing, installing and reviewing

, the HED solutions. As such, they help assure uniformity in approach and  !

j' provide an evaluative base for the verification process. Some of the i atandards were provided in the LaSalle County Station SR, e.g., the 7 1cbeling standard. Finally, as a result of the additional HEDAT  ;

review required to generate this Supplemental report the i

j. clarification to some of the HEDs contain additional detail which [

will facilitate the NRC's evaluation.

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Subject:

Verification that selected improvements will provide  !

j the necessary correction and will not introduce new HEDs i

l NRC Concern: The licensee is required to describe a formal process I

and plan which it will implement to accomplish a rigorous,  !

integrated, verification of design improvements.  !

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s i Pego 8 CECO Response: The verification process utilizes both static and dynamic reviews. Corrective actions to be implemented at LaSalle County Station are reviewed by the multidisciplinary DCRDR team as

,- ( per CECO's April 14, 1983 response to Supplement 1 of NUREG-0737.

The team reporting to the Production Services Department consists of Licensed Operators, Human Factors Specialists, Instrument and Control a Engineers, and other engineering disciplines as needed.  !

l The static review includes the application of appropriate guidelines cnd standards to each corrective action to ensure compliance-with accepted human engineering considerations. The dynamic review includes the application of techniques to determine the operational '

-impact the. proposed design change will have on the operations of the 1 plant. Various approaches to' discerning these influences are  :

, cvailable to the review team. These includes table top reviews,

'curveys and interviews with operations personnel, mock-up and oimulation. When mock-ups of the control room are used, one quarte- I scale or larger will be used. The technique selected is based upon the nature and extent of change resulting from the design .

modifications. Operations personnel are involved in all stages of this review so that corrective actions benefit from operator i oxperience. Drawings or mock-ups of recommended design modification <

cre reviewed by operations personnel. Operations involvement in any  !

design modification is an important step in the process of  :

implementing corrective actions. .

When appropriate, control room modifications are designed as a

• j package. For example, labeling changes, background shading, and 1-control relocation would be mocked up for plant engineering and .

operations approval. Designing modifications as a package ensures  :

j that the modifications are integrated and that no new HEDs are  !

introduced by the changes.

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At present, each control room modification for LaSalle Station is 4 required to be reviewed by the human factors group at CECO. For each

mod received, a human factors evaluation is conducted and .

{- recommendations forwarded to the cognizant engineer. Once [

modifications are implemented on the controls panels, human factors i j

ongineers and station representatives review the changes using the 1 oppropriate static and dynamic verification techniques described above.  ;

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NRC

Subject:

Coordination of control room improvements with changes from other Supplement i to NUREG-0737 Initiatives 1 l i <

! NRC Concerns CECO should confirm that the information displayed and

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! controls provided in the control room support the information and ~

control requirements of the upgraded EOPs.

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I Ceco Reponse During the conduct of the DCRDR, LaSalle County Station Ooperatorsandhumanfactorsspecialists, performed a Validation of Control Room Function in which existing as part of the DCRDR Team, procedures were utilized to evaluate the adequacy of the control room design for the mitigation of transient events. If for any reason controls and/or displays were deemed to be inadequate they were

' documented as HEDs and subsequently evaluated by the HEDAT. 1 At the time of the conduct of our review the station was still using procedures developed from Rev. 1 of the GE BWR Owners Group Emergency ,

Procedure guidelines (EPGs). The DCRDR Task Analysis database was l

, generated from taske gleaned from Rev. 3G of the EPGs. Hence, though  ;

i not comprehensive or complete, a preliminary review of the adequacy I of control room instrumentation to support symptom oriented  !

J procedures was conducted at LaSalle County Station in concert with the conduct of the DCRDR. Nonetheless, CECO in its response to Supplement i to NUREG-0737 has committed to a. thorough human factors  ;

ongineering review of each station's upgraded EOPs. A substantial olement of that review will be a comparison of the stations' DCRDR t Task Analysis database with the upgraded EOPs thereby integrating the l various review approaches into discerning the adequacy of the controls cnd displays contained in each stations' control room for the  !

sitigation of transient events.

t i i l NRC Sub3ect Other DCRDR activities not specifically required by [

, Supplement i to NUREG-0737 ,

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l 1. Review of Remote Shutdown Facilities NRC Concern: The NRC audit team noted that the suppression pool level meter had scale graduation increments that were inconsistent i with good human engineering practice. Therefore, the licensee should i provide zone markings on this meter which would indicate normal and  ;

abnormal operating ranges to aid the operator. l

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CECO Response: The HEDAT agrees with the NRC's assessment of the l 1 importance of the Suppression Pool Level indication at the Remote l Shutdown panel. Therefore, that indicator will be permanently zone l

} banded by the completion of the first refueling outage, which is the l next scheduled refueling outage. .

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Pcgo: 10 7- NRC Sub3ect Other DCRDR activities not specifically required by

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2. Operating Experience Review NRC Concern: Although the OER conducted at LaSalle County is contributing to the success of the DCRDR, an examination of the documentation indicated that additional operator follow-up interviews would have added significantly to this process.

CECO Response Ceco maintains that its conduct of OER's, which exceeded Supplement 1 to NUREG-0737 requirements, demonstrates its commitment to safe nuclear power generation and the adequate human factoring of its control rooms. In excess of 20% of the Human Engineering Discrepancies (HEDs) discerned at LaSalle County Station were discovered via this process. That percentage represents a cignificant contribution to the entire process.

As indicated at the Pre Implementation Audit, follow-up interviews were conducted on an as-needed basis by the Human Factors Specialist (HFS). The determination as to whether interviews were necessary was cade by the HFS and the SRO licensed Subject Matter Expert (SME) casisting with this aspect of the review, after a review of the cummarized questionnaire response. Follow-up interviews were conducted if there was any confusion as to the content and/or intent of the response on the part of the reviewers. We are convinced that the approach we implemented contained sufficient methodological cafeguards, as delineated in our Program Plan, to preclude the possibility that a significant number of additional HEDs would have been discerned should either additional follow-up interviews been conducted or different reviewers been involved.

NRC Sub3ect: DCEDR Results NRC Concern #1: Enclosure A to the SER identifies and discusses HEDs for which proposed corrections are not satisfactory. Responses to these concerns should be provided in a supplemental SR.

CECO Response #14 Responses to the NRC concerns about individual HEDs identified and discussed in the SER are contained in this Supplement to the LaSalle County Station DCRDR Summary Report in the 4

following Appendices:

Commonwealth Edison Company's Revised Response / Clarification to HEDs Referred to in the NRC's Safety Evaluation (SE) Report of the LaSalle County Station DCRDR Safety Evaluation Report -

Enclosure 1

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Revised Responses

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i 4 Commonwealth Edison Company's Revised Response / Clarification

, to HEDs Referred to in the NRC's Safety Evaluation (SE) Report of the LaSalle County Station DCRDR i t

Safety Evaluation Report - Enclosure A >

Revised Responses i s' (SER Encl. A) i NRC Concern #2: Appendix A of Enclosure B to the SERF (TER dated August 4, 1987) identifies a number of HEDs which the licensee does  ;

not plan to correct. The Justification provided for not correcting >

these HEDs was determined to be inadequate by the staff for the ,

reasons discussed on'pages 27 and_28 of Enclosure B and as. stated in l Appendix A. These concerne should be addressed in a supplement to ,

the licensee's SR which should be submitted on a schedule negotiated with the project manager.

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Ceco Response #2: Responses to the NRC concerns about individual i HEDs: identified and discussed in Appendix A of Enclosure B to the SER [

(TER dated August 4, 1987) are contained in this Supplement to the i LaSalle County Station DCRDR Summary Report in the following

• Appendices

' Commonwealth Edison Company's Revised Response / Clarification  !

to HEDs Referred to in the NRC's Safety Evaluation (SE) Report O of the LaSalle County Station DCRDR j Safety Evaluation Report - Enclosure B (TER)

Revised Responses i (TER Append. A1)  !

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Commonwealth Edison Company's Revised Response / Clarification f to HEDs Referred to in the NRC's Safety Evaluation (SE) Report  !

l' of the LaSalle County Station DCRDR  !

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l Safety Evaluation Report - Enclosure B (TER) l Revised Responses  !

(TER Append. A2) l t

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i Commonwealth Edison Company's Revised Response / Clarification  ;

l to HEDs Referred to in the NRC's Safety Evaluation (SE) Report 6 1

, of the LaSalle County Station DCRDR i

Safety Evaluation Report - Enclosure B (TER)

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Revised Responses I (TER Append. A3)

e Pogo: 12 O NRC Concern #3 Due to the delay in

• he refueling outage schedule, CECO should reevaluate the proposed 1aplementation schedule for correcting HEDs at LaSalle County and provide assurance that safety significant HEDs will be corrected during the first refueling outage scheduled for each unit (Unit 1 - February 1988, Unit 2 - July 1988).

CECO Response #3: The HEDAT reevaluated all Category i HEDs in ,

terms of their implementation schedule in response to this concern. l

In one instance the corrective action has been implemented and the HED corrective status is complete. Six Category 1 Level 'C' HEDs were Accept-As-Is with no corrective action anticipated. The remaining eight Category 1 HEDs entailed system / panel redesign that require such a significant amount of engineering leadtime that the earliest realistic implementation outage is the second. These are individually discussed in the appendices to this Supplement.

NRC Concern #4: A number of HEDs previously identified in the October 1985 SR, and later at the June 1986 audit, were to be corrected during the first refueling outage. However, from the April 21, 1987 CECO letter, it appears that several of these HED i corrections are now to be implemented by the second refueling outage.

Ceco should provide acceptable Justification for the proposed delay in correcting these HEDs which are listed below 13 69 i

15 10 354 118 4

206 120 341 144 313 152 CECO Response #4 These HEDs are individually discussed in the l

following Appendix to this Supplement to the LaSalle County DCRDR Final Summary Report:

! Commonwealth Edison Company's Revised Response / Clarification

! to HEDs Referred to in the NRC's Safety Evaluation (SE) Report '

of the LaSalle County Station DCRDR i

Safety Evaluation Report - Enclosure 1 Revised Responses (SER Encl. 1) r

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() NRC Sub3ect: Conclusion 1. Control Room Survey 4

NRC Concern: The staff requires that CECO document the human factors guidelines it used to conduct the control room survey as l discussed during the PIA. '

CECO Response: The human factors guidelines used during the LaSalle County Station DCRDR to identify control room deviations from accepted human factors principles were reconfigured and reapplied to be identical to those used during the Zion, Quad Cities, Byron and Braidwood control room surveys. These guidelines were derived from those in NUREG-0700. MRC staff concerne related to differences between these Ceco guidelines and NUREG-0700 were resolved as reported in the "Safety Evaluation By The Office of Nuclear Reactor Regulation Related to Detailed Control Room Design Review Commonwealth Edison Company Zion Nuclear Power Station, Units 1 and 2, Docket Nos. 50-295 and 50-304", section 4, page 2, dated March 10, 1987.

t NRC Su3 beet: Conclusion 2. Assessment of HEDs NRC Concern CECO is required to provide written confirmation that:

, O (1) the combined effects of HEDs on operator performance, and (2) the cumulative or interactive effects of HEDs were considered in the assessment process. In addition, CECO is required to provide ,

assurance that HED 0162 has been reclassified as Category 1 as agreed  !

to during the 69C audit. The schedule for correcting HED 0162 should  !

be advanced to reflect the reclassification.

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! CECO Response: The combined effects of HEDs on operator performance

! and the cumulative or interactive effects of HEDs were considered throughout the review and assessment process. During the review I process each HED was related to a checklist guideline number, i regardless of where in the review process it was identified. This j served to identify how often a particular problem was identified, which helped direct our attention during the assessment.

As a function of the assessment process, the cumulative and i interactive effects were considered and assessments modified to l address these concerns. Also, several CRDR systems design

! recommendations and their interactive effects were reviewed in great detail on CAD drawings. These revealed both the cumulative strengths and weaknesses of our design recommendations and facilitated the i final design specifications.

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o Page: 14

[)Inaddition,

\~

per the discussions conducted during the PIA, HED index '

number 162 was upgraded in category status to category 1. Since the potential consequences from an operator error due to this discrepancy did not change, the Level, 'B', remained the same (see page SER Encl.

1-13 of this Supplement). The corrective action for this HED however ontails a change to components on the PM13J panel, the Containment Monitoring panel. That panel is scheduled to undergo complete redesign in response to other HEDs associated with it. CECO intends to implement corrective actions in a rigorous, integrated and coordinated fashion so as to preclude the introduction of additional HEDs and ensure as well a human engineered control room as is retrospectively possible. The engineering and manufacturing lead time necessary to redesign it necessitates a second refueling outage implementation date.

NRC

Subject:

Conclusion 3. Selection of Design Improvements NRC Concern: The licensee is required to reevaluate the proposed conceptual solutions for correcting HEDs identified in Enclosure A to this SER, and to provide specific actions to correct each HED in aufficient detail to permit NRC evaluation.

Ceco Response 5: The LaSalle County Station SR summarizes proposed OcorrectivesolutionstospecificHEDs. Some of those solutions (MODS) cre in various stages of engineering, which require long lead times. ,

Some of those solutions, such as the background shading, labeling, etc.,

require iterative human factors engineering reviews. Solutions for which it is not possible to provide the degree of detail desired at this time, are and will continue to be verified by the Huamn Factors Engineering Review team. This team is involved in the conceptual design stage, the MOD review stage and the post implementation stage to assure that each MOD has corrected the HED problem and did not introduce new HEDs. Some of the solutions cite ' standards'. These otandards were developed from the checklist used in the DCRDR, as well as other accepted Human Factors reference sources, to provide

' standard' guidance to team members designing, installing and reviewing the HED aolutions. As such, they help assure uniformity in approach and provide an evaluative base for the verification process. Some of the otandards were provided in the LaSalle County Station SR, e.g., the labeling standard. Finally, as a result of the additional HEDAT review required to generate this Supplemental report the clarification to some of the HEDs contain additional detail which will facilitate the NRC's evaluation.

NRC Sub1ect: Conclusion 3(a). Selection of Design Improvements NRC Concern Identify the annunciators that require corrective cetion, propose the action to be implemented, and propose a schedule for completing the action.

1

e l

Pcgo 15 l CECO Response The HEDAT has reevaluated the HEDs associated with O the Station's annunciator system. As a result, a comprehensive and integrated program will be implemented to review the content of each ,

annunciator tile to ensure that it corresponds to the Station's j accepted Abbreviation Standard. Legend content will be modified as necessary and the tile will be reengraved in accordance with accepted Human Factors Engineering design criteria. Concurrently, the tile's content will be evaluated by an operations Sub]ect Matter Expert (SME) and a Human Factors Specialist (HFS) to determine which are time-critical and therefore of a relatively higher priority. Those so designated will have a red border placed around the perimeter of the tile to indicate to the operator that these alarms require immediate attention. Given the magnitude of this program it has been scheduled for completion by the end of the second refueling outage.

NRC

Subject:

Conclusion 3(b). Selection of Design Improvements NRC Concern: Analyze the need for using guardrails, as proposed, to prevent inadvertent actuation of controls located near the front edge of certain panels, and provide the results of the analyses and a description of the guardrails to be installed, if needed, for NRC review.

CECO Response: The need for guardrails was established prior to O\ their implementation on the benchboards and prior to the recommendation for the vertical panels. The analysis focused on the vulnerability of controls at or near the area frequented by the operators. The analysis revealed that the J-handle and DT-2 switches located in proximity to traffic areas are susceptible to possible inadvertent actuation. The potential for this problem was borne out at other plants which experienced inadvertent actuations and subsequently mitigated the problem with guardrails. The guardrails to be installed will be round steel of a 5/8" diameter. They will protrude a maximum of 4" from the panel. All angles will be curved and they will connect to the panel at varying intervals. The guardrails on the vertical boards will serve two purposes: '

1) they will direct personnel away from the boards when they are passing by, and 2) act as a barrier for equipment, such as procedure t carts, from damaging the panels.

NRC Sub1ect: Conclusion 3(c). Selection of Design Improvements i

l l NRC Concerns Reevaluate the overuse of colors to provide panel background shading and padding for correcting ceratin HEDs, and propose actions for correcting some of these HEDs which will aid rather than hinder operator actions during emergency operations.

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

l Page: 16 l 1

CECO Responses A primary technique for allowing the operator to cort out the immediately relevant stimuli is the enhancement of displays and controls. Effective enhancement permits timely  ;

q. ccquisition of meaningful information, facilitates correct i identification of relevant control options, and allows the operator to maintain effective cognizance over system status, i Surface techniques such as using demarcation and simic lines, color shading, and other cues are primary techniques for layout onhancement. Color enhancement is used in nuclear power plant control rooms to help clarify component identification and functional relationships among various components. Many problems, such as

, matrices of undifferentiated omponents, physically displaced j controls and their associated displays, can be remedied through color shading.

j. Background shading also improves the efficiency of information transfer to the operator and assists his decision-making process by organizing desired associations between panel elements, and ctandardizing information presentation. Color enhancements also can facilitate learning and retention where components and controls are located, especially for new operators. Components having a common

color also are seen as forming a group.

! Since the goal of shading is to provide operator aids, if the i operator does not agree with or approve the enhancement, it probably j will not be successful. Operator participation is a requirement i throughout the color shading process and was integral during the j colection of color enhancements at LaSalle County Station.

! SAIC makes reference that the number of colors used for coding

} chould not exceed eleven and should be kept to the minimum needed to provide sufficient information as identified on page 6.5-11 in I NUREG-0700. We reiterate that LaSalle County uses only six colors for coding purposes. The color shading does not represent system status or state. It is merely a perceptual aid designed to facilitate l cystem identification. There is no meaning assigned to the shading

and the shading should not be conceived of as coding.

Another factor in determining the utility of background shading ic the area of the surface to which we are applying background chading. A control room the size of LaSalle County's board can afford to use a greater number of color enhancements than control rooms with losser area, provided it has been systematically applied using sound human engineering and operating principles. Several industry documents recognize the utility of using a number of background chading colors. One EPRI document advocated and provided an example which included eight colors for one sample panel. In addition, there are precedents set throughout the industry which clearly demonstrates the effectiveness of using over twenty colors for enhancement to Oaupportsystem identification.

e Pego 17 A total of six colors were chosen to be applied across the main control boards at LaSalle County for background shading during the Preliminary Design Assessment. Principles for color use, outlined in sections 6.5 and 6.6 of NUREG-0700, guided the selection of colors to be used on the control panels. Colors were selected from a pool of high contrast and matte finish shades used at other stations applied against a "Kewanee Beige" coard color. As an engineered retrofit, their application extends from a total-board design evaluation that followed a system-by-system approach.

In general, controls and displays at LaSalle were found to be grouped by function with few "extraneous" or "maverick" components.

However, in these cases, background shading affords a means to functionally group these components. Both the main component group and their "maverick" components in a system were colored identically.

Background shading was also applied to systems nested among others. In the few cases in which this technique was applied, a high contrast background shade was applied to the centrally positioned group, thereby enhancing the separation of the adjacent system.

On the whole, the selection and use of background shading is designed to work in concert with other perceptual aids and the placement design of instruments. The total-board design evaluation holds in check the potential overuse of one or more perceptual aids.

Thus, where background shading is applied, the use is conservative, necessary and meaningful for operator performance.

In addition, lines of demarcation will be used, where possible, to enhance system grouping. Demarcation will be used between closely-spaced but functionally distinct systems that do not have individual components placed within other system groupings. The use of demarcation instead of background shading, in these instances, will prevent the overuse of color. The proposed demarcation consists of circumscribing functional or selected groups with a contrasting line in areas where physical space or panel edges do not already visually set apart the related components.

NRC Sub3ect: Conclusion 3(d). Selection of Design Improvements NRC Concern Analyze the need for installing an "ergonomically designed stepladder" for correcting HEDs associated with controls and/or displays which are above the maximum recommended height. For j those controls and displays which must be manipulated or read in time-critical situations, propose appropriate corrective actions.

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Page: 18 O CECO Response: In response to this concern a comprehensive review of the control room panels was performed by a Human Factors

' Specialist (HFS) and a operations Subject Matter Expert (SME) to identify all the controls and displays outside the acceptable height anvelope specified in the Ceco checklist (items 1.2.5.a(1) and

,= 1.2.5.b(1)). Those controls and displays were compared to the DCRDR Task Analysis database to determine whether any were identified as required to mitigate a transient event. For those that were, the j- relevant tasks were extracted from the database and evaluated by a HFS and SME to ascertain which instruments might be used in a time-critical fashion, given the constraints of the task action steps

, they were associated with.

No review.

controle with a time-critical function were discerned in this Given that guardrails exist that will prevent inadvertent cctuation of controls in the case where an operator must lean over the panel slightly in order to manipulate a control, none of the non j time-critical controls will be relocated.

Some displays were identified in the review that may have to be read i

in-a time-critical fashion. In all cases these displays were edgewise ceters and were above the maximum recommended display height. All 4

recorders were within the recommended envelope. To address this

! problem, these time-critical displays will be zone banded so that i

t cperators can determine at a glance whether a parameter is in normal j v or abnormal range.

1

) The HEDAT feels that the use of the ergonomically designed stepladder l

was misconstrued. That stepladder was never intended for operator use to manipulate or read instrumentation in a time-critical

! oituation. Rather, it was intended to be used to facilitate operator Job performance and promote personal safety in non time-critical cituations, such as when replacing annunciator light bulbs.

I Consequently, it is the company's intention to provide that aid to our operators in the control room.

{

I' l

i j NRC Sub3ect: Conclusion 4. Verification that HEDs are corrected and that new HEDs are not introduced I

i l NRC Concerns a. Provide a description of the systematic process to i

be used to verify that proposed design improvements i

correct HEDs and do not introduce new HEDs.

l l b. Confirm that operations personnel, performing as

! members of the DCRDR multidisciplinary review team, will contribute significantly to the verification process.

i 4

__ _ ._. __ __ _ _ _ _ _ _ _ _ m - __ _ _ ._ . _ _

r i

Pcgo 19 O c. Confirm that control room design improvments will be verified as a package to the extent possible.

d. Confirm that control room design improvements will be verified on either the control room, the i simulator, or a full scale mock-up.  ;

l r

CECO Response: The verification process utilizes both static and dynamic reviews. Corrective actions to be implemented at LaSalle l County Station are reviewed by the multidisciplinary DCRDR team as per CECO's April 14, 1983 response to Supplement 1 of NUREG-0737. l l The team reporting to the Production Services Department consists of l Licensed Operators, Human Factors Specialists, Instrument and Control  !

Engineers, and other engineering disciplines as needed.

i The static review includes the application of appropriate guidelines and standards to each corrective action to ensure compliance with i accepted human engineering considerations. The dynamic review l l includes the application of techniques to determine the operational l t

impact the proposed design change will have on the operations of the  ;

plant. Various approaches to discerning these influences are available to the review team. These includes table top reviews, ,

surveys and interviews with operations personnel, mock-up and ,

simulation. When mock-ups of the control room are used, one quarter O

scale or larger will be used. The technique selected is based upon the nature and extent of change resulting from the design modifications. Operations personnel are involved in all stages of i this reveiv so that corrective actions benefit from operator '

i experience. Drawings or mock-ups of recommended design modification d

are reviewed by operations personnel. Operations involvement in any design modification is an important step in the process of ,

implementing corrective actions.

l

) When appropriate, control room modifications are designed as a i j package. For example, labeling changes, background shading, and

control relocation would be mocked up on panel drawings and submitted

, to plant engineering and operations for approval. Designing  ;

i modifications as a package ensures that the modifications are  ;

integrated and that no new Hf:Ds are introduced by the changes.  !

At present, each control ream modification for LaSalle County Station is l l

required to be reviewed by the human factors group at Ceco. For each l

mod received, a human factors evaluation is conducted and l recommendations forwarded to the cognizant engineer. Once  ;

modifications are implemented on the controle panels, human factors engineers and station representatives review the changes using the j appropriate static and dynamic verification techniques described above.

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Pcgos 20 O NRC Sub3ect: Conclusion 5(a).

from other programs Coordination with improvements i

NRC Concerns Provide confination that the control room design supports the upgraded emergency operating procedures (EOPs).

l CECO Reponse During the conduct of the DCRDR, LaSalle County Station operators and human factors specialist, as part of the DCRDR Team, '

performed a Validation of Control Room Function in which existing

! procedures were utilized to evaluate the adequacy of the control room design for the mitigation of transient events. If for any reason controls and/or displays were deemed to be inadequate they were  :

documented as HEDs and subsequently evaluated by the HEDAT. At the time of the conduct of our review the station was still using ,

j procedures developed from Rev. 1 of the GE BWR Owners Group Emergency '

1 Proceudre guidelines (EPGs). The DCRDR Task Analysis database was generated from taske gleaned from Rev. 3G of the EPGs. Hence, though ('

not comprehensive or complete, a preliminary review of the adequacy of control room instrumentation to support symptom oriented i procedures was conducted at LaSalle County Station in concert with the  !

conduct of the DCRDR. Nonetheless, Ceco in its response to  :

Supplement 1 to NUREG-0737 has committed to a thorough human factors -

engineering review of each station's upgraded EOPs. A substantial t element of that review will be a comparison of the stations' DCRDR Task Analysis database with the upgraded EOPs thereby integrating the various review approaches into discerning the adequacy of the controls

and displays contained in each stations' control room for the j l mitigation of transient events. ,

NRC Sub3ect: Conclusion 6(a). Remote Shutdown Panel I

l

NRC Concerns Provide assurance that permanent zone banding which l indicates normal and abnormal operating ranges on the suppression pool level meter on the remote shutdown panel will be installed by startup following the next refueling outage. ,

CECO Response The HEDAT agrees with the NRC's assessment of the -

importance of the Suppression Pool Level indication at the Remote ,

i Shutdown panel. Therefore, that indicator will be permanently zone "

banded by the completion of the first refueling outage, which is the next scheduled refueling outage. l i

i I

I, t

I

Pcga: 21 NRC

Subject:

Conclusions 7(a). DCRDR HEDs NRC Concern Propose corrective actions, which are acceptable to the staff, for the HEDs identified in Enclosure A to this SER.  ;

CECO Responsen Responses to the NRC concerns about individual HEDs ,

identified and discussed in Enclosure A to the SER are contained f.a  :

this Supplement to the LaSalle County Station DCRDR Summary Report (

in the following Appendix i

. Commonwealth Edisc'a Company's Revised Response / Clarification to HEDs Referred to in the NRC's Safety Evaluation (SE) Report j of the LaSalle County Station DCRDR

.l Safety Evaluation Report - Enclosure A Revised Responses (SER Encl. A) i i

NHC Sub3ect: Conclusion 7(b). DCRDR HEDs NRC Concerns Provide either adequate Justification for not correcting / partially correcting significant HEDs, or propose O satisfactory corrective actions for HEDs identified in Tables Al through A3 of Appendix A to Enclosure 8 (TER dated August 4, 1987).

j CECO Response: Responses to the NRC concerns about individual i HEDs identified and discussed in Tables Al through A3 in Appendix A i i

of Enclosure B to the SER (TER dated August 4, 1987) are contained

, in this Supplement to the LaSalle County Station DCRDR Summary Report 7 in the following Appendices:

r Commonwealth Edison Company's Revised Rwsponse/ Clarification

! to HEDs Referred to in the NRC's Safety Evaluation (SE) Report -

of the LaSalle County Station DCRDR Safety Evaluation Report - Enclosure B (TER) 7 Revised Responses -

. (TER Append. A1)  !

?

j and, [

i i

l l

4 l

o-Pcgo: 22 Commonwealth Edison Company's Revised Response / Clarification to HEDs Referred to in the NRC's Safety Evaluation (SE) Report O' of the LaSalle County Station DCRDR Safety Evaluation Report - Enclosure B (TER)

Revised Responses  !

(TER Append. A2) and, Commonwealth Edison Company's Revised Response / Clarification to HEDs Referred to in the NRC's Safety Evaluation (SE) Report of the LaSalle County Station DCRDR Safety Evaluation Report - Enclosure B (TER)

Revised Responses (TER Append. A3)

NRC Sub3ect: Conclusion 7(c). DCRDR HEDs NRC Concern Reevaluate the proposed implementation schedule for correcting HEDs and provide assurance that safety significant HEDs will be corrected during the first refueling outage scheduled for O each unit (Unit 1 - February 1988, Unit 2 - July 1988).

Ceco Response: The HEDAT reevaluated all Category i HEDs in terms of their implementation schedule in response to this concern.

In one instance the corrective action has been implemented and the HED corrective status is complete. Six Category 1 Level 'C' HEDs were Accept-As-Is with no corrective action anticipated. The remaining eight Category i HEDs entailed system / panel redesign that

require such a significant amount of engineering leadtime that the

earliest realistic implementation outage is the second. These are l 4

individually discussed in the appendices to this Supplement.

1

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i f

4 4

a I

Pcg3: 23 NRC Sub3ect: Conclusion 7(d). DCRDR HEDs -

NRC Concern Provide acceptable Justification for the delay in implementing corrective actions for HEDs as identified in the CECO letter dated April 21, 1987.

1 CECO Response: The following HEDs were changed from a first to a second refueling outage in terms of when corrective actions would be '

be made in the April 21, 1987 Ceco letter to the NRC.

13 69 15 10 354 118 4

206 120 341 144 313 152 These HEDs are individually discussed in the following Appendix to this Supplement to the LaSalle County DCRDR Final Summary Report:

Commonwealth Edison Company's Revised Response / Clarification to HEDs Referred to in the NRC's Safety Evaluation (SE) Report j of the LaSalle County Station DCRDR Safety Evaluation Report - Enclosure 1 Revised Responses (SER Encl. 1) i i

1 O

Pcgos 24 l

O i

Index of LaSalle County Station Implementation Date Modification i HED# PAGE IMPLEMENTATION DATES FSR / SUPPLEMENT 1 13, 15, 90 / SER Encl. 1- 1 Previous 1st Refueling Outage 354 Revised: 2nd Refueling Outage 206 33 / SER Encl. 1- 3 Previous: 1st Refueling Outage Revised: 2nd Refueling Outage 341 26 / SER Encl. 1- 4 Previous 1st Refueling Outage Revised: 2nd Refuelitig Outage 313 204 / SER Encl. 1- 5 Previous 1st Refueling Outage Revised: Accept As In 10 82 / SER Encl. 1- 8 Previous 1st Refueling Outage Revised: Accept As Is 120 178 / SER Encl. 1-10 Previous 1st Refueling Outage

Revised

2nd Refueling Outage

() 144 186 / SER Encl. 1-11 Previous:

Revised:

1st Refueling Outage Complete

, 260 412 / SER Encl. A- 3 Previous: Accept As Is Revised: 2nd Refueling Outage 498, 395, 150 / SER Encl. A- 5 Previous: Accept As Is

! 451 Revised: 2nd Refueling Outage 495 153 / SER Encl. A- 6 Previous: 1st Refueling Outage Revised: 2nd Refueling Outage

! 204, 198 154 / SER Encl. A- 7 Previous 1st Refueling Outage

! Revised: 2nd Refueling Outage I

200 156 / SER Encl. A- 8 Previous 1st Refueling Outage j Revised: 2nd Refueling Outage 201 157 / SER Encl. A- 9 Previous 1st Refueling Outage Revised: 2nd Refueling Outage 202 158 / SER Encl. A-10 Previous: Not Applicable Revised: 2nd Refueling Outage 115 51 / SER Encl. A-11 Previous: 2nd Refueling Outage Revised: Complete

)

o Pcgo 25

< Index of LaSalle County Station Implementation Date Modification HED# PAGE IMPLEMENTATION DATES FSR / SUPPLEMENT 1 297, 298 61 / SER Encl. A-16 Previous let Refueling Outage Revised: 2nd Refueling Outage 40 74 / SER Encl. A-18 Previous: 1st Refueling Outage Revised: 2nd Refueling Outage-132 355 / TER Append. Al- 5 Previous: Accept As Is Revised: 2nd Refueling Outage 463, 467, 10 / SER Encl. 1-8 Previous Accept As Is 492, 234 Revised: 2nd Refueling Outage 141, 142 184 / TER Append. A2- 6 Previous Accept As Is Revised: 2nd Refueling Outage 181 236 / TER Append. A2- 8 Previous: Accept As Is Revised: 2nd Refueling Outage

() 344, 462 238 / TER Append. A2-10 Previous Revised:

Accept As Is 1st Refueling Outage 163 239 / TER Append. A2-11 Previous: Accept As Is Revised: 12/31/88 160 160 / TER Append. A2-12 Previous: Accept As Is Revised: 12/31 456 259 / TER Append. A2-14 Previous: Accept As Is Revised: 1st Refueling Outage 533 267 / TER Append. A2-15 Previous: Accept As Is Revised: 1st Refueling Outage 119 268 / TER Append. A2-16 Previous Accept As Is j

Revised: 2nd Refueling Outage 305 319 / TER Append. A2-17 Previous Accept As Is Revised: 2nd Refueling Outage i

lO 1

i l

o Pcgo 26 O Index of LaSalle County Station Implementation Date Modification HED# PAGE IMPLEMENTATION DATES FSR / SUPPLEMENT 1 343 325 / TER Append. A2-17 Previous Accept As Is Revised: 2nd Refueling Outage 128 352 / TER Append. A2-24 Previous Accept As Is Revised: 2nd Refueling Outage 130 353 / TER Append. A2-26 Previous Accept As Is Revised: 2nd Refueling Outage 93 376 / TER Append. A2-29 Previous Accept As Is Revised: 2nd Refueling Outage 482 383 / TER Append. A2-32 Previous Accept As Is Revised: 2nd Refueling Outage 530 435 / TER Append. A2-39 Previous: Accept As Is Revised: 2nd Refueling Outage 429 100 / TER Append. A3- 1 Previous: 2nd Refueling Outage Revised: Complete 428 101 / TER Append. A3- 2 Previous: 2nd Refueling Outage Revised: Complete 24 114 / TER Append. A3-13 Previous Accept As Is Ruvised: 2nd Refueling Outage 289 207 / TER Append. A3-15 Previous 1st Refueling Outage Revised: 2nd Refueling Outage 112 210 / TER Append. A3-16 Previous 1st Refueling Outage Revised: 2nd Refueling Outage 192, 355 245 / TER Append. A3-17 Previous Accept As Is 1 Revised: 12/31/88

509, 510, 246 / TER Append. A3-18 Previous Accept As Is i 511 Revised: 12/31/88 504 320 / TER Append. A3-28 Previous: 1st Refueling Outage Revised: 2nd Refueling Outage O

o '

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.s O Index of LaSalle County Station Implementation Date Modification i

HED# PAGE IItPLEMENTATION DATES FSR / SUPPLEMENT 1 . _ _

178 321 / TER Append. A3-29 Previous 1st Refueling Outage Revised: 2nd Refueling Outage 306 326 / TER Append. A3-30 Previous Accept As Is Revised: 2nd Refueling Outage i 237 344 / TER Append. A3-31 Previous Accept As Is ,

Revised: 2nd Refueling Outage  ;

240 240 / TER Append. A3-33 Previous Accept As Is Revised: 2nd Refueling Outage 309 350 / TER Append. A3-35 Previount Accept As Is Revised: 2nd Refueling Outage 308 351 / TER Append. A3-37 Previous Aclept As Is Revised: 2nd Refueling Outage 131 354 / TER Append. A3-39 Previous:

O Revised:

4,ccept As Is 2nd Refueling Outage l

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Consonveslth i?dison Company's Revised Response / Clarification to HEDs He:terred to in. the NRC's Safety Evaluation (SE) Report

of the LaSalle County Station DCRDR "Safety Evaluation keport -

Enclosure 1 Revised Responses -'

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t' (SER Encl. 1) t i I

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A y J  ! I' b , PAGE: SER Encl. 1- 1 cll j

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. i  ?

'(

) LASALLE STATION '

t ,

REVILED RESPONEE/ CLARIFICATION TO HEDS REFERRED TO

IH THE NRC'E, SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 13, 15 & 354 s,HED CATEGORY 2A i

(

>J'FSR;PAGE

'< 90 s

3? ,

FJNbhMG ~

'C.orhead light'ing is, causing glare that interJeres eith the readability of disp 1Ays. (Photo Log No. F-2, F-3) <

! t

RESPONSE

The lighting in the control room y111 be modified to minimize the glare.

Alternatives to be considered include configuration of louvres, different cize louvres, modifying light configuration, changing wattage of light bulbs.

NRC/SAIC COMMENT This HED was identified in the October 1935 SR and at the June 1986 audit as being corrected during the first' refueling outage. The subsequent April'21, 1987 CECO letter, however, indic.ites that the corrective action for this HED O willacceptable bo. implemented by the second refueling outage. CECO should provide Jualification fcr the proposed delay in implementation.

b CECO CLARIFICATION l A preliminary evaluation of the Alghting and glare problems has been done by a' en. architect engineer. Existing lignt 1.evels are basically adequate but may require some small additions in locs1 areas. A. number of alternatives exist for the reduction of glare. All will bC cc.nvidored and all or some will be implemented to reduce glare. Since the approachec vill interact with one another, their interactive effects need to be evaluated. For example, larger fixture lamps may be required to increase lighting levels

• f in areas which do not meet minimum lighting requirements. The consequences of this corrective ,nction may result in further increases

/ in glare. However, addition of ceiling light diffusers and modification of existing loverall ceiling grids near board areas experiencing glare can be installed but would require modification to existing ceiling structures. Counters and desh tops may be replaced or have a coating l applied to reduce glare and improve contrast ratios, antiglare covers l may be installed on the CRT surfaces to reduce glare and small hoods may be placed over curved meters to reduce glare. It is anticipated that eleven months would be required to solidify the design'and prepare for

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. , _ . . - - , . _ - - _ _ . . . .--.g.-.,~,.L . _ - _ - _ . ._ .- . _ . . _ . _ . . _ , , , -- --

F' AGE : SER Encl. 1- 2 l

()installationaswellastogetthenecessarymaterialsdelivered on site. Project engineering and the station require six months lead time prior to an outage to schedule and coordinate activities and to ensure that all QA/QC requirements have been met regarding the work to be performed. That means that the earliest the modification could be implemented would be an outage 17 months from now. Both units scheduled first outages will have passed by that time necessitating a second outage date for the correction of this HED.

IMPLEMENTATION IST REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

(E:) ,

l

\

PAGE: SER Encl. 1- 3

~N

-) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 206 HED CATEGORY 2A FSR PAGE 33 FINDING The PMO3J panel does not contain an annunciator acknowledge station.

Operators were observed responding to annunciator alarms for that panel at adjacent panels during the validat. ion.

RESPONSE

Annunciator response controls will be added to PMO3J. This will aid the operators in acknowledging alarms on this panel.

NRC/SAIC COMMENT This HED was identified in the October 1985 SR and at the June 1986 audit as being corrected during the first refueling outage. The subsequent April 21, 1987 CECO letter, however, indicates that the corrective action for this HED will be implemented by the second refueling outage. CECO should provide acceptable Justification for the proposed delay in implemeritation.

(

CECO CLARIFICATION

The PMO3J panel is the condensate and feedwater panel. A number of HEDs were identified during the DCRDR that cited this panel. The HEDAT in considering the interactive and cummulative effect of these HEDs decided that the entire panel would be redesigned. This will entail the relocation l of controls and displays as well as the modification of lines of l demarcation, background shading and mimics. Due to the extensive nature of these changes, they were scheduled for the second outage. The addition of i an annunciator acknowledge station to the panel was anticipated as part of

! that modification package. The specification of a first refueling outage l date for this HED in the Final Summary Report was an error. The second l outage is commensurate with the HEDATs' original intentions and hence the l change was made in the April 27th submittal.

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l REVISED IMPLEMENTATION 2ND REFUELING OUTAGE

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- () LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 341 HED CATEGORY 1B FSR PAGE 26 FINDING The operator survey indicated a need for an averaging circuit (or even new '

sensor location) for determining bulk or average suppression pool temperature. The current charts are hard to read and suppression pool temperature stratification affects the sensors.

RESPONSE

The current recorder contains points for air temperature as well as water temperature. The air temperature points will be removed, thus improving the readability of the charts. The operators will be able to determine average temperature when the charts have been modified.

NRC/SAIC COMMENT s HED was identified in the October 1985 3R and at the June 1986 audit as

)Thisbeing corrected during the first refueling outage. The subsequent April 21, 1987 Ceco letter, however, indicates that the corrective action for this HED will be implemented by the second refueling outage. CECO should provide acceptable Justification for the proposed delay in implementation.

CECO CLARIFICATION The PM13J panel is the containment monitoring panel. A number of HEDs were identified during the DCRDR that cited this panel. The HEDAT in considering the interactive and cummulative effect of these HEDs decided that the entire panel would be redesigned. This will entail the relocation of controls and displays, the addition / deletion of controls and displays (such as the recorder points identified in this HED), as well as the addition of lines of demarcation, background shading and mimics. Due to the 4

extensive nature of these changes, they were scheduled for the second outage. The specification of a first refueling outage date for this HED was an error. The second outage is commensurate with the HEDATs' original intentions and hence the chanOe was made in the April 27th submittal.

IMPLEMENTATION iST REFUELING OUTAGE hEVISED IMPLEMENTATION 2ND REFUELING OUTAGE ,

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( LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 313 HED CATEGORY 2C FSR PAGE 204 FINDING The turbine vibration phase angle selector, turbine vibration phase angle XVI-TSOO5, and eccentricity speed control valve bypass valve position instrumentation are not used by the control room operators. (Photo Log No. B-7)

RESPONSE

This squipment will be removed from the control panels.

NRC/SAIC COMMENT This HED was identified in the October 1985 SR and at the June 1986 audit as being corrected during the first refueling outage. The subsequent April 21, 1987 CECO letter, however, indicates that the corrective action for this HED will be implemented by the second refueling outage. CECO should provide acceptable Justification for the proposed delay in implementation.

(

CECO CLARIFICATION This HED was reevaluated by the HEDAT. When the DCRDR was conducted nearly three years ago it was true that the cited instruments were not used by the control room operators. Operations input at the HEDAT indicated that this is no longer the case. They indicated that while not time-critical the instrumentation is used during startups and system testing and is desirable to have at its current location on the PMO2J panel. Consequently, reevaluation of this HED by the HEDAT has determined that the discrepancy l and problem with the instrumentation no longer exists and that therefore it will not be removed from the control room.

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REVISED IMPLEMENTATION ACCEPT AS IS O

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I LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO i IN THE NRC'S SAFETY EVALUATION-(SE) OF THE DCRDR. '

I HED # 69 HED CATEGORY IC FSR PAGE 72 FINDING There are controls on vertical panels that are located outside the 34 to 70 l inch envelope above the floor, recommended by the guidelines. (Photo Log No. A-11)

RESPONSE

An ergonomically designed step ladder will be provided for use on these panels. In addition, guardrails will be added to PMO6J and PM13J to protect against inadvertent actuation of controls.

NRC/SAIC COMMENT The reviewers are concerned that the use of stepladders would aggravate the i situation rather than improve it. CECO should determine which controls must '

be manipulated in a time-cri~cical situation and provide an appropriate Also, the April 21, 1987 CECO letter indicated that the O corrective correctiveaction.

action is to be implemented by the second refueling outage. Ceco should provide acceptable Justification for the proposed delay in the implementation of the corrective action.

CECO CLARIFICATION

! The following controls were cited in both the HED and in the DCRDR Task Analysis:

"POST LOCA H2/02 MON SYS" (2PM13J)

"INST NITROGEN DRYER PURGE OUTLET VALVE" (1PM13J)  ;

"DRYWELL VENT PURGE OUTLET VALVE" (2PM06J)  !

"MAIN STEAM CH SELECT" (2H13-P600)

"POWER SUPPLY" (2H13-P635)  ;

"TRIP CHECK ADJUST" (2H13-P636)

The cited controls from the original HED are examples. A comprehensive review of the control room panels was performed by a HFS and an SME to identify all the controls and displays outside the envelopes specified in

.the CECO checklist. Those controls / displays were compared to the DCRDR Task

• Analysis. data base to determine whether any were identified as required to mitigate a transient event. Relevant tasks were evaluated and SME input was utilized to ascertain which instruments might be used in a time critical fashion. No controls with a time critical function were discerned. Given that guardrails exist that will prevent inadvertent actuation of controls in [

e

PAGE: SER Encl. 1- 7 O*thecaseswhereafifthpercentilefemaleoperatormustleanoverthepanels in order to manipulate a control, none of the non time critical controls will be relocated. Displays outside the envelope that may have to be read j in a time critical sense will be zone banded so that operators can determine at a glance whether the parameter is in a normal or abnormal range.

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LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO 1 IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 10 HED CATEGORY 1C FSR PAGE 82 FINDING The following panels are mirror imaged across the two units; PM16J, PM13J, PMO9J, PM10J, N62-P601, N62-P600, PMO5J, PMO6J, PMO7J. Only the PMO7J panels have mirrored equipment pieces across both units. (Photo Log No. I-14)

RESPONSE

The mirror imaging is between panels, not within panels. Only the PMO7J panels are located adjacent to each other. These panels are enhanced by mimicking and demarcation and the operators report no difficulty in differentiating between them. The other panels (located in the horseshoe) will be enhanced by color-coded guardrails. The guardrails, in addition to existing panel labels, will clearly differentiate between the respective O, units.

NRC/SAIC COMMENT l There is a concern that the proposed color-coded guardrail will not enhance I the control room but may be an additional source of clutter. Also, the April 21, 1987 CECO letter indicated that the corrective action is to be implemented by the second refueling outage. CECO should provide acceptable Justification for the proposed delay in the implementation of the corrective action.

CECO CLARIFICATION Reevaluation by the HEDAT resulted in concurrance with the NRC's concerns l

about overuse of color in the control room. Therefore, the guardrails will not be color-coded. Existing panel labels are sufficient to differentiate between panels. Since no corrective action is warranted, the implementation date has been changed to "Accept As Is".

IMPLEMENTATION iST REFUELING OUTAGE

' ACCEPT AS IS CREVISEDIMPLEMENTATION i

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-s LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 118 HED CATEGORY 3C i FSR PAGE 171 '

FINDING Surface coding paint on some controls is chipped or vorn off. (Photo Log No. A-21, A-21.1)

RESPONSE

Surface coding paint will be replaced on all controls where it has worn off or chipped. In addition, shift supervisors will be advised to notify maintenance when coding wears off any controls.

NRC/SAIC COMMENT This HED was identified in the October 1985 SR and at the June 1986 audit as being corrected during the first refueling outage. The subsequent April 21, ,

1987 CECO letter, however, indicates that the corrective action for this HEr  ;

-m will be implemented by the second refueling outage. Ceco should provide (f acceptable Justification for the proposed delay in implementation.

CECO CLARIFICATION The corrective action will be implemented by the first refueling outage.

Surface coding paint will be replaced on all controls where it has worn off or chipped. In addition, shift supervisors will be advised to notify maintenance when coding wears off any controls.

IMPLEMENTATION IST REFUELING OUTAGE l REVISED IMPLEMENTATION iST REFUELING OUTAGE l

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( LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 120  ;

HED CATEGORY 2C FSR PAGE 178 FINDING Legend pushbuttons are not distinguishable from legend lights on panels PM02J, H13-P603, H13-P602, OPM08J. (Photo Log No. A-25)

RESPONSE

A painted border will be added around the perimeter of pushbuttons to differentiate between pushbuttons and legend lights.

NRC/SAIC COMMENT This HED was identified in the October 1985 SR and at the June 1986 audit as being corrected during the first refueling outage. The cubsequent April 21, 1987 CECO letter, however, indicates that the corrective action for this HED will be implemented by the second rofueling outage. CECO should provide ,

acceptable Justification for the proposed delay in implementation.

CECO CLARIFICATION It is Commonwealth Edisor 's intention to implemwnt a comprehensive and integrated background shading, mimic and line of demarcation program.

To allow for sufficient tiue to design coordinate and integrate the program an implementation date of the second outage was specified. The corrective action for this HED entails shading and was consequently incorporated into that program which necessitated a change in the implementation date.

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() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 144 HED CATEGORY 1B FSR PAGE 186 FINDING Control positions for three key-operated controls are missing or inappropriate. (Photo Log No. A-32)

RESPONSE

The cited switches will be labeled.

21RC/SAIC COMMENT This HED was identified in the October 1985 SR and at the June 1986 audit as being corrected during the first refueling outage. The subsequent April 21, 1987 CECO letter, however, indicates that the corrective action for this HED vill be implemented by the second refueling outage. CECO should provide acceptable Justification for the proposed delay in implementation.

Ow-4ECO CLARIFICATION The cited switches have been labeled. Corrective action for this HED is complete.

IMPLEMENTATION iST REFUELING OUTAGE REVISED IMPLEMENTATION COMPLETED O

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(-,,) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 152 HED CATEGORY 2C FSR PAGE 187 l

FINDING On continuous adjustment rotary controls, there is no pointer indicator on the control knob. Instead, the pointer indicator is on the knob skirt.

(Photo Log No. A-33)

RESPONSE

A white dot will be added to the control knob as a pointer.

NRC/SAIC COMMENT This HED was identified in the October 1985 SR and at the June 1986 audit 7e being corrected during the first refueling outage. The subsequent April 21, 1987 CECO letter, however, indicates that the corrective action for this HED will be implemented by the second refueling outage. CECO should provide acceptable Justification for the proposed delay in implemantation.

CECO CLARIFICATION Feedback to the operator concerning Generator Volt adjustment is provided via volt indicators on the vertical section of the panel above the cited control switch. In fact, the operator

• adjusts" voltage to a specific level via that indicator and does not "set" the voltage adjust control switch to any particular, predetermined position so that the actual position of the switch, per se, is irrelevant. Nonetheless, a white dot will be added to the control knob as a pointer by the first refueling outage.

IMPLEMENTATION iST REFUELING OUTAGE REVISED IMPLEMENTATION iST REFUELING OUTAGE O

PAGE: SER Encl. 1-13 p)g, LASALLE STATION' REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 162 I HED CATEGORY 1B FSR PAGE 231 FINDING Successive values indicated by unit graduations on three control room meters and recorders are other than those recommended by the guideline.

Recommended values are 5, 10, 15, 20, or 2, 4, 6, 8, 10, or 1, 2, 3, 4, 5, or some multiple of these values by 10. These scale markings are difficult for the operator to interpret. (Photo Log No. B-16)

RESPONSE

The reactor core isolation cooling pump pressure suction and the low pressure core spray pump amperes meters (on H13-P601) are not time-critical instruments. They are well labeled and the operators report no difficulties with their use.

The air temperatures for the drywell suppression temperature recorder will be relocated to a new meter and marked with the recommended unit

) graduations.

s NRC/SAIC COMMENT The category should be changed to category I and the schedule for implementation of the corrective action should be advanced.

CECO CLARIFICATION The category has been changed to category I. However, the corrective action for this HED entails a change to components on the PM13J panel, the Containment Monitoring panel. That panel is scheduled to undergo complete redesign in response to other HEDs associated with it. As part of its commitment to the NRC, CECO intends to implement corrective actions in a rigorous, integrated, and coordinated fashion so as to preclude introduction of additional HEDs and to ensure as well a Human Engineered control room as is retrospectively possible. Given the engineering and manufacturing lead time necessary to redesign it, a second refueling outage implementation date has been made.

IMPLEMENTATION 2ND REFUELING OUTAGE O REVISED IMPLEMENTATION 2ND REFUELING OUTAGE l

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Commonwealth Edison Company's Revised Response / Clarification to HEDs Referred to in the NRC's Safety Evaluation (SE) Report of the LaSalle County Station DCRDR Safety Evaluation Report - Enclosure A Revised Responses (SER Encl. A)

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() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 20 HED CATEGORY 2C FSR PAGE 103 FINDING Telephones on some control room panels (PMO2J, H13-P601, PMO5J) have cords resting on the floor. (Photo Log No. G-21, G-22)

RESPONSE

The telephone cords are stretched across the floor due to the current lack of telephones on the N62-P600 and N62-P601 panels. Telephones will be added to these panels.

NRC/SAIC COMMENT While the action indicated in the response will ensure that enough telephones will be available in the control room, CECO does not indicate it will take corrective action on the existing long phone cords.

Cs vECO CLARIFICATION The existing long phone cords will be replaced with shorter phone cords to reduce the tripping hazard. This action, in concert with the addition of more phones, will ensure adequate and safe communication capability for the operator.

IMPLEMENTATION 2ND REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

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() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

'HED # 468 & 337 HED CATEGORY 2A FSR PAGE 5 ,

FINDING i

During the task analysis and verification, tasks were identified in which the operator was required to determine the scram air header pressure. There.

is an annunciator in the control room to inform the operator that the pressure is either too high or too low, but there is no indication in the control room of actual pressure. The addition of a display for the scram ,

air header pressure would facilitate operations.

RESPONSE

The scram air header pressure annunciator will be split into a low pressure and a high pressure alarm. Due to the complexity of this engineering modification, it will be completed by the second refueling outage.

NRC/SAIC COMMENT l-['T Currrntly, there is no direct indication of scram air header preuture

\~/ available in the control room. The proposed split annunciator alarm would ,

not provide the operator with the required direct indication of scram air i header pressure.

4 CECO CLARIFICATION j The HEDAT reevaluated this HED. The tasks requiring the display of the  :

scram air header pressure were concerned with bleeding air pressure off the scram air header as an alternate means of scramming the reactor in an ATWS type event. In the BWR Owners Group EPG's this approach was provided as an j alternate and was similarly adopted by the station in its EOPs as one of ,

many alternate rod insertion techniques. Station management would make the decision as to which approach to take in this type of an event. Time would ,

exist for Equipment Attendents to go to the local panel, where adequate i indication of scram air header pressure exists, to carry out the sequence of steps necessary to accomplish the task. The HEDAT feels that though the '

i indication would be "nice to have" in the control room it is not necessary '

to accomplish the EOP tasks and that from the control room operators perspective the availability of a "High" and a "Low" annunciator is sufficient.

IMPLEMENTATION 2ND REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE I

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PAGE: SER Encl. A- 3 p]

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LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 260 HED CATEGORY 2B FSR PAGE 412 FINDING The "feedwater turbine handanck" and the "feedwater turbine speed 1SI-FWO46" on Unit i have been combined into one piece of equipment for 1A and 1B on Unit Two - "Lovejoy Control Corporation (LCC) reactor feed pump turbine (RFPT) 2A control startup station". Unit One and Unit Two should have the came arrangement. (Photo Log No. D-38, D-38.1, D-39, D-39.1)

RESPONSE

An oewluation is underway to determine if the Unit Two equipment (loveJoy control system) is better than the Unit One equipment (General Electric).

The Unit One =quipment will not be changed until it is proved that the Unit Two equipment :s superior (based on system performance).

NRC/SAIC COMMENT 1 and Unit 2 have different control mechanisms for similar systems. At O*' Unit present, CECO is evaluating the control mechanisms, after which the superior equipment will be implemented. The CECO implementation schedule, however, indicated that no action will be taken ("accept as is").

CECO CLARIFICATION If one system is demonstrative 1y superior to the other, that system will be implemented on the sister unit. The HEDAT anticipates the evaluations to be completed in time to install the superior system, if there is one, by the completion of the second outage.

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IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE

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-(,) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 248 & 397 HED CATEGORY 2A FSR PAGE 139 FINDING A prioritization scheme is not in place for the annunciator system.

RESPONSE

A prioritization scheme will be implemented to improve annunciators.

NRC/SAIC COMMENT According to CECc's implementation schedule, a Category 2-A HED should be completed by the end of the first refueling outage.

CECO CLARIFICATION The hCDAT has reevaluated the HEDs associated with the Station's annunciator r system. As a result, a comprehensive and integrated program will be I_s implemented to review the content of each annunciator tile to ensure it k- corresponds to the Station's accepted Abbreviation Standard. Those that do not will then be reengraved so as to comply with the CECO Human Factors Engineering Design criteria. Concurrently, the tile's content will be evaluated by an operations Subject Matter Expert (SME) and a Human Factors Specialist (HFS) to determine which are time critical and of high priority.

Those so designated will have a red border around the perimeter of the tile.

Given the extensive nature of this program, a second refueling outage commitment date is required.

IMPLEMENTATION 2ND REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE l

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(' LASALLE STATION REVISED RESPONSE /CLAR.TFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 498, 395 & 451 LED CATEGORY 1A FSR PAGE 150 FINDING Some annunciators have legends which are not specific and unambiguous.

RESPONSE

The cited tiles will be reworded to provide unambiguous legends. The present annunciator wording has not caused any problems due to oparator cimunderstanding. The annunciator tiles mentioned will be corrected as the tiles are revised for other reasons.

NRC/SAIC COMMENT CECO doec not intend to change the existing tiles until they need to be replaced for another reason. Ceco should review the annunciators and inplement corrective actions for those that warrant correction immediately.

O UECO CLARIFICA!' ION The HEDAT has reevaluated the HEDs associated with the Station's annunciator cystem. As a result, a comprehensive and integrated program will be implemented to review the content of each annunciator tile to ensure it corresponds to the Station's accepted Abbreviation Standard. Those that do not will then be reengraved so as to comply with the Ceco Human Factors Engineering Design criteria. Concurrently, the tile's content will be evaluated by an operations Subject Matter Expert (SME) and a Human Factors Specialist (HFS) to determine which are time critical and of high priority.

Those so designated will have a red border around the perimeter of the tile.

Given the extensive nature of this program, a second refueling outage commitment date is required.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

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) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 495 HED CATEGORY 2B FSR PAGE 153 FINDING Abbreviations and acronyms used on annunciators are not consistent with others used in the control room.

RESPONSE

A standardized abbreviation list is being developed and implemented to legends for all new annunciator tiles.

NRC/SAIC COMMENT CECO does not intend to change the existing tiles until they need to be

' replaced ;!or another reason. CECO should review the annunciators and implement corrective actions for those that warrant correction immediately.

ECO CLARIFICATION

\' The HEDAT has reevaluated the HEDs associated with the Station's annunciator system. As a result, a comprehensive and integrated program will be implemsnted to review the content of each annunciator tile to ensure it corresponds to the Station's accepted Abbreviation Standard. Those that do not will then be reengraved so as to comply with the CECO Human Factors Engineering Design criteria. Concurrently, the tile's content will be evaluated by an operations Subject Matter Expert (SME) and a Human Factors Specialist (HFS) to determine which are time critical and of high priority.

Those so designated will have a red border around the perimeter of the tile.

Given the extensive nature of this program, a second refueling outage commitment date is required.

IMPLEMENTATION iST REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

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HED # 204 & 198 HED CATEGORY 2B FSR PAGE 154 FINDING Letter height on annunciator tiles is not identical for all tiles.

RESPONSE

Operators report no difficulty in reading annunciator tiles. However, otandards for annunciator tiles (letter height, width, stroke-width, etc.)

will be incorporated into a procedure and will be used on all subsequent onnunciator tile engravings.

NRC/SAIC COMMENT CECO does not intend to change the existing tiles until they need to be replaced for another reason. CECO should review the annunciators and implement corrective actions for those that warrant correction immediately.

DECO CLARIFICATION The HEDAT has reevaluated the HEDs associated with the Station's annunciator system. As a result, a comprehensive and integrated program will be implemented to review the content of each annunciator tile to ensure it corresponds to the Station's accepted Abbreviation Standard. Those that do not will then be reengraved so as to comply with the CECO Human Factors Engineering Design criteria. Concurrently, the tile's content will be evaluated by an operations Subject Matter Expert (SME) and a Human Factors Specialist (HFS) to determine which are time critical and of high priority.

Those so designated will have a red border around the perimeter of the tile.

Given the extensive nature of this program, a second refueling outage commitment date is required.

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HED # 200 HED CATEGORY 2B FSR PAGE 156 FINDING The minimum space between characters on many annunciator tiles is not at least one stroke width.

RESPONSE

Standards will be included in a procedure for the letter dimensions for annunciator tiles. All new annunciator tiles will comply with this standard.

NRC/SAIC COMMENT Ceco does not intend to change the existing tiles until they need to be replaced for another reason. CECO should review the annunciators and implement corrective actions for those that warrant correction imnediately.

--CECO CLARIFICATION The HEDAT has reevaluated the HEDs associated with the Station's annunciator system. As a result, a comprehensive and integrated program will be implemented to review the content of each annunciator tile to ensure it corresponds to the Station's accepted Abbreviation Standard. Those that do not will then be reengraved so as to comply with the CECO Human Factors Engineering Design criteria. Concurrently, the tile's content will be evaluated by an operations Subject Matter Expert (SME) and a Human Factors Specialist (HFS) to determine which are time critical and of high priority.

Those so designated will have a red border around the perimeter of the tile.

Given the extensive nature of this program, a second refueling outage commitment date is required.

IMPLEMENTATION iST REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

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HED # 201 HED CATEGORY 2B  ;

FSR PAGE 157 l FINDING The minimum space between words on some annunciator tiles does not meet the guideline of one character width.

RESPONSE

Standards will be included in a procedure for the letter dimensions for annunciator tiles. All new annunciator tiles will comply with the standard. l l

NRC/SAIC COMMENT CECO does not intwnd to change the existing tiles until they need to be ,

replaced for another reason. CECO should review the annunciators and iwplement corrective actions for those that warrant correction immediately.

' CECO CLARIFICATION The HEDAT has reevaluated the HEDs associated with the Station's annunciator ,

system. As a result, a comprehensive and integrated program will be implemented to review the content of each annunciator tile to ensure it corresponds to the Station's accepted Abbreviation Standard. Those that do ,

not will then be reengraved so as to comply with the CECO Human Factors i Engineering Design criteria. Concurrently, the tile's content will be evaluated by an operations Subject Matter Expert (SME) and a Human Factors  ;

Specialist (HFS) to determine which are time critical and of high priority.

4 Those so designated will have a red border around the perimeter of the tile.

Given the extensive nature of this program, a second refueling outage  !

commitment date is required. '

4 1

IMPLEMENTATION IST REFUELING OUTAGE I L

i REVISED IMPLEMENTATION 2ND REFUELING OUTAGE [

5 L

• t

_-n ..

PAGE: SER Encl. A-10 k ,) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SF) OF THE DCRDR.

HED # 202 HED CATEGORY 2B FSR PAGE 158 FINDING The space between lines on some annunciator tiles does not meet the recommended guideline of one-half the character height. (Photo Log No. I-18)

RESPONSE

Standards will be included in a procedure for the letter dimensions for annunciator tiles. All new annunciator tiles will comply with the standard.

NRC/SAIC COMMENT CECO does act intend to change the existing tiles until they need to be replaced for another reason. Ceco should review the annunciators and implement corrective actions for those that warrant correction immediately.

S CECO CLARIFICATION The HEDAT has reevaluated the HEDs associated with the Station's annunciator system. As a result, a comprehensive and integrated program will be implemented to review the content of each annunciator tile to ensure it corresponds to the Station's accepted Abbreviation Standard. Those that do not will then be reengraved so as to comply with the CECO Human Factors Engineering Design criteria. Concurrently, the tile's content will be eve.luated by an operations Subject Matter Expert (SME) and a Human Factors l Specialist (HFS) to determine which are time critical and of high priority.

Those so designated will have a Red border around the perimeter of the tile.

Given the extensive nature of this program, a second refueling outage commitment date is required, l IMPLEMENTATION NOT APPLICABLE i

REVISED IMPLEMENTATION 2ND REFUELING OUTAGE l

O

1 PAGE: SER Er.cl. A-11 i

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 115 HED CATEGORY 3C FSR PAGE 51 FINDING The 2H13-P603, 1H13-P635, 2H13-P635 and 1H13-P604 panels have missing panel cections in which unwanted objects may enter. (Photo Log No. G-1, G-2, G-3, G-4, G-5)

RESPONSE

Missing panel sections will be replaced.

NRC/SAIC COMMENT The proposed corrective action has significant engineering requirements which necessitate a delay in implementation. However, CECO should implement o temporary corrective measure in the interim.

O ECO CLARIFICATION

\- I Commonwealth Edison Company felt subsequent to the HEDAT that this problem deserved immediate attention. Therefore, the missing panel sections cited in the HED have been corrected.

IMPLEMENTATION 2ND REFUELING OUTAGE REVISED IMPLEMENTATION COMPLETED i

b O

PAGE: SER Encl. A-12

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 398, 360, 364, 366, 51, 57, 75, 551, 64, 48 & 401 HED CATEGORY 1A FSR PAGE 160 l

FINDING Instrumentation on the electrical penel (PM01J) is not functionally grouped.

Specifically, AC distribution, diesel generator, synchronization scope and oil circuit breaker instrumentation are not functionally grouped.

In addition, the feeds on buses 141 and 142 ars not the same, i . e. . left corresponds to stations auxiliary transformer (SATs en one and unit auxiliary transformer (UAT) on the other. (Photo Log No. D-11, D-11.1, D-21, E-25, E-15, C-36)

RESPONSE

A modification has been approved for PM01J. This panel will be reorganized and enhancements added to clarify functional groupings. An integrated approach will be used for the modifications. Due to the complexity of this panel and the proposed changes, this modification will be completed by the

( ) second refueling outage.

NRC/SAIC COMMENT The proposed corrective action has significant engineering requirements which necessitate a delay in implementation. However, CECO should implement a temporary corrective measure in the interim.

CECO CLARIFICATION Background shading, mimics, and lines of demarcation currently exist on the PM01J panel to aid the operator in the performance of duties at this panel. This is considered by the HEDAT to be adequate "corrective" measures in the interim before panel redesign.

IMPLEMENTATION 2ND REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

PAGE: SEH Encl. A 13 '

e

( -

LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATIOM (SE) OF THE DCRDR.

HED # 286, 478, 371, 197, 362, 372 & 476 HED CATEGORY 1A FSR PAGE 363 FINDING There are three major systems located on the PM13J panel - continuous monitoring, accident monitoring and humidity monitoring. Controls and displays for these systems are not grouped by task sequence or frequency of use and systems are difficult to identify. (Photo Log No. C-28, C-28.1, C-29)

N

RESPONSE

Suitable enhancements (background shading, demarcation) will be added to .

PM13J to clarify functional groupings. Instrumentation will also be ./ ,

rearranged as necessary to enhance groupings.

NRC/SAIC COMMENT The proposed corrective action is not specified in sufficient detail to allow a rigorous verification. Also, the engiaeering requirements for such O- a modification necessitate a delay in implementation. CECO should implement a temporary corrective action in the interim.

CECO CLARIFICATION The PM13J panel will be replaced and will be redesigned to enhance functional groupings and the use of displays and controls. Background shading and demarcation will also be used tb enhance functional groupings. Labels will be used to identify equipment and systems. Given the functional importance of this panel for both normal and abnormal operations a significant amount of engineering lead time is required to ensure the panel redesign is implemented in a safe and integrated fashion without creating additional HEDs. An effort will be made to complete the implementation by the second outage. It may not be possible to implement these changes on Unit i by that date. In the interim, labels will be placed by the existing equipment to more clearly identify function and temporary linrra of demarcation will be added to separate systems.

IMPLEMENTATION 2ND REFUELING OUTAGE O REVISED IMPLEMENTATION 2ND REFUELING OUTAGE

= ,

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

-v - - - - -

7 Q??. .

~[C'N^

/ 3 PACE: SER Encl. A-14 i

yf ll l l

i

)- LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERAF.0 TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

.HED # 87 HED CATEGORY 1A ~

FSR PAGE 424 FINDING .

There are meters, located on PM02J and PM01J, which are arranged in unbroken rows containing more than five meters. (Photo Log. No. E-12, E-12.1)

, RESPONSE

$ Although the meters are physically located in unbroken rows, labeling 91 , techniques perceptually break up the rows of disp 1mys. In addition, ,

onhancements will be added to PM01J to clarify funcitonal groupings. Due to {

/f.' :( the complexity of this panel.and the proposed changes, this modification '

will be completed by'the second refue).ing outage. ~

?

t  ! '

NRC/SAIC,COMMEM*.'f, The proposed corrective action has significant engineerdny reeuirements

(

whiuh mecessitate a delay in implementation. However, CECO waould implement  :

a te orary corrective measure in the interim.

(

' CECO ~CL RIFICATION i A/ittiough the meters are physically located in unbroken rows, labeling

! . techniques perceptually break up the rows t of displays. Moreover, background

' 's h adin g, mimics, and lines of demarestion currently exist on the PM01J panel to aid the operator in the performance of duties at this panel. This is considered by the HEDAT to be adequate "corrective" measures in the interim

, before panel redesign, which because of the complexity of this panel and the j lproponed changes, will be completed by the second refueling outage.

l s

IMPLEMENTATION 2ND REFUELING OUTAGE i

REVISED IMPLEMENTATION 2ND REFUELING OUTAGE 4 I

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,--avi.,.-+------,---.------.--..-- - - . - -

..r.

1 PAGE: SER Encl. A-15

, t 5 i

k, LASALLE' STATION '.

REVIZCD RESPONSE / CLARIFICATION TO HEDS REFEARED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

.NED # 235 HED CATEGORY 1A FSR PAGE 430 FINDING The synchroscope lights and associated indicators are not sufficiently close enough to the turbine generator to per. sit the operators to clearly read the displays when synchronizing the turbinu generator to che grid. (Photo Log No. D-17, E-127 ,

j f.

RESPONSyl[ /

A modifjpation has been approved for PM01J. The panal will be reorganized end enhancements added to clarify functio-al groupings. Due to the complexity of/this panel and the proposed ch,unges, this modification will be completed by<tbo second refueling c'itage.

' '),

I' NRC/SAIC COMMENT The proposed corrective action has significant engineering requirements O which necessitate ,a delay in implementation. However, CECO should implement c temporary ccIrective measure in the interim.

1 g ,

CECO CLARIFICA? ION Reevaluation cf this problem by the HEDAT reeulted in concurrence with the NRC's comments. A supervising relay has been installed to assure proper cynchronization of the turbine to the grid.

/

IMPLEMENTATION

, 2ND REFUELING OUTAGE > >

l REVISED IMPLEMENTATION

, _.2ND REFUELING OUTAGE

< i ,

L l

1

)

PAGE: SER Encl. A-16 s

LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED'TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 297 & 298 HED CATEGORY 3C FSR PAGE 61 i

FINDING l The highest controls on the vertical portion of the benchboards are not )

within reach radius of the standing 5th percentile female. (Photo Log No. ,

G-20)

RESPONSE

Guardrails-are in place to protect controls from inadvertent actuation if the 5th percentile female must use an extended reach or stretch position to cetivate controls. In addition, an ergonomically designed stepladder will be provided in the control room whenever any 5th percentile females are assigned control room duties.

NRC/SAIC COMMENT The reviewers are concerned that the use of stepladders would aggravate the O cituation rather than improve it. CECO should determine which controle must be manipulated in a time-critical situation and provide an appropriate corrective action.

CECO CLARIFICATION A comprehensive review of the control room panels was performed by a HFS and an SME to identify all the controls and displays outside the envelopes specified in the CECO checklist. Those controls / displays were compared to the DCRDR Task Analysis data base to determine whether any were identified er required to mitigate a transient event. Relevant tasks were evaluated and SME $nput was utilized to ascertain which instruments might be used in a time critical fashion. No controls with a time critical function were discerned. Given that guardrails exist that will prevent inadvertent actuat.on of controls in the cases where an operator must lean over the panels elightly in order to manipulate a control, none of the non time critical controls will be relocated. Displays outside the envelope that may have to be read in a time critical sense will be zone banded so that operators can determine at a glance whether the parameter is in a normal or O

PAGE: SER Encl. A-17 l

()obnormalrange. The ergonomically designed stepladder was never intended  !

for operator use in time critical situations. Rather, it was intended to'be used to facilitate operator Job performance in non time critical. situations, such as replacing annunciator light bulbs.

IMPLEMENTATION .

1ST REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE 4

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4

O HID # 69 HED CATEGORY 1C FSR-PAGE 72 Referenced on Page: SER Encl. 1-6 O

O

PAGE: SER Encl. A-18 l

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO '

, ,y IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED.# 40 '

HED CATEGORY 2C FSR PAGE 74  !

FINDING Some displays on vertical panels in the main control room are located in an

= area outside the recommended 41" and 70" (above the floor) envelope.

Log No. A-12, A-12.1 thru A-12.6) (Photo .'

RESPONSE '

Although these displays slightly deviate from the guideline recommendations, none are used for-monitoring safety-related equipment and, therefore, have a

. negligible impact on performance. An ergonomically designed stepladder will be provided for use on these panels.

NRC/SAIC COMMENT ,

The. reviewers are concerned that the use of stepladders would aggravate the CECO should determine which displays must O situation rather than improve it.

he read in a time-critical situation and provide an appropriate corrective action.

CECO CLARIFICATION The following displays are cited in both the HED and in the task analysis:

"PRIMARY CONT WATER CHILLER PUMP 2B" (PMO6J) i "DRYWELL VENT / PURGE OUTLET VALVE" (indicator lights; PMO6J) '

, "RECOMBINER A INLET TEMP" (N62-P600)

"DW HUMIDITY SAMPLE A OUTBD ISOL VALVES & PUMP" (PM13J)  ;

"DRYWELL SUCT 2CMO22A" (indicator lights; PM13J)

!

• POST LOCA H2/02 MON SYS" (indicator lights; PM13J) l "OFF STANDBY ANALYZE" (indicator lights; PM13J)  ;

l "POST LOCA CNMT MON SYS A HIGH H2" (indicator lights; PM13J) [

j "TURB STOP VALVE SCRAM TRIP BYPS RELY" (H13-P611)

I

The cited displays are examples. A comprehensive review of the control room i- panels was performed by a HFS and an SME to identify all the controls and displays outside the envelopes specified in the CECO checklist. Those controls / displays were compared to the DCRDR Task Analysis data base to  !

! determine whether any were identified as required to mitigate a transient l 4 event. Relevant tasks were evaluated and SME input was utilized to l ascertain which instruments might be used in a time critical fashion. No l i

controln with a time critical function were discerned. Given that l guardrails exist that will prevent inadvertent actuation of controls in the 3

l O cases where an operator must lean over the panels slightly in order to manipulate a control, none of the non time critical controls will be relocated. Displays outside the envelope that may have to be read in a time l

PAGEt SER Encl. A-19

( ) critical sense will be zone banded so that operators can determine at a glance whether the parameter is in a normal or abnormal range. The orgonomically designed stepladder was never intended for operator use in time critical situations. Rather, it was intended to be used to facilitate operator Job performance in non time critical situations, such as replacing ennunciator light bulbs.

IMPLEMENTATION iST REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

i lO l

l PAGE: SER Encl. A-20

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) JF THE DCRDR.  !

i HED # 376 . l HED CATEGORY 1C l FSR PAGE 75 FINDING Back panel equipment is difficult to monitor because an operator has to be  !

relieved by another in order to go back and check them; some back panel  ;

recorders are too high.

RESPONSE

Adequate control room staffing provides for extra personnel to monitor back panel _ indications. Back panel instrumentation (specifically recorders) is ,

non-time-critical to monitor. An ergonomically designed stepladder will be j

! provided for use on these panels.

NRC/SAIC COMMENT The reviewers are concerned that the use of stepladders would aggravate the Ceco should determine which controls must L

()situationratherthanimproveit.

be manipulated in a time-critical situation and provide an appropriate  !

j corrective action. L i

CECO CLARIFICATION

[ The only potentially time-critical instrumentation on the back panels are

the radiation monitors. However, redundant indications are provided in the .,

primary operating area in the form of radiation alarms and computer displays (

and printouts. The stepladder would not have been used during time-critical  :

situations on the back panel as all time-critical information is presented in the primary operating area.  ;

F i IMPLEMENTATION '

iST REFUELING OUTAGE  ;

i 8

r

REVISED IMPLEMENTATION i 1ST REFUELING OUTAGE l

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()

l l

. . , . - ,, - - - . . ----. .i*

O HED # 10 '

HED CATEGORY 1C FSR-PAGE 82 Referenced on Page SER Encl. 1-8 O

O

O HED # 286 HED CATEGORY 1A FSR-PAGE 362 Referenced on Page: SER Encl. A-13 i

O l

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[ Lt.SALLE STATION

's- REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 46 HED CATEGORY 2C FSR PAGE 370 FINDING The turbine bearing lift pumps, turbine turning gear, turbine oil reservoir vapor extractor, turbine main shaft suction pump, and turbine turning gear oil pump controls (on PMO2J) are functionally related and poorly grouped.

(Photo Log No. C-34)

RESPONSE

Background shading will be added to the PMO2J panel to ensure functional groupings. All background shading modifications will be coordinated with other corrective actions (relocations, demarcation, mimics) to ensere that new HEDs will not be created.

NRC/SAIC COMMENT The proposed corrective action is a conceptual solution and is not specified

( ) in sufficient detail to permit a rigorous verification.

CECO CLARIFICATION The cited turbine controls will share the same color of background shading to enhance their functional relations to one another. The background shading modification will be integrated with other corrective actions to ensure that new HEDs will not be created.

IMPLEMENTATION 2ND REFUELING OUTAGE REVISED IMPLEMENTATION 2ND REFUELING OUTAGE t

O t

Commonwealth Edison Company's Revised Response / Clarification to HEDs Referred to in the NRC's Safety Evaluation (SE) Report of the Lafalle County Station DCRDR  :

Safety Evaluation Report - Enclosure B (TER) -

Revised Responses (TER Append. A1)

O r

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PAGEt TER App nd. Al- 1 LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

HED # 375 HED CATEGORY 2C FSR PAGE 41 FINDING Off gas pre- and post-treatment radiation chart racorders should be moved to the off gas front panels. This would help in cor.< elating off gas system changes to the change in pre / post treatment radiation changes.

RESPONSE

The placement of off gas pre- and post-treatment recorders on back panels is acceptable because they are not used during time-critical or emergency  ;

situations.

HRC/SAIC COMMENT The Justification for not correcting this HED, and/or the description of the discrepancy, is too brief, ambiguous, or general to allow an adequate

( } evaluation to be made.

CECO CLARIFICATION The Pre- and Post- Treatment Off Gas Radiation recorders located on the H13- >

P604 backpanel record rad levels in the off gas system before and after treatment. As such they are functionally related to the radiation detection system as opposed to the off gas system. Consequently, they were located with the radiation release detection equipment on the H13-P604 backpanel. Nonetheless, they are readily available from the Off Gas panel in situations requiring their use. Moreover, information displayed on the recorders is available from the computer if necessary. Relocation of the "discrepant" recorders from the backpanel area to the Off Gas panel is therefore not warranted. ,

I IMPLEMENTATION ACCEPT AS IS l

REVISED IMPLEMEhTATION '

ACCEPT AS IS

! I

PAGE: TER Appand. Al- 2

(/ LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 8, 266 & 518 HED CATEGORY 28 ,

FSR PAGE 81 FINDING The status of plant equipment under the control of one unit is not displayed on the other unit which is capable of controlling that equipment.

RESPONSE t Common system equipment is controlled by one of the respective units. Since it is the specific unit's responsibility, current placement is appropriate.

NRC/SAIC COMMENT The Justification for not correcting this HED, and/or the description of the discrepancy, is too brief, ambiguous, or general to allow an adequate evaluation to be made.

, ECO CLARIFICATION The HEDAT feels the description of the HED Finding is erroneous given the equipment cited in the HEDs. That equipment is common equipment, ie., that equipment that can be used on either unit. Specifically cited were the common station air compressor, the clean condensate pumps, the well water pumps, the common RBCCW pump, the diesel fire pumps, and the common service water pumps. The controls and displays for this equipment are located on one of the two units, but not both. Hence, both units are not capable of controlling the equipment as the finding suggests. When the equipment is ,

needed on the unit not having control of the equipment, it is run for the unit by the sister unit. As is the case with all system equipment, training "

and procedure govern the use of the common equipment. l 4

IMPLEMENTATION  !

ACCEPT AS IS lJ REVISED IMPLEMENTATION i ACCEPT AS IS  !

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

PAGE: TER App 3nd. Al- 3

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 507 & 508 HED CATEGORY 2C FSR PAGE 89 FINDING Some control room panel surface colors, background shadings, mimics and label colors have luminance ration which exceed the maximum of 3:1 for task crea va. adjacent darker surroundings or 1:3 for task area vs. adjacent lighter surroundings.

RESPONSE

Color luminance is a factor in operations when colors are not easily discriminable and recognizable. All colors in the control room are recognizable to the operators. They report no difficulties in the chosen colors.

NRC/SAIC COMMENT The Justification for not correcting this HED, and/or the description of the is too brief, ambiguous, or general to allow an adequate O discrepancy, evaluation to be made.

CECO CLARIFICATION Color luminance is a factor in workspace design when colors are used for coding purposes and must be readily and easily discriminable and recognizable. Control panel colors at LaSalle were used for background shading purposes only. No coding is implied. In addition, the purpose of the background shading is to highlight functional control / display relationships which the current scheme accomplishes. No modifications are

warranted.

l 1 f IMPLEMENTATION l ACCEPT AS IS l

REVISED IMPLEMENTATION l

ACCEPT AS IS

.O l

PAGE: TER Appand. A1- 4 I LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

HED # 412 HED CATEGORY 2C FSR PAGE 282 FINDING There is some confusion as to what points of the system are being monitored on the off gas panel (N62-P600).

RESPONSE

Control room operators are adequately trained to identify system points.

NRC/SAIC COMMENT The Justification for not correcting this HED, and/or the description of the discrepancy, is too brief, ambiguous, or general to allow an adequate ovaluation to be made.

CECO CLARIFICATION O The original HED instrument panel, concernedN62-P600, the to addition of mimics enhance its to the use. The Offconsists panel Gas primarily of recorders and indicators to display SJAE pressures and flows, recombiner temperatures, adsorber temperatures, off gas flows, moisture separator temperatures, and off gas filter differential pressures. The panel is uncluttered, and well labeled. Operators receive adequate training on the off gas system, its use, and its controls.

IMPLEMENTATION ACCEPT AS IS l

l REVISED IMPLEMENTATION ACCEPT AS IS O

PAGE: TER Appand. Al- 5 j i

i LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO ,

IN THE NRC'S SAFETY-EVALUATION (SE) OF THE DCRDR. j

-HED # 132  :

HED CATEGORY 2C FSR PAGE 355  !

i FINDING Red and green are used in combination on CRT displays. According to  !

criteria, this practice should be used as little as possible. 5 RESPONSE-C Red and green are generally used for opposite meanings and are therefore rarely used together. In addition, shape and position cues provide i redundant information to the operators. t NRC/SAIC COMMENT i The-Justification for not correcting this HED, and/or the description of the discrepancy, is too brief, ambiguous, or general to allow an adequate  !

ovaluation to be made. l ECO CLARIFICATION I LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes ,

an "Abnormal" condition when the unit is above 30% power. The CECO computer l display conventions currently do not use green board coding, which in part  !

accounts for the cited discrepancy. The feasibility of using green board coding for the computer graphics is being explored at CECO's Byron PWR i

station. Several displays have been modified and their use l is being evaluated. One problem is that green board coding does not provide l l for indication of equipment status beyond normal / abnormal, for example, l 4 open/ closed, on/off, etc. Resolutions to this proLlem are being evaluated. .

. When the "green board convention" computer graphics problems have been l successfully resolved at Byron, the convention will be implemented at l

. LaSalle if feasable.  ;

I

! i i-IMPLEMENTATION l ACCEPT AS IS REVISED IMPLEMENTATION

. 2ND REFUELING OUTAGE  ;

f h

._ . ___ __ _ . _ . __ . _ _ . _ _ .. _ _ _ _ _ _ _ _ .-__m. ._ __

I I

f F

Commonwealth Edison Company's Revised Response / Clarification ,

to HEDs Referred to in the NRC's Safety Evaluation (SE) Report i of the LaSalle County Station DCRDR Safety Evaluation Report - Enclosure B (TER)

Revised Responses '

(TER Append. A2) 4 f l

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PAGE: TER Appsnd. A2- 1 O LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 463, 467, 492 & 234 HED CATEGORY 1A FSR PAGE 10 FINDING During the task analysis and verification, it was observed that there are tasks performed using emergency systems on the H13-P601 panel in which the operator is required to ascertain dryvell pressure and suppression pool level. Current indication is located on the PMO6J panel (narrow range) and the PM13J panel (vide range) for drywell pressure and PM13J for suppression pool level. Operators should have ready access to these parameters on the H13-P601 panel to facilitate emergency operations. (Photo Log No. F-29)

RESPONSE

Under accident conditions, one operator is assigned to monitor containment conditions of pressure, temperature and water level, and initiate actions when directed to by the emergency procedures. Most of these actions are required when the parameters reach graphical limit rather than at any single

value. The other operator at H13-P601 is responsible for maintaining and restoring vessel level and monitoring associated parameters. This information is also available on the SPDS. Staffing levels are adequate to monitor and coordinate all appropriate information within the required time limits.

NRC/SAIC COMMENT The basis for the austification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION Though staffing levels are adequate to address the EOP tasks requiring Drywell Pressure and Suppression Pool Level information, and though no operational problems concerning Drywell Pressure and Suppression Pool Level information being received in a timely manner have been encountered when the i

EOPs have been implemented, a wide range Drywell Pressure and Suppression Pool Level indicator will be placed on the H13-P601 panel. However, since the 1E instrumentation requirements for this safety related information are

t PAGE: TER Append. A2- 2  :

()cetbytheindicatorsonthePM13Jpanelthedisplaystobeplacedonthe H13-P601 panel may not necessarily meet those criteria. In addition, since this corretive action involves structural modification to an ESF panel, an implementation date of the second refueling outage is necessary to allow for cufficient engineering lead time.

IMPLEMENTATION ACCEPT AS IS r

REVISED IMPLEMENTATION 2ND REFUELING OUTAGE i

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PAGE: TER AppOnd. A2- 3 i

O

( ,f LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 193 HED CATEGORY 2C FSR PAGE 29' FINDING -

It was noted during the validation that there is no indication of flow for the chiller fans.

RESPONSE

The need for chiller fan flow is not time critical and only used for troubleshooting.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1

1. It does not address operational or behavioral factors or issues.

() 2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error. '

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION The chiller system is not a safety related system. Any need for chiller fan flow information is not time critical, that is, time exists to dispatch an of.erator to the local panel to obtain the necessary information. Moreover, no remedial action can be taken from the control room in instances of system

malfunction and an operator would have to be dispatched regardless.

Therefore, no operational benefit would be derived from the installation of a chiller fan flow indicator.

l IMPLEMENTATION  :

ACCEPT AS IS REVI3ED IMPLEMENTATION

ACCEPT AS IS

O l

I

(

PAGE: TER Append. A2- 4 l l

i d

()

LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC*S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 195 i HED CATEGORY 28 i FSR PAGE 30  ;

I i~ FINDING  !

During the validation, it was observed that the primary containment chillers ;

could not be started from the main control room. The unavailability of-a ,

control switch for the chiller could delay operation of the primary ,

containment ventilation system. i i  !

RESPONSE  !

The primary containment chiller system is designed so that it cannot be i otarted from the control room, to insure that the system is not reset _before [

the cause of the trip is identified. Safe startup of the chillers requires '

on operator in attendance at the equipment to monitor operator parameters.

t I

~

NRC/SAIC COMMENT  :

i The basis for the Justification for not addressing this HED is not adequate I

!()foroneormoreofthefollowingreasons

1. It does not address operational or behavioral factors or issues. I

2. It does not sufficiently address the discrepancy.  ;

3. It cites absence of previous operator error. [

. p

4. It cites utility, industry, or manufacturer's standard. [

t CECO CLARIFICATION  !

The Primary Containment Chiller system is not a safety related system. It i

. was nonetheless designed so that it cannot be started from the control room l in order to insure that the system will not be reset after a trip until the i

! cause of the trip is identified and corrected. Otherwise, serious damage (

! could be done to the system. A safe startup of the chillers requires an j operator in attendance at the local panel to monitor locally displayed

operational parameters. All procedures requiring the operation of the  !

! Chiller system are non time-critical, meaning eufficient time exists to l dispatch an operator to the local panel to operate the system. F l

IMPLEMENTATION  !

ACCEPT AS IS }

t i l- REVISED IMPLEMENTATION -

) ACCEPT AS IS i

f *

. _ _ __ -i.__.% r Q g PAGE: TER Append. A2- 5

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

HED # 301 HED CATEGORY 2C FSR PAGE 70  :

FINDING The display face angle from the line of sight of the seated 5th percentile female to the annunciator (on the reactor panel) is less than the required 45 degrees.

RESPONSE t This panel is actually a sit / stand console, designed to be operated from a standing or seated position. All controle are within the reach radius of an operator in a standing position.

l NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

() 1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.  :

i CECO CLARIFICATION The reactor panel is a sit / stand panel. Space allocations for sitting were ;

designed and built into the panel to allow operators to sit and monitor '

, reactor power parameters when manipulating control rods during startups and -

! shutdowns. When that Job task is being performed another operator is available on the unit to assist. Moreover, by procedure and training, when ,

an alarm comes up the operator is required to stop manipulating rods and l respond to the alarm as dictated in the annunciator response procedure. In t order to respond to the alarm the operator is required to get up from a .

seated position. From a standing position the annunciators comply with the  !

line of sight criteria. The HEDAT feels the discrepancy documents a non problem and consequently no corrective action is necessary.

j IMPLEMENTATION ACCEPT AS IS

lEVISED IMPLEMENTATION

ACCEPT AS IS 4

3

PAGE: TER AppOnd. A2- 6

()

i LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR. ,

t HED # 141 & 142 HED CATEGORY 18 FSR PAGE 184 ,

FINDING Some key-operated controls are not required since the function being l controlled is not necessary to be secured against activation by unauthorized i personnel. Some key-operated controls have the key inserted in them during a11' operations. (Photo Log No. A-29, A-30)

RESPONSE

The key-operated controls are designed so that in the cases where security is an issue, the keys can be removed from the locks and controlled. The '

key-operated controle also indicate an additional caution to the operators that these are safety related controls. The keys do not impede operations.

NRC/SAIC COMMENT

( } The basis for one or for morethe of Justification the following for not addressing this HED is not adequa reasons

1. It does not address operational or behavioral factors or issues.

l 1

2. It does not sufficiently address the discrepancy. [

3. It cites absence of previous operator error, j 4. It cites utility, industry, or manufacturer's standard.

} I CECO CLARIFICATION 4

The HEDAT reevaluated these HEDs and concurrs with the NRC's comments. l There is no longer a need to secure the components cited in the  ;

discrepancies and the switches will therefore be replaced with ones more <

appropriate to the components functions. Due to the necessary engineering  !

lead time and the proximity of the first refueling outage this corrective action will be implemented by the end of the second outage. t 1 [

IMPLEMENTATION f ACCEPT AS IS j REVISED IMPLEMENTATION 4 ()2NDREFUELINGOUTAGE i i

l I -

, PAGE: TER Append. A2 7 l

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO NEDS REFERRED TO f

IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

~

HED e 146 j

> HED CATEGORY,2C FSR PAGE 190-4

~

FINDING '

The diesel generator _ feed and bus diesel generator feed rotary controls have position indications painted on the top of the knob. It is difficult to E e tell which position the control is in. (Photo Log No. A-36) ,

i j RESPONSE .[

The two detents (trip, close) available for this switch are 90 ,

degrees apart. This distance is sufficient to insure rapid identification of position. ,

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate  ;

for one or more of the following reasons:  !

() 1.-It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

4

3. It cites absence of previous operator error. -

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION I i

The cited controls have two detents at the 10 O' Clock and 2 O' Clock .

! positions. In accordance with the LaSalle Station Position coding l l Convention, the Trip function is at the 10 O' Clock position and the Close .

l function is at the 2 O' Clock position. The control remains where it is l placed. The detents mre appropriately labeled and a vnite line has been  !

l painted on the black knob surface to reinforce knob position. Indicator lights located directly above the controle illuminate to further identify

] the position / condition of the switches and the breakers they control. No j

additional action is required. l I f i

IMPLEMENTATION  ;

ACCEP7 AS IS I l

i())REVISEDIMPLEMENTATION l ACCEPT AS IS l

l -

)

l HED # 162 IIED CATEGORY 3B FSR-PAGE 231 Referenced on Page: SER Encl. 1-13 l

l i

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I L

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9

PAGE: TER Append. A2- 8 I)

\# LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (GE) 0F THE DCRDR.

HED # 181 HED CATEGORY 28 FSR PAGE 236 FINDING Meaning attached to a particular color is not narrowly defined and is not consistent across application in the control room.

RESPONSE

A green board concept is used for plant indication lights. Other uses of color are not confusing to the operators since they are trained in the use of color. Additionally, multiple coding techniques are used for instrumentation throughout the control room.

HRC/SAIC COMMENT The basis for the austification for not addressing this HED is not adequate for one or more of the following reass6.s

() 1.

2.

It does not address operational or behavioral factors or issues.

It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites 4111ty, industry, or manufacturer *n standard.

CECO CLARIFICATION LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes i an "Abnormal" condition when the unit is above 30% power. The CECO computer l display conventions currently do not use green board coding, which in part accounts for the cited discrepancy. The feasibility of using green board coding for the computer graphics is being explored at Ceco's Byron PWR station. Several displays have been modified and their use is being evaluated. One problem is that green board coding does not provide for indication of equipment status beyond normal / abnormal, for ur. ample, open/ closed, on/off, etc. Resolutions to this problem are being evaluated.

O

PAGE: TER Appond. A2- 9

)

1 t

When the "green board convention" computer graphics problems have heren successfully rtoolved at Byron, the convention will be implemented at  :

LaSalle if feasable.  ;

y,

, \. 4 IMPLEMENTATION ACCEPT AS IS i s  ;

i REVISED IMPLEMENTATION r 2ND REFUELING OUTAGE I

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PAGE: TER App;nd. A2-10 t

i

(') f REVISED RESPONSE / CLARIFICATION TC HEDS REFERRED TO LASALLE STATION' IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

HED # 344 & 462 HED CATEGONY 3B \'

FSR PAGE 238 FINDING Green banding should be in place for all normal operating ranges for all recorders and indicators. (Photo Log. No. G-24, G-25, G-26)

RESPONSE ..

Jreen banding will be added to all instrunientation where it would be

appropriate.

1 NRC/SAIC COMMENT The < bassis for the Justification for not addressing this HED is not adequate ,

fclr one or more of the following raasons:  ;

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

}

3. It cites absence of previous operator error. ,

4. It cites utility, industry, or manufacturer's standard.

i I CECO CLARIFICATI0t! '

The HEDAT has reevaluated this HED and finds that the Final Summary Report submitted to the NRC was in error in regards to the implementation date. An implementation of "Accept As Is" was inadvertently submitted, it should have read " First Refueling Outage". This has bren corrected in our records and '

i data base, and the corrective action has bien scheduled into first outage i activities. ,

i IMPLEMENTATION j ACCEPT AS IS i ,

i REVISED IMPLEMENTATION i iST HEFUELING OUTAGE r

4 ,

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w-----~w yv.-- - ,yw-- . , - , . , _ - - , - , - , . , , , - . . . - - - - - - - -- - ---- w

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PAGEt TER. Append. A2-11 lj $ i,ii

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j I

g .

LASALLO STATION-

'BEVISED RESPONSE / CLARIFICATION TO HEDS REFERRio TO

,I,N THE NRC'S SAFETY EVALUATION (SE) OF THE y

DCRDR.

HED # 163 HED CATEGORY 3C FSR PAGE 239 'r Y

FINDING i/,

jj /; Pointer tips on the reales of meters and recorders cover the scale graduations.- Th'e ability to see the gra'duations of the affected parameter is' critical when reading meters. (Photo Log No. B-17, H-6. H-7)

,1 ,.

i 1 .- ,s RESPONSE .

j. ,

Recorders have scale paper wit,h aatching scales on them. Calibration is keyed off the-recorder scale pacer not the recorder scale. All control room waters are readable. Pointer tips are designed eo sr.. ale' graduations can be seen. i

.)

I g [

, (( NRC/SAIC COMMENT' $

+ .

The basip for the austification for not addressing this NED is not adeque'.s '

for one or-more of the following reasons L 1. It does not address operational or behavioral factors or issues.

l l r 2. It does not sufficiently address the diIer'epancy.

3. It cites absence of previous operator error.

. j i l

l  !

s 4. 2t cites utility, industry, .or manuf acturer 'rs , standard.

.; 1 1:  !

l CECO CLARIFICATION ( ,-

The HEDAT re* evaluated the recorders documented in this HED. The problem is mosk acqute,with the 'Bajleyi brand of recorder. r Thede recorders will be replaced z with state-of-bhe-ar,t digital recorders. Since many of these recorders are used on the Pd13J panel for which a redesign commitment has

-been made and others are hanociated with class 1E parameters, the

repiccoment process wi.t1 r.ot be complete' v.ntil the end of tSe second outage.

Other recorders affected by this problem will be modified c. a case-by-case basis, In most instances it will entail'a customized f,1x by our Instrument Maintenance ',departrnent. A good faith effort will be made to address these other re' corders by 12-31-U8.

V i' i IMPLEMENTATION /

ACCEPT AS IS '

REVISED IMPLEMENT /. kON ,

12/31/88 ., 1 \

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p ,

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PAGE: TER Appsnd. A2-12

,m t

\ ') LASALLE STAT 10N REVIEMD RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 160 HED CATEGORY 2C FSR PAGE 247 FINDING There is difficulty in reading the legends on legend lights under ambient lighting conditions when the legend light is not lit. This is primarily true of the red, green and dark blue lights. (Photo Log No. B-21)

RESPONSE

There are numerous indications to legends on legend lights available to the operator. These include color coding, position coding, and component labeling. The operators report no problems in identifying the meaning of legend lights.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate

_ for one or more of the following reamunst s_/ 1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

In addition, The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HZDs.

Apparently related HEDs are numbers 192, 355, 509, 510, 511, 216, 215, 283, 217, 218, 219, 220, 221, 222, and 293.

CECO CLAHIFICATION One of the objectives of the multidisciplined HEDAT and particularly the partic.4.pation of the Lgad Humsn Factors Specialist was to ensure that cumulative and/or interactive effects were concidered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheleos, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. Thene HEDs are concerned with the apparent lack of legend light discriminability either because of differences in lens cap color, light intensity and contrast ratios, or non O adherence checklist. to In engraving all individual were small and of no import.

specifications documented instances the deviations in thethe from CECO Human F criteria Upon reevaluation the HEDAT feels this

• _. __ _ ~ _ _ _ _ _

PAGE: TER Appand. A2-13

)remainsthecaseexcsptforthe "blue" indicator light lens caps. For these there is little consistency across the control room. Therefore, an effort will be mads to obtain lens caps that meet CECO Human Factors Engineering contrast-ratio criteria. These will be engraved in accordance with CECO engraving guidelines and installed in the control room by 12-31-P8.

IMPLEMENTATION ACCETT AS IS REVISED-IMPLEMENTATION 12/31/88 P

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l .

O l

l PAGE: TER App 2nd. A2-14 1

Isi LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 456 HED CATEGORY 3C FSR PAGE 259 FINDING Dur ing the task analysis and verification, a number of indicator lights were identified that should contain wording to indicate the status of the energized lights related equipment, but which currently contain no legend.

(Photo Log No. H-9)

RESPONSE

The addition of wording on the cited lights is unnecessary due to the redundant coding in place for indicator lights. The indicator lights are color coded as well as position coded for operator use.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

/^g k/

s 1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industly, or manufacturer's standard.

CECO CLARIFICATION Reevaluation by the HEDAT resulted in concurrence with the NRC's comments.

The indicator lights cited in the original HED will be appropriately engraved in accordance with the Station's Human Engineering labeling standard. A good faith effort will be made to complete this corrective action by the end of the first refueling outage.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 1GT REFUELING OUTAGE l

l l

D l

PAGE: TER Appand. A2-15

( ,) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR. l l

HED # 533 HED CATEGORY 2C FSR Pi.GE 267 FINDING Color selection for dual-pen recorders is inconsistent. Although red and blue have been selected for pen colors, there is no consistent selection of color for the upper and lower pens. Potential problems exist in parameter identification and chart maintenance (inking). (Photo Log No. B-25.1)

RESPONSE

Labels for dual-pen recorders list pen colors in the order listed on the chart paper. The operators report no difficulty in determining recorder parameters.

NRC/SAIC COMMEhT The basis for che Justification for not addressing this HED is not adequate e for one or more of the following reasons:

1. It does not cddress operational or behavioral factors or issues.

2. It does not su.!ficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION Reevaluation of this HED by the HEDAT has resulted in concurrence with the NRC's comments. Therefore, all control room recorders will be modified such that all pen number is have the same color, all pen number 2s have the same color, etc. Actual pen color selection will be made after a review of the control room's current pen color useage so as to minimize disruption to operations. Recorder labels will be reengraved as appropriate.

IMPLEMENTATION ACCEPT AS IS i

f 7EVISED IMPLEMENTATION

(,_,lST REFUELING OUTAGE l

t

PACE 2 TER Appsnd. A2-16

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO ,

IN.THE NRC'S SAFETY EVALUATION.(SE) OF THE DCRDR.

HED # 119 HED CATEGORY 2C FSR PAGE 268-FINDING The "control rod drive temperatures" is a multi-point recorder with a manufacturer's channel capacity of 24 points. The channel capacity has been expanded to record 185 points via additional electronic equipment.

Operators are required to convert bank point numbers to rod numbers via a temporary conversion table. The guidelines recommend not expanding a multi-point recorder beyond its capability.

RESPONSE

This recorder is only used to monitor control rods with temperature problems. Such rod indication will deviate beyond the average parameter. .

Any point out of tolerance is easily detected.

! NRC/SAIC COMMENT

! The basis for the Justification for not addressing this HED is not adequate '

l- for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error, i

l 4. It cites utility, industry, or manufacturer's standard.

I l

! CECO CLARIFICATION l Reevaluation by the HEDAT has produced concurrence with the NRC's comments on this HED. Therefore the discrepant recorder will be replaced with a state-of-the-art electronic recorder that meets Human EngineerAng design standards.

IMPLEMENTATION ACCEPT AS IS rsREVISED IMPLEMENTATION j i HD REFUELING OUTAGE 1

l

PAGE: TER Appsnd. A2-17

.( ) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED1 305 HED CATEGORY 3C FSR PAGE 319 FINDING The mimic colors on the following panels are not discriminante1y different from each other; H13-P601 (brown, black and blue); PMO3J (orange and red);

PMO2J (orange, red and yellow); PM01J (black and blue); PM16J (black and blue); PMO6J (two shades of green). (Photo Log No. H-17, H-18, H-19, H-20)

RESPONSE

The use of color for discriminating mimics is not critical for the operation of this panel. Mimics are redundantly coded by use of beginning and ending points and labeling as well as color.

NRC/SAIC COMMENT The basis for the Juetification for not addressing this HED is not adequate for one or more of the following reasons:

Os 1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

In addition, The Justification of this individual HED does not apptsar to consider the cumulative or interactive effect of other related HEDs.

Apparently related HEDs are numbers 504, 178, and 306.

CECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the apparent lack of consistency in the use of colors on the mimics as well as the apparent lack of sufficient contrast between the colors used. Mimics are used on the cited panels as an operator aid. The HEDAT therefore feels that appropriate and consistent use of color on them is O important. Consequently, mimics will be evaluated by a Human Factors

PAGE: TER App 2nd. A2-18 OEngineeringspecialistandanOperationsrepresentativetoensuretheir accurracy and to develop a consistent mimic color standard for use at the otation that will be in consonance with the station's color useage standard.

Mimic size and use of symbols will also be standardized. This will be cccomplished in concert and coordination with the background shading and lines of demarcation programs.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

O

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

PAGE: TER Appand. A2-19

/3

( ,) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUAT70N (SE) OF THE DCRDR.

HED # 343 HED CATEGORY 2C FSR PAGE 325

' FINDING The off gas system holdup drain line valves are shown in series on the control board mimics, but are actually separate lines above where the pipe connects to common headers (on N62-P601). The mimic should be corrected to conform to system structure.

RESPONSE

The mimic correctly reflects the flexibility of the system in that either off gas condenser can be used for either train.

NRC/SAIC COMMENT The basis for the austification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

l()

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION Reevaluation of this HED by the HEDAT resulted in concurrence with the NRC's comments. Therefore, the off gas mimic will be modified appropriately in concert and coordination with the station's background shading and lines of l demarcation programs.

IMPLEMENTATION ACCEPT AS IS l

REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

I

PAGE: TER App 2nd. A2-20

()

,m LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 414 HED CATEGORY 2B FSR PAGE 328 FINDING Some of the items in the right-hand column of P-1 (where numbers are used to designate special items or routines) are difficult to understand or interpret. Better identification of parameters monitored would enhance operations.

RESPONSE

The cited acronyms are referenced in the procedure [ LOP-CX-(series)], which is available to the operators.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

() 1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION P-1 is a computer program accessible to the operator that runs the OD-17 computer routine that presents core thermal data. The numbers referred to in the HED are code numbers whose meanings are available to the operator via the procedure for the program located at the unit. This information is supplemental to that presented on the screen. Operators receive training in the use of the computer and in the interpretation of the data presented by this program. As an operkter aid, the program is acceptable as is.

l i

IMPLEMENTATION ACCEPT AS IS l

CCEPT AS IS C)UEVISEDIMPLEMENTATION 1

l .

PAGEt TER Appand. A2-21 O

(_j LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 415 HED CATEGORY 2B FSR PAGE 329 FINDING Thermal abbreviations are difficult to understand or interpret. They should 011 be verified to correspond with technical specification abbreviations.

A list of standard names, acronyms, abbreviations, part/ system numbers chould be used.

RESPONSE

The acronymme and abbreviations are referenced in the procedure, which is available to the operators.

NRC/SAIC COMMENT The basis for the Justification for not eddressing this HED is not adequate for one or more of the following reasons:

() 1.

2.

It does not address operational or behavioral factors or issues.

It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION Nuclear thermal dynamics is a complex topic. It is an integral aspect of plant operations and as such operators are trained and tested in it. Core thermal dynamic data is available to the operator via the computer (Program P-1, routine OD-17). Because of the complexity of the data and the limited display space available on the control room computer system (CRTs and Printers), the use of Thermal acronyms and abbreviations is necessary.

Through training and the RO licensing process operators become familiar with the meaning and interpretation of the acronyms and abbreviations associated with thermal dynamics. In addition, they are defined and explained in the computer procedure available at each unit. As such, they are standardized

! as the HED suggests and no further action is warranted.

l l IMPLEMENTATION ACCEPT AS IS

' ACCEPT AS IS C.REVISEDIMPLEMENTATION I

l l

PAGE: TER Appand. A2-22

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

HED # 124 HED CATEGORY 2C FSR PAGE 330 FINDING The computer system does not provide prompting and structuring features which allow the operator to request additional information.

RESPONSE

The computer system is not interactive so that these features would not really fit in with the overall structure of the system. Documentation containing additional information is provided at the computer workstation.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION The process computer system available to the operator in the control room was designed as an operational aid to provide operators with desirable information in a readily useable fixed format under normal and transient conditions. In either of those conditions, an operator would be expected to be using the information available to him/her to take action on the control panels and to monitor the actions' effectiveness. An interactive computer system with menus, prompts, program stops for data input, and data structuring features would not be conducive to the function for which the machine was intended. Additional and supplemental 1nformation is readily available to the operator from other sources.

IMPLEMENTATION ACCEPT AS IS O REVISED IMPLEMENTATION l ACCEPT AS IS l

PAGE: TER Appsnd. A2-23 0 ,

LASALLE STATION REVISED RESPONSE / CLARIFICATION TO~HEDS REFERRED TO-IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED #. 125 HED CATEGORY 2C FSR PAGE 331 FINDING The computer system does not contain prompting and structuring features which allow the operator to request corrected information when an error is detected.

RESPONSE

The system is not interactive so that these features would not fit in with the overall structure of the system. Error messages are displayed when an orror is made and documentation for these messages and the responses are I

provided at the computer workstation.

MRC/SAIC COMMENT The basis for the austification for not addressing this HED is not adequate

-for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address tha discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION The process computer system available to the operator in the control room was designed as an operational aid to provide operators with desirable information in a readily useable fixed format under normal and transient conditions. In either of those conditions, an operator would be expected to be using the information available to him/her to take action on the control panels and to monitor the actions' effectiveness. An interactive computer system with menus, prompts, program stops for data input, and data structuring features would not be conducive to the function for which the machine was intended. Additional and supplemental information is readily available to the operator from other sources.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION

( ACCEPT AS IS 1

I PAGE: TER Appand. A2-24 l

\

( j LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 128 HED CATEGORY 2C FSR PAGE 352 FINDING The color red is used to highlight points that are alarming on CRT displays and for closed, open, or on, for other CRT displays, Highlighting methods used for emergency conditions should not be used in association with normal conditions.

RESPONSE

The indicated uses of the color red on CRTs is consistent with that used oisewhere in the control room. The use of red for an alarming point is also consistent across all CRT displays which contain points.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It citen utility, industry, or manufacturer's standard.

In addition, the Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs.

Apparently related HEDs are numbers 237, 240, 309, 308, 130 and 131 as listed in section A3 on page 29 of the TER.

CECO CLARIFICATION The following response addresses seven HEDs the NRC felt to be related (see the NRC/SAIC Comment above). Four of the HEDs deal with CRT hardware issues while three deal with color graphic software issues, i.e., consistent use of color. One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs O

l 1

PAGE: TER App 2nd. A2-25

( ) the identified in the TER as related to this HED.

readability / comprehensibility and use of These HEDs are concerned with color of the control room computer CRT displays. The following comments relate to the HEDAT's reevaluation of the CRT hardware issues while the final paragraph is concerned with the use of color issues. Though the CRTs in use at LaSalle are of graphic quality, they do not contain the amount of picture elements per square inch suggested by the CECO guidlines and NUREG 0700 for the display of Complex shapes. The HEDAT maintains that "Complex" shapes are not presented on the control room CRTs and hence there is no need to, "distinguish between them". Consequently, the current CRTs are adequate.

Concerning the issue of use of color, LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes an "Abnormal" condition when the unit is above 30% power. The CECO computer display conventions currently do not use green board coding, which in part accounts for the cited discrepancies.

The feasibility of using green board coding for the computer graphics is being explored at CECO's Byron PWR station. Several displays have been modified and their use is being evaluated. One problem ie that green board coding does not provide for indication of equipment status beyond normal / abnormal, for example, open/ closed, on/off, etc. Resolutions to this problem are being evaluated at the two stations. When the "green board convention" computer graphics problems have been successfully resolved at Byron, that convention will be implemented at LaSalle if feasable.

Resolution and implementation is anticipated prior to the completion of the

[OT cecond refueling outage.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE l

l O

i 1

PAGE: TER App 2nd. A2-26 I l

l 1

.(%) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 130 HED CATEGORY 2C FSR PAGE 353 FINDING The color green is used in CRT displays to indicate an open breaker, a normal condition, a closed valve or an "off" condition. According to criteria, the color green should be used to indicate a safe condition, no operator action required or that a parameter valve is within tolerance.

RESPONSE

The CRTs in the control room are considered Job peformance aids and are made available for diagnowtic purposes. The use of graphics, shapes, alphanumeric and colors are provided to improve the operators' understanding-of plant status. These coding techniques are used consistently. While at the boards, the operators implement their decisions where all coding (labels, color, etc.) is consistently used and understood by the operators.

Additionally, the operators are trained to make decisions and take action based on control board status.

l NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

I In addition, the Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs.

Apparently related HEDs are numbers 237, 240, 309, 308, 128 and 131.

CECO CLARIFICATION The following response addresses seven HEDs the NRC felt to be related (see the NRC/SAIC Comment above). Four of the HEDs deal with CRT hardware issues I while three deal with color graphic software issues, ie., consistent use of

( color. One of the objectives of the multidisciplined HEDAT and particularly O

l

PAGE: TER Appand. A2-27

()theparticipationoftheLeadHumanFactorsSpecialistwas to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the readability / comprehensibility and use of color of the control room computer CRT displays. The following comments relate to the HEDAT's reevaluation of the CRT hardware issues while the final paragraph is concerned with the use of color issues. Though the CRTs in use at LaSalle are of graphic quality, they do not contain the amount of picture elements per square inch suggested by the CECO guidlines and NUREG 0700 for the display of Complex shapes. The HEDAT maintains that "Complex" shapes are not presented on the control room CRTs and hence there is no need to, "distinguish between them".

Concerning the issue of use of color, LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes an "Abnormal" condition when the unit is above 30% power. The CECO computer display conventions currently do not use green board coding, which in part accounts for the cited discrepancies.

The feasibility of using green board coding for the computer graphics is being explored at CECO's Byron PWR station. Several displays have been modified and their use is being evaluated. One problem is that green board coding does not provide for indication of equipment status beyond normal / abnormal, for example, open/ closed, on/off, etc. Resolutions Os to this problem are being evaluated at the two stations. When the "green board convention" computer graphics problems have been successfully resolved at Byron, that convention will be implemented at LaSalle if feasable.

Resolution and implementation is anticipated prior to the completion of the second refueling outage.

IMPLEMENTATION ACCEPT AS IS l

REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

^

l PAGE: TER Appand. A2-28 I

l i

i LASALLE STATION

/-]s REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO l

IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 426 HED CATEGORY 2B FSR PAGE 360 FINDING The alarm typer should not print position changes because this clutters the printout and makes it difficult to zero in on a specific alarm of interest.

The current system creates a nuisance printout and clutters typer with irrelevant information.

' RESPONSE Inforr.ation fron the alarm types is used for the diagnostic review which occurs after an event.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

() 1.

2.

It does not address operational or behavioral factors or issues.

It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION The alarm typer is present in the control room as an operational aid to the 2 operator. Its intended function is to serve as an archival data record of actuated sensors to allow for diagnostic review subsequent to an event. As such, any change in sensor condition that potentially triggers an alarm will be recorded. Auditory signalling, however, is reserved for instances in j which significant sensor actuation activity occures. Nonetheless, the alarm

! typer printout can appear cluttered, particularly after a Reactor SCRAM situation. It is felt that the potential operational benefit of knowing which sensor caused an alarm outweighs the "nuisance" characteristic of having all alarming sensors printed.

IMPLEMENTATION ACCEPT AS IS O REVISED IMPLEMENTATION ACCEPT AS IS I

PAGE: TER App 2nd. A2-29 (j LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO L IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 93 HED CATEGORY 1C FSR PAGE 376 FINDING The "Reboiler Leak Detection Monitor 1D18-K752" is located in the middle of five control room Heating Ventilation Air Conditioning (HVAC) Monitors on (OPM14J). (Photo Log No. D-10)

RESPONSE

This display is adequately labeled and easily identified as a unique instrument. The operators are clearly aware it is not related to the HVAC monitors.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

() 1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION The "Reboiler Leak Detection Monitor" is a radiation monitor located with similar monitors on a common panel, OPM14J. It is uniquely labeled so that it is readily identifiable. Nonetheless, the monitor will be moved two monitor spaces to the left so that the HVAC monitors can all be grouped together.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

PAGE: TER Appand. A2-30 tO. -

5 LASALLE STATION

~#

REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 361 HED CATEGORY 1C FSR PAGE 379 FINDING The residual heat removal blowdown valves are not grouped appropriately.

They should be grouped together to avoid operator confusion and error.

(Photo Log No. G-8)

RESPONSE

These valves are containment isolation valves and are divisionally separated. The grouping, with other isolation valves is appropriate.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION To reiterate our original response to this HED, the cited valves (the RHR Blowdown Isolation Valves) are containment isolation valves, are safety related, and are divisionally separated. They are divisionally integrated with the other containment isolation valves. The purpose of this panel arrangement is to group all safety related containment isolation valves together so that in a transient condition requiring a containment isolation, the operator can quickly confirm that the required isolation has occurred by glancing at the position indication for this cluster of valves.

e IMPLEMENTATION ACCEPT AS IS

, REVISED IMPLEMENTATION

'CCEPT AS IS i

PAGE: TER Append. A2-31 LASALLE STATION

] REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 367 HED CATEGORY 1C FSR PAGE 381 FINDING The operator survey determined that the residual heat removal / reactor core isolation cooling valves are spread out on H13-P601. (Photo Log No. G-9)

RESPONSE

These valves are adequately labeled and sufficient mimicking is available to aid the operators in recognizing functional groupings.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION The Residual Heat Removal / Reactor Core isolation cooling valves are separated on the H13-P601 panel due in part to divisional separation criteria. They are functionally grouped with related displays, appropriately labeled, and effectively incorporated within an ECCS mimic.

No problems were discerned with these controls during either the Reviev's task analysis or validation of control room function. The HEDAT feels these controls are appropriately placed.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION ACCEPT AS IS O

PAGE: TER Appsnd. A2-32

()

LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 482 HED CATEGORY 2C FSR PAGE 383 FINDING During the task analysis and verification, it was noted thet the indicator lights above the control switches on the PMO6J panel are spaced so far apart that lights for ad3acent controls appear to be related. (Photo Log No. F-9)

RESPONSE

The control room operators are aware of the relationship between the indicator lights and their respective controls. These lights are redundant indications of status, and the operators report no degradation in performance due to their arrangement.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION Reevaluation of this problem by the HEDAT resulted in concurrence with the NRC's comments. To emphasize the relationship of controis-to-lights, sub system size lines of demarcation will be drawn between nonrelated lights l vertically, and horizontally between the two rows of separate controls.

l IMPLEMENTATION ACCEPT AS IS i

REVISED IMPLEMENTATION 2ND REFUELING OUTAGE l

O l

PAGE: TER Appand. A2-33 l LASALLE STATION REVISED. RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.-

HED # 252 HED CATEGORY 2A FSR PAGE 389 i

FINDING During validation, operators were observed to pause frequently in the performance of Job duties on the heater drain system to verify their actions. The addition of mimics would facilitate operations. (Photo Log No. D-18)

RESPONSE

The heater drain system is not a safety system. It functions automatically

, during accident situations and does not require the operator's immediate attention.

I NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.  !

2. It does not sufficiently address the discrepancy.

4 3. It cites absence of previous operator error. i

(

4. It cites utility, industry, or manufacturer's standard.

• F i CECO CLARIFICATION I L The HEDAT reevaluated this problem in light of the NRC's comments and feels l the original evaluation and response was appropriate. The Heater Drain  ;

system is not safety related nor is its operation time critical. It is only '

used during startups and shutdowns. In transient situations the system functions automatically and does not require the operator's immediate  ;

attention. Finally, the original finding cites the operators for pausing in -

the performance of Job duties which by procedure and training they are supposed to do in order to verify the actions they have taken. Therefore the HEDAT feels no "corrective" action is necessary. ,

IMPLEMENTATION ACCEPT AS IS O REVISED IMPLEMENTATION ,

ACCEPT AS IS  !

.. _ - _, .._.. _-_ _.. - -- , . - _ _ I _. _ _ _ _ _ --

PAGE: TER Appand. A2-34

.( ) LASALLE STATION REVISED RESPCNSE/ CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HEDlt 58 HED CATEGORY 1C FSR PAGE 392 FINDING The manual, outboard, and f*")ard isolation emergency controls are located on H13-P601. These contro : Are difficult to identify and should be accentuated. (Photo Log No. D-22)

RESPONSE

The cited controls are color eoded red and shape coded differently than the other controls. This is adequate accentuation.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

O.

\/ 2. It does not sufficiently address the discrapancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION The HEDAT has reevaluated this HED and concludes that the cited controls are readily identifiable. They are the only round push-button type controls within the demarcated area of this section of the H13-P601 panel. They are red in color (because of their "Fmergency" function). The other controls on this section of the panel are black pistol grip type controls. As stated in the original response, their unique shepe and color is adequate accentuation. No additional accentuation ic requirec.

IMPLEMENTATION ACCEPT AS IS t

l l

l REVISED IMPLEMENTATION OCCEPTASIS O

- -- .n-- - - -

PAGE: TER Appand. A2-35 I-O LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 543 HED CATEGORY 1C FSR PAGE 395 FINDING The reactor coolant level indicator is located with the residual heat removal B groap of meters (on H13-P601) but is not controlled by that system only. (Photo Log No. F-10)

RESPONSE

Operators report no problems with the location of the reactor coolant level indicator. Its arrangement on H13-P601 is appropriate since it is also used when the operators are working with the high pressure core spray (MPCS) system.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION The Reactor Level Fuel Zone indicator cited in the HED displays reactor levels from -311 inches to -111 inches in the vessel, the area around the active fuel. The DCRDR Task Analysis identified this indication as required. It also determined that all features relevant to the current indication were acceptable, ie., scale, units, range, and location.

Therefore, no further action is required.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION

( iCCEPT AS IS

PAGE: TER App 3nd. A2-36 m

k ,) LASALLE STATION  !

REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO 1 IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

i HED # 473 HED CATEGORY 1C FSR PAGE 396 FINDING During the task analysis and verification, it was observed that the reactor pressure and the reactor wide range level indicators, though functionally related, are not grouped together on the H13-P603 panel. (Photo Log No. I-25)

RESPONSE

These indicators are used during feedwater operation. Therefore their location is appropriate.

NRC/SAIC COMMENT The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

[ 1. It ooes not address operational or behavioral factors or issues.

v

2. It does not sufficiently address the discrepancy.

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard. <

CECO CLARIFICATION While it is true that reactor level and pressure are functionally related, the wide range level indication is located closer to the feedwater control station and away from the pressure indication because reactor level is directly controlled by che feedwater system and feedback as to reactor level is necessary when manipulating the feedwater controls. Moreover, when reactor level is below 0 inches with feedwater available this is the only indicator available to tell the operator if reactor level is increasing. Its present location and arrangement is therefore appropriate and no corrective action is warranted.

IMPLEMENTATION ACCEPT AS IS O REVISED IMPLEMENTATION ACCEPT AS IS

PAGE: TER Appsnd. A2-37

( LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO g

+ 1' IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 532 ^!

HED CATEGORY 2C FSR PAGE 401 FINDING Annunciator panel designations for panel H13-P601 proceed from A to D, then F, then E. (Photo Log No. F-14) +

i RESPONSE -

The operators do not use the letters above each annunciator panel as a designator.- The annunciators are referenced by the control panel where they are located. In addition, all annunciator procedure books are located in front of respective panels so search time to locate procedures is not required.

NRC/SAIC COMMENT j i The basis for the Justification for not addressing this HED is not adequate for one or more of the following reasons:

1. It does not address operational or behavioral factors or issues.

~

2. It does not sufficiently address the discrepancy. '

3. It cites absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard. '

CECO CLARIFICATION '

While it is true that the annunciator box letters proceed A to D, F and then '

E on the H13-P601 panel, it is of no consequence because the letters have ao , .

sequential meaning and are only used as partial identifiers. Each annunciator tile is uniquely identified via the panel number, eg. 1H13-P601, the letter designate of the annunciator window box, eg. A, and the grid X and Y coordinates the tile occupies, eg. 1 04. The tiles are thus referenced in all procedures, training manuals, maintenance work requitats, '

shift logs, etc. Since the letters are only used as designators with no

. order or other significance implied the HEDAT feels no "corrective" action ,

is warranted.

IMPLEMENTATION

, ACCEPT AS IS

( REVISED IMPLEMENTATION i

) ACCEPT AS IS f 1 0

4

p. - _

y ,

1

, PAGE: TEk Appsnd. A2-38

[ LASALLE STATION  ;

Dr' REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO l IN THE NRC'S SAFETY EVALUATION (SE)' 0F THE DCRDR. l HED # 550 HED CATEGORY 2C FSR PAGE 403 A i' FINDING

ThehtrMin stop valve is located in a stf ing of other valvest IV-1, MSV-2, rIV 7, IV-3, on PMO2J. (Photo Log No. F-22)

, < f /. <

t i !

< , RESPONSE The main stop valve (MSV-2) is used only during chest warming of the turbine during startup. It is not used in emergency situations and the operators repu i'no difficulty in its location.

NRC/SAIC COMMENT

The basis for the.austification for not addressing this HED is not adequate 3

for one or teore of the following reasons:

L) i <

b. . < 1. It does not address operational or behavioral factors or issues.

op).4

(_ 2. It does not sufficiently addreas the discrepancy.

3. It'c13es absence of previous operator error.

4. It cites utility, industry, or manufacturer's standard.

CECO CLARIFICATION i The indication cited in the HED is the Main Stop Valve's nervo valve's current draw in amps. It is located with other Turbine servo valve current indicators in a vendor panel on the PMO2J panel. It is directly above indication for the stop valve's position, and above the control for the valve. The valve is physically located downstream of the Main Steam Isolation Valvea at the turuine and is used during startups to preheat and expand ths; turbine shall in order to prevent turbine damage. The HEDAT has reevaluktod this HED arid determined that the ir.dication is appropriately located given its function and significance.

u IMPLEMENTATION <

ACCEPT AS IS 07EVISEDIMPLEMENTATIQi' ACCEPT AS IS ),

1

~'

(R',5 y, lh 3 j

'[,i V '

I PAGE: TER App;nd. A2-39

/

y i I

7"N '

i s

(' '~ )#

r , / 'LASALLE STATION

',&IN REVISED ' R81"GK7// CLARIFICATION (SE) TO HEDS REFERRED TO i

, THE NRC'S SAFETY EVALUATION OF THE DCRDR.

'd HED # 530 /

HED CATEGORY 2C /

FSR PAGE 435 ,,

/

1 FINDING ,

Source range monitor (SRM) bypewujconprols and indicators (H13-P601) are not consistent. The indicators are IJ4d out A,B,C,D while the control detents cre laid out in a lockwise order pf A,C,B,D. (Photo Log No. F-13)

, i RESPON54 I; The SRM bypass control is not a tint-critical instrument and not important for postreccident monitoring. The operators do not report any difficulty

), in opert. tion due to the current layout.

) /\

l <

NRC/SAIC(*;CMMENT The badiL/ for the Justificat. ion for not addressing this HED is not adequate for one or more of the following reasons:

[G} ,  ; .) . Lt does not addr $ss oppre,tional or behavioral factora or issues.

2) It does not sufficientLy' address the discrepancy.

3. It cites absence of previous operator error.

4.,It cites uqJ11ty, induct.vy,/or manufacturer's standard.

s CECO CLARIFICATION ,

A reevaluation of this HED by the HEDAT resulted in concurrence with the NRC's comments. Thebefore, the SRM Bypass Control vill be rewired so that the .nonitors are "bypassed" in a clockwise order of "A, B, C and D". Since the negative transfer of training for this modification will be strong because this the current' layout is a EWY industry standard, an implementation of the second refueling outage is achievable.

1 s

IMPLEMENTATION ACCEPT AS IS J

REVISED IMPLEMENTATIUN ND REFUELING OUTAGE

/

e

Commonwealth Edison Company's Revised Response / Clarification

, to HEDs Referred to in the NRC's Safety Evaluation (SE) Report  ;

of.the LaSalle County Station DCRDR  ;

i Safety Evaluation Report - Enclosure B (TER) J Revised Responses (TER .tppend. A3) i I  ;

I i i

i i

L

?

t l

l t

{

i I

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

t.

PAGE .TER Appand. A3- 1 j

() LASALLE STATION REVISED RESPCKEE/ CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 429 HED CATEGORY 2C FSR PAGE 100 i- TINDING  !

=A different radio channel is needed for operations to that other departmental activities do not interfer with operations activities. Radio communication should consider the extent to which radio interference could cdversely affect control room operations.

RESPONSE

Radios are used priuarily by personnel associated with operations to insure t operations is kept informed of plant activities. A third radio channel will  ;

be added to be used for pagers. This will reduce the traffic on the

' existing channels.

NRC/SAIC COMMENT

, The Justification of this individual HED does not appear to consider the

, cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 428, 538, 561, 562, 563, and 24.

CECO CLARIFICATION

! One of the objectives of the multidisciplined HEDAT and particularly the i participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were l assessed. This in fact was done et the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, i cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. The HEDs cited all concerned aspects of the plant's communication system. That system is composed of  !

four parts; one is the VHF radio, another is the Sound Powered Phone ,

! network, a third is the pager, and the fourth is the regular phone system. l Operato a have access to all four systems but rarely use the sound powered i i

phones; these are generally reserved for use by the instrument maintenace ,

department for instrument calibrations where immediate and frequent communication is important. Sound powered headsets and patch cords are available to d.he operator at the center deak. The operators primary means

+

i i

l I 1 i r

PAGE: TER Appand. A3- 2 O of identified communication with the plant is the VHF and documented during the DCRDR radio system. A problem was with the availabilAty of cufficient radio channels for operations use. In response, a third channel has been added. In place procedures govern radio channel use.

IMPLEMENTATION 2ND REFUELING OUTAGE-REVISED IMPLEMENTATION COMPLETED i

O i

i J

. O l

l I . .- - . _ _ _ - . . - - . _ .

- )

PAGE: TER Append. A3- 3

,( )

LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

~HED # 426 HED CATEGORY 2C FSR PAGE 101 FINDING

.The radio pager is on the control room channel. There should be no radio pagers on the control root' operating frequency since this interferes with operations. Pager can interrupt a critical operating information channel and delay operator in respor. ding to an emergency.

RESPONSE

A third radio channel will be used for pagers. This will reduce the traffic on the existing channels.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently re.1sted HEDs are numbere 429, 538, 561, '362, 563, and 24.

CECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Irad Human Factors Specialist was to ensure tnat cumulative and/or interactive effects were considerec when HEDs were assessed. This in fac' sas done at the time ,f the original HEDAT, though admittedly not speciated on each HED's response. Honethe19ss, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. The HEDs cited all concerned aspects of the plant's communication system. That system is composed of four parts; :ne is the Vh? radio, another is the Sound Powered Phone network, a third is the pak?r, and the fourth is the regular phone system.

Operators have access to all four systems but rarely use the sound powered phones; these are generally "eaerved for use by the instrument maintenace ,

department for instrument callorationr where immediate and frequent communication is important. Sound powered headsets and patch cords are available to the operator at the c37ter desk. The operators primary means of communication with the plant is t.,> VHF radio system. A problem was identified and documented during the DCRDR with the availability of sufficient radio channels for operations use. In response, a third channel has been added in order to reserve at least two channels for operations use.

O I

l

• i

PAGE: TER Appand. A3- 4

( 'p Other channels are available but are generally used by other groups or

' departments, eg., security. In place procedures govern radio channel use.

The other communication systems are readily available to the operators.

Both regular and page phones are located at primary control panel workstations and at the unit and center desk. Page messages are heard over loudspeakers. These are appropriately placed in the control room to cover the main control panels and center desk.

IMPLEMENTATION 2ND REFUELING OUTAGE REVISED IMPLEMENTATION COMPLETED O

O

PAGE: TER'Appsnd. A3- 5

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR. I HED # 538 HED CATEGORY 2C

-FSR PAGE 110 FINDING Patch cords and at least one sound powered phone are not stored at each patch panel location.

RESPONSE

Control room operators do not routinely use sound-powered telephones.

Therefore, the lack of these phones does not affect control room operations.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or int'ractive effect of other related HEDs. Apparently related HEDs are numbers 429, 428, 561, 562, 563, and 24.

CJECO CLARIFICATION One of the obaectives of the multidisciplined HEDAT and particularly the participation of the Lead fiuman Factore Specialist was to ensure that e lulative aid /or 11teractive effects were considered when HEDs were '

a_ Jessed. Tais in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cume3=tive/ interact.ive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. The HEDs cited all concerned aspects of the plant's communication system. That system is composed of '

four parts; one iA tne VHF radio, another is the Sound Powered Phone network, a third da the pager, and the fourth is the regular phone system.

Operators have necess to all four systems but rarely use the sound powered phones: these r.rre generally reserved for use by the instrument maintenace department fx. 'natrument calibrations where immediate and frequent communicatie.i 2s important. Sound powered headsets and patch cords are available to the operator at the center desk. The operators primary means

PAGE: TER Appand. A3- 6

)ofcommunicationwiththeplantistheVHFradiosystem.

~

A problem was identified and documented during the DCRDR with respect to the availability of patch cords and at leaet one sound powered phone at each patch panel location. Since the sound powered phone system is rarely used by the operators, the availability of this equipment at the center desk is cufficient.

IMPLEMENTATION ,

ACCEPT AS IS REVISED IMPLEMENTATION ACCEPT AS IS O

1 1

4

PAGEs--TER Appand. A3- 7

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO  !

IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.- l HED # 561

~ HED CATEGORY 2C FSR PAGE 111 .

FINDING A well marked accessible location for the sound powered phones is.not i provided in the control room.  ;

i 4

RESPONSE ,

Control room operator s do not routinely use sound powered telephones.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the

! cumulative ~or interactive effect of other related HEDs. Apparently related .i HEDs are numbers 429, 428, 538, 562, 563, and 24.

CECO' CLARIFICATION [

O One of the obaectives participation of the of Lead theHuman multidisciplined HEDATwas Factors Specialist andtoparticularly ensure thatthe cumulative and/or interactive effects were considered when HEDs were l assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless,  ;

cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs l identified in the TER as related to this HED. The HEDs cited all concerned aspects of the plant's communication system. That system is composed of

. four parts; one is the VHF radio, another is the sound powered phone network, a third is the pager, and the fourth is the regular phone system.  !

Operators have access to all four systems but rarely use the sound powered phones; these are generally reserved for use by the instrument maintenace  !

l department for instrument calibrations where immediate and frequent  !

i communication is important. Sound powered headsets and patch cords are  !

! available to the operator at the center desk. The operators primary means

! I

{

l'  :

b l

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eew-e-m.--wen,wa. m,+- _w , - - . _ - = , - - -T"'P '""W' '

'----""7FD

"'T'T"-TT 79

PAGE: TER Appand. A3- 8

( ) of communication with the plant is the VHF radio system. A problem was identified and documented during the DCRDR with respect to marking of the l location of the sound powered phones. Since the sound powereo phone system l is rarely used by the operators, the equipment is available at the center desk. All operators are trained as to the location of this equipment should <

they ever find a need to use it. ,

l IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION ACCEPT AS IS O

O t

PAGE: TER App 3nd. A3- 9

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO H

IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 562 '

HED CATEGORY 2C FSR PAGE 112 FINDING Sound powered phones do not have the capability of switching directly into l the paging system.

RESPONSE

Control room operators do not routinely use sound-powered telephones.

NRC/SAIC COMMENT ,

The justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 429, 428, 538, 561, 563, and 24.

CECO CLARIFICATION O Cne of the objectives participation of the of theHuman Lead multidisciplined HEDATwas Factors Specialist andtoparticularly ensure thatthe cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though '

admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. The HEDs cited all concerned aspects of the plant's communication system. That syntem is composed of four parts; one is the VHF radio, another is the sound powered phone network, a third is the pager, and the fourth is the regular phone system.

Operators have access to all four systems but rarely use the sound powered phones; These are generally reserved for use by the instrument maintenace department for instrument calibrations where immediate and frequent communication is important. Sound powered headsets and patch cords are available to the operator at the center desk. The operators primary means b

O

PAGE: TER Appand. A3-10 i 4

of communication with the plant is the VHF radio system. A problem was identified and documented during the DCRDR with respect to the lack of ability of the Sound Powered Phones to switch directly into the paging l oystem. Since the Sound Powered Phone System is rarely used by the operators that feature is not required nor is it desireable.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION ACCEPT AS IS O

l.

. O

\

• 1

PAGE: TER Appand.'A3-11

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

HED # 563 HED CATEGORY 2C FSR PAGE 113 FINDING Jacks for the sound powered phone system are not provided at every work otation so the long cords may be required which could result in a tripping hazard.

RESPONSE

Control room operators do not routinely use sound powered telephones.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 429, 428, 538, 561, 562, and 24.

OECOCLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was dona at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. The HEDs. cited all concerned

, aspects of the plant's communication system. That system is composed of four parts; one is the VHF radio, another is the Sound Powered Phone network, a third is the pager, and the fourth is the regular phone system.

Operators have access to all four systems but rarely use the sound powered phones; these are generally reserved for use by the instrument maintenace department for instrument calibrations where immediate and frequent communication is important. Sound powered headsets and patch cords are available to the operator at the center desk. The operators primary means O

\

i PAGE: TER Appsnd. A3-12 of communication with the plant is the VHF radio system. A problem was identified and documented during the DCRDR with respect to the lack of Sound Powered Phone Jacks at all work stations. Since the sound Powered Phone System is rarely used by the operators this is not a problem.

. IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION ,

ACCEPT AS IS I I

i O

1 t

O  :

'i

PAGE: TER Appsnd. A3-13 l

O LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 24  !

HED CATEGORY 2C  !

FSR PAGE 114 FINDING i The location of loudspeakers in the control room does not provide adequate coverage to all areas in the control room.

RESPONSE

The "dead spot" areas are located on back panels. All main control room locations are audible to the operators. The unit operator is relieved prior to going to the back panel area.

NRC/SAIC COMMENT  !

The Justification of this individual HED does not appear to consider the '

cumulative or interactive effect of other related HEDs. Apparently related

, HEDs are numbers 429, 428, 538, 561, 562, and 563.

s DECO CLARIFICATION I One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs l identified in the TER as related to this HED. The HEDs cited all concerned ,

aspects of the plant's communication system. That system is composed of four parts; one is the VHF radio, another is the Sound Powered Phone network, a third is the pager, and the fourth is the regular phone system.

Operators have access to all four systems but rarely une the sound powered phones these are generally reserved for use by the instrument maintenace  !

department for instrument calibrations where immediate and frequent l communication is important. Sound powered headsets and patch cords are  !

available to the operator at the center desk. The operators primary means l of communication with the plant is the VHF radio system. A problem was  !

identified and documented during the DCRDR with the availability of sufficient radio channels for operations use. In response, a third channel will be added in order to reserve at least two channels for operations use.

Other channels are available but are generally used by other groups or departments, eg., security. In place procedures govern radio channel use.  ;

4 h

O o l

l PAGE: TER App 3nd. A3-14 l

()Theothercommunicationsystemsarereadilyavailabletotheoperators.

Both regular and page phones are located at primary control panel ,

workstations and at the unit and center desk. Page messages are heard over  ;

loudspeakers. These are appropriately placed in the control room to cover  ;

the main control panels and center desk. Backpanel areas do contain "dead spot

• locations. A loudspeaker will be placed in this region to cover this area.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

i i

iO

PAGE: TER App 3nd. A3-15

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

HED # 289 HED CATEGORY 2B FSR PAGE 207 FINDING The "drywell air suppression chamber and suppression pool water integrity CM037" (on PM13J) recorder has two scales measuring temperatures ranging from 0-250 degrees. The top scale measures drywell and suppression chamber air temperatures (3 pts) in increments of 1.75 degrees. The bottom scale measures suppression pool water temperatures (14 pts) in increments of 10.

It is necessary to compare the two scales and because of the increment difference, it is difficult. (Photo Log No. B-9)

RESPONSE

The drywell air temperature parameters will be removed from this recorder and relocated to a new recorder and labeled with consistent graduations.

NRC/SAIC COMMENT a The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. An apparently i related HED is number 112.

CECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HED ,

identified in the TER as related to this HED. This resulted in concurrence with the NRC's comment. Therefore, the drywell air and suppression pool water temperature recorder will be replaced with one more appropriate to the <

displays' function. This will be done in conaunction with the redesign of the PM13J panel committed to as the response to HEDs 286, 476, 478, 371, 372, 197, and 362.

IMPLEMENTATION IST REFUELING OUTAGE l

2ND REFUELING OUTAGE

PAGE: TER Appsnd. A3-16

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO, IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 112 HED CATEGORY 2C FSR PAGE 210 FINDING The drywell air suppression chamber and suppression pool water recorders contain information for seventeen points. An operator is required to make at least two conversions before making an assessment regarding any particular point. (Photo Log No. B-10)

RESPONSE

A Job performance aid which identifies each point will be permanently engraved and placed on the recorder door so as not to obscure the recorded trend.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. An apparently

( } related HED is number 289.

CECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HED identified in the TER as reisted to this HED. This resulted in concurrence with the NRC's comment. Therefore, the drywell air and suppression pool water temperature recorder will be replaced with one more appropriate to the displays' function. This will be done in conjunction with the  ;

redesign of the PM13J panel committed to as the response to HEDs 286, 476, 478, 371, 372, 197, and 362.

. IMPLEMENTATION iST REFUELING OUTAGE REVISED IMPLEMENTATION  !

2ND REFUELING OUTAGE '

I

PAGE: TER App 3nd. A3-17 7s LASALLE STATION

( )

REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 192 & 355 HED CATEGORY 2C FSR PAGE 245 FINDING The color of blue legend lights is not clearly identifiable. On Unit One, blue lights look green while unlit, and look white when lit. On Unit Two, blue lights look blue when unlit but look violet when lit. (Photo Log No.

B-20, H-9)

RESPONSE

The control room oporators are aware of the slight color differences in blue legend lights. They report no difficulty in discriminating the color of legend lights.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 355, 509, 510, 511, 160, 216, 215, 283, 217, 218, 219, 220, 221, 222, and 293.

CECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the apparent lack of legend light discriminability either because of differences in lens cap color, light intensity and contrast ratios, or non adherence to engraving specifications documented in the CECO Human Factors checklist. In all individual instances the deviations from the criteria were small and of no import. Upon reevaluation the HEDAT feels this remains the case except for the "blue" indicator light lens caps. For these there is little consistency across the control room. Therefore, an effort will be made to obtain lens caps that meet CECO Human Factors Engineering contrast ratio criteria. These will be engraved in accordance with Ceco engraving guidelines and installed in the control room by 12-31-88.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 12/31/88

PAGE: TER App 3nd. A3-10

.- t i. , LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO l IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 509, 510 & 511 NED' CATEGORY 2C FSR PAGE 246 FINDING'

Light intensity of some indicating lights and legend pushbuttons (as

, compared to the surrounding panel) is less than the recommended 10X.

i i

RESPONSE

The light of all indicating lights and pushbuttons is discriminable from the

' surrounding panel due to the bright light contrasting to the painted panel.

1 NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 192, 355, 510, 511, 160, 216, 215, 283, 217, 218, 219, 220, 4

221, 222, and 293.

CECO CLARIFICATION l One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that i cumulative and/or interactive effects were considered when HEDs were

) ansessed. This in fact was done at the time of the original HEDAT, though l admittedly not specified on each HED's response. Nonetheless,

cumulative / interactive effects were re-evaluated by the HEDAT for the i HEDs identified in the TER as related to this HED. These HEDs are concerned i with the apparent lack of legend light discriminability either because of I

differences in lens cap color, light intensity and contrast ratios, or non l adherence to engraving specifications documented in the CECO Human Factors

checklist. In all individual instances the deviations from the criteria were small and of no import. Upon reevaluation the HEDAT maintains that i aside from the documented problem concerning the consistency and readability of the "blue" legend light indicators, the cummulative as well as individual l impact of the other cited deviations is negligable. Therefore, new

• blue" l indicator light lens caps will be obtained and installed that meet the l checklist criteria.

l l

l IMPLEMENTATION f ACCEPT AS IS iO REVISED IMPLEMENTATION 12/31/88 l

l_____ -

O HED # 160 HED CATEGORY 2C FSR-PAGE 247 Referenced on Page: TER Append. A2-12, A2-13 O

O

PAGE: TER Appond. A3-19

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS. REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 216 HED CATEGORY 3C FSR.PAGE 249 FINDING The character font styles on legend lights are not consistent throughout the control room.

RESPONSE

Character font styles on legend lights vary slightly, depending on the vendor supplier. The legend lights are readable arai the different font styles do not adversely affect operator performance.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 192, 355, 509, 510, 511, 160, 215, 283, 217, 218, 219, 220, 221,-222, and 293.

CECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of tne original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER um related to this HED. These HEDs are concerned with the apparent lack of legend light discriminability either because of differences in lena cap color, light intensity and contrast ratios, or non adherence to engraving specifications documented in the CECO Human Factors checklist. In all individual instances the deviations from the criteria were small and of no import. Upon reevaluation the HEDAT maintains that aside from the documented problem concerning the consistency and readability of the "blue" legend light indicators, the cummulative as well as individual impact of the other cited deviations is negligable. Therefore, new

• blue" indicator light lens caps will be obtained and installed that meet the checklist criteria. No other lens cape will be. changed and no "corrective action" will be taken on this non-problematic deviation.

IMPLEMENTATION ACCEPT AS IS

( hEVISED IMPLEMENTATION ACCEPT AS IS

PAGE: TER App 9nd. A3-20 1

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 215 & 283 't i HED CATEGORY 3C I FSR PAGE 250 l l

[

FINDING  !

i-Character heights on legend lights do not subtend a visual angle of 15 t cinutes.

l l

4

RESPONSE

Legend lights are read in the lit condition. The backlighting of the legende aids in readability.

1 NRC/SAIC COMMENT

The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 192, 355, 509, 510, 511, 160, 216, 283, 217, 218, 219, 220, 221, 222, and 293.

1 4

i &ECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though I admittedly not specified on each HED's response. Nonetheless,

cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned I with the apparent lack of legend light discriminability either because of l differences in lens cap color, light intensity and contrast ratios, or non

adherence to engraving specifications documented in the CECO Human Factors

) checklist. In all individual instances the deviations from the criteria l were small and of no import. Upon reevaluation the HEDAT maintains that aside from the documented problem concerning the consistency and readability of the "blue" legend light indicators, the cummulative as well as individual impact of the other cited deviations is neg11 gable. Therefore, new ' blue' l indicator light lens caps will be obtained and installed that meet the i checklist criteria. No other lens caps will be changed and no "corrective l action" will be taken on this non-problematic deviation.

1 i

i IMPLEMENTATION

j. ACCEPT AS IS REVISED IMPLEMENTATION

! CCEPT AS IS 4

l l-d h

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

PAGEt TER Append. A3-21 I

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO I

IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 217 '

HED CATEGORY 3C

.FSR PAGE 251 FINDING i Legend light type styles are not consistent throughout the control room.

RESPONSE

Character font styles on legend lights vary slightly depending on the vendor cupplier. The legend lights are readable and the different font styles do not adversely affect operator performance.

i-6 NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the ,

cumulative or interactive effect of other related HEDs. Apparently related l HEDs are numbers 192, 355, 509, 510, 511, 160, 216, 215, 283, 218, 219, 220, 221, 222, and 293.

l I

! oECO CLARIFICATION l

One of the objectives of the multidisciplined HEDAT and particularly the  !

participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were casessed. This in fact was done at the time of the original HEDAT, though cdmittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the  !

HEDs identified in the TER as related to this HED. These HEDs are concerned [

with the apparent lack of legend light discriminnbility either because of differences in lens cap color, light intensity and contrast ratios, or non  !

, adherence to engraving specificatione documented in the Ceco Human Factors t l

! checklist. In all individual instances the deviations from the criteria j were small and of no import. Upon reevaluation the HEDAT maintains that .

4 aside from the documented problem concerning the consistency and readability L

of the "blue" legend light indicators, the cummulative as well as individuel l impact of the other cited deviations is negligable. Therefore, new "blue" indicator light lens caps will be obtained and installed that meet the

! checklist criteria. No other lens caps will be changed and no "corrective action" will be taken on this non-problematic deviation. ,

I I

l IMPLEMENTATION i

] ACCEPT AS IS

! . REVISED IMPLEMENTATION l CCEPT AS IS l l  ;

1 i

l

PAGE: TER App;nd. A3-22 LASALLE STATION

(#

l' REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 218 HED CATEGORY 3C FSR PAGE 252 FINDING Legend lights on the reactor panel (on H13-P603) have white markings on black backgrounds. The guideline recommends black markings on white backgrounds. (Photo Log No. B-22)

RESPCNSE These displays are easy to read since they are backlit. A separate annunciator is in place to alert the operators to a related trip.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related MEDs. Apparently related HEDs are numbers

• 92, 355, 509, 510, 511, 160, 216, 215, 283, 217, 219, 220, 221, 222, and 293.

CECO CLARIFICATION One of the objectives of the mulsidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the >

HEDs identified in the TER as related to this HED. These HEDs are concerned with the apparent lack of legend light discriminability either because of differences in lens cap color, light intensity and contrast ratios, or non adherence to engraving specifications documented in the Ceco Human Factors checklist. In all individual instances the deviations from the criteria were small and of no import. Upon reevaluation the HEDAT maintains that aside from the documented problem concerning the consistency and readability of the "blue" legend light indicators, the cummulative as well as individual impact of the other cited deviations is negligable. Therefore, new

• blue" indicator light lens caps will be obtained and installed that meet the checklist criteria. No other lens caps will be changed and no "corrective action' will be taken on this non-problematic deviation.

IMPLEMENTATION ACCEPT AS IS OREVISED ACCEPT AS ISIMPLEMENTATION

PAGE: TER App 3nd. A3-23 O REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO LASALLE STATION l

IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 219 HED CATEGORY 3C FSR PAGE 253 FINDING -

The stroke width-to-height ratio for some legend lights is not between the recommended 116 and 1:8.

RESPONSE

The small deviation in stroke width-to-height ratios (1:4.29 - 1:11) for legend lights does not pose any difficulties in operator readability.

NRC/SAIC COMMENT .

The Justificaticn of this individual HED does not appear to consider the l cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 192, 355, 509, 510, 311, 160, 216, 215, 283, 217, 218, 220, '

221, 222, and 293.

1 CECO CLARIFICATION l l One of the ob J ectives of the multidisciplined HEDAT and particularly the  ;

participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were i assessed. This in fact was done at the time of the original HEDAT, though i

admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the apparent lack of legend light discriminability either because of differences in lens cap color, light intensity and contrast ration, or non l adherence to engraving specifications documented in the CECO Human Factors  !

checklist. In all individual instances the deviations from the criteria were small aad of no import. Upon reevaluation the HEDAT maintains that f

aside from the documented problem concerning the consistency and readability i of the "blue" legend light indicators, the cummulative as well as individual -

impact of the other cited deviations is negligable. Therefore, new "blue" ,

! indicator light lens caps will be obtained and installed that meet the

checklist criteria. No other lens caps will be changed and no "corrective i action" will be taken on this non-problematic deviation. ,

t i

IMPLEMENTATION ACCEPT AS IS  !

4 REVISED IMPLEMENTATION  !

ACCEPT AS IS ,

t e '

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

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

c PAGE:'TER Appsnd. A3-24 ;

h9 O LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE MRC'S SAFETY l EVALUATION (SE) OF THE DCRDR.,

w

,d s.

HZD # 220 NED CATEGORY 3C 1 FSR-PAGE 254  ;)

FINDING The letter ~ width-to-height-ratio for some legend lights is not between 1:1  ;

cnd 3:5.  ;

t I

RESPONSE I The small deviation in width-to-height letter ratios (1:1.83 - 1:2.71) for legend lights does not pose any difficulties in operator readability.- .  !

(N .

NRC/SAIC COMMENT l The Justification of this individual HED does not appear to consider the .

{

cumulative or interactive effect of other related HEDs. Apparently related l HEDs are numbers 192, 355, 509, 510, 511, 160, 216, 215, 283, 217, 218,3219,..;

221, 222, and 293. , "1 ECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the  !

participation of the Lead Human Factors Specialist was to ensure that  ;

cumulative and/or interactive effects were considered when HEDs were  !

assessed. This in fact was done at the time of the original HEDAT, though  !

admittedly not specified on each HED's response. Nonetheless,  ;

cumulative / interactive effects were re-evaluated by the HCDAT for the '

HEDs identified in the TER as related to this HED. These HEDs are concerned i with the apparent lack of legend light discriminability either because of j differences in lens cap color, light intensity and contrast ratios, or non adherence to engraving specifications documented in the Ceco Human Factors  !

checklist. In all individual instances the deviations from the criteria j were small and of no import. Upon reevaluation the HEDAT maintains that i aside from the documented problem concerning the consistency and readabil:lty

~

[

of the "blue' legend light indicators, the cummulative as well as individual f impact of the other cited deviations is negligable. Therefore, new

• blue"  ;

indicator light lens caps will be obtained and installed that meet the checklist criteria. No other lens caps will be changed and no "corrective (

action" will be taken on this non-problematic deviation. 1 IMPLEMENTATION ACCEPT AS IS EVISED IMPLEMENTATION  :

Q=CCEPTASIS i i

e

~ ~~ " ^ " ^ ~^

g ' f .. ' 3 ;, ' ~ ~

^-

o 4 ,

PAGE: TER; Append. A3-25 . ,

6 1 (h LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO ,

IN THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

i HED # 221 i HED CATEGORY 3C iFSR PAGE 255 e , <

1 FINDING The space between characters of legend lights is not the recommended minimum

M' of one stroke-width. a LV RE5PONSC The small deviation in space between characters for legend lights (.0030 -

inches),does not pose any difficulties in operator readability. i

-b a

NRC/SAIC COMMENT '

-The Justification of this individual HED d.aes not appear to consider the i cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 192, 355, 509, 510, 511,p.60,'216, 215, 283, 217, 218, 219, 220, 222, and 293.

^O i

f

~

~-4ECO CLARIFICATION  :

One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factorn Specialist.vas to ensure that  ;

j. cumulative and/or interactive effects were considered when HEDs were l assessed. This in fact was done at the time of the criginal HEDAT, though  !

admittedly not specifiedion each HED's responsq. ,Menetneless, '

cumulative / interactive effects were re-evaluated by the WEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned ,

with the apparent lack of legend. light discriminability either because of  !

differences in lens cap color, . light intoontty and centrast ratios, or non adherence to engraving specifications documented in the Ceco Human Factors i checklist. In all individual instances the deviations from the criteria i were small and of no import. -Upon reevaluation tho.NEDAT mainteins that i aside from the documented problem concerning the' consistency wed readability .

of the "blue" legend light indicatorn, the cunanistive as well as individual [

I impact of the other cited deviations se negligable. Therefore, new

• blue" l indicator light lens caps will be obtained and installed that meet the  !

checklist criteria. No other lens caps will be~ changed and no "corrective {

action" will be taken on this non-problematic deviation.  ;

I l IMPLEMENTATION (

ACCEPT AS IS  :

. i l REVISED IMPLEMENTATION i

! %CCEPT AS IS

_ {

I l 1  !

i  !

l  ;

l

+

_ __ ___ _ _ _ .. . _ _ ... _ _ _ - . _ _ . __-.i

PAGE: TER Appand. A3-26

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 222 HED CATEGORY 3C

.FSR PAGE 256 FINDING The minimum space between lines on some legend lights is not at least or.e half the character height.

RESPONSE

The small deviation (.15 irches) in space between characters for legend lights does not pose any difficulties in operator readability.

HRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 192, 355, 509, 510, 511, 160, 216, 215, 283, 217, 218, 219, 220, 221, and 293.

CECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the apparent lack of legend light discriminability either because of differences in lens cap color, light intensity and contrast ratios, or non adherence to engraving specifications documented in the CECO Human Factors checklist. In all individual instances the deviations from the criteria were small and of no import. Upon reevaluation the HEDAT maintains that aside from the documented problem concerning the consistency and readability of the "blue" 1cgsnd light indicators, the cummulative as well as individual impact of the other cited deviations is negligable. Therefore, new "blue" indicator light lens caps will be obtained and installed that meet the checklist criteria. No other lens caps will be changed and no "corrective action" will be taken on this non-problematic deviatica.

l IMPLEMENTATION ACCEPT AS IS l

j ACCEPT AS IS OREVISEDIMPLEMENTATION

PAGE: TER Appand. A3-27

()

LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 293 HED CATEGORY 3C FSR PAGE 257 FINDING Legend mesJhges on some legend light indicators contain more than three lines of text. (Photo Log No. H-11, H-12)

RESPONSE

Each legend line on legend lights (except for those on the reactor panel) contains one word (or abbreviation) and are easily readable to the operators in a timely manner. Typically, on the reactor panel, one light cover may house two status lights - each light with its own legend.

NP.C/SAIC COMMENT The Justification of th!.s individual HED does not appear to consider the cumulative or interactjve effect of other related HSDs. Apparently related HEDs are numbers 192,.355, 509, 510, 511, 160, 216, 215, 283, 217, 218, 219, 220, 221 and 222.

CECO CLARIFICATION One of the ob]ectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure +. hat cumulative and/or interactive effects were considered when HEDs were assassed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the apparent lack of legend light discriminability either because of differences in lens cap color, light intensity and contrast ratios, or non adherence to engraving specifications documented in the CECO Human Factors checklist. In all individual instances the deviations from the criteria were small and of no import. Upon reevaluation the HEDAT maintains that aside from the documented problem concerning the consistency and readability of the "blue" legend light indicators, the cummulative as well as individual impact of the other cited deviations is negligable. Therefore, new "blue" indicator light lens caps will be obtained and installed that meet the checklist criteria. No other lens caps will be changed and no "correcttve action" will be taken on this non-problematic deviation.

IMPLEMENTATION ACCEPT AS IS O REVISED IMPLEMENTATION ACCEPT AS IS

i l

l l

O HED # 305 HED CATEGORY 3C FSR-PAGE 319 Referenced on Page: TER Append. A2-17, A2-18 lO l

l O

j

PAGE: TER Appsnd. A3-28

^

,~

(\) LASALLB STATION REVISED PESPONSE/ CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 504 HED CATEGORY 3C FSR PAGE 320 FINDING The mimie lines depicting nuclear steam are not the same throughout the control room. On N62-P601, nuclear steam is mimicked in black; on H13-P601 it is mimicked in red.

RESPONSE

The black nuclear steam mimic on N62-P601 will be replaced with a red mimic to provide consistent use of color.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the

, cumulative or interactivo effect of other related HEDs. Apparently related HEDs are numbers 305, 178, and 306.

l

\

dECOCLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Menetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the tpparent lack of consistency in the use of colors on the mimics as well as the apparent lack of sufficient contrast between the colors used. Mimics are used on the cited panels as an operator aid. The HEDAT therefore feels that appropriate and consistent use of color on them is important. Consequently, mimics will be evaluated by a Human Factors Engineering specialist and an Operations reprasentative to ensure their accurracy and to develop a censistent mimic color standard for use at the station that will be in consonance with the station's color useage standard.

dinic size and use of symbcis will also be standardized. This will be accomplished in concert and coordinatic: with the background shading and lines of demarcation programs IMPLEMENTATION iST REFUELING OUTAGE C,REVISEDIMPLEMENTATION 2ND REFUELING OUTAGE l

l .

l . .__ _

i l

PAGE: TER App nd. A3-29  !

l

,m

(_). LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 178 HED CATEGORY 3C FSR PAGE 321 FINDING The arrows indicating flow directions for the containment monitoring and leak detection mimic on PM16J are not clearly marked. They are too small and are poorly contrasted with the mimic colors. (Photo Log No. H-21)

RESPONSE

The arrows on the containment monitoring and leak detections mimic will be painted white to improve the contrast.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 305, 504, and 306.

DCECO CLARIFICATION One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were asaessed. This in fact was dene at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effec'.s were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned l with the apparent lack of consistency in the use of colors on the mimics as well as the apparent lack of sufficient contrast between the colors used. Mimics are used on the cited panels as an operator aid. The HEDAr therefore feels that appropriate and consistent use of color on them is important. Consequently, mimics will be evaluated by e Human Factors Engineering specialist and an Operations representative to ensure their accurracy and to develop a consistent mimic color standard for use at the I station that will be in consonance with the station's color useage standard.

l Mimic size and use of symbols will also be standardized. This will be accemplished in concert and coordination with the background shading and lines of demarcation programs.

l IMPLEMENTATION iST REFUELING OUTAGE sREVISED IMPLEMENTATION

! ND REFUELING CUTAGE l

PAGE: TER Appand. A3-30 t LASALLE STATION

,/

REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 306 HED CATEGORY 3C FSR PAGE 326 FINDING Symbols on mimics are not used consistently.

RESPONSE

Control room operators are aware of mimic symbols. The symbols have caused no confusion for the operators.

NRC/SAIC COMMENT The Justific-tion of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 305, 504, and 178.

l f'CECOCLARIFICATION) One of the objectives of the multidisciplined HEDAT and part participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response. Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the apparent lack of consietency in the use of colors on the mimics as well as the apparent lack of sufficient contraat between the colors used. Mimics are used on the cited panels as an operator aid. The HEDAT therefore feels that appropriate and consistent use of color on them is important. Consequently, mimics will be evaluated by a Human Factors Engineering specialist and an Operations representative to ensure their accurracy and to develop a consistent mimic color standard for use at the station that will be in consonance with the station's color useage standard.

Mimic size and use of symbols will also be standardized. This will be accomplished in concert and coordination with the background shading and lines of demarcation programs.

[

IMPLEMENTATION ACCEPT AS IS (O _,2EVISED IMPLEMENTATION 2ND REFUELING OUTAGE

PAGE: TER App 2nd. A3-31 bi LASALLE STATION

( ) REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 237 HED CATEGORY 2C FSR PAGE 344 FINDING Complex symbols for the benchboard CRTs have seven picture elements per oymbol height.

RESPONSE

Complex symbols are readable to the operators. The small deviation from the guidelines does not affect performance.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 240, 309, 308, 128, 130 and 131.

O'ECO CLARIFICATION The following response addresses seven HEDs the NRC felt to be related (see the NRC/SAIC Comment above). The HEDAT upon evaluation of these HEDs feels they are peripherally related at best. Four of the HEDs deal with CRT hardware issues while three deal with color graphic software issues, i.e.,

consistent use of color. One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response.

Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the readability / comprehensibility and use of color of the control room computer CRT displays. The following commants relate to the HEDAT's reevaluation of the CRT hardware issues while the final paragraph is concerned with the use of color issues. Though the CRTs in use at LaSalle are of graphic quality, they do not contain the amount of picture elements per square inch suggested by the CECO guidlines and NUREG 0700 for the display of Complex shapes. The HECAT maintains that "complex" shapes are not presented on the control room CRTs and hence there is no need to, "distinguish between them". Consequently, the current CRTs are adequate.

n U

PAGE: TER Appsnd. A3-32

("%

Concerning the issue of use of color, LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes an "Abnormal" condition when the unit is above 30% power. The CECO computer display conventions currently do not use green board coding, which in part accounts for the cited discrepancies.

The feasibility of using green board coding for the computer graphics is being explored at CECO's Byron PWR station. Several displays have been modified and their use is being evaluated. One problem is that green board coding does not provide for indication of equipment status beyond normal / abnormal, for example, open/ closed, on/off, etc. Resolutions to this problem are being evaluated at the station. When the "green board convention" computer graphics problems have been successfully resolved, that convention will be implemented at LaSalle if feasable.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

O

. l

PAGE: TER Appand. A3-33

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THl DCRDR.

HED # 240 HED CATEGORY 2C FSR PAGE 345 FINDING Alpha-numeric characters for the benchboard terminale have 5 picture olements per character height, which is less than the recommended 10.

RESPONSE' Alpha-numeric charactees on the CRTs are readable to the operators. The deviation from the guidelines does not affect performance.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 237, 309, 308, 128, 130 and 131.

OPECO The fo). CLARIFICATION lowing response addresses seven HEDs the NRC felt to be related (see c the NKS'SAIC Comment above). The HEDAT upon evaluation of these HEDs feels they .T peripherally related at best. Four of the HEDs deal with CRT hardwar.e issues while three deal with color graphic software issues, i.e.,

consistent use of color. One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors '

Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in-fact was done at the time of the original.HEDAT, though admittedly not specified on each HED's rempor,se. '

Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this'HED. These HEDs are concerned with the readability / comprehensibility and use of color of the i control room computer CRT displays. The following comments relate to the i

HEDAT's reevaluation of the CRT hardware issues while the final paragraph is concerned with the use of color issues. Though the CRTs in use at LaSalle are of graphic quality, they do not contain the amount of picture elements per square inch suggested by the CECO guidlines and NUREG 0700 for the display of Complex shapes. The HEDAT maintains that "complex" shapes are i not presented on the control room CRTs and hence there is no need to, "distinguish between them". Consequently, the current CRTs are adequate.

Nonetheless, it is recognized that the control room environment and its

.needs are dynamic, as are the technological advancements in "picture presentation", eg. CRTs vs. LCDs. As equipment reaches its service life and is replaced further evaluations will be made to determine whether the At such times CECO O resolution qualitytoofadhere the CRTs needs to be criteria.

upgraded.

will endeavor to the published t

-. --,n._, -_n, , - - , _ , , _ - _ _ -

PAGE: TER Append. A3-34

/O G Concerning the issue of use of color, LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes an "Abnormal" condition when the unit is above 30% power. The CECO computer display conventions currently do not use green board coding, which in part accounts for the cited discrepancies.

The feasibility of using green board coding for the computer graphics is

- being explored at CECO's Byron PWR station. Several displays have been modified and their use is being evaluated. One problem is that green board coding does not provide for indication of equipment status beyond normal / abnormal, for example, open/ closed, on/off, etc. Resolutions to this problem are being evaluated at the station. When the "green board convention" computer graphics problems have been successfully resolved, that convention will be implemnted at the LaSalle Station if feasible.

IMPLEMENTATION ACCEPT AS IS REVISED !dPLEMENTATION 2ND RF?UELING OUTAGE O

O I

PAGE: TER Appand. A3-35

.p) i LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO

7. THE NRC'S SAFETY EVALUATION (SE) 0F THE DCRDR.

l HED # 309 HED CATEGORY 2C FSR PAGE 350 FINDING Fifty resolution elements / inch are not used for graphics displays on CRTs as recommended by the guidelines.

RESPCHSE High resolution graphics are not required for the type of graphical information used in the control room.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 237, 240, 308, 128, 130 and 131.

hl:ECOCLARIFICATION

%/ The following response addresses seven HEDs the NRC felt to be related (see the NRC/SAIC Comment above). The HEDAT upon evaluation of these HEDs feels they are peripherally related at best. Four of the HEDs deal with CRT hardware issues while three deal with color graphic software issues, ie.,

consistent use of color. One of the ob]ectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of l

the original HEDAT, though admittedly not specified on each HED's response.

Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the readability / comprehensibility and use of color of the control room computer CRT displays. The following comments relate to the HEDAT's reevaluation of the CRT hardware issues while the final paragraph is concerned with the use of color issues. Though the CRTs in use at LaSalle are of graphic quality, they do not contain the amount of picture elements l per square inch suggested by the CECO guidlines and NUREG 0700 for the display of Complex shapes. The HEDAT maintains that "Complex" shapes are not presented on the control room CRTs and hence there is no need to,

"distinguish between them". Consequently, the current CRTs are adequate.

O l .

PAGE: TER Appand. A3-36

%) Concerning the issue of use of color, LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes an "Abnormal" condition when the unit is above 30% power. The CECO computer display conventions currently do not use green board coding, which in part accounts for the cited discrepancies.

The feasibility of using green board coding for the computer graphics is being explored at CECO's Byron PWR station. Several displays have been modified and their use is being evaluated. When the "green board convention" computer graphics problems have been successfully resolved, that convention will be implemented at LaSalle if feasible.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE

, O I

PAGE: TER Appand. A3-37

) LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 308 HED CATEGORY 2C FSR PAGE 351 FINDING A 5x7 dot matrix is used for characters on CRTs instead of a 7x9 dot matrix.

RESPONSE

The difference in legibility in the control room operating environment between the 5x7 and 7x9 dot matrix is minimal. The operators report no difficulty in reading CRT characters.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other related HEDs. Apparently related HEDs are numbers 237, 240, 309, 128, 130 and 131.

l

• ECO CLARIFICATION l

(/

%- The following response addresses seven HEDs the NRC felt to be related (see l the NRC/SAIC Comment above). The HEDAT upon evaluation of these HEDs feels j they are peripherally related at best. Four of the HEDs deal with CRT hardware issues while three deal with color graphic software issues, ie.,

consistent use of color. One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of the original HEDAT, though admittedly not specified on each HED's response.

, Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT l for the HEDs identified in the TER as related to this HED. These HEDs are

! concerned with the readability / comprehensibility and use of color of the l

control room computer CRT displays. The following comments relate to the HEDAT's reevaluation of the CRT hardware issues while the final paragraph is concerned with the use of color issues. Though the CRTs in use at LaSalle are of graphic quality, they do not contain the amount of picture elements per square inch suggested by the CECO guidlines and NUREG 0700 for the display of Complex shapes. The HEDAT maintains that "Complex" chapes are not presented on the control room CRTs and hence there is no need to, "distinguish between them". Consequently, the current CRTs are adequate.

O

f PAGEt TER Appsnd. A3-38 O Concerning the issue of use of color, LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes an "Abnormal" condition when the unit is above 30% power. The CECO computer display conventions currently do not use green board coding, which in part accounts for the cited discrepancies.

The feasibility of using green board coding for the computer graphics is being explored at CECO's Byron PWR station. Several displays have been modified and their use is being evaluated. One problem is that green board coding does not provide for indication of equipment status beyond normal / abnormal, for example, open/ closed, on/off, etc. Resolutions to this problem are being evaluated at the station. When the "green board convention" computer graphics problems have been successfully resolved, that convention will be implemented at LaSalle Station if feasible.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

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HED # 128 HED CATEGORY 2C FSR-PAGE 352 Referenced on Page: TER Append. A2-25, A2-26 i

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O HED # 130 HED CATEGORY 2C FSR-PAGE 353 Referenced on Page: TER Append. A2-27, A2-28 O

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PAGE: TER Appsnd. A3-39

() LASALLE STATION REVISED RESPONSE / CLARIFICATION TO HEDS REFERRED TO IN THE NRC'S SAFETY EVALUATION (SE) OF THE DCRDR.

HED # 131' HED CATEGORY 2C FSR PAGE 354 FINDING The color yellow is used in CRT displays for lettering outlines and point ids. According to criteria, yellow should be used to indicate hazard, potentially unsafe, caution, attentien required or that a marginal parameter value exists.

RESPONSE

Yellow was used for lettering outlines and point ids because of its high contrast and readability.

NRC/SAIC COMMENT The Justification of this individual HED does not appear to consider the cumulative or interactive effect of other reluted HEDs. Apparently related HEDs are numbers 237, 240, 309, 308, 128 and 130.

l CECO CLARIFICATION The following response addresses seven HEDs the NRC felt to be related (see the NRC/SAIC Comment above). The HEDAT upon evaluation of these HEDs feels they are peripherally reisted at best. Four of the HEDs deal with CRT hardware issues while three deal with color graphic software issues, ie.,

consistent use of color. One of the objectives of the multidisciplined HEDAT and particularly the participation of the Lead Human Factors Specialist was to ensure that cumulative and/or interactive effects were considered when HEDs were assessed. This in fact was done at the time of j the original HEDAT, though admittedly not specified on each HED's response. >

i Nonetheless, cumulative / interactive effects were re-evaluated by the HEDAT for the HEDs identified in the TER as related to this HED. These HEDs are concerned with the readability / comprehensibility and use of color of the control room computer CRT displays. The following comments relate to the HEDAT's reevaluation of the CRT hardware issues while the final paragraph is concerned with the use of color issues. Though the CRTs in use at LaSalle are of graphic quality, they do not contain the amount of picture elements per square inch suggested by the CECO guidlines and NUREG 0700 for the l display of Complex shapes. The HEDAT maintains that "Complex" shapes are not presented on the control room CRTs and hence there is no need to, "distinguish between them". Consequently, the cirrent CRTs are adequate.

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PAGE: TER App 9nd. A3-40 1

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Concerning the issue of use of color, LaSalle station adheres to a green board color coding convention in which the color "green" denotes a "Normal" condition and the color "red" denotes an "Abnormal" condition when the unit is above 30% power. The CECO computer display conventions currently do not use green board coding, which in part accounts for the cited discrepancies.

The feasibility of using green board coding for the computer graphics is being explored at CECO's Byron PWR station. Several dioplays have been modified and their use is being evaluated. One problem is that green board coding does not provide for indication of equipment status beyond normal / abnormal, for example, open/ closed, on/off, etc. Resolutions to this problem are being evaluated at the station. When the "green board convention" computer graphics problems have been successfully resolved, that convention will be implemented at LaSAlle if feasible.

IMPLEMENTATION ACCEPT AS IS REVISED IMPLEMENTATION 2ND REFUELING OUTAGE O

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CROSS-REFERENCE INDEX

(-~q HED.INDEX No. Page 8_ TER Append. Al- 2 10 SER Encl. 1- 8 13 SER Encl. 1- 1 20 SER Encl. A- 1 24 TER Append. A3-13 40 SER Encl. A-16 46 SER Encl. A-21 58 TER Append. A2-34 69 SER Encl. 1- 6 87 SER Encl. A-14 93 TER Append. A2-29 112 TER Append. A3-16 115 SER Encl. A-11 118 SER Encl. 1- 9 119 TER Append. A2-16 120 SER Encl. 1-10 124 TER Append. A2-22 125 TER Append. A2-23 128 TER Append. 42-24 130 TER Append. A2-26 131 TER Append. A3-39 132 TER Append. Al- 5 O 141 144 146 TER SER TER Append. A2- 6 Encl. 1-11 Append. A2- 7 3

152 SER Encl. 1-12 160 TER Append. A2-12 162 SER Encl. 1-13 163 TER Append. A2-11 178 TER Append. A3-29 181 TER Append. A2- 8 192 TER Append. A3-17

, 193 TER Append. A2- 3 195 TER Append. A2- 4 200 SER Encl. A- 8 201 SER Encl. A- 9 202 SER Encl. A-10 204 SER Encl. A- 7 1 206 SER Encl. 1- 3 3

215 TER Append. A3-20 i 216 TER Append. A3-19 217 TER Append. A3-21 l 218 TER Append. A3-22  !

219 TER Append. A3-23 l 220 TER Append. A3-24 1 221 TER Append. A3-25 222 TER Append. A3-26 235 SER Encl. A-15 I

O 237 TER Append. A3-31 I-1

{

A CROSS-REFERENCE INDEX

'\,

HED INDEX# Page #

240 TER Append. A3-33 248 SER Encl. A- 4 252 TER Append. A2-33 260 SER Encl. A- 3 286 SER Encl. A-13 289 TER Append. A3-15 293 TER Append. A3-27 297 SER Encl. A-16 301 TER Append. A2- 5 305 TER Append. A2-17 306 TER Append. A3-30 308 TER Append. A3-37 309 TER Append. A3-35 313 SER Encl. 1- 5 341 SER Encl. 1- 4 343, TER Append. A2-19 344 TER Append. A2-10 361 TER Append. A2-30 367 TER Append. A2-31 375 TER Append. Al- 1 376 SER Encl. A-20 398 SER Encl. A-12 O 412 414 415 TER TER TER Append. Al- 4 Append. A2-20 Append. A2-21 426 TER Append. A2-28 428 TER Append. A3- 2 429 TER Append. A3- 1 456 TER Append. A2-14 463 TER Append. A2- 1 468 SER Encl. A- 2 473 TER Append. A2-36 482 TER Append. A2-32 495 SER Encl. A- 6 498 SER Encl. A- 5 504 TER Append. A3-28 507 TER Append. Al- 3 509 TER Append. .13-18 530 TER Append. A2-39 532 TER Append. A2-37 533 TER Append. A2-15 538 TER Append. A3- 5 543 TER Append. 42-35 550 TER Append. A2-38 561 TER Append. A3- 7

562 TER Append. A3- 9 563 TER Append. A3-11 I-2 l

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