ML20203L272

Forwards Util Response to Concerns Expressed in NRC Re Technical Evaluation of Dcrdr Summary Rept

ML20203L272
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/19/1986
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Berkow H Office of Nuclear Reactor Regulation
References
P-86528, TAC-56125, NUDOCS 8608250447
Download: ML20203L272 (32)

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16805 WCR 19 1/2, Platteville, Colorado 80651 August 19, 1986 Fort St. Vrain Unit No. 1 P-86528 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. H. N. Berkow, Director Standardization and Special l Projects Directorate Docket No. 50-267

SUBJECT:

Technical Evaluation of the Fort St. Vrain Control Room Design Review Summary Report

REFERENCE:

NRC Letter (G-86316)

Heitner to Walker Dated 6/13/86

Dear Mr. Berkow:

The purpose of this letter is to provide you with Public Service Company's response to the request for " specific information" contained in the above Reference.

If you have any questions, please contact M. H. Holmes at (303) 480-6960.

Very truly yours, h/Yl} inn ~lw D.W.Warembourg8}<

Manager, Nuclear Engineering Division DWW:DJG/asa Attachments l

060900044' fW'31" ,

PDp AI)OCP Ot'00 l' -

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Attachment to P-86528 Public Service Company's Response to the Concerns Addressed by the Nuclear Regulatory Commission's TECHNICAL EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW

SUMMARY

REPORT On April 30, 1985, Public Service Company (PSC) submitted a Summary Report (SR) of the Detailed Control Room Design Review (DCRDR) as required by NUREG-0737. PSC staff members met with the Nuclear Regulatory Commission (NRC) staff in Bethesda, MD, on July 16, 1985, to discuss this SR. An NRC letter dated August 27,1985, (D. R.

Hunter to 0. R. Lee), requested a Supplemental Summary Report and provided minutes of the July 16, 1985, meeting. An included Summary listed the documentation considered "necessary to complete NRC review". A telephone conference was held between PSC and NRC staff members on September 19, 1985, to clarify these requests.

PSC submitted, by letter dated October 29, 1985, the supplementary information requested by the NRC. Due to the integrated approach to making modifications to panels and resolving HEDs, PSC has submitted to the NRC, proposed design packages for each separate panel or panel section where changes will occur, on a schedule corresponding to the completion of each proposed panel redesign.

By letter (P-86005) dated January 17, 1986, PSC requested advance approval of four (4) proposed changes to the Fort St. Vrain (FSV)

Control Room. In further discussions with the NRC staff, these changes were limited to the following three items:

- Circulator Brake and Seal Indication Changes (CN-1984)

- Control Room Furnishing and Arrangement (CN-1899)

- Control Room Lighting (CN-1898)

A letter dated June 13, 1986, indicated that the staff had reviewed the changes and found them acceptable and that PSC could proceed with implementation.

Dividing the design analysis submittals into manageable " packages" offered staffing and scheduling advantages for both preparation and review efforts. However, this approach presented some definite disadvantages for the reviewers. HEDs were often addressed in part by several submittals and the resolution of problems applicable to a particular device were documented by different work divisions.

While PSC has maintained an integrated approach to the resolution of HEDs, individual submittals may not reflect this fact. PSC's responses to Science Application Incorporated (SAI) comments will establish the interrelationship between certain segmented efforts and provide clarification of the HED dispositions.

Page 1 of 31

The included SAI report requested specific informat;on relative to 13 items addressed by various Human Engineering Discrepancies (HEDs).

This response will address ea::h item for which additional information is required as an item number (Items #1 through #13). The format of this response will include the SAI comments and provide PSC's response to that comment.

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i 1 ITEM #1 Panel I-01 Design Package i

SAI COMMENT HED-0698 (Category 2) - The discrepancies described are j that there is no indicator associated with the t controller for HC-11214 and there is not a precise or accurate flow and pressure control. The resolution described reveals that an indication of reactor pressure and demarcation will be added in addition to functional i grouping. In reference to the lack of a precise or

accurate flow and pressure control, PSC states that

< while " additional control devices may improve certain i reactor pump up and pump down actions, the cost versus i benefit factor doesn't support a system redesign." PSC

! does not cite behavioral and operational factors in its

! justification for not taking corrective action for this ,

} portion of the HED. In order to progress towards an  ;

j acceptable resolution of the HED, PSC should provide

! either a correction to this portion of the HED or a i justification based upon behavioral and operational -

factors.

4 PSC RESPONSE

Background

]

HED-0698 listed five (5) controls on Control Board I-01 3

and cited two problems. HC-11214 was cited as not

! having an associated indicator (showing the parameter

being controlled). FC-2402, HS-2401, HS-2403, and HS-2407 were listed and associated with a general

, problem in " pump-down, equalize and etc., operations",

l (not precise or accurate flow or pressure control). Two j other HEDs, numbers 0463 and 0464 were initiated as a i result of Reportable Occurrence (R.O. #83-008). This j R.O. cited the fact that the operator exceeded a 100 psia reactor pressure limit during pump-up operations.

Distractions within the Control Room and instrument grouping were considered to be the contributing factors to this incident. Corrective options include increased ,

staffing and providing an indication of reactor pressure t near HC-11214.

HED-0698 was generated from the operator responses to the following specific question:

"Li st any controls that are difficult to

adjust as precisely as they need to be adjusted."

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There were three responses to the question as follows:

Purified helium flow when pumping up (HC-11214)

FC-2402, HC-11214, HS-2401, HS-2403, HS-2407 HC-11214, no response until = 40?f, One phase of evaluating an HED is in determining the validity of a particular response within the context of the question. Another consideration is in determining whether a particular response is based on an actual operational requirement or on a perceived requirement, and if the basis is a perception, is there in fact validity to that perception. This report will present those considerations upon which the evaluation and disposition of HED-0698 was based.

System Function The primary purpose of the Helium Storage System is to provide storage for the plant helium inventory and the means to transfer that inventory from the Primary Coolant System to the storage tanks (pump-down) or from the storage tanks to the Primary Coolant System (pump-up).

Secondly, it provides high pressure helium for testing the reserve shutdown system, backup helium to the Helium Circulator buffer seals, various purging operations, and storage for makeup helium requirements. Sufficient valving is provided so that the Helium Storage System may be used in several different operating modes with the Prestressed Concrete Reactor Vessel (PCRV) either pressurized or depressurized.

System Operating Procedure (50P) 24 provides instructions for accomplishing some 30 operations involving the transfer of helium into and out of the PCRV as well as between transport and storage facilities within System 24. (Each procedure step indicates an a.pproximate setting for HC-11214, not a precise value.)

All thirty operations use System 24 controls in various combinations depending on the particular helium transfer task to be accomplished. Each transfer operation has a set of associated variables. These variables include static pressure values of the two storage volumes (T-2401 and T-2402), the Helium Transport and the PCRV.

The differential pressure between each volume directly affects the helium flow rate between any two volumes.

Page 4 of 31

4 The function of HC/HV-11214 is to admit high pressure (source pressure higher than PCRV) helium to the PCRV.

The rate of this admittance to the PCRV volume is not critical, however, a high rate of admittance does in fact affect another system and will be discussed under System Configuration. The pressure increases slowly during the initial pressurizing activity due to the large volume. This situation provides a time frame for an operator to perform other chores during the course of PCRV pressurization activities and does offer the opportunity to violate Technical Specification L.C.0.

4.2.7, by pressurizing the PCRV above 100 psia with the missile covers not being installed.

Operator interviews provided additional insight into the operational aspect of this system. Operators generally concurred that the installed controls function to meet the system objectives. The operational problem inferred by the responses to the question, " List any controls that are difficult..." was determined to result from the difficulty of pressurizing the PCRV from a helium trailer and not from the potential for violating L.C.0.

4.2.7. (HV-11214 control logic contains a pressure switch which prevents over pressurizing the PCRV at the full operating pressure.)

System Configuration Figure I shows a simplified diagram of the Helium Transfer System and its association with HC/HV-11214 and the PCRV. Admitting helium via HV-11214 serves to reduce the flow from the Purified Helium Header. This results in increasing the differential across the Purified Helium Compressor (s) and may result in the tripping of this unit. The operator avoids tripping the compressor by limiting the admission of helium via HV-11214. Given the possible differences in pressure between the source and the PCRV, careful monitoring of the Purified Helium Compressor differential and careful manipulation of HV-11214 becomes necessary. This is the basis for the lack of precise or accurate flow and pressure control cited by HED-0698.

Operator Actions Operator tasks associated with helium transfer operations are, for the purpose of this discussion, divided into control room and non-control room (or dispatch) tasks.

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-- - -- - - - - ._. - _ _ _ m ___e ..-a_w.L. -

SIM.IFIEI) DIK#M

$ $ To HELIlM STORNE & TRWSER SYSTEM PCRV h

I Penetration

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Depressurization c F.O. --

y Purified Helium I-01 Compressors N

U F.C.

Helium Storage T-2401 xgp HC

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Bottles l 121 j Helium r----- Other

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Transport PS ' p ""

• C Connection

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! Q Q V-24119 W

HV- HV-2407 2434 X7 } HV-

- HV-2403 / {j 2406 Helium __

a t~ 'J G

Pur[fcation g, W Y-HV- FC- PV- High PI-23-2 2406 j 2401 2402 2433 Pressure

-2 Helium Bottles Transfer Compressor i

FIGUE 1 1

f.

i Dispatch tasks include receiving helium transport

vehicles, the connection of transport vehicles to the Helium System, manipulation of manual valves and various monitoring operations. Again, for this discussion, control room tasks are further divided into two groups.

i The first group of tasks are those supporting the I transfer of helium between volumes, interspace pressurization and other tasks not directly associated with adjusting primary coolant pressure. While completion of these tasks are essential to plant operations, there is no affect on a Critical Safety

( Function (CSF). The second group of tasks are those j required to pressurize and maintain the required pressure in the PCRV.

l Operator actions associated with pressurization activities consist of completing a valve line-up from the selected source and opening HV-11214 by increasing the setpoint dial on HC-11214. The operator then monitors the Purified Helium Compressor differential pressure on PDI-2340/41 and reactor pressure on PI-21286

< (both indications are on I-01). Valve opening is j adjusted to minimize the affect on the Purified Helium l Compressor differential pressure and closed when the

desired reactor pressure is attained.

j j Safety Considerations ,

L The Final Safety Analysis Report (FSAR) Section 9.5.5 addresses the safety considerations relative to the i Helium Transfer and Storage System. The results of this I analysis show that a release of the total helium i

inventory to the PCRV does not compromise PCRV integrity

[ and plant safety. There are also administrative j controls which regulate the transfer of helium for j makeup use.

Discussian j An option considered was the conversinn of HV-11214 to a flow control valve with a control setpoint determined i such that flow from the Purified Helium Compressor is i not affected. This scheme alone does not accommodate reactor pressure established by various requirements.

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! A system utilizing this approach requires certain other j qualification such as manual or auto initiation,

operator adjustment of setpoint depending on power

} levels.

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Providing a means of decreasing flow as the PCRV reaches a predetermined (operator set) pressure setpoint may provide relief from the requirement for monitoring the pressurization operation, however, this particular approach also has certain operator interface requirements, i.e., operator setpoint adjustment.

Shifting the point of operator interface does not appear to offer improved operation.

Conclusion The addition of a separate pressurization line into the PCRV is desirable. This would alleviate any adverse affects on the Purified Helium Compressor operation (or on the Helium Circulator Buffer differential.) However, this is not a feasible modification to the existing PCRV structure.

While the required functions may be within the scope of machine allocated functions, the frequency of these operations, the associated design, installation costs, training requirements, procedural and documentation costs do not justify a reallocation of these functions.

Providing a functionally grouped direct indication of the parameter being controlled on I-01, removing HS-11214 (which removed one unnecessary step from the pressurization sequence) providing functional grouping and functional labeling appears to offer the more reasonable combination for improving the man-machine interface.

It is a fact that HV-11214 does not respond correctly to control signals in the lower 30-40% of the control range. This may be either a maintenance or design consideration and is being pursued by a General Services Action Request. This action request is outside the scope of the Control Room Improvement activity.

The design and installation of control systems to accomplish the functions described is certainly a possibility, however, any perceived operational benefits do not justify the design, installation, maintenance and training costs.

To imply that a particular option is not cost effective should not be interpreted as implying a compromise to safety due to the expense of installation. The safety considerations previously analyzed in the FSAR are not being changed or compromised.

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ITEM #2

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Panel I-01 Design Package I

i SAI COMMENT HED-0704 (Category 2) -

The discrepancy described is that all delta pressure controllers work opposite to other controllers. The resolution described is that

! some of the discrepant controllers (PDC-2548 through 4

PDC-2555) will be relocated to panel I-48, placed "in remote" and operated from " Panel I-9310 local setpoint."

The other discrepant controllers are to be labeled with j parameter control positions such as "INCR", "DECR"; and i circuit changes will enable the parameter to be

! increased by pressing drive to the right. PSC's explanation of the resolution of the discrepancy

. concerning opposite direction of control movement by relocation of controllers PDC-2548 through PDC-2555 does not clearly address the discrepancy. PSC should provide

! a clearer explanation of how relocating the controllers

! to Panel I-48, placing them "in remote" and operating them froni " Panel I-9310 local setpoint" corrects this ,

discrepancy. +

! PSC RESPONSE i

PDC-2548 through PDC-2555 are pulse output devices which drive motorized valves installed across the dew point moisture monitor heads. These valves control nitrogen j (differential pressure) to effect the degree of cooling.

4 l The original design placed these controllers on Control j

Board I-01 with the intent that operators would control cooling by controlling the differential. In reality, the operation is the primary responsibility of r

! non-operating personnel, and needlessly involved '

l operators to adjust the controllers on I-01, while i non-operating personnel monitored the results displayed j on I-10, a backside board.

l Investigation showed that a setpoint control was located adjacent to each moisture detection equipment bin on I-10 and that setpoint control from I-01 was unnecessary. (This local I-10 setpoint control was not labeled to correctly reflect its function and was ignored in favor of the more readily recognized control on I-01).

1 i The I-01 controls, PDC-2548 through PDC-2555 were ,

! relocated outside the Control Room and are now 1 i considered as blind controllers (setpoint selector l placed in remote), with the primary setpoint controls on

! I-10. As non-operable controls, these controllers are i l not subject to the controller convention established for

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the Control Room. This setpoint control, while not an operator control, was designed and labeled to conform to the applicable Design Directives.

Relocating these controllers effectively reduced the operator work load and freed board space for functional grouping of devices required on I-01 Control Board. Use of the original setpoint control on I-10 results in better control since a single person reads the indicator and makes the adjustment based on the value observed.

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ITEM #3

, Panel I-02 Design Package 1

i SAI COMMENT HED-0400 (Category 3) -

The discrepancy described is j that two hand-switches (Emergency Water Boost Pumps IA i

and IB) should be, but are not located together on Panel j I-05 near associated functions. The resolution described appears to that the discrepant handswitches

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will be temporarily grouped with Bearing Water Controls on Panel I-02 and that regrouping of instrumention Panel

! I-05 will be approached with the intent of locating the 1 two discrepant handswitches with associated controls on i Panel I-05. It does not appear that the location of the 1

two handswitches will be finalized until the instrument j regrouping on Panel I-05 is finalized. The evaluation 1 of the correction to this discrepancy will not be l completed until the finalized regrouping on Panel I-05 l 1s submitted for NRC review (scheduled for 2/18/86).

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PSC RESPONSE HS-21535 and HS-21536 are shown relocated to the 1 " Common" section of I-05 by Attachment D to Attachment 6b-13, submitted on 2/18/86 as referenced above.

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l ITEM #4 Panel I-03 Design Package, l SAI COMMENT l

HED-0597 (Category 1) - The discrepancy described is that the startup, wide range and power instruments are marked in Arabic numbers while the corresponding j references on Panel I-10 are in Roman numerals. The resolution described is that the Roman numerals will be retained and the Arabic numbers changed to Roman. PSC states that this will make it consistent with industry practice. However, industry practice for numerals in j general (not specific to individual instrumentation) and

that recommended by NUREG-0700 is that numerals be in l Arabic, not Roman, PSC should explain how this is consistent with its design directive corresponding to the use of numerals.

PSC RESPONSE

Industry practice (other nuclear plants) does in fact utilize Roman numerals to identify certain plant protective systems and/or neutron channels. This

, practice stems from certain manufacturers and is continued through the documentation and use of this l

equipment. Public Service Company's design directives i do not preclude the use of Roman numerals, but supports l higher level human factors principles which promote use of numbering systems which are consistent within given applications and unambiguous between applications.

NUREG-0700, Section 6.6.3.4e states: "Use of Roman

! numerals should be avoided." This " Guideline" appears to be based only in the difficulty of interpreting a  ;

i series of Roman numerals, such as the year MCMXXCVI. '

i The use of Roman numerals I through X does not present I

this difficulty and is not subject to the same argument.

Public Service Company identifies eight (8) nuclear 1

channels with Roman numerals I through VIII. The use of i

Roman numerals to identify a specific group of components, functions or channels should not be confused with the instrument number identification scheme which identifies each component with an alpha-numeric i designation.

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A valid argument does exist for the use of unique symbols (such as Roman numerals) to differentiate between certain functions. While an in-depth discussion of this argument will not be presented in this response, it is based on the fact that there are eight (8) neutron channels, three (3) Plant Protective System (PPS) input channels, and two (2) PPS output channels. However, the 4 fact remains that there is no justification for eliminating certain simple types of symbols or characters on the basis that interpreting a series of these symbols or characters is difficult. Tests conducted during operator interviews established a 100%

accuracy rate in the recognition and interpretation of i

Roman numerals I through VIII.

The continued use of Roman numerals in this particular application has been evaluated and is considered acceptable.

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ITEM #5 Panel I-03 Design Package SAI COMMENT

HED-0654 (Category 1), 496 (Category 4), and 661 (Category 2) - One of the discrepancies described for recorder NR-1199, FR-11262, and XR-11262 is the inadequacy of the chart paper in displaying information needed by the operator (e.g., numerical markings and

range of readings). The resolutions described cite the relocation of recorders to Panel I-09, the addition of an indicator, an explanation mentioning the recorder ( s) not being an operator tool but one used by Technical Services, and the unchangeability of the recorders. It is not clear from the description of the resolutions whether the discrepancy concerning the inadequacy of the chart paper is going to be corrected. PSC should address the resolution of the discrepancy in order to progress towards an acceptable resolution of these HEDs.

PSC RESPONSE HED-0654 problem description applicable to NR-1199 states: " Recorder Scale Markings and/or range do not agree with alternate instrumentation". HED-0654 disposition applicable to NR-1199 indicates that the alternate indication is to be changed by CN-1887 and that the recorder is used for historical data and is being moved to I-09.

j HED-0496 problem description states: "NR-1199 was selected and installed for Technical Services use and does not provide the operator with needed or useable information. The resolution indicates that the recorder will be relocated to I-09 and a digital indicator will

! be provided for operator use. In actuality, three l digital indicators, NI-1199, NI-11379 and NI-11380, will be added to display the three values recorded by NR-1199/XR-11272/FR-11272 (see right side of Attachment D1 to Attachment 6b-5).

HED-0661 lists two problems for NR-1199/XR-11262/

FR-11262:

1. Recorder chart does not have numerical markings, and

2. Current values are not visible to operator.

Page 13 of 31

The disposition of this HED indicates that a mass flow indicator is being added by CN-1887 and that NR-1199/XR-11262/FR-11262 is not an operator used item and will be moved to I-09 and used for historical data only, by CN-1878.

To directly address the SAI comment, the inadequacy of the chart paper for operator use will not be corrected.

The HEDs which cite inadequacy are based on Control Room Design Review Audit "yes/no" questions for Control Room recorders. No attempt was made at the time of that audit effort to ascertain the end use of the recorder information.

The primary and original purpose of the recorder was for use in determining the extent of any " Power to Flow Ratio" excursion. This task is accomplished by Technical Services after the fact, and requires a time / amplitude history rather than a current display of the parameter. While operator interviews provided an indication that the recorded values were not used by the operators, other information (procedures, technical specifications, etc.) established some requirements for the information.

In summary, moving recorder NR-1199/XR-11262/FR-11262 to I-09 accomplishes the following:

1. Retains the recorder in the Control Room so that its operation is routinely monitored and provides reasonable access to the historical data, and

2. Provides board space for the addition or relocation of more readily useable displays.

The purpose of this recorder is to provide a historical record of Power to Mass Flow excursions which is analyzed after-the-fact by non-operating personnel.

Operating informational requirements are met by the addition of direct reading digital indicators.

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ITEM #6 Panel I-03 Design Package

! SAI COMMENT HED-0655 (Category 1) - The discrepancy described is that recorder scales are not clearly readable and resolvable from the operating position. For recorder TR-2256, the resolution described is that the recorder will be rescaled. For recorders NR-1131 and NR-1133-1, the resolution described is that they will be relocated.

No resolution is described for recorder NR-1131-1. A review of the drawings of the modified panel arrangement found that the new location of recorders NR-1131 and NR-1133-1 is apparently at the same panel height but on the other side of the board. The new location of these recorders relative to controls on Panel I-03 does not seem to have changed to the extent that the recorders are any closer to the operating position. PSC should clarify how the new location of recorders NR-1131 and NR-1133-1, relative to the operations performed, has

. improved the readability and resolution of recorder l information. In addition, PSC should describe the resolution of the discrepancy associated with recorder NR-1131-1.

PSC RESPONSE HED-0655 Continuation Sheet 1 of 2, typically submitted with Attachment 6b-1, 6b-5, and 6b-24, lists NR-1131-1(B) immediately under NR-1133-1(R). This is a superfluous entry resulting from a typing error on Control Room Survey Sheets CRS-59-1 through 59-4 and 60-1. NR-1131/1133-1 is a two (2) pen recorder with the NR-1131 function assigned to the Red pen and NR-1133-1 ,

function assigned to the Blue pen.

NR-1131-1(R) and NR-1134-1(B) is a two (2) pen recorder located on I-49 and correctly shown on HED-0655 Continuation Sheet 2 of 2.

The copy of HED-0655 (included with the I-03 Control Board redesign submittal Attachment 6b-5) failed to provide a clear connection between the efforts l associated with Control Board I-03 redesign (CN-1887) and the Recorder Scale & Paper Changes (CN-2177). The

, entry applicable to the relocation of NR-1131/NR-1133-1 l should have included a more direct reference to the Scale & Paper Design Analysis effort of CN-2177.

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NR-1131/NR-1133-1 was listed on this HED as a result of negative answers to the following two (2) Survey questions:

1. If recorder has fixed multi-index scales, are they clearly discernible?

2. Is the fixed index scale (s) readable from the operator's range of vision?

! Survey personnel were instructed to record a negative

! answer if any difficulty was experienced in reading or interpreting a scale. Survey personnel were not to attempt to evaluate applicability of a Survey question or the adequacy (or inadequacy) of any particular device.

i The Recorder Scale & Paper Design analysis effort included an evaluation of each recorder cited by an HED.

This evaluation took into account the conditions for use and the type of information required.

NR-1131/1133-1 displays " counts per second" (pen 1) on a

1 to 3 x 105 log scale, and " Percent Power" (pen 2) on a 10 -' to 10' log scale (see Figure 2). There are three interrelated items that make this recorder difficult to read

1. The pen 1 pointer is physically located under the scale associated with pen 2 and the pen 2 pointer is above the pen 1 scale.

2. The absence of functional labeling l (HED-021) adds to the difficulty in i

making the association between pens and scales.

3. The log scales are subdivided to a

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smaller increment than required and makes resolving values difficult.

The corrective actions for this recorder are (see Figure 2):

l 1. The application of colored transparent i

tape over each scale to aid in correlating pen assignments with the scale. (Red to Red and Blue to Blue).

2. Provide functional labeling which correlates the pen color with the

. function and instrument number

! identification.

page 16 of 31

Blue Pen i 1 10 102C UNYS PER

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10 102 CPSt

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COUNTS PEffSECONE i (CP,S) ,

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_ IO 102 l 'l0 PERCENT POWE 1

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l ll COUNTS PER SECOND NOTE: Not to Scale RCUE 2 l

l 3. Provide a fixed index scale which has scale increments consistent with the information requirements and engineering units labeled in accordance with DD-LAB-1. Note: Space constraints may preclude using .16" high superscripts.

4. Provide chart paper formatted to provide increments consistent with the proposed fixed index scale and engineering units

on the applicable chart segment.

i NR-1133-1 is listed on the "Information and Control Requirements" for the " Reactor Shutdown" task analysis effort. The specific information required from this recorder is quantitative in nature, i.e., <5%,

decreasing flux, etc. The above corrective actions will accommodate these quantitative uses.

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Panel I-09 Recorder Move Design Package SAI COMMENTS (General)

A review of the material describing the methodology, resolution of HEDs, draft design directive for selection of recorders, and proposed modification of Panel I-09 found PSC's plans to be generally acceptable. With the exception of the HEDs cited below, the resolution of individual HEDs was found to be acceptable. Although PSC's research methodology considers a recorder's application in plant operation, a concern remains regarding the relocation of recorders that may be needed for plant operations. Specifically, the concern is for recorders related to controls and displays on panels other than I-09 that may need to remain with these i components in order to maintain or establish functional PSC should grouping and support plant operations.

indicate if any recorders needed to support plant operations on panels other than I-09 have been moved to

I-09, and if so, how operations will be conducted l satisfactorily in each case. In addition, PSC should respond to the concerns discussed below.

PSC RESPONSE (General) l It is fact that a large number of recorders were originally placed on the Fort St. Vrain Main Control Board without considering the informational needs of the operator. This practice appears to be more historically based than actual need based. An extension of this practice is that of connecting all available (vendor supplied) measured points to these recorders. There was no recognized need or established basis for separating performance analysis, operational required, and troubleshooting type information.

I It became apparent during operator interviews that some operators do not differentiate between information J

required for historical use, performance assessment, troubleshooting efforts, and operator actions. (There are cases where performance assessment directly influences operating practices.) Many recorded values

fall into the non-operating classifications, however, -

j these same values are viewed by operators as " good to know" type information. Given the space limitations of j the existing design, it becomes imperative to differentiate between " required" and other classifications of information. " Required" type indications are then functionally grouped with associated controls and the source of other information ,

classifications are placed in secondary locations.

1 Page 18 of 31 i

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,.,-___ . _ _m. - _ _ _ ,- , . . __ -

One element of the Control Room Design Improvement Analysis phase has been to determine informational needs for routine operations. (Control Room Design Review Task Analysis made this determination for emergency type operations.) Various operational analysis efforts served to establish minimums and extensive operator interviewing established some preferences. The decision to move certain recorders was based on the following considerations:

. 1. Informational needs assessment - If the operator requires current values of a 1 measurement to make an immediate control adjustment, then provide that information in a more directly resolvable format, i.e., digital readout, analog meter, etc.

2. Task analysis informational needs assessment.

3. Recorders require routine service, maintenance and calibration usually preformed in place and insuring some disruption to the Control Room routine.

Any relocation of recorders that is technically justified will tend to minimize the problem.

4. The eleven (11) inch Westronics recorders each utilize 1.37 square feet of vertical control board area. Any relocation of recorders that are not essential to the operations preformed at a particular work station will free board space for more effective uses.

Each recorder, each pen or channel assignment was evaluated to determine if that specific information was required on the Main Control Board. If it was determined that specific information was required,

alternate sources were assessed, and finally alternate

methods of displaying specific information were considered. In many cases, a direct reading indication exists on the control board.

As a result of this effort, a determination has been made that those recorders being moved to I-09 are not required on the Main Control Boards. Where specific information is required to make a control change, that information exists or is being provided by a direct indication.

j Page 19 of 31 I

The following (Items #7 through #13) is a continuation of the response to " Panel I-09 Recorder Move Design Package" comments.

ITEM #7 SAI COMMENT HED-0653 (Category 1) - The discrepancy described is as follows:

" Recorders do not have index scale (s) and/or scale pointer and/or appropriate markings of the parameter (s) '-

being measured and/or process or engineering units consistent with the intended use." The resolution described for recorder NR-1133-2 was that the discrepancy was reevaluated and found not to be a discrepancy. PSC should provide more information on its reevaluation and an explanation of the changed conclusion.

)! PSC RESPONSE NR-1133-2 was cited by three different HEDs, numbers 0502, 0653, and 0656. Two of these three HEDs were

initiated as a result of negative answers to various survey questions. The particular problems cited are

HED-0502 cited operator attitudes and training concerns with respect to the use of Nuclear instrumentation.

This HED was outside the scope of the CRDR and was i referred as a training issue.

I NR-1133-2 was listed on HED-0653 as a result of negative l answers to the following two (2) questions:

1. Does the recorder have process or engineering units consistent with the 1

required parameter?

Survey person's note

" Process or

engineering units not clear - Percent?"

2. Does recorder have a fixed index scale i appropriate for parameter?

( Survey person's note: " Process units not clear - Percent?" (Range 0.K.)

NR-1133-2 was listed on HED-0656 as a result of a negative answer to the following question: ,

"Are fixed index scale increments in units of 1, 2, 5 or power of 10 multiples?"

, Page 20 of 31 1

Survey personnel were instructed to record a negative answer if any difficulty was experienced in reading or j interpreting a scale, or if the survey question could j not be answered affirmatively. Survey personnel were 3 not to attempt to evaluate applicability of a Survey question or the adequacy (or inadequacy) of any particular device.

The Recorder Scale & Paper Design analysis effort included an evaluation of each recorder cited by an HED.

This evaluation took into account the conditions for use and the type of information required.

! The scale on NR-1133-2 does in fact have engineering units listed as " percent" on both the fixed scale and the chart paper. For this reason, the evaluator

dispositioned HED-0653 as "no discrepancy".

The evaluator did recognize that the characters on the i fixed index scale were of substandard size and that the scale was marked in 2.5 percent increments. A new fixed index scale and chart were designed. A sketch of the revised index scale is included on Figure 3. This configuration meets the intent of Design Directive DD-RSN-1 and all informational requirements.

The chart character sizes do not comply will all size requirements of DD-LAB-1. The five inch wide paper utilized by this type of recorder provides some inherit i

limitations on character sizes and density l relationships. Operators actually " read" the recorder i by observing the printed point position relative to the fixed index scale. Historical use of the chart provides i the option of a closer scrutinization of the paper, l

~

characters and printed points. This operation is usually accomplished on a work surface (desk, table top, etc.) and at a viewing distance of 12-18 inches, thus not requiring letter heights consistent with 24-30 inch viewing distances.

! Attachment A to the I-09 recorder move summary i (Attachment 6b-7 applicable to CN-1878) shows " Move to

, I-09 and Rescale". HED-0656 included with submittal

6b-7 shows " relocate to I-09 on CN-1878 and scale l

coordination by CN-2177". The rescaling and relocation of this recorder is being accomplished by CN-1878. The

! disposition for HED-0656 has been corrected to reflect this fact.

Attachment A submitted with the Scale & Paper j Coordination package (Attachment 6b-24) shows " Move to i I-09 and rescale" (by CN-1878). This is consistent with the intent of Attachment 6b-7.

i Page 21 of 31 i

INIEX SCALE & GiART Applicable to NR-ll33-2

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' P! ease review this proof and return the copy with your approval or modification as noted. We will wait until hearing from you l before proceeding further.

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ITEM #8 SAI COMMENT HED-0654 (Category 1) -

The discrepancy described is that recorder scale markings and/or range do not agree with alternate instrumentation. The resolution described is that alternate instrumentation to some recorders will be changed and other recorders will be relocated to Panel I-09. It appears that regardless of location, these still serve as alternate instrumentation even though primarily used for historical purposes. If this is so, then the scales should be modified to agree with instrumentation for which they serve as alternates.

PSC RESPONSE There are four (4) recorders listed by HED-0654 that are being moved to I-09.

HED-0654 was initiated as a result of a negative response to the following Survey (CRS-63) question:

"Does the recorder range and scale marking agree with alternate instrumentation."

Survey personnel were instructed to record a negative answer to the above question if any differences (range, markings, increments) existed. Survey personnel were not to attempt to evaluate the acceptability of a scale or to determine if scale markings agreed in principle.

The Recorder Scale and Paper Design Analysis effort included an evaluation of each recorder cited by an HED.

This evaluation took into account the conditions for use and the type of information required. While scale markings may differ in some manner and require a l negative answer to the survey question, these same '

scales may be entirely acceptable for use. The basis of acceptability for the four (4) recorders discussed above as:

PR-1108 -

This recorder was cited as being different than alternate instrumentation (indicators PI-1108, 1109, and 1110) due to the fact that PR-1108 has a 0-1000 psia scale and the three indicators have 0-100 psia scales with a times 10 multiplication required. PI-1108, 1109, and 1110 are to be rescaled to 0-1000 psia. (See Disposition of HED-0654 and disposition of HED-0538 included in the second submittal as Attachment 6b-5.)

NR-1199 - This recorder is being moved to I-09 and is not considered as a necessary alternate Page 22 of 31

i

. I to NI-1199. . See PSC Response to Item #5 of this submittal. (NR-1199 on I-03 is to be changed to a digital indicator. See second submittal, Attachment 6b-5.)

TR-4637/TR-4638 - These recorders were cited as being different than alternate instrumentation (indicators TI-4637/38 and '

TI-4637-1/38-1) due to the fact that the chart l paper increments differed (the fixed index i scales are identical). The chart paper for these recorders will be changed by CN-1878.

(See HED-0652 included with the eighth submittal, Attachment 6b-24, and related discussion of TR-4637/38 in PSC's Response to Item #9 of this submittal.)

i I

i Page 23 of 31

t j ITEM #9 j SAI COMMENT i HED-0655 (Category 1) - The discrepancy described is

that recorder scales are not clearly readable and i resolvable from the operating position. The resolution i described for recorders TR-4637 and TR-4638 is

! " Reevaluated - no discrepancy". PSC should provide more

{ information on its reevaluation and an explanation of

the changed conclusion.

]

PSC RESPONSE l

l TR-4637 and TR-4638 are listed on HED-0655 as a result

of a negative response to the Survey Checklist (CRS-59-3)

i

"If recorder has fixed multi-index scales, are j they clearly discernible?"

j Survey person's note: Scale is not labeled 4

with corresponding parameter information cr assigned a color trace.

l These recorders were also listed on HED-0654 as a result I of a negative response to the Survey Checklist (CRS-63)

! question, "Do Recorder Range and Scale markings agree i with alternate instrumentation?"

i

) The chart paper and the hinged index strip (typical for

! 64 Series Foxboro recorders) have a 50-150'F range, with i 10' major, 5' intermediate and l' minor subdivisions.

The fixed index scale has a 50-150'F range with 20'

major, 10' intermediate and 2' minor subdivisions. The I alternate indicators, TI-4637/38 and TI-4637-1/38-1 have I scales corresponding to the recorder fixed index scale.

• i

! At present, these recorders are located at 75 1/2" centerline above the floor level on I-13 (HED-0384).

, This location is above the specified height for

recorders and results in some difficulty in reading and j resolving the scale / chart. 7

With reference to the Survey person's note, it is  ;

unclear what was meant by " scale is not labeled with a color trace." An existing label does provide pen / color .

assignments. The fixed scale is readable and  ;

resolvable. A possible basis for the Survey person's note is that fact that the pen pointers are missing from  ;

i these recorders. Making correlation between pen, pen i position assignment difficult, the pen pointers are

! being replaced on all Foxboro recorders and on ,

j TR-4637/38 by CN-1878 specifically. With consideration  ;

j given the fact that these recorders are to be relocated i

j Page 24 of 31 i

I L _ _ . _ _ _ - _ - - - _ - _ _ _ - - - _ _ _ _ _ _ _ _ . _ _ _

to I-09 at an elevation within the specified height limitations, the problem cited by HED-0655 was dispositioned as " Reevaluated, no discrepancy".

These recorders are to be relocated on the west end of I-09 at an elevation of 55" centerline. New chart paper is being specified and a new legend label provided which shall be in accordance with 00-LAB-1. The existing label meets size and text requirements, however, the format is being changed for consistency. (See disposition of HED-0652 included with the eighth submittal as Attachment 6b-24.)

Page 25 of 31

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

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ITEM #10

, SAI COMMENT l HED-0658 (Category 2) - The discrepancy described is that the recorders have more than six points or channels l being recorded. The resolution described for recorder GR-5154, TR-5156, and TR-92105 is that these recorders lc) are used to monitor plant parameters from which plant adjustments are made, but not on a continual basis.

This justification for not taking corrective action on these recorders is inadequate. The fact that these

, recorders are used to monitor plant pa;ameters from j which plant adjustments are made, however frequently

used, may be reason enough to take corrective action.

PSC should provide either a corrective action or a justification for not taking corrective action which 4

cites behavioral or operational factors (e.g., potential operator error and consequences / impact of postulated error (s) upon plant operations and safety) to an extent greater than that generally implied by the HED category assignment.

i PSC RESPONSE

]

HED-0658 was generated as a result of affirmative j answers to the Survey Checklist (CRS-61-2) question, i "Are there more than 6 points recorded?"

i i The disposition of HED-0658 is in error. Recorders i GR-5154, TR-5156, and TR-92105 are not used as a basis j for making plant adjustments. Several critical i parameters represented by these recorders also result in

} equipment trips. Specific points on these recorders are l alarmed to alert the operator of a parameter exceeding j normal value. The operator will then view the recorder

! to determine which measurement point caused the alarm

! and dispatch an equipment operator to investigate.

l These recorders provide historical records for diagnostic use. This purpose does not preclude

, monitoring parameters that may be indicative of pending long term bearing wear, rotor balance, trouble, i.e.,

etc. The original of HED-0658 was redispositioned to correct this error cited.

The checklist item which initiated HED-0658 derived from a recommendation which helps to insure readability and resolvability of recorder charts.

i

'j While this checklist item is of use in identifying potential prcblems, it does not take into account the

type of information recorded, the user abilities, or the end use of the information.

i i

Page 26 of 31 1.-.,.-.--,-.--,- . . , .- . - - - _ . . . - - - - - . - . . .- --. _.

The evaluation of these three recorders (see PSC's Response to the " Panel I-09 Recorder Move Design Package" comments included as part of this submittal) evaluated the need for information from these recorders, thus precluding an evaluation of deriving needed information from a multi point (pen) recorder.

i Page 27 of 31

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

ITEM #11 SAI COMMENT HED-0695 (Category 3) - The discrepancy described is that recorders associated with controllers on Panel I-01 are located on Panel I-13. The resolution described is that the recorders are to be relocated to Panel I-09.

This action does not correct the discrepancy since functional grouping of these recorders with related controllers still does not exist.

PSC RESPONSE l

HED-0695 was initiated as a result of responses to the l following operator Survey question:

" List any systems or subsystems you operate in which a particular control or display is too 4 far away from others you have to use with it, or is on another panel."

This HED does not necessarily represent a problem but provided documentation to assure further investigation of the condition.

i Cooling water flow is controlled by TC-4637/38 &

J TC-46209/10. These are auto / manual controls on I-01.

Cooling water temperature (controlled parameter) indicators TI-4637/38, TI-4637-1/38 and TI-46209/10 display cooling water header temperatures. These indicators are functionally grouped with the controllers d

(see I-01 revised layout, submittal #1, Attachment i~ 6b-1). These controllers are normally operated in automatic mode from a manually adjusted setpoint.

Technical Specification conditions are also alarmed, thus alerting the operator of an out-of-tolerance condition. Recorder TR-4637/8 provides a time history of cooling water temperatures for trending and historical use. Setpoint adjustments may be influenced by trend information, but are based primarily on current parameter values derived from the temperature indicators.

The decision to move recorder TR-4637/38 to I-09 was based on several considerations, one of which was to locate these units closer to the related controls.

Board space limitations of I-01 (typical of all Fort St.

l Vrain Main Control Boards) preclude grouping all devices (particularly recorders) with other system controls.

Functional grouping activities considered the operational requirements of System 46 in determining placement of TR-4637/38.

Page 28 of 31

1 ITEM #12 SAI COMMENT 1

HED-0746 (Category 3) - The discrepancy described is not clear. That is, it is not clear if the lack of functional grouping is between the two recorders listed in the HEDE form of between these recorders and some other components. If only the two recorders are not functionally grouped, then the resolution described - to

! functionally group the recorders on Panel I is adequate. However, if the lack of functional grouping j addresses the relationship of these recorders with other related components, then the resolution described does not appear to correct the discrepancy (i.e., functional grouping still does not exist),

s PSC RESPONSE There are four recorders, TR-2227 (Steam Generator Module Hot Reheat Steam Temperatures), TR-2255 (Steam

. Generator Module Main Steam Temperatures), FR-2222 j (Steam Generator Module Flow), and TR-2232 (Steam Generator Module Cold Reheat Steam Temperatures), that are presently used during Steam Generator Boil-out

, operations conducted on the I-05 Control Board. The two more important of these four, TR-2227 and TR-2255, are located on I-01. TR-2232 and FR-2222 are located on I-13.

Investigative efforts conducted early in the CRDR effort resulted in the conclusion that these recorders could not be functionally grouped on or near I-05. Alternate

> displays were evaluated. The proposed "fix" (see submittal #2, Attachment 6b-5) placed a CRT on I-04 from

, which Steam Generator Module flow and temperature information will be displayed (see Remarks column of Attachment A to submittal #2, Attachment 6b-7). These parameters are also available on the Data Logger displays at each operator's station.

2 The function of these four recorders is being retained

on I-09 (new Molytec recorders) for historical use, i Actual control changes will be made based on information j displayed by the new computer driven display discussed above.

l l The disposition of HED-0746 is correct, however, additional information may have been beneficial in evaluating the integrated approach to this and other related HEDs.

Page 29 of 31

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ITEM #13 SAI COMMENT HED-0786 (Category 3) - The discrepancy described is that the two Helium Purification System temperature recorders are on the back panel, but the nitrogen and

! helium flow controllers are on the front panel. The

! resolution described is that one of the two recorders will be removed from the Control Room and the other will be relocated to Panel I-09. The resolution does not address the discrepancy cited, that is, inadequate grouping of associated components.

PSC RESPONSE HED-0786 cites TR-2321 and TR-2322 for functional location. This HED was initiated as a result of responses to the following operator Survey question:

" List any systems or subsystems you operate in which a particular control or display is too far away from others you have to use with it, or is on another panel."

This HED does not necessarily represent a problem but provided documentation to assure further investigation

of the condition.

i Investigation efforts determined that the temperature displayed by TR-2321 were of value to purification train regeneration efforts conducted from Reactor Building

, elevations 4869 and 4881. These regeneration activities are performed by equipment operators and need not involve Control Room operators.

Thus, functionally grouping this recorder resulted in its relocation to Reactor Building elevation 4881 near local Panel I-22.

I Four (4) temperatures displayed by TR-2321 were determined to be required for Regulation Guide 1.97 post accident monitoring. These four (4) temperature points

were added to TR-2322 for display within the Control

, Room.

1 TR-2322 records four (4) temperatures associated with the Low Temperature Filter Absorber ( LTFA) . These temperatures are of value in system performance analysis

! and diagnostic efforts. All parameters (temperature, pressure, flows and differentials) required for correct system operation are provided by direct indication and are functionally grouped on I-01 (see submittal #1,

Attachment 6b-1).

l f

Page 30 of 31 i

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While the operator does need to assess the effectiveness of the Low Temperature Filter Absorber, it is not a time critical task or one which requires constant monitoring.

Loss of (low) flow on I-01 indication alerts the operator that System performance is degrading.

Operators may then verify LTFA blockage by observing temperatures on TR-2322.

Relocating TR-2322 does not change any functional grouping considerations or degrade System 23 operations, however, it does offer some grouping advantages to other systems on I-13. This change does not raise new or different safety considerations, or alter the operator work load.

l 1

Page 31 of 31