ML20199F515

Revised Human Factors Engineering Dcrdr Technical Evaluation Rept for Beaver Valley Power Station Unit 2

ML20199F515
Person / Time
Site:	Beaver Valley
Issue date:	03/28/1986
From:	Johnson G, Johari Moore LAWRENCE LIVERMORE NATIONAL LABORATORY
To:	Eckenrode D NRC
Shared Package
ML20199F520	List: ML20199F515 ML20203G227 ML20203G237
References
NUDOCS 8604010214
Download: ML20199F515 (14)

Text

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i IlUMAN FACTORS ENGINEERING DETAILED CONTROL ROOM DESIGN REVIEW TECIINICAL EVALUATION REPORT FOR DUQUESNE LIGIIT COMPANY BEAVER VALLEY POWER STATION UNIT 2 l

James W. Moore 4

Gary L. Johnson Lawrence Livermore National Laboratory March 28,1986 l

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TABLE OF CONTENTS

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1. Background ...................................................... 1

2. Assessm ent o f D C R DR Ac tivi ties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.1 D C R D R R e view Tea m . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.1.1 R e qui re m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.1.2 D is c ussi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.1.3 C o ncl usi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.2 Function and Task Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.2.1 R e q ui re m e nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.2.2 D is c ussi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.2.3 C o ncl usi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3 Comparison of Control and Display Requirements With a Co nt rol R oo m In ve nt o ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.1 R e qui re m e nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.2 D is c ussi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.3 C o ncl usi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.4 Co nt rol Room Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.4.1 R e qui re m e nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.4.2 D is c us si o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.4.3 Co ncl usi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.5 Assessm ent o f II E Ds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.5.1 R e qui re m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.5.2 D is c ussi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.5.3 C o ncl usi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 2.6 Selection of Design Improvements ............................. 7 2.6.1 R e q ui re m e nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 2.6.2 D is c ussi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 2.6.3 Co ncl usi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 2.7 Verification that Design Improvements Provide  :

Necessary Correction and Do Not Introduce New IIEDs . . . . . . . . . . . 8 j 2.7.1 R e q u i re m en t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 j 2.7.2 D i s c ussi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 J

2.7.3 C o n cl us i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2. 8 Coordination of the DCRDR With Other Programs . . . . . . . . . . . . . . . 9 2.8.1 R e qu i re m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.8.2 D is c us si o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.8.3 C o nc l usi o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

3. Summary........................................................ 9

4. R e f er e n c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

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HUMAN FACTORS ENGINEERING DETAILED CONTROL ROOM DESIGN REVIEW TECIINICAL EVALU ATION REPORT FOR DUQUESNE LIGHT COMPANY BEAVER VALLEY POWER STATION UNIT 2 i

1. BACKGROUND Licensees and applicants for operating licenses shall conduct a Detailed Control Room Design Review (DCRDR). The objective is to " improve the ability of nuclear power plant control room operators to prevent accidents or cope with accidents if they occur by improving the information provided to them" (NUREG-0660, Jtem I.D.1). 2 The need to conduct a DCRDR was confirmed in NUREG-0737 and Supplement 1 to NUREG-0737. I DCRDR requirements in Supplement 1 to N UREG-0737 replaced those in earlier documents. Supplement 1 to NUREG-0737 requires each applicant or licensee to conduct a DCRDR on a schedule negotiated with the Nuclear Regulatory Commission (NRC).

N UREG-0700 3 describes four phases of the DCRDR and provides applicants and licensees with guidelines for its conduct. The phases are:

1. Planning

2. Review

3. Assessment and Implementation

4. Reporting NUREG-0800 Section 18.1 5 provides additional guidance to be used in developing and evaluating DCRDR programs.

Supplement i to NUREG-0737 requires that the DCRDR include the following elements:

1. Establishment of a qualified multidisciplinary review team.

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

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

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

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

6. Selection of design improvements.

! 7. Verification that selected design improvements will provide the necessary correction and do not introduce new HEDs.

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8.- Coordination of control room improvements with changes from other programs such as the safety,. parameter display system (SPDS), operator training, Reg. Guide 1.97 ** Instrumentation, and upgraded emergency operating

! procedures (EOPs).

Licensees are expected to complete Element 1.during the DCRDR's planning phase,

, Elements 2 through 4 during the DCRDR's review: phase, and Elements 5 through 7 during the DCRDR's assessment and implementation phase. Completion of Element 8 is expected to cut across the planning, review, and assessment and implementation phases.

A summary report is to be submitted at the end of the DCRDR. As a minimum it shall: i

1. Outline proposed control room changes.

2. Outline proposed schedules for implementation.

3. Provide summary justifi$ation.for IIEDs with safety significance to be left j uncorrected or partially corrected.

The NRC staff evaluates the organization, process,' and results of the DCRDR. Results of the evaluation are documented in a Safety Evaluation Report (SER) published within l two months after receipt of the Summary Report.

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, 2. ASSESSMENT OF DCRDR ACTIVITIES 4

Duquesne Light Company's (DLC) DCRDR Summary Report for the Beaver Valley Power Station Unit 2 13 was submitted on December 2,1985. The NRC staff conducted a preimplementation audit of the Beaver Valley Power Station DCRDR February 11 and 12, 1986. The evaluation of the Beaver Valley Power Station Unit 2 DCRDR provided in this TER is based on review of the Summary Report and on documentation reviewed and discussions conducted during the on-site audit.

Based on our review of the BVPS 2 Summary Report, we agree that DLC has satisfied certain requirements of Supplement 1 to NUREG-0737. In addition, DLC demonstrated

{ that methodologies previously accepted by the' NRC had been successfully implemented.

Therefore, discussions at the preimplementation audit were limited to elements of the

DCRDR which we did not fully understand or agree with based upon the information provided in the BVPS 2 Summary Report.- The following is a list of the topic areas discussed during the preimplementation audit

o Control Room Survey o Assessment of IIEDs o Selection of Design Improvement o Verification Process for Determining that Design Improvements Provide the I Necessary Correction and Do Not Introduce New IIEDs J

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Since the BVPS is a multiunit, control room brief discussions were held concerning the relationship between the BVPS Unit 1 and 2 DCRDR efforts. These two efforts have essentially been performed independently. There is, however, an effort underway to standardize conventions (e.g., labeling, location aids, abbreviations) used in both units.

Additionally, BVPS 1 and 2 did swap IIEDs identified by each unit's DCRDR and review them for applicability to the respective units. There was no attempt by Duquesne Light Company to make the control rooms at BVPS identical as operators will be licensed on only one unit, thus eliminating the need for identical control rooms.

During the preimplementation audit, the NRC review team identified a number of open items, incomplete items, and possible problem areas in the BVPS 2 DCRDR. These items will be discussed in detail in later sections of this report. Ilowever, it should be noted that Duquesne Light Company will need to respond to these items in a supplemental summa ~y report at least 120 days prior to fuel load.

2.1 DCRDR REVIEW TEAM 2.1.1 Requirement Supplement 1 to NUREG-0737 requires the establishment of a qualified multidisciplinary review team to conduct a DCRDR. Guidelines for review team selection are found in 4 N UR EG-0700, and Appendix A to Section 18.1 of the Standard Review Plan, N UREG-0800.

2.1.2 Discussion The qualifications of the review team members and level of involvement in DCRDR review tasks had previously been found acceptable by the NRC in the Beaver Valley Power Station Unit 2 In-progress Audit Report,14 dated August 23, 1984. The DCRDR Summary report documents that the actual review team composition and level of involvement is consistent with that previous acceptance.

2.1.3 Conclusion The DCRDR team members have the necessary qualifications and multidisciplinary participation in review tasks to satisfy the requirements of Supplement 1 to NUREG-0737, 2.2 FUNCTION AND TASK ANALYSES 2.2.1 Requirement Supplement 1 to NUREG-0737 requires the applicant to perform a function and task analyses to identify control room operator tasks and to identify control room operator information and control needs during emergency operations. Supplement 1 to NUREG-0737 recommends the use of function and task analyses that have been used as the basis for developing emergency operating procedures technical guidelines and plant-specific emergency operating procedures to define these needs.

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2.2.2 Discussion The NRC had previously reviewed and found acceptable the process and methodology for conducting the BVPS 2 System Review and Task Analysis (SRTA) during the Beaver Valley Power Station Unit 2 In-Progress Audit.

4 DLC's description of the SRTA process and methodology contained in the Summary

, Report included samples of working documents used in the SRTA. These documents appeared to be acceptable and provided an acceptable auditable paper trail.

! 2.2.3 Conclusion 2 The BVPS 2 Summary Report demonstrated that DLC has successfully implemented the methodology for the DCRDR SRTA which was previously accepted by the NRC.

2.3 COMPARISON OF CONTROL AND DISPLAY REQUIREMENTS WITH A CONTROL ROOM INVENTORY 2.3.1 Requirement Supplement 1 to NUREG-0737 requires the applicant to make a control room inventory and to compare the operator display and control requirements determined from the task analyses with the control room inventory to determine missing controls and displays, i Guidance in NUREG-0700 also calls for a review of the human factors suitability of instruments and controls used to satisfy operator information and control requirements.

1 2.3.2 Discussion The comparison of control and display requirements with a control room inventory was reviewed by the NRC during the BVPS 2 In-Progress Audit and found to be acceptable as reported in the BVPS 2 In-Progress Audit Report, dated August 23, 1984.

2.3.3 Conclusion In reviewing the BVPS 2 Summary Report, we conclude that DLC has acceptably implemented the inventory process previously found acceptable by the NRC.

2.4 CONTROL ROOM SURVEY 2.4.1 Requirement Supplement 1 to NUREG-0737 requires that a control room survey be conducted to identify deviations from accepted human fact 6rs principles. NUREG-0700 provides 7

guidelines and criteria for conducting a control room survey.

2,4.2 Discussion BVPS 2 has executed the DCRDR control room survey through the use of a photo mock-up of the control boards and the actual control boards. The checklist used by the DCRDR review team was based on Section G of NUREG-0700. The survey process is t

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generally sound and well documented. During the preimplementation audit the NRC review team conducted a minisurvey in the control room to check the survey process.

While conducting the. minisurvey, the NRC review team identified a few items that were not identified by the BVPS 2 control room survey. The following is a list of these items:

o Meter character size on vertical control boards. There are two different sizes of characters on the display faces of these meters. The problem is more acute on displays with characters of the smaller size. The scale units size on these ,

displays is also a problem.

o A control display integration problem exists on vertical control board

, Section C Extraction Steam portion control / status light panel. The problem involves the controls and indicators for the Extraction Steam Isolation Valves, the Main Steam Drain Isolation Valves, and Feedwater Heater Isolation Valves.

o No lamp test or check procedure exists for single indicator lights with single filament bulbs. i o Lighted pushbuttons cannot be distinguished from light indicators on the Turbine Control Panel.

o Lack of a system to ensure annunciator tiles removed for maintenance or bulb replacement will be restored to the proper location, o Lack of coding between Trip and Reset switches for SI, CIS, and Reactor, o Inconsistent use of nomenclature between meter faces, control board labels, and procedures for steam generator instrumentation.

There are a number of survey items that BVPS 2 has indicated have yet to be I completed. These items are identified in the BVPS 2 Summary Report. The following is  ;

a list of survey sections that are not yet completed:

o Work space ,

o Emergency Equipment o IIVAC o Illumination o Noise o Maintainability i o Communications o Annunciators o Computer Systems m , - .--

I I With the exception of the llVAC, illumination and noise surveys, DLC intends to

. complete these items prior to fuel load. The three exceptions are to be delayed until af ter the completion of start-up testing and fuel load so that these surveys will not be i biased by the unique control room conditions that typically exist during an initial startup.

i Along with the survey sections yet to be completed are some survey sections which contain many checklist items that have yet to be evaluated (i.e., unable to assess items) because, at the time of the survey, control room construction was not sufficiently

complete to allow review of these items.

2.4.3 Conclusion Based upon review of the Beaver Valley Power Station 2 Summary Report and discussions i at tne preimplementation audit, we find the BVPS 2 DCRDR survey to be generally adequate and performed in a systematic manner. However, the NRC review team noted a few IIEDs during the preimplementation audit that were not recorded as part of the BVPS 2 survey process. These items were due either to differences in judgment between DLC and the NRC review team or isolated errors during the survey. We do not feel the items identified by the NRC review team are indicative of a systematic problem with DLC's survey process.

Due to the numcrous NUREG-0700 checklists and checklist items that have not yet been i completed, a final determination of the survey acceptability cannot be made. With the three exceptions noted above, all incomplete survey sections must be completed prior to fuel load and the results of these surveys reported in detailin the supplemental summary report. The supplemental summary report must also describe DLC's plans and provide DLC's schedule commitment for completing the control room survey with regards to the three sections to be deferred until after fuel load. Remote shutdown locations (e.g.,

emergency shutdown panel and alternate shutdown panel) as well as the control room should be included in these surveys. In addition, DLC should respond in the supplemental

, summary report to those survey items that the NRC review team identified during the minisurvey conducted at the preimplementation audit.

1 2.5 ASSESSMENT OF llEDs 2.5.1 Requirement i Supplement 1 to NUREG-0737 requires that HEDs be assessed to determine which IIEDs

are significant and should be corrected.

. 2.5.2 Discussion The DVPS 2 assessment process had been previously found to adequate by the NRC during l the in-progress audit. However, during our summary report review of the assessment process we identified a number of items for which we did not understand the assessment or did not expect to agree with the proposed resolution. Each of these items was I

reviewed during the preimplementation audit and with few exceptions the audit team agreed with DLC's assessment when considered in the context of the BVPS 2 control room hardware. The exceptions are:

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, o Annunciator Prioritization. One of the primary purposes of alarm systems is to attract the attention of operators to a condition that they could overlook unless alerted by an alarm. The BVPS 2 control room contains a large number of annunciators. In discussing the annunciator system at the preimplementation audit the NRC audit team discovered that the BVPS 2 Control Room does not have a formal prioritization scheme for annunciators.

i In our opinic,n, it is essential to prioritize annunciators to permit operators to direct their attention to high priority alarms during emergency situations. We recommend DLC reassess annunciator prioritization in the BVPS 2 control room.

! o Lack of Targets on alternate shutdown panel (ASP) and emergency shutdown panel (ESP) Control Switches. DLC assessment missed the fact that this IIED is an artifact of a procedure error that required a number of operator actions which accomplish nothing. DLC needs to correct the procedures.

2.5.3 Conclusion Based on our review of the BVPS 2 Summary Report and preimplementation audit discussions we generally agree that the DCRDR assessment process is adequate.

liowever, until the exceptions noted in the above discussion are addressed in the supplemental summary report we cannot make a final determination that the DCRDR assessment process is in compliance with the requirements of Supplement 1 to N UREG-0737, 2.6 SELECTION OF DESIGN IMPROVEMENTS 2.6.1 Requirement Supplement I to NUREG-0737 requires the selection of control room improvements that will correct significant IIEDs. It also states that improvements that can be accomplished with an enhancement program should be done promptly.

2.6.2 Discussion During our review of the BVPS 2 Summary Report we identified a number of proposed improvements which we did not fully understand based on the information provided in the summary report. Discussions at the preimplementation audit clarified most of our concerns and resulted in the NRC review team agreeing with a number of proposed improvements.

There are, however, a number of IIEDs that DLC has expressed an intent to correct, but the details of the proposed correction are not yet sufficiently developed to allow our assessment. These items are:

o liierarchical Labeling o Functional Demarcation 1

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I o Meter Banding o Tagout Process

. DLC should describe the ultimate resolution to these HEDs in the supplemental summary report with sufficient detail to allow NRC assessment. We recommend inclusion of specifications, guidelines and procedures developed to control these efforts. In addition, we recommend that DLC make extensive use of sketches and photos to illustrate the resolutions.

The NRC audit team noted that DLC classified many HEDs as NO ACTION REQUIRED or NO HED when, in fact, these HEDs are to be resolved by a design change or a procedure development that was planned or in progress at the time of the preimplementation audit. The DCRDR review team must track these items to insure that an acceptable resolution is achieved by the efforts noted in the proposed resolutions, llow the DCRDR review team performs this tracking process must be 4 explained in the supplemental summary report.

The DLC should insure that when items are reworked as part of a proposed solution to an HED, all related HEDs which can be reasonably corrected as part of this proposed fix are also corrected (e.g., correction of annunciator tiles word spacing and message length when new tiles are engraved to correct deviation from standard terminology conventions). This includes items which DLC may have evaluated as not significant enough to correct.

2.6.3 Conclusion In general, the BVPS 2 selection of design improvements process appears sound and well executed. It appears that DLC plans to meet the intent of the requirements of

Supplement 1 to NUREG-0737. However, until DLC addresses concerns and recommend-ations with the selection of design improvements process in the supplemental summary report, we are unable to give a final opinion as to this process' compliance with the

! requirements.

2.7 VERIFICATION THAT DESIGN IMPROVEMENTS PROVIDE NECESSARY

! CORRECTION AND DO NOT INTRODUCE NEW HEDs i

, 2.7.1 Requirement 3

Supplement 1 to NUREG-0737 requires verification that selected design improvements

, will provide the necessary correction and will not introduce new IIEDs into the control room.

2.7.2 Discussion The methodology DLC used to ensure that improvements correct IIEDs without introducing new IIEDs was found to be acceptable by the NRC during the in-progress audit. During preimplementation audit discussions, DLC stated that human factors

, involvement in the design change process was the responsibility of Stone and Webster. l j _ _ _ _ _ __ _ _ ._ __ . . _ _ _ . . . . - _ , . _ _ ._,_

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2.7.3 Conclusion Based on our review of the BVPS 2 Summary Report and preimplementation audit discussions, we agree with this finding, in general. DLC, however, will need to provide a detailed description of Stone and Webster's involvement in this process in the supplemental summary report. Although it appears that DLC will meet the intent of the requirements to Supplement 1 to NUREG-0737, a final evaluation cannot be made until the above process description is submitted for NRC review.

2.8 COORDINATION OF TIIE DCRDR WITH OTHER PROGRAMS 3

2.8.1 Requirement Supplement 1 to NUREG-0737 requires that control room improvements be coordinated with changes from other programs: e.g., Safety Parameter Display System (SPDS);

. operator training, Regulatory Guide 1.97 (R.G.1.97) instrumentation, and upgraded emergency operating procedures (EOPs).

2.8.2 Discussion The BVPS 2 program for coordination of the DCRDR with other activities was found to be acceptable by the NRC during the in-progress audit conducted July 26 and 27,1984.

2.8.3 Conclusion In our review of the summary report and based upon preimplementation discussions, we concur with this finding. The DLC DCRDR coordination effort appears to be well planned and implemented throughout the review process. It appears DLC has satisfied the requirements of Supplement 1 to NUREG-0737 for coordination of the DCRDR with other programs.

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SUMMARY

l Based upon our review of the Beaver Valley Power Station Summary Report and the preimplementation audit conducted February 11 and 12,1986, we find DLC has generally satisfied the requirements of Supplement 1 to NUREG-0737. The following items remain to be completed, evaluated, or verified,' and should be addressed in a supplemental summary report to be submitted at least 120 days prior to fuel load.

1. Complete the following survey sections.

o Workspace o Emergency Equipment o Maintainability l o Communications o Annunciators o Computer Systems l

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2. Provide a schedule commitment and a description of the plans for the completion

of the following control room surveys.

o HVAC

. o Illumination

o Noise f 3. Complete survey checklists containing items which have yet to be evaluated (i.e.,

unable to access items).

i 4. Include emergency shutdown panel and alternate shutdown panel in the above surveys.

i Respond to the following problems identified by the NRC review team during the 5.

audit:

I o Meter character size on vertical control boards. There are two different sizes 1

of characters on the display faces of these meters. The problem is more acute j on displays with characters of the smaller size. The scale units size of these displays is also a problem.

o A control display integration problem exists on vertical control board Section C Extraction Steam control / status light panel. The problem involves the controls and indicators for the Extraction Steam Isolation Valves and the Main Steam Drain Isolation Valves, and Feedwater Heater Isolation Valves.

o No lamp test or check procedure exists for single indicator lights with single filament bulbs.

o Lighted pushbuttons cannot be distinguished from light indicators on the Turbine Control Panel.

o Lack of a system to ensure annunciator tiles removed for maintenance or bulb replacement will be restored to the proper location.

o Lack of coding between Trip and Reset switches for SI, CIS, and Reactor, o Inconsistent nomenclature between meter faces, in control board labels and procedures for steam generator instrumentation.

6. DLC should reassess the need for annunciator prioritization in the BVPS 2 control i

, room.

7. DLC should discuss the solution to the HED having to do with lack of targets on the ASP and ESP control switches. DLC's assessment process missed the fact that this HED is actually a procedure problem rather than a hardware problem.

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8. DLC should describe in detail the following programs which were still in the l development process during the preimplementation audit:

o liierarchical labeling o Functional Demarcation o Meter Banding o Tagout Process

9. DLC will need to provide an explanation of the process which will be used to track IIEDs which were to be resolved by a design change or procedure development that was in progress or in the planning stage at the time of preimplementation audit.

4. REi?ERENCES

1. U.S. Nuclear Regulatory Commission, NUREG-0737, " Clarification of TMI Action Plan Requirements," November 1980, Supplement 1, December 1982.

2. U.S. Nuclear Regulatory Commission, NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," October 1981.

3. U.S. Nuclear Regulatory Commission, NUREG-0700, " Guidelines for Control Room Design Review," September 1981.

4. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.97, " Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs During and Following an Accident," December 1980.

5. U.S. Nuclear Regulatory Commission, NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 18.1, Control Room, Rev. O, September 1984.

6. DLC Memo, J. V. Vassell (DLC) to J. D. Sieber (DLC), NDINSM:1750, " Control Room Nameplates," August 14,1985.

7. DLC Informal Memo, " Engraving Guidelines"  !

8. DLC Procedure, " Beaver Valley Power Station Operating Manual, Chapter 56C, Alternate Safe Shutdown from Outside Control Room, Unit 2," Rev. O, January 28,1986.

9. DLC Memo, J. V. Vassell to K. D. Grada, " Terms and Abbreviations Standards,"

NDINSM:1628, June 6,1985.

10. DLC Memo, F. D. Schuster to T. P. Noonan, " Nameplate Engraving Meeting,"

ND2052:0048, May 23,1985.

11. DLC Beaver Valley Power Station Unit 2 Start Up Manual, Attachment 3.4.6-12, Standard Abbreviations for the Operating Manual", proposed Rev. 3.

12. DLC Memo, E. T. Ellmann to R. E. Martin and J. P. Thomas, "CRDR and Iluman Factors at BVPS 2," 2NCD-05742, January 8,1986.

13. DLC Beaver Valley Power Station Unit 2 Summary Report, submitted December 2,1985.

14. U.S. Nuclear Regulatory Commission, in-Progress Audit Report, dated August 23,1984.

JYB:860302:3/28/86