ML20206G236

Technical Evaluation of Dcrdr,Summary Rept & Supplementary Info for Fort St Vrain Nuclear Generating Station

ML20206G236
Person / Time
Site:	Fort Saint Vrain
Issue date:	01/24/1986
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20206G226	List: ML20206G222 ML20206G236
References
CON-NRC-03-82-096, CON-NRC-3-82-96 NUDOCS 8606250129
Download: ML20206G236 (32)

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1 TECHNICAL EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW

SUMMARY

REPORT AND SUPPLEMENTARY INFORMATION FOR THE i

r FORT ST. VRAIN NUCLEAR GENERATING STATION I

January 24, 1986 Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Prepared by:

Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102 l

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,;. o FOREWORD This Technical Evaluation Report (TER) documents the findings of a review of the Public Service Company (PSC) of Colorado's Detailed Control Room Design Review (DCRDR) for its Fort St. Vrain (FSV) Nuclear Generating Station. SAIC's evaluation was performed in support of the Division of Human Factors Safety under contract NRC-03-82-096, Technical Assistance in Support of Licensing Actions: Program III. SAIC previously participated in the review of the Program Plan, an in-progress audit of FSV, review of the FSV DCRDR Summary Report, and a meeting between NRC staff and representa-tives o f PSC.

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1 TABLE OF CONTENTS Section Pa ge BACKGROUND ON FSV DCRDR ....................... 1 BACKGROUND ON DCRDR REQUIREMENTS . . . . . . . . . . . . . . . . . . . 4 PLANNING PHASE . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

1. Qualifications and Structure of the DCRDR Team ....... 5 REVIEW PHASE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

1. Function and Task Analysis and Comparison of Control and Display Requirements With a Control Room Inventory ... 6

2. Control Room Survey . . . . . . . . . . . . . . . . . . . . . 7 ASSESSMENT AND IMPLEMENTATION PHASE ................. 8

1. Assessment of HEDs ..................... 8

2. Selection of Design Improvements and Verification That Improvements Provide the Necessary Corrections Without

. Introducing New HEDs .................... 9

3. Coordination of the DCRDR With Other Improvement Programs . . 10 REVIEW 0F PANEL DESIGN PACKAGES AND HED RESOLUTIONS ......... 11

SUMMARY

AND CONCLUSIONS ....................... 18 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 APPENDIX A - REVIEW COMMENTS ON THE DESIGN DIRECTIONS ........ 23 APPENDIX B - PSC's SCHEDULE FOR IMPLEMENTING THE CONTROL ROOM IMPROVEMENT PROGRAM . . . . . . . . . . . . . . . . . . . 27 I

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TECMICAL EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW SupMARY REPORT AND SUPPLEMENTARY INFORMATION FOR THE FORT ST. VRAIN NUCLEAR GENERATING STATION BACKGROUND ON FSV DCRDR l

In accordance with the requirements of Supplement I to NUREG-0737, the Public Service Company (PSC) of Colorado submitted a Program Plan for con-ducting a Detailed Control Room Design Review (DCRDR) of the Fort St. Vrain (FSV) Nuclear Generating Station control room on July 13,1983 (Reference 1). Based on the review of the Program Plan, the NRC staff proposed that an in-progress audit of the FSV DCRDR be conducted. The on-site, in-progress audit was conducted during the week of March 12-15, 1984. At the time of the in-progress audit a full evaluation was not possible as several parts of the licensee's review activities had nn yet been completed. Based on the documentation available and discussions with PSC personnel during the in-progress audit, the NRC prepared and forwarded a report on its findings to PSC (R'eference 3). The NRC concluded in this report that PSC had demon-strated the necessary level of commitment to perform a successful DCRDR.

With the exception of the task analysis and minor portions of other activities, the activities that had been performed and the plans for the upcoming activities were found to be acceptable. PSC submitted to the NRC a letter, dated April 30, 1985, with an attached Summary Report of the FSV DCRDR (Reference 4). A review of the letter and Summary Report determined that although PSC responded to the concerns raised in the NRC in-progress audit, there remained areas of the DCRDR where additional documentation and discussion were necessary in order to perform a more conclusive review. A detailed evaluation of the Summary Report determined that the proposed HED resolutions and implementation schedules were not final. The NRC concluded that the Summary Report may not have been an accurate presentation of the final proposed control room changes and implementation schedule and there-fore did not meet the requirements of Supplement 1 to NUREG-0737. In order to provide a forum for discussion and documentation review, a meeting was held by the NRC with PSC on July 16, 1985. The concerns the NRC had from 1

the review of the FSV DCRDR Summary Report were addressed by PSC in the meeting, and the majority of the concerns were resolved. Although some concerns remained from the meeting, most of the action items left to be performed involved providing documentation of previously undocumented and unsubmitted DCRDR information. In order to allow a complete and conclusive evaluation to be made of the FSV DCRDR, the NRC requested that PSC provide I the following documentatic.i (Reference 5):

1. Qualifications and Structure of the DCRDR Team o The resume of the human factors specialist.

2. Function and Task Analysis and Comparison of Control and Display Requirements with a Control Room Inventory e Sample filled-in data forms of the analysis and identifica-tion of information and control needs, e Sample filled-in data forms of the verification of the needs being satisfied in the control room, e Sample filled-in data forms of the validation of E0P steps, actions, information and control needs, traffic patterns, and component locations.

3. Control Room Survey e Sample documentation which is sufficient in content and scope to demonstrate clearly how the following activities have considered dynamic criteria or principles:

- Operator survey questionnaires (several samples)

- E0P walk-throughs (several samples)

- Control Room Systems Review Group (CRSRG) Review (human factors guidelines)

- Detailed study of all control and indicator arrangements and groupings 2

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,. o e Those criteria in NUREG-0700 Section 6 that were not covered in the FSV control room survey.

4. Selection of Design Improvements and Verification That Improve-ments Will Provide the Necessary Corrections Without Introducing New HEDs e The 12 Design Directives.

] e The human factors guidelines the CRSRG uses in its review, e A clear description of each HED, its fix, and any documenta-tion such as control panel drawings which illustrates the panel design before and after its reconfiguration according

to the control room improvement package.

5. Coordination of the DCRDR With Other Improvement Programs e A description of how the DCRDR is being coordinated with training and staffing (other than to resolve HEDs) and the SPDS.

e A schedule outlining the dates for completion of its NUREG-0737 Supplement 1 initiatives since the integration of improvement programs impacts the DCRDR schedule.

A telephone conference between NRC and PSC was held on September 19, 1985, to clarify certain aspects of the NRC's requests. PSC submitted, by

letter dated October 29, 1985, the supplementary information requested by the NRC. The findings from a review of the supplementary information submitted are presented in the following sections of this report. These findings represent the consolidated observations, conclusions, and recommen-

) dations of the NRC and SAIC.

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j BACKGROUND ON DCRDR REQUIREfERTS Licensees and applicants for operating licenses are required to 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 Item I.D.1). The need to conduct the DCRDR was confirmed in NUREG-0737 and in Supplement I to NUREG-0737.

DCRDR requirements in Supplement I to NUREG-0737 replaced those in earlier documents. Supplement I to NUREG-0737 requires each applicant or licensee to conduct its DCRDR on a schedule negotiated with the NRC. Guidelines for conducting a DCRDR are provided in NUREG-0700 while the assessment processes for NRC are contained in NUREG-0800. (The NUREG documents cited are listed as References 9 through 13).

A DCRDR is to be conducted according to the licensee's own Program Plan (which must be submitted to the NRC). According to NUREG-0700, it should include four phases: (1) planning (2) review (3) assessment, and (4) reporting. The product of the last phase is a Summary Report which, accord-ing to Supplement I to NUREG-0737, must include an outline of proposed control room changes, their proposed schedules for implementation, and summary justification for human engineering descrepancies with safety signi-ficance to be left uncorrected or partially corrected. Upon receipt of the licensee's Summary Report and prior to implementation of proposed changes, the NRC must prepare a Safety Evaluation Report (SER) indicating the accept-ability of the DCRDR (not just the Summary Report). The NRC's evaluation encompasses all documentation as well as briefings, discussions, and audits.

The purpose of this Technical Evaluation Report is to assist the NRC by providing a technical evaluation of the FSV DCRDR process and results.

The DCRDR requirements as stated in Supplement I to NUREG-0737 can be summarized in terms of the nine specific elements listed below:

1. Establishment of a qualified multidisciplinary review team.

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2. Use of function and task analysis to identify control room operator tasks and 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 HEDs are significant and should be corrected.

6. Selection of design improvements that will correct those

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7. Verification that selected design improvements will provide the necessary correction.

. 8. Verification that improvements can be introduced in the control room without creating any unacceptable human engineering

, discrepancies.

9. Coordination of control room improvements with changes resulting from other improvement programs such as SPDS, operator training, new instrumentation (Reg. Guide 1.97, Rev. 2), and upgraded emer-gency operating procedures.

PLANNING PHASE

1. Qualifications and Structure of the DCRDR Team In order to complete the documentation necessary to evaluate fully PSC's compliance with this requirement of Supplement 1 to NUREG-0737, the NRC requested and received the resume of the human factors specialist (HFS).

A review of the resume has found the qualifications of the HFS to be more than adequate to provide the necessary human factors expertise for the FSV DCRDR. PSC has met this requirement of Supplement 1 to NUREG-0737.

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REVIEW PHASE ,

PSC's review or exesution phase activities included the following:

1. Task Analysis

2. Control Room Survey

3. Operating Experience Review l Activities 1 and 2 addressed specific DCRDR requirements contained in Supplement 1 to NUREG-0737. PSC included in Activity 1 not only a definition of emergency operation tasks and task information and control requirements but also a verification that the task requirements were present in the control room and a validation of the control room in supporting emergency operations. An operating experience review is not required by Supplement I to NUREG-0737 and therefore will not be discussed at length in the TER. However, to summarize, the NRC found that PSC's operating experi-ence review provided valuable contributions to the DCRDR.

1. Function and Task Analysis and Comparison of Control and Display Requirements With a Control Room Inventory PSC submitted filled-in "Information and Control Requirements" forms used for the following two postulated events: Assurance of Core Cooling -

Primary Flow and Adequate Core Cooling - General. These forms were divided into the following five columns: Ta s k /S te p, Information and Control Requirements, Specific Requirements (Range / Scale / Resolution), Existing Instrument / Control, and Remarks. A review of these filled-in forms found that PSC satisfactorily identified information and control needs for each task / step involved in the procedure being exercised and verified the adequacy of the control room instruments in satisfying the information and control requirements.

The licensee also provided filled-in data forms of the validation of E0P steps, actions, information and control needs, tra ffic patterns, and component locations. The forms consisted of operational flow diagrams, task analysis walk-through forms, layout diagrams of the control room, and front panel elevation maps which indicate operator task locations. The task analysis walk-through forms were comprised of columns provided for general 6

i step description, operator cue involved, instruments involved by step, alarms, communications, and remarks. The events covered by the filled-in forms were Reactor Shutdown and Assurance of Adequate Core Cooling.

A review of the submitted documentation confirmed the NRC's previous conclusion that these activities were thoroughly performed. PSC has demon-strated the performance of a task analysis and a verification and validation of control room capabilities which satisfies the Supplement 1 to NUREG-0737 requirements for (1) a Function and Task Analysis, and (2) a Comparison of Control and Display Requirements with a Control Room Inventory.

2. Control Room Survey PSC submitted sample documentation in response to the NRC's concern regarding the adequacy with which dynamic survey criteria were considered.

A review of the sample documentation of the operator survey questionnaires and E0P walk-throughs found that dynamic criteria were not systematically and comprehensively considered and evaluated. In addition, the CRSRG guide-lines were not used to survey the control room and to identify HEDs; rather, they were used to review design improvements or HED corrections. However, the sample documentation of the detailed study of control and indicator arrangements and groupings demonstrate that PSC's iterative control room improvement design program does take into account human factors principles of a dynamic nature. A review of this sample documentation and the HEDs provided elsewhere in the supplementary information found that PSC had sufficiently considered dynamic criteria to satisfy the NRC's concern in this regard.

In response to the NRC's request for information concerning the criteria in NUREG-0700 that were not included in the control room survey, PSC submitted a computerized listing of NUREG-0700 guidelines which were not addressed or were addressed indirectly during the control room survey. PSC also provided its rationale for not including each item listed in the control room survey.

A review of this documentation found that the rationale for omitting most of the NUREG-0700 criteria listed was acceptable. Although the inclu-sion of some of the criteria omitted would have allowed a more rigorous 7

survey of the control room to be performed, the omission of these criteria did not preclude an effective and productive survey.

In summary PSC's control room survey could have been more inclusive of established hi an factors evaluation criteria. However, the survey per-formed did identify many deviations from necepted human factors principles through rigorous application of the evaluation criteria used in PSC's survey. PSC has met this requirement of Supplement 1 to NUREG-0737.

ASSESSMENT AND IMPLEMENTATION PHASE

1. Assessment of HEDs The NRC audit team concluded during the in-progress audit that PSC's' overall assessment approach had been well defined and should be described in detail in the Summary Report. A review of the Summary Report found that although PSC's assessment process appeared rigorous and systematic, sample HEDs which demonstrate the use of the rating scales to assess and categorize HEDs and definitions of the four assessment categories would provide a clearer presentation of the assessment process. In the meeting held by the NRC with PSC on July 16, 1985, PSC provided sample HEDs that underwent the assessment process and definitions of the rating scales used in the cate-gorization of each HED. PSC's assessment process accounted for cumulative and interactive effects of innocuous and significant HEDs by referencing photographs of control room components. Attached to or written on these photographs was information listing all the HEDs associated with the parti-cular component. PSC stated that the consideration of cumulative and inter-active effects lead to the upgrading of some HEDs from category 4 to categories of higher significance. Due to the relative ease of correcting certain HEDs, PSC placed HEDs such as inadequate labeling and meter scaling in categories 1 or 2 without performing the assessment process. Labeling HEDs were typically placed in category 1, and those meter scalir.g HEDs that were not safety related were placed in category 2.

PSC's proposed implementation schedule does not differentiate between the correction of HEDs in the four assessment categories. Due to the integrated approach PSC has taken to determine the correction of HEDs and to develop a control room improvement package, all HED corrections PSC is 8

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intending to perform will be implemented prior to start-up following the fourth refueling cycle of FSV.

In conclusion, PSC's HED assessment process was found to be rigorous and systematic. PSC has satisfactorily met this requirement of Supplement I to NUREG-0737.

2. Selection of Design Improvements and Verification That Improvements Provide the Necessary Corrections Without Introducing New HEDs PS C's process for selecting and verifying design improvements, described as the Improvement Design Program methodology, was found to be highly iterative and rigorous. However, the NRC concluded from its meeting with PSC that more imformation was needed that described the documents that formed the bases of the Improvement Design Program methodology. Specifi-cally, the NRC requested that PSC submit the following documentation:

e The 12 Design Directives e The human factors guidelines the CRSRG uses in its review In ad'dition, to enable an adequate evaluation of HED resolutions and the overall control room improvement design package to be performed, the NRC requested PSC to submit documentation which clearly described the specific discrepancy in each HED, its fix, and any documentation such as control panel drawings which illustrates the panel design before and af ter its reconfiguration according to the control room improvement design package.

PSC provided the above-requested documentation in the supplementary i n fo rm a t i on. A review of the 12 Design Directives found them to be quite sufficient as the basis of the Improvement Design Program. Almost all of the Design Directives either met or exceeded the content of that given in NUREG-0700. There were some areas of certain Design Directives that could have been improved (see Appendix A of this TER for suggested improvements).

However, all Design Directives were found to be acceptable as guidance to rely upon in developing and verifying an integrated improvement design package.

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i A review of the guidelines used by the CRSRG in its review of change notices found that although the CRSRG does not conduct a human factors i i

review, change notices presented to the CRSRG must consider established human factors principles. The CRSRG's review of change notices followed the CRSRG Operating Guidelines (EMAP-1). These guidelines direct the change notice coordinator to address the questions contained in EMAP 1 A and 18.

These questions direct the change notice coordinator, among other things, to establish compliance of the change notices to establish (d humar factors principles (e.g., such as those provided in the Design Directives). The CRSRG can disapprove a change notice or suspend its review in the case of noncompliance with human factors principles until satisfactory compliance or justification for noncompliance has been established. The review of the CRSRG guidelines provided by PSC in the supplementary information was found i to address adequately, although indirectly, established human factors principles in the review of change notices and in the verification of selected design improvements.

PSC provided descriptions of each HED, its fix, and supporting documen-tation such as control panel drawings in the supplementary information. In

. general, a review of this material found that the resolution of HEDs associated with the proposed panel design packages submitted thus far was acceptable. Specific comments from this review are presented in the " Review of Panel Design Packages and HED Resolutions" section of this TER.

1. In summary, PSC's process and results in the selection and verification of design improvements have been found to be acceptable. The 12 Design Directives and the CRSRG review guidelines have been found to be acceptable as the bases of this process. If the panel design packages remaining to be submitted are of similar quality to those submitted to date, then the

! Supplement 1 to NUREG-0737 requirements for the (1) Selection of Design i Improvements and (2) Verification That the Improvements Provide the Necessary Corrections Without Introducing New HEDs will have been met.

3. Coordination of the DCRDR With Other Improvement Programs The NRC concluded from its meeting with PSC that in order to progress j towards closing out this requirement of Supplement 1 to NUREG-0737, the l l following documentation should be submitted by PSC:

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e A description of how the DCRDR is being coordinated with training and staffing (other than resolution of HEDs) and the SPDS.

e A schedule outlining the dates for completion of its NUREG-0737, Supplement 1 initiatives since the integration of improvement programs impacts the DCRDR schedule.

PSC provided information corresponding to the above documentation needs in Attachments 7a and 7b of the supplementary information submitted October 29, 1985. Attachment 7a describes how the DCRDR is being coordinated with training and staffing (other than resolution of HEDs) and the SPDS as appli-cable to NUREG-0737, Supplement 1 initiatives. Attachment 7b gives the schedule for completion of SPDS installation DCRDR, the Reg. Guide 1.97 review, E0P upgrade, and overall control room improvement activities.

A review of the information provided found PSC's coordination of the DCRDR with training and staffing and the SPDS to be satisfactory. PS C's coordination of the DCRDR with training and staffing is approached through the existing design control process. All control room changes documented in change notices are reviewed by the CRSRG. PSC indicates in Attachment 7b that all NUREG-0737, Supplement 1 initiatives will be completed prior to Fort,St. Vrain's fourth refueling outage. Although PSC did not state in the supplementary information when the fourth refueling outage will occur (PSC did mention Spring 1987 in the meeting), its phasing for completion of these initiatives is acceptable.

In summary, the documentation provided by PSC in Attachments 7a and 7b satisfactorily describes coordination of the DCRDR with sta ffing and training and the SPDS. PSC's coordination of the DCRDR with the other improvement programs, if completed as described in the supplementary information and Summary Report, will meet the requirements of Supplement 1 to NUREG-0737.

REVIEW OF PANEL DESIGN PACKAGES AND HED RESOLUTIONS In response to the Supplement 1 to NUREG-0737 requirement to provide proposed control room changes, implementation schedules, and justifications for safety-significant HEDs left uncorrected or partially corrected, PSC has I 11

provided proposed panel design packages in its submittals dated October 29, 1985 and December 3,1985. Due to its integrated approach to making modifications to panels and resolving HEDs, PSC is submitting 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. These panel design packages typically include a list of all HEDs associated with a particular panel or panel section, copies of the HED evaluation forms, elevation drawings showing the original and modified panel configurations, sample copies of operator interview records documenting operator feedback on proposed modifications, a summary of the proposed changes for the particular panel, and a list of the labels on the panel. Comments on each of the panel design packages submitted thus far are provided below. Appendix B of this TER indicates PSC's schedule for submittal of the remaining panel design packages.

Panel I-01 Design Package A review of the material describing the methodology, resolution of HEDs, and proposed modification of panel I-01 found PSC's plans to be acceptable. With the exception of the HEDs cited below, the resolution of individual HEDs was found to be acceptable. PSC should provide responses to the concerns discussed below:

HED 698 (Category 2) - The discrepancies described are that there is no indicator associated with the 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 demarca-tion will be added in addition to functional 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 reactor pump up and pump down actions, the cost versus benefit factor doesn't support a system redesign." PSC does not cite behavioral and opera-tional factors in its justification for not taking corrective action for this portion of the HED. In order to progress towards an accept-able resolution of the HED, PSC should provide either a correction to this portion of the HED or a justification based upon behavioral and operational factors.

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HED 704 (Category 2) - The discrepancy described is that all delta I pressure controllers work opposite to other controllers. The resolu-  ;

tion described is that some of the discrepant controllers (PDC-2548-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 labelled with parameter control positions such as "INCR," "DECR"; and 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-PDC-2555 does not clearly address the discrepancy. PSC should provide a clearer explana-tion of how relocating the controllers to panel I-48, placing them "in remote" and operating them from " panel I-9310 local setpoint" corrects this discrepancy.

Panel I-02 Design Package A review of the material describing the methodology, resolution of HEDs, and proposed modification of panel I-02 found PSC's plans to be acceptable. With the exception of the HEDs cited below, the resolution of individual HEDs was found to be acceptable. PSC should provide a response to the concerns discussed below:

HED 400 (Category 3) - The discrepancy described is that two hand-switches (Emergency Water Boost Pumps I A and IB) should be but are not located together on panel I-05 near associated functions. The reso-lution described appears to be that the discrepant handswitches will be temporarily grouped with Bearing Water Controls on panel I-02 and that regrouping of instruments on panel I-05 will be approached with the intent of locating the two discrepant handswitches with associated controls on panel I-05. It does not appear that the location of the two handswitches will be finalized until the instrument regrouping on panel I-05 is finalized. The evaluation of the correction to this discrepancy will not be completed until the finalized regrouping on panel I-05 is submitted for NRC review (scheduled for 2/18/86).

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.O Helium Circulator Brake and Seal Indication Design Package A review of the materials describing the methodology, resolution of HEDs, and proposed modification to the Helium Circulator Brake and Seal indications found PSC's plans to be acceptable.

Annunciator Control Switches for Panels I-01, I-02, I-03, I-05, I-06, and I-13 Design Package A review of the materials describing the methodology, resolution of HEDs, and proposed modification to the annunciator controls found PSC's plans to be acceptable, provided no operator reach problems are introduced by the new annunciator control switch locations.

Panel I-03 Design Package A review of the material describing the methodology, resolution of HEDs, and proposed modification of panel I-03 found PSC's plans to be acceptable. With the exception of the HEDs cited below, the resolution of individual HEDs was found to be acceptable. PSC should provide responses to the concerns discussed below:

HED 597 (Category 1) - The discrepancy described is that the startup, wide range and power instruments are marked in arabic numerals while the corresponding references on panel I-10 are in Roman numerals. The resolution described is that the Roman numerals will be retained and the arabic numerals changed to Roman. PSC states that this will make it consistent with industry practice. However, industry practice for numerals in general (not specific to individual instrumentation) and that recommended by NUREG-0700 is that numerals be in arabic, not Roman. PSC should explain how this is consistent with its Design Directive corresponding to the use of numerals.

HED 654 (Category 1), 496 (Category 4), and 661 (Category 2) - One of the discrepancies described for recorders 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, range of readings).

The resolutions described cite the relocation of recorders to panel I-14

. ', I 09, the addition of an indicator, an explanation mentioning the recorder (s) not being an operator tool but one used by Tech Services, and the unchangeability of the recorders. It is not clear from the i 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.

HED 655 (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 seetn 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 information. In addition, PSC should describe the resolution of the discrepancy associated with recorder NR-1131-1.

Panel I-04 Design Package A review of the materials describing the methodology, resolution of HEDs, and proposed modification of panel I-04 found PSC's plans to be acceptable.

Remote, I-06J, and I-15 Annunciator Unit Installations Design Package A review of the materials describing the methodology and proposed modification of the annunciator units for the remote, I-06J and I-15 panels found PSC's plans to be acceptable.

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Panel I-09 Recorder Movo Design Package A review of the material describing the methodology, resolution of HEDs, draft Design Directive for selection of recorders, and proposed modi-fication 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. Specifi-cally, the concern is for recorders related to controls and displays on panels other than I-09 that may need to remain with these components in order to maintain or establish functional grouping and support plant opera-tions. PSC should indicate if any recorders needed to support plant opera-tions on panels other than I-09 have been moved to I-09, and if so, how i operations will be conducted satisfactorily in each case. In addition, PSC should respond to the concerns discussed below:

HED 653 (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.

HED 654 (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, away from similar instruments. For those recorders relo-cated 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.

l HED 655 (Category 1) - The discrepancy described is that recorder scales are not clearly readable and resolvable from the operating l l

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position. The resolution 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.

HED 658 (Category 2) - The discrepancy described is that the recorders have more than six points or channels being recorded. The resolution described for recorders GR-5154. TR-5156, and TR-92105 is that these recorders are used to monitor plant parameters from which plant adjust-ments 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 parameters from 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 cites behavioral or operational factors (e.g., potential operator error and consequences / impact of postulated error (s) upon plant opera-tions and safety) to an extent greater .than that generally implied by the HED category assignment.

., HED 695 (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 func-tional grouping of these recorders with related controllers still does not exist.

HED 746 (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 or 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 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).

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HED 786 (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.

Hydraulic System Control / Indication Functional Grouping on Panel I-06A Design Package A review of the materials describing the methodology, resolution of HEDs, and proposed modification to the Hydraulic System control / indication functional grouping on panel I-06A found PSC's plans to be acceptable.

Control Room Furnishings and Arrangements Design Package A review of the materials describing the methodology, resolution of HEDs, and proposed modification to control room furnishings and arrangement found PSC's plans to be acceptable.

Control Room Lighting Design Package A review of the materials describing the methodology, resolution of HEDs, and proposed modification to the control room lighting found PSC's plans to be acceptable.

Operator Aids Design Package A review of the materials describing the methodology / procedure, resolu-tion of the HED, and proposed application of operator aids found PSC's plans to be acceptable.

l SUMARY AND CONCLUSIONS The supplementary information provided by PSC thus far has addressed the concerns of the NRC that remained from the July 16, 1985 meeting.

Through this documentation, past documentation, and discussions and meetings l

18

i. . .

held with the NRC, PSC has demonstrated a strong commitment towards meeting the DCRDR requirements of Supplement I to NUREG-0737 and improving the human factors design, operability, and safety of its control room and remote

( shutdown capability, especially through the process conducted in the I

Improvement Design Program and the corresponding results of the program as described in the panel design packages submitted to date. Corrective actions were taken on approximately 99% of the HEDs listed in the panel design packages. Approximately 98% of the discrepant controls and displays corresponding to the panel design packages submitted were associated with corrections. In addition, PSC is to be commended for establishing a basis for performing human factors reviews of future, post-DCRDR changes to the control room through the use of its Design Directives.

According to PSC's schedule for completion of NUREG-0737, Supplement 1 initiatives, it will continue to submit design packages to the NRC until the last submittal dated 8/19/86 (see Appendix B of this TER). The NRC's review of PSC's DCRDR at FSV will be completed upon receipt of all scheduled DCRDR submittals from PSC provided that the submittals are found to be acceptable with no significant concerns identified. In order to progress towards the completion of the FSV DCRDR, PSC should continue to submit design packages according to its schedule. In addition, PSC should provide responses to those concerns identified with the HEDs listed in the " Review of Panel Design Packages and HED Resolutions" section of this TER and to any concerns identified with the remaining submittals. The following is a summary of the NRC's conclusions regarding each requirement of Supplement I to NUREG-0737:

e Qualifications and Structure of the DCRDR Team PSC has satisfactorily met this requirement.

e Function and Task Analysis l PSC has satisfactorily met this requirement.

e Comparison of Control and Display Requirements With a Control Room Inventory PSC has satisfactorily met this requirement.

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e Control Room Survey PSC has satisfactorily met this requirement.

e Assessment of HEDs PSC has satisfactorily met this requirement.

e Selection of Design Improvements PSC's process and results in selecting design improvements have been found to be acceptable. If the panel design packages remaining to be submitted are of similar quality to those submitted thus far, then PSC will have met this requirement .

e Verification That the Improvements Will Provide the Necessary Corrections Without Introducing New HEDs l PSC's process and results in verifying design improvements have been found to be acceptable. If the panel design packages remaining to be submitted are of similar quality to those submitted thus far, then PSC will have met this requirement.

e Coordination of the DCRDR With Other Improvement Programs PSC's process and scheduling to coordinate the DCRDR with other improvement programs have been found to be acceptable. If PSC maintains this process and schedule for completing the improvement progra ms, then it will have met this requirement.

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REFERENCES

1. " Fort St. Vrain Nuclear Generating Station Control Room Design Review Program Plan," attachment to letter from H.L. Brey, PSC, to J.T.

Collins, U.S. NRC, dated July 13, 1983.

2. " Nuclear Regulatory Commission Sta ff Comments on the Fort St. Vrain Detailed Control Room Design Review Program Plan," attachment to memorandum from W.T. Russell, U.S. NRC, to G.C. Lainas. U.S. NRC, dated November 22, 1983.

3. " Nuclear Regulatory Commission In-Progress Audit of the Detailed Control Room Design Review for Fort St. Vrain Nuclear Generating Station," attachment to memorandum from V.A. Moore, U.S. NRC, to E.

Johnson, U.S. NRC, dated May 7, 1984.

4. "Public Service Company of Colorado Fort St. Vrain Nuclear Generating Station Control Room Design Review Summary Report," attachment to

' letter from D.W. Warembourg, PSC, to E.H. Johnson, U.S. NRC, dated April 30,1985.

~ 5. "Results of Staff Review of the Ft. St. Vrain Detailed Control Room Design Review (DCRDR) Summary Report," included in memorandum from W.H.

Regan, Jr., U.S. NRC, to E.J. Butcher, U.S. NRC, dated August 16, 1985.

6. "NRC Meeting With Public Service Company of Colorado Concerning the Detailed Control Room Design Review of Ft. St. Vrain Nuclear Generating Station," enclosure to memorandum from W.H. Regan, Jr., U.S. NRC, to E.J. Butcher, U.S. NRC, dated August 16, 1985.

7. "Public Service Company Response to the Nuclear Regulatory Commission's

' request for additional information' (Detailed Control Room Design Review Summary Report)," attachment to letter from D.W. Warembourg, PSC, to E.J. Butcher, Jr., U.S. NRC, dated October 29, 1985.

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8. "Public Service Company Response to the Nuclear Regulatory Commission's

' request for additional information' (Detailed Control Room Design Review Summary Report)," attachment to letter from D.W. Warembourg, PSC, to H.N. Berkow, U.S. NRC, dated December 3, 1985.

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

10. NUREG-0737, " Requirements for Emergency Response Capability," U.S. NRC, Washington, D.C., November 1980.

11. NUREG-0737, Supplement 1 " Requirements for Emergency Response Capabil-ity," U.S. NRC, Washington, D.C., December 1982, transmitted to reactor licensees via Generic Letter 82-33, December 17, 1982.

12. NUREG-0700, " Guidelines for Control Room Design Reviews," U.S. NRC, Washington, D.C., September 1981.

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

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e APPENDIX A REVIEW COPMENTS ON THE DESIGN DIRECTIVES I

\

23

. 1 DD-AAS-1: Abbreviation, Symbol, and Acronym Selection A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements. PSC should ensure that the listing of abbreviations and acronyms is comprehensive of all needed abbre-viations and acronyms (e.g., abbreviation for " pump").

DD-ASP-1: Annunciator Selection and Placement (draft)

A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements with the exception of two areas of concern:

1. Criteria have been omitted on reflash capability for multichannel or shared alarms, even though such criteria were present in the FSV control room survey.

2. Some criteria have been omitted concerning first out annunciators, even though such criteria were present in the FSV control room survey. It is not clear whether tFe information listed in Table B (referenced on p. 5 of the Design Directive) satisfies the need for such criteria.

DD-CBL-1 : Control Board layout (draft)

A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements. Even though the application of mimics on FSV's densely populated control boards may be minimal, PSC should consider including specific criteria for applying mimics (e.g., mimic line dimensions, use of arrows, etc.) since the density of components on the control boards mandates careful techniques for mimic design and application.

DD-APL-1: Annunciator Panel Legends (draft)

A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements.

l l

l 24 1 i

DD-CRL-1: Cathode Ray Tube Location and DD-CRT-1: Cathode Ray Tube Selec-tion A review of these Design Directives found them to be acceptable as bases for selecting and verifying design improvements.

DD-ILS-1: Indicating Lamp Selection and Location A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements. Although PSC may have some significant problems with providing lamp test capability or dual bulbs / fila-ments for the FSV indicator lights in some areas of the control room, the apparent omission of criteria on lamp test provisions or dual bulbs / fila-ments from this Design Directive may preclude the consideration and incor-poration of such capabilities in the Improvement Design Program and in the future. Although PSC is incorporating lamp test capability in some areas of the control room, other areas needing lamp test capability are not to be provided with such. The lack of lamp test capability for these areas should be addressed by reasonable justification for not taking corrective action, not by omitting relevant criteria from the Design Directive. That is, not taking corrective action on discrepancies such as the lack of lamp test provisions should be justified, not avoided.

DD-KEY-1: Keyboa rds A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements.

DD-SLS-1: Screen Layout and Structuring A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements. This Design Directive could be improved by adding criteria on the consistency of color coding throughout the control room across various applications such as CRTs, SPDS, control board enhancements, etc.

25 I

.i

. DD-AIS-1: Selection of Analog Indicators (draft)

A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements.

DD-LAB-1 Control Room Panel and Component Labeling A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements.

DD-SWI-1: Switch Selection A review of this Design Directive found it to be acceptable as a basis for selecting and verifying design improvements. A concern exists regarding Figure 5 in this Design Directive in that the preferred and alternate instrument number locations for switches may be obstructed by the switch handle. PSC may want to consider investigating the feasibility of using one of the lower corners (e.g., lower right) of switch escutcheons or the area just below one of the lower corners to locate instrument numbers (without detracting considerably from the functional labeling).

26

.,s. & ,-s n'

o l

l APPENDIX 8 PSC'S SCHEDULE FOR IMPLEENTING THE CONTROL ROOM IMPROVEMENT PROGRAM 4

l 27 i

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