ML20207K609
ML20207K609 | |
Person / Time | |
---|---|
Site: | Zion File:ZionSolutions icon.png |
Issue date: | 12/30/1986 |
From: | Leblond P COMMONWEALTH EDISON CO. |
To: | Harold Denton Office of Nuclear Reactor Regulation |
References | |
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.1, TASK-TM 2548K, NUDOCS 8701090464 | |
Download: ML20207K609 (77) | |
Text
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i
- s) One Fwst Nabonal Plaza. Chica00. IlliDoiS Address Reply tx Post Omce Box 767
/ Chicago, Illinois 6069U. 0767 December 30, 1986 Mr. Harold R. Denton, Director' office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Connaission Washington, DC 20555
Subject:
Zion Nuclear Power Station Units 1 and 2 Detailed Control Room Design Review -
NUREG-0737, Item I.D.1 NRC Docket Nos. 50-295 and 50-304 References (a): May 1, 1986, letter from P. C. LeBlond to H. R. Denton (b): Augu.at 21, 1986, letter from S. A. Varga to D. L. Farrar.
Dear Mr. Denton:
Reference (a) provided the NRC Staff with copies of the Detail?d control Room Design Review (DCRDR) final sunsaary report for Commonwealth Edison Company's Zion Station. This report both summarized how each phast of the review was conducted and identified all of the human engineering discrepancy (HED) findings along with Commonwealth Edison's responses and proposed schedule for_the implementation of the respective corrective actions. Reference (b) provided Commonwealth Edison Company with a list of the NRC Staff's concerns that resulted from their review of reference (a).
A meeting was held on December 11, 1986 in Bethesda, MD between Commonwealth Edison personnel and Mr. J. A. Norris, along with other members of the NRC Staff and their contractors. The concerns transmitted in reference (b) formed the basis of that discussion.
Enclosed with this letter is six copies of Commonwealth Edison Company's response to the individual issues discussed at the December 11, 1986 meeting.
It is our understanding that the information contained in j
this report, with the exception of the issues discussed below, are i
acceptable to the NRC Staff.
j The December 11, 1986 meeting resulted in the identification of seven (7) general issues for which agreement was'not reached.
In addition, Commonwealth Edison personnel have identified six (6) issues that require updating from the information previously provided in reference (a). A brief discussion of these thirteen issues is provided in the attachment to this The information needed to resolve these issues will be provided to [6 letter.
the NRC Staff by July 1, 1987.
a k\\
8701090464 861230 L
PDR ADOCK 05000295 g
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Mr. H. R. Denton December 30, 1986 Reference (a) provided the NRC Staff with the currently planned refueling outages for Zion Units 1 and 2.
In addition, an approximate nine month lead time was established to adequately plan for these refueling outages. As discussed at the December 11, 1986 meeting, Commonwealth Edison Company will utilize the outages delineated in reference (a) as the first and second refueling outages for DCRDR planning purposes, if NRC approval for the nondisputed issues is obtained prior to March 1, 1987.
If any questions arise concerning this matter, please contact this office.
Very truly yours, P. C. LeBlond l
Nuclear Licensing Administrator 1m Attachments Enclosures cc: Region Inspector - Zion J. A. Norris - NRR 4
2548K
ATTACHMENT HED #s SUBJECT (Page No.)
363, 403 Schedule for addition of component cooling (5-5) pressure gauge 285, 186, 188, 151, 367 Schedule for addition of critical radiation (5-6) monitor display 124 Schedule for print-out capability for multi-(5-7) input alarms.
54 Schedule for ensuring consistency between (5-8) annunciator tiles and printout.
290 Method to be utilized to minimize control (5-41) room lighting glare.
406 Instrument air white light indicates " standby".
(5-42) 307 The labeling of fuses to reduce delays.
(5-57)
The above seven issues were identified at the 12/11/86 meeting. The six issues below represent the additional items of clarification briefly discussed on 12/11/86.
133, 322, 391, 134, Movement of 3 specific annunciators. Subsequent (5-52) review reveals inadequate room for the Ercess Letdown Heat Exchanger alarm.
234, 392, 435, 79, 227 Key-lock switches on the main control board will i
222 be replaced.
(N.A.)
i l
\\
i
e
. (Cont'd)
HED #s SUBJECT (Page No.)
42 Same issue as HED 54, page 5-8 discussed above.
(263) 43 There is no " HELP" function on the computer (264) system.
It may be a more substantial effort than previously believed.
233 The replacement of the feedwater header isolation (157) valve switches may not be necessary due to revised valve usage.
72 Zion Station may reduce the test frequency to (118) once per day.
NOTE: Page numbers refer to either the original submittal or the revised responses 4
2548K
i COMMONWEALTH EDISON COMPANY
- l RESPONSE TO AUGUST 21, 1986 LETTER OF REQUEST FOR CLARIFICATION OF
=
ZION STATION DCRDR I
FINAL
SUMMARY
REPORT RESPONSES DECEMBER 19, 1986 l
I I
l i
I
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 2 NRC/SAIC COMMENT Use of Color Codine and Backaround Shadino There is a concern associated with the use of background shading for resolving HEDs that address functional grouping of control panel instrumentation.
Independently of the six colors used in the licensee's color-coding standard, which is within the NUREG-0700 guidelines (n=11) for color usage with enhancements, the background shading program appears to introduce an additional 28 colors that are to be associated with various systems found in the control room.
CECO's excessive use of color is unacceptable since it is not in keeping with reasonable human engineering practice.
This overuse of color could lead to a reduction in the effectiveness of this technique and possibly introduce operator confusion and error.
The licensee should reexamine the proposed use of color, particularly in conjunction with the back-ground shading at Zion Station and be able to provide assurance that the proposed applications will not be counter productive.
The following HEDs are to corrected by the proposed background shading enhancements and the color-coding standard.
lied Page RED Pace 0332, 0413, 0156, 0329 284 0221, 0328, 0352 307 0376 285 0355 309 0150 291 0159 312 0333, 0395, 0166, 0432 294 0160 313 0335 296 0161 314 0354 298 0163 316 0393 299 0165 317 0389 301 0145 338 i
CLARIFICATION:
)
i A primary technique for allowing the operator to sort out the
]
immediately relevant from the irrelevant stimuli is the enhance-ment of displays and controls.
Effective enhancement permits i
timely acquisition of meaningful information, facilitates correct identification of relevant control options, and allows the operator to maintain effective cognizance over system status.
2-1
Surface techniques such as using demarcation and mimic lines, color shading, and other cues are primary techniques for layout enhancement.
Color enhancement is used in nuclear power plant control rooms to help clarify component indentification and functional relationships relative to other components.
Many problems, such as large matrices of undifferentiated components, physically displaced controls and their associated displays, can be remedied through color shading.
Background shading also improves the efficiency of information transfer to the operator and assists his decision-making process by organizing panel elements minimizing existing visual clutter, optimizing desired associations between panel elements, and standardizing information presentation.
Color enhancements also can facilitate learning and retention of where components and controls are located, especially for new operators.
Components having a common color also are seen as forming a group.
Since the goal of shading is to provide operator aids, if the operator does not agree with or approve the enhancement, it probably will not be successful.
Operator participation is a requirement throughout the color shading process and was integral during the selection of color enhancements at Zion Station.
SAIC makes reference to the number of colors used for coding should not exceed eleven and should be kept to the minimum needed to provide sufficient information as identified on page 6.5-11 in NUREG-0700.
We reiterate that Zion uses only six colors for coding purposes.
The color shading does not represent system status or state. It is merely a perceptual aid designed to facilitate system identification.
There is no meaning assigned to the shading and the shading should not be conceived of as coding.
Another factor in determining the ultility of background shading is the area of the surface to which we are applying background shading.
A control room the size of Zion's boards can afford to use a greater number of color enhancements than control rooms with lesser area, provided it has been systematically applied using sound human engineering and operating principles.
Several industry documents recognize the utility of using a number of background shading colors.
One EPRI document advocated and I
provided an example which included eight colors for one sample panel.
In addition, there are precedents set throughout the industry which clearly demonstrates the effectiveness of using over twenty colors for enhancment to support system identifica-I tion.
A total of nineteen colors have been chosen to be applied across I
the main control boards at Zion for background shading.
Principles for color use, outlined in sections 6.5 and 6.6 of NUREG-0700, guided the selection of colors to be used on the 2-2
control panels.
Colors were selected from a pool of high-contrast and matte finish shades used at other stations applied against a "Kewanee Beige" board color.
As an engineered retrofit, their application extends from a total-board design evaluation that followed a system-by-system approach.
In general, controls and displays at Zion were found to be grouped by function with few " extraneous" or " maverick" compon-ents.
- However, in these cases, background shading affords a means to functionally group these components.
Both the main component group and their " maverick" components in a system will be colored identically.
Safety-related component groups will be background shaded.
For example, engineered safeguards monitor lights and manual activa-tion controls are located primarily on the engineered safeguards panel.
However, these controls and displays also appear on panels across the total benchboard area.
Similarity of func-tion, in these cases, served as the basis for their grouping by a common background shade.
Background shading will also be applied to systems nested among others.
In the few cases this technique will be applied, a high I
contrast background shade applied to the centrally positioned group will enhance the separation of adjacent systems.
On the whole, the selection and use of background shading is designed to work in concert with other perceptual aids and the
' placement design of instruments.
The total-board design evaluation will hold in check the potential overuse of one or more perceptual aids.
Thus, where background shading will be applied, use will be conservative, necessary and meaningful for operator performance.
In addition, lines of demarca' tion will be used, where possible, to enhance system grouping.
Demarcation will be used between closely-spaced but functionally distinct systems that do not have individual components placed within other system groupings.
The use of demarcation instead of background shading, in these instances, will prevent the overuse of color.
The proposed demarcations consists of circumscribing functional or selected groups with a contrasting line in areas where physical space or panel edges do not already visually set apart the related components.
CWE:91-86 2-3
ISSUE 3 NRC/SAIC COMMENT Verification That Selected Desian Imorovements Will Provide the Necessary Corrections and Will Not Introduce New HEDs The Zion in-progress audit report indicated that when accom-
- plished, the proposed verification process should meet the requirements of Supplement 1
to NUREG-0737.
However, having reviewed the proposed use of color and background shading, there is a
concern with the high number of colors to be used and the excessive application of the background shading technique.
The review team is concerned that this problem may stem from an ineffective application of the verification process.
The licensee should provide documentation to assure that a formal plan has been applied for accomplishing a
rigorous and I
integrated verification of design improvements.
CLARIFICATION:
I The corrective actions to be implemented at Zion are reviewed to ensure their effectiveness from a
human engineering perspec-tive.
The CECO verification process utilizes both static and dynamic reviews.
The corrective action review team consisting of human factors specialists and CECO Nuclear Services Technical personnel are supported on an as needed basis by subject matter experts and people from appropriate engineering disciplines, similar to the process used during the DCRDR.
In addition, the team members have at their disposal all information generated on the Zion DCRDR data base.
The static review includes the application of appropriate guidelines and standards to each corrective action to ensure compliance with accepted human engineering considerations.
The dynamic review includes the application of techniques to determine the operational impact the proposed design change will have on the operations of the plant.
Various approaches to discerning these influences are available to the review team.
These include:
table top reviews, surveys and interviews with operations personnel, mock-up and simulation.
The technique selected is based upon the nature and extent of change resulting from the design modification.
]
At
- present, each control room modification for Zion station is I
required to be reviewed by the human factors group at CECO.
For each mod
- received, a human factors evaluation is conducted and recommendations forwarded to the cognizant engineer.
3-1
The utilization of color enhancement at Zion is a very effective tool in addressing a number of discrepancies as stated in Item 2.
The background shading proposed in the final summary report was preliminary in nature and had not been through the entire verification process.
The enhancements have not yet been finalized.
We are still going through final design iterations prior to commencement of the design change.
These final design changes are pending integration with other modification efforts (i.e.
heirarchical
- labeling, lines of demarcation, instrument and control relocation, and mimics) to ensure integrated and effective control boards.
The Zion verification process follows the guidelines established by the industry and is applied in a systematic fashion to verify the effectiveness of each design change.
1 I
I CWE:91-611-17-101 3-2
NRC COMMENTS ZION STATION 19 DECEMBER 1986 j
ISSUE 5 A
)
HED #s:
0281. 0345. 0356. 0402. 0097. 0337 CATEGORY : _L LEVEL: A i
CECO RESPONSE:
Narrow range steam generator meters will be added for each of the four steam generators on CB08.
l NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation schedule is required.
CECO CLARIFICATION:
A problem was identified when steam generator (SG) level dropped, resulting in a reactor trip.
This occurred during start-up while using Aux FW to control level from CB05, where SG wide range level indications are available.
At power, Aux FW is in STBY and FW is controlled at CB08 where there are narrow range level indications.
When the operator controls on Aux FW from CB05, he occasionally likes to use narrow range level.
indications on CB08, which is about 15 feet away from CB05.
Duplicate narrow range SG indicators should be added to CB08 (next to the auxiliary feedwater (AFW) controls) to minimize travel when it is desirable to use narrow range SG level to control AFW.
Although this control is not time-critical and not important from a safety point of view, narrow range steam generator meters will be added for each of the four steam generators on CB08.
Because of the infrequent use and minor inconvenience to the operator, completion by second refueling outage should be adequate.
I CWE 91-611-17-03 5-1
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0284. 0405. 0365. 0287. 0148. 0323 CATEGORY:_1_ LEVEL: A CECO RESPONSE:
A dedicated narrow range two pen recorder will be added to CB06 to display auctioneered high Tavg and Tref.
This will allow the computer-driven recorder which is currently used for Tavg and Tref to be available for subcooling trends in post accident situations.
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
Because of fluctuating average temperature (Tavg) during start-up, an operator must adjust rod position at CB06 to regulate temperature, using the full rod motion control.
The nearest narrow-range Tavg recorder is at the right end of CB06, about 8 feet, on a computer assigned recorder which can measure narrow range.
About 3 feet to the right of the rod position adjustment location are meters for each loop's Tavg and a wide-range Tavg recorder.
The operr. tor prefers that the narrow-range Tavg recorder be near the rod position control.
In addition, the operator can trend subcooling only by the computer or manually.
A dedicated narrow range two-pen recorder will be added to CB06 to display auctioneered high Tavg and Tref during the second refueling outage.
This will allow the computer-driven recorder which is currently used for Tavg and Tref to be available for subcooling trends in post accident situations.
CWE 91-611-17-03 5-2
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0330. 0362. 0390 CATEGORY:
1 LEVEL:
B I
CECO RESPONSE:
A meter for pressurized pressure (with the range of 0-3000 psig) will be added to CB06.
The reactor coolant system pressure indicators will be rearranged to insure functi'onal grouping.
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
A midrange (500-1700 psig) pressurizer pressure meter is needed on CB06.
Currently, there are four meters (PI-455A, PI-456, PI-457, and PI-458) and a recorder (PR-455) which cover a range of 1700-2500 psig; a meter (PI-403) covering a range of 0-600 psig; and a wide range recorder (PR-403) covers 0-3000 psig.
While the wide range meter covers the requested range, the divisions are too great (50) to meet operational requirements.
The 0-600 psig meter for pressurizer pressure on CB06 will be changed to a meter with the range of 0-1800 psig and divisions of 20.
The reactor coolant system pressure indicators will be rearranged to insure functional grouping.
Because of the infrequent amount of time that the pressurizer pressure is in the affected range, and because of various other pressure indications available, it is adequate to complete this meter change by the second refueling outage.
CNE 91-611-17-03 5-3
I l
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0343. 0315 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
Computer graphics for the process computer will be designed to display the cited parameters.
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
The operators indicated that it vould be useful to have the capability to trend more computer points.
Specifically, I
indicators for bearing temperatures for the emergency core cooling system (ECCS) pumps, residual heat removal, component cooling water, auxiliary feedwater, and safety injection are needed in the control room.
Rapid bearing temperature I
determination may prevent pump burnout.
Currently, the ECCS pump bearing temperatures are obtained from the computer.
Computer graphics for the process computer will be designed to display the cited parameters.
Because of the complexity of adding sensors to the bearings and computer programming to estab3.ish graphics, it will be tight trying to meet the second refueling outage.
The equipment is periodically inspected for problems and some have local bearing temperaturc indications; this should continue to suffice until surveillance is expanded by the computer graphics.
Pump destruction by bearing failure is infrequent and minimized by existing pump maintenance.
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CWE 91-611-17-03 5-4
1 NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0363. 0403 CATEGORY:
1 LEVEL:
A CECO RESPONSE:
A component cooling system pressure indicator with a range of 0-200 psig will be added to CB08.
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
During the validation, it was observed that the component cooling systems, an engineered safety feature system, does not I
have an indication of system pressure.
Subject matter experts commented that the lack of this indication can contribute to operational problems, particularly in a transient condition involving auxiliary building contamination and component cooling restarts following pump trips.
- However, there are six annunciators that deal only with component cooling (CC) pumps, one of which identifies low CC pump discharge pressure.
A component cooling system pressure indicator with a range of 0-200 psig will be added to CB08.
However, because of the identified indications, it is not detrimental if this improvement is not completed until the second refueling outage.
NOTE:
This item remains open pending the assimilation of additional information.
This information vill be forwarded per our discussion with the NRC on 12/11/86.
CWE 91-611-17-03 5-5
NRC COMMENTS i
ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0285. 0186. 0188. 0151. 0367 CATEGORY:
1 LEVEL:
A CECO RESPONSE:
A Ramtek computer will be added to the primary operating area to display all critical radiation monitoring parameters.
Due to the time required for the coordination, design, and procurement I
of equipment for this modification, it will be completed by the third refueling outage.
NRC/SAIC COMMENT:
Proposed implementation dates are such that I
further justification for implementation is required.
CECO CLARIFICATION:
It was reported in the operator survey that a status panel of radiation monitoring meters is needed in the primary operating I
area.
Presently, these monitors are located on the back panels.
Specifically, the four radiation monitoring recorders (on CB73) would be more appropriately placed in the main operating area.
In addition, the numerals on the point displays for four of the recorders have rubbed off so that the point being monitored cannot be determined.
A Ramtek computer will be added to the primary operating area to display all critical radiation monitoring parameters.
Because of the time required for the coorcination, design and I
procurement of equipment for this modification, it will be completed by the third refueling outage.
The present situation is not optimum, but has worked adequately for several years; therefore, the time needed to design and install a new system I
will not affect safe operations.
Annunciators are available to alert the operator that the " ARMS I
are Hi," which prompts the operator to subsequently review the back panel.
This task is not time-critical.
The electrical differences in the instrumentation will require more substantial and complex sof tware programming requiring great design detail.
This, in turn, will have a substantial effect on lead time.
NOTE:
I This item remains open pending the assimilation of additional information.
This information will be forwarded per our discu M on with the NRC on 12/11/86.
CWE 91-611-17-03 5-6
i NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
I HED #s:
0124 CATEGORY:
2 LEVEL:
C CECO RESPONSE:
Printout capability will be provided for all time-critical multi-input alarms.
i NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
There are several annunciators which address more than one specific condition on a single tile.
Printout capability will be provided for all time-critical multi-input alarms.
The design complexity of separating the specific conditions and making the computer printout capability is monumental.
Although not optimum, it has been adequate to use backup information from meters, charts, computer, and local inspections to identify the specific problem related to a multi-point input annunciator.
This should continue to be adequate until the second refueling outage when the work will be complete.
NOTE:
This item remains open pending the assimilation of additional information.
This information will be forwarded per our discussion with the NRC on 12/11/86.
I CWE 91-611-17-03 5-7
NRC COMMENTS ZION STATION 19 DECEMBER 1986 HED #s:
0054 CATEGORY:
2 LEVEL:
C I
CECO RESPONSE:
I The cited annunciator printouts and tiles will be relabeled to contain the same wording.
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
Computer printouts and annunciator tiles do not contain the same wording.
The computer printouts and annunciator tiles will be composed to strive for the same wording.
It is anticipated that the existing annunciators will remain the same, for the most part, with any new annunciators conforming to the standards.
The computer printout will be changed to be more compatible with the annunciator wording, subject to limited field space and a compromise between using the abbreviation standard and the existing annunciator wording.
This is a non-time-critical problem which will take until the second refueling outage to optimize.
NOTE:
This item remains open pending the assimilation of additional information.
This information will be forwarded per our discussion with the NRC on 12/11/86.
i CWE 91-611-17-03 5-8
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0336. 0167 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
The control room vent switches will be swapped with the computer heating ventilation and air conditioning equipment to functionally group the auxiliary building fans together.
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
The auxiliary building fans (on OCB05) are separated by unrelated control room vent switches.
The control room vent switches will be swapped with the computer heating ventilation and air conditioning equipment to functionally group the auxiliary building fans together.
This is not time-critical.
These changes will be coordinated with several other modifications to the OCB05 panel by the completion of the second refueling outage.
A comprehensive and systematically engineered modification will ensure effective response to resolution and verification of interrelated problems and will facilitate training.
CWE 91-611-17-03 5-9 l
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0412 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
The AFW pump 1A steam pressure indicator will be relocated next to the AFW Pump 1A discharge pressure indicator.
I NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
The auxiliary feedwater (AFW) pump 1A steam pressure indicator (on CB08) should be relocated to be adjacent to the AFW pump 1A discharge pressure indicator.
The AFW pump 1A steam pressure indicator will be relocated next I
to the AFW pump 1A discharge pressure indicator.
This action is not time-critical.
These changes will be coordinated with several other modificacions to panel CB08 by the completion of the second refueling outage.
A comprehensive and systematically engineered modification will ensure an effective response to the resolution and verification of interrelated problems and will facilitate training.
CWE 91-611-17-03 5-10
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 HED #s:
0421 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
The cited instrumentation will be swapped to result in an alphabetic, left-to-right order.
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
The CCW from residual heat removal heat exchanger valves and associated displays (on CB08) are not arranc,ed in alphabetic, I
left-to-right order.
The valve control for MOV-CC9412B is to the left of MOV-CC9412A; the HX-lD display is to the left of the HX-1A display.
This action is not time-critical.
The cited instrumentation will be swapped tc result in an alphabetic, left-to-right order.
This change will be coordinated with several other modifications to the CB08 panel.
A comprehensive and systematically engineered modification will ensure effective response to the resolution and verification of interrelated problems and will facilitate training by the completion of the second refueling outage.
CWE 91-611-17-03 5-11
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0372 CATEGORY:
1 LEVEL:
B I
CECO RESPONSE:
The meters and valves will be rearranged to conform to a left-to-right order.
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
During the validation it was noted that the arrangement of the steam supply isolation valves to the auxiliary feedvater turbine driven pump does not reflect a left-to-right manner, nor does it reflect the physical layout of the valves in the plant.
The supply isolation valves from the A & D steam generator precede the common header isolation valve in the plant.
However, the control switch for the common header precedes the control switches for the A & D steam generator isolation valves going from left to right on the control board.
The meters and valves will be rearranged to conform to a left-to-right order.
At present, they are properly labeled and the operators have been trained with the present design.
This design should be sufficient until this modification is completed by the end of the nccand refueling outage, on schedule with other modifications to this same panel.
CNE 91-611-17-03 5-12
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 A
HED #s:
0420. 0261 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
The Unit 2 BIT flow meters will be rearranged to conform to the Unit 1 arrangement (of A-B-C-D).
NRC/SAIC COMMENT:
Proposed implementation dates are such that further justification for implementation is required.
CECO CLARIFICATION:
The order of the boron injection (BIT) flow meters on Unit 2 (on CB07) does not conform to operators' expectations that the order is the same as that of Unit 1.
On Unit 1,
the meters are ordered A-B-C-D, left-to-right; on Unit 2 the meters are order A-C-D-B, left-to-right.
These meters are used during safety injection actuation to determine a course of action.
The Unit 2 BIT flow meters will be rearranged to conform to the Unit 1 arrangement of A-B-C-D.
The tasks associated with these meters are not time-critical; they are infrequently used and are automatic actuation, automatic operation.
They are used to verify whether or not there is a flow in all four.
If not, the deviation is noted and then acted upon.
Although we recognize that a change will support operating, the magnitude of the changes to the Zion board necessitates comprehensive and integrated planning to effectively support the design, training and operating process.
The lack of relative potential for impact, projected for this design change, supports the present modification schedule.
This will be completed by the end of the second refueling outage.
I CWE 91-611-17-03 5-13
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 B
HED #s:
0114 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
Axes labeling will be provided for the annunciator tile matrices.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
The vertical and horizontal axes of annunciator panels will be permanently labeled with alphanumerics for ready coordinate designation of each tile in an expeditious manner.
They will he implemented no later than the end of 1987.
I CWE 91-611-17-03 5-14
NRC COMMENTS ZION STATION 19 DECEMBER 1986 HED #s:
0193 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
The cited displays will be labeled appropriately.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
There are eight displays which do not have printing on the display face or on adjacent labeling providing information about either the parameter being displayed or the units used for the display.
Labels to identify the displayed parameters and/or units of measurement will be applied to the respective instruments in an expeditious manner.
They will be implemented no later than the end of 1987.
I CWE 91-611-17-03 5-15 I
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 B
HED #s:
0]94 CATEGORY:
2 LEVEL:
C CECO RESPONSE:
The meaning for most non-legend indicator lights is apparent due to the color coding standard.
The others will be appropriately labeled.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
The meaning for most non-legend indicator lights is apparent.
Size, shape, color and location of the SVAG valve lights make them unique; a JPA book covering all non-legend light indicators will be developed.
Operators will receive training in the content and use of the JPA prior to its introduction in the control room. This will be completed no later than the end of 1987.
I I
CWE 91-611-17-03 5-16
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 B
HED #s:
0180 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
The cited recorders will be appropriately labeled.
NRC/SAIC COMMENT:
Interim corrective measures should be impicmented.
CECO CLARIFICATION:
Six recorders do not have labels that identify parameters recorded.
A job performance aid, a laminated placecard identifying the unlabeled points, will be located in proximity to the recorder as an interim measure.
Permanent labeling will be implemented prior to the completion of the second refueling outage.
The five remaining recorders will be labeled to identify the red and blue pens by the end of 1987.
CWE 91-611-17-03 5-17
l NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 H
HED #s:
0195 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
The cited instrumentation will be appropriately labeled.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
The meter for the steam dump levels controller (on CB03),
radiation readers (on CB20 and CB21), and the condensate storage tank level meter (on CB04) are unlabeled.
The cited instrumentation will be appropriately labeled in an expeditious manner in conformance with standard human factors principles and practices.
They will be labeled no later than the end of 1987.
I I
CWE 91-611-17-03 5-18
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 Il HED #s:
0206 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
The discrete functional control positions will be labeled for the cited components.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
Discrete functional control positions are not identified for eight components:
Turbine Drain Valves (Unit 1)
Safety Injection Actuate (Unit 1, 2)
Safety Injection Actuate (Unit 1, 2)
Bus 6 Voltmeter (Unit 1, 2)
Traveling Screens 2A, 2C, 2G (Unit 2)
Traveling Screens 2B, 2D, 2F (Unit 2)
(2 each) Boron Injection Tank to Boric Acid Tanks Isol (Unit 2)
The discrete functional control positions will be labeled for the cited components by the end of 1987.
I CWE 91-611-17-03 5-19
\\
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 B
HED #s:
0437 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
Switch positions will be labeled on the cited controls.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
Some of the controls do not have labeled switch positions.
Manipulating controls with unlabeled switch positions may be confusing because of uncertainty as to the correct switch position:
Safety Injection Actuate - needs " Actuate" switch position label Reac Cool Syst to RHR Pumps Isol Valves (RH3701, RH3702) -
needs " Auto" switch position label Switch positions will be labeled on the cited controls in an expeditious manner.
They will be implemented no later than the~
end of 1987.
I I
I l
CWE 91-611-17-03 5-20 l
l
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 B
HED #s:
0176 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
The lights for the cited temperature control flow to demineralizer valve control will be labeled appropriately.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
The three-way temperature control flow to demineralizer valve control (on CB07) has a blue and a yellow light and switch positions " normal," " auto," and " divert" (in that sequence).
The switch spring returns to the " auto" position and the lights are unlabeled.
The valve control is presently labeled satisfactorily.
Labeling will be improved and indicator lights modified to conform to the color coding and labeling program to be implemented by the end of 1987.
I I
I CWE 91-611-17-03 5-21
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 C
HED #s:
0224 CATEGORY:
3 LEVEL:
C I
CECO RESPONSE:
The cited labels will be relabeled correctly.
Unit I will be relabeled "1AOV-VC8167" and Unit 2 will be relabeled "2AOV-VC8167.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
The unit identifiers on the "three-way valve to deboration demins" (on CB07) are incorrect.
The label on Unit 1 is labeled "2AOV-VC8167" and on Unit 2 is labeled "lAOV-VC8167."
The labels will be relabeled correctly.
Unit I will be relabeled "lAOV-VC8167" and Unit 2 will be relabeled "2AOV-VC8167."
This will be completed in an expeditious manner, by the end of 1987.
CWE 91-611-17-03 5-22
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 C
HED #s:
0267 CATEGORY:
3 LEVEL:
C I
CECO RESPONSE:
I The numeral "1"
will be added to the label of the cited instrument.
I NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
The numeral "1"
is missing from the Unit 2 valve indication for
{
the excess letdown heat exchanger isolation valve "2AOV-VC8381."
j The Unit 2 valve indication for the excess letdown heat I
exchanger isolation valve will be relabeled expeditiously, by the end of 1987.
I I
CWE 91-611-17-03 5-23
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 C
HED #s:
0288. 0436 CATEGORY:
3 LEVEL:
B CECO RESPONSE:
The cited switch will be relabeled with appropriate spacing to avoid confusion.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
The labeled switch positions for the " pressurizer pressure operated relief valve" labels are confusing (on CB06).
The intended switch positions are:
auto low temp / auto /open.
Because of the spacing and size of the characters, the switch positions appear to read:
auto temp / auto low /open.
The switch positions will be relabeled by the end of 1987.
4 CWE 91-611-17-03 5-24
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 C
HED #s:
0349 CATEGORY:
3 LEVEL:
B CECO RESPONSE:
The cited instrumentation will be relabeled appropriately.
In addition, all control room instrumentation will be relabeled to clarify function, consistently present abbreviations, and standarize label formats.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARIFICATION:
In task analysis, many labels were identified as:
not adequately describing the function of an associated control / display; containing misspelled words or abbreviations; lacking necessary information; or ambiguous.
These labeling problems appear on both the component as well as the switch position labels.
The cited instrumentation will be relabeled appropriately.
A review of the label list identified on the HED will be conducted to identify those components of a potential time-critical safety I
significance and temporary labels implemented where appro-priate.
This will be completed in an expeditious manner and no later than the end of 1987.
I CWE 91-611-17-03 5-25
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 C
HED #s:
0200 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
The fire panel alarms will be relabeled to ensure labels will be placed close to the panel elements.
NRC/SAIC COMMENT:
Interim corrective measures should be implemented.
CECO CLARITICATION:
The descriptions for the fire panel alarms are on the cabinets opposite the alarm panels.
The fire panel alarms will be relabeled to ensure that labels will be placed in proximity to panel elements.
This vill be completed in an expeditious manner, by the end of 1987.
1 I
l CWE 91-611-17-03 5-26
NRC COMMENTS STON STATION 19 DECEMBER 1986 ISSUE 5 C
HED #s:
0383 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
The cited label will be reengraved " bearing outlet".
The seal and bearing temperature meters will be switched to reflect the order of flow.
NRC/SAIC COMMENT:
Temporary corrective measures should be implemented in the interim.
CECO CLARIFICATION:
The reactor coolant pump seal and bearing outlet temperature meters (on CB07) have confusing labels.
The " bearing inlet" is the " bearing outlet" on plant diagrams.
Switch position of the seal and bearing temperature meters do not reflect the order of flow.
The label will be reengraved " bearing outlet."
This will be completed in an expeditious manner by the end of 1987.
I CWE 91-611-17-03 5-27
NRC COMMENTS ZION STATION 19 DECEMBER 1986 HED #s:
0371 CATEGORY:
3 LEVEL:
B CECO RESPONSE:
AOP-12 will be revised to clarify the systems.
All normal operating procedures will be revised to conform to a two-column format.
In addition, the annunciator response manual will be I
revised to include all annunciators.
The revision of procedures to a two-column format will require additional time and, therefore, will be completed by the end of the second refueling outage.
NRC/SAIC COMMENT:
Should be considered for the first refueling outage.
CECO CLARIFICATION:
AOP 12 will be revised to clarify the systems.
All emergency and abnormal operating procedures have been revised to conform to a two-column format.
These procedures are presently undergoing a comment and revision period.
Thus, full implementation of these revised procedures will take place by the end of 1987.
1 CWE 91-611-17-03 5-28
(
l NRC COMMENTS e
ZION STATION 19 DECEMBER 1986 ISSUE 5 D
HED #s:
0071. 0296 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
The P.A.
System will be fine-tuned and repaired to ensure that the system is consistenly intelligible.
In addition, an override capability for transmission of emergency messages from the control room will be provided for the P.A.
system.
NRC/SAIC COMMENT:
Should be considered for the first refueling outage.
CECO CLARIFICATION:
I The public address (P.A.)
system is not consistently intelligible.
I The P.A.
Will be adjusted for the best response achievable. It will then be fine-tuned and repaired by the completion of the lfirst refueling outage, to attempt to ensure that the system is consistently intelligible.
In addition, an override capability I
for transmission of emergency messages from the control room will be provided for the P.A.
System by the completion of the second refueling outage.
I l
I I
I CWE 91-611-17-03 5-29
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 D
HED #s:
0217 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
A stop will be added to the audio gain on the announcing system to preclude reducing the volume to an inaudible level.
NRC/SAIC COMMENT:
Should be considered for the first refueling outage.
CECO CLARIFICATION:
For the announcing system, the audio gain controls are not limited to preclude reducing the volume to an inaudible level.
I A stop will be added to the audio gain on the announcing system to preclude reducing the volume to an inaudible level.
This will be implemented by the completion of the first refueling outage.
CWE 91-611-17-03 5-30
i NRC COMMENTS ZION STATION i
19 DECEMBER 1986 ISSUE 5 D
HED #s:
0340 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
Redundant means of communication are available to the operators.
This includes radios, walkie-talkies, and pagers.
NRC/SAIC COMMENT:
Should be considered for first refueling outage.
CECO CLARIFICATION:
The operators indicated that there are some areas in the plant where individuals are required to leave the area to communicate with the control room personnel.
Operators have reported significant delays in communications to the following areas:
Unit 1 560' level, Unit 1 592' level, Unit 2 iron horse, feedwater pumps, 560' level in turbine building and by the amertap system.
Redundant means of communication are available to the operators.
This includes radios, walkie-talkies, and pagers.
Accept as is.
l I
CWE 91-611-17-03 5-31
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 D
HED #s:
0112 CATEGORY:
3 LEVEL:
B CECO RESPONSE:
Retractable cords will be installed to prevent the tripping hazard from phone cords.
NRC/SAIC COMMENT:
Should be considered for first refueling outage.
CECO CLARIFICATION:
The conventional-powered telephones on the benchboards have cords that are not of the nonkink or self-retracting type.
Nonkink cords will be installed to prevent the tripping hazard from phone cords.
This will be implemented by the completion of the first refueling outage.
i CWE 91-611-17-03 5-32
NRC COf@lENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 D
HED #s:
11121 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
A location will be dedicated to the storage of the sound-powered headsets.
This location will be appropriately labeled.
NRC/SAIC COMMENT:
Should be considered for the first refueling outage.
CECO CLARIFICATION:
A location has presently been dedicated to the storage of the sound-powered headsets.
This location is currently appro-l priately labeled. This corrective action has been completed, i
j CWE 91-611-17-03 5-33
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 D
HED #s:
0299 CATEGORY:
2 LEVEL:
C.
CECO RESPONSE:
Longer cords, which will be retractable, will be installed on the system.
NRC/SAIC COMMENT:
Should be considered for the first refueling outage.
CECO CLARIFICATION:
The telephone cords for phones located at the control boards are not long enough to reach the ends of the operator's work envelope.
i Longer, nonkink cords will be installed on the system by the completion of the first refueling outage.
l l
I t
CWE 91-611-17-03 5-34
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 D
HED #s:
0397 CATEGORY:
2 LEVEL:
B l
CECO RESPONSE:
I Zone banding will be added to the two CST meters consistent with related instrumentation.
NRC/SAIC COMMENT:
Should be considered for the first refueling outage.
CECO CLARIFICATION:
The condensate storage tank (CST) meters do not have zone i
banding similar to the other related CST meters located on CB04.
Zone banding will be added to the two CST meters consistent with related instrumentation, by the completion of the first refueling outage.
CWE 91-611-17-03 5-35
NRC COMMENTS ZION STATION 19 DECEf1BER 1986 ISSUE 5 D
HED #s:
0416 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
The zone banding on the LI-460A and LI-461 meters will be modified to match that on LI-459A.
NRC/SAIC COMMENT:
Should be considered for the first refueling outage.
CECO CLARIFICATION:
During the task analysis and validation, it was noted that the pressurizer level indicators LI-460A and LI--461 do not have zone banding identical to that on LI-459A.
These indicators display the same parameter and are located next to one another on CB06.
The zone banding on the LI-460A and LI-461 meters will be modified to match that on LI-459A by the completion of the first refueling outage.
I I
CWE 91-611-17-03 5-36
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0339 CATEGORY:
1 LEVEL:
A CECO RESPONSE:
Modifications have been included in a required reading package which is distributed to all license holders.
I NRC/SAIC COMMENT:
Hands-on training prior to the control roem modifications becoming operational is more appropriate, especially considering the number of control room changes due to the DCRDR.
CECO CLARIFICATION:
I Sequencing Mock-up/ Simulator modification, training schedule, operational duty schedule, and all control room modifications would be required in order to provide hands-on training.
This would be a monumental undertaking and may delay modification implementation.
A verification program has been developed to ensure operator input into the design changes.
At present, operators receive a written package describing procedural and equipment changes.
Modifications are incorporated into existing procedures and operators are required to know all modifications l for the requalification process.
In addition to the required reading package, the half-size photo mock-up, available in the Zion training department, will be used as applicable to provide operators with pre-control room mod implementation, I
familiarization and training.
Finally, each modification package contains a training form, administrative 1y controlled, on which the type of training required by the modification is determined.
The Zion training department maintains a record of I
this form, the training offered and individual operator compliance to the training required.
CWE 91-611-17-03 5-37
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0069. 0304. 0218 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
An override capability for transmission of emergency messages from the control room will be provided for the public address system.
NRC/SAIC COMMENT:
Some measure such as the establishment of a procedure to improve communications should be taken in the interim.
CECO CLARIFICATION:
An evaluation is continuing for an override capability for transmission of emergency messages from the control room over the public address system.
There are dedicated phone lines in the control room that provide direct links to several agencies and plant areas (including NRC, NARS, TSC, and OS lines).
The emergency plan implementing procedures (EPIP) provide instruc-tions for the sequence of use and testing of emergency phones and radios.
I CWE 91-611-17-03 5-38
m NRC COMMENTS ZION STATION 19 DECEMBER 1986 HED #s:
0309 CATEGORY:
3 LEVEL:
B CECO RESPONSE:
An annunciator standard addressing labeling of tiles, including character heights and space between characters, and an abbreviation standard have been developed and will be implemented on all new annunciator tiles.
NRC/SAIC COMMENT:
The operator survey has identified that some annunciators' character heights are not large enough.
While a new annunciator standard will be implemented on all new annunciator tiles, it is suggested that CECO apply this standard to all tiles required for performing time-critical tasks by the first refueling outage.
CECO CLARIFICATION:
The original HED had its origin in the 1981 Preliminary Design Assessment operator survey. The subsequent 1985 DCRDR operator survey did not produce an analogous observation. Therefore, the corrective actions implemented in the intervening four years adequately resolved the original concern.
l I
I
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0084 CATEGORY:
1 LEVEL:__A CECO RESPONSE:
The operators reported problems only with the " holder" switches.
The escutcheon plates for " holder" switches will be replaced with color-coded plates to code them as hold open/ hold closed switches.
NRC/SAIC COMMENT:
The licensee should verify that the use of color-coded plates will resolve this discrepancy without introducing new HEDs.
CECO CLARIFICATION:
The color coding of the escutcheon plates for " holder" switches will be reviewed in the corrective action verification phase to ensure that no new discrepancies are introduced and existing problems resolved.
Other coding techniques are available (shape and texture coding) and will be implemented, if necessary, by the completion of the first refueling outage.
I I
I
'"" ~'
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0290 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
The control room lighting will be modified to minimize the glare.
Alternatives to be considered include configuration of louvers, different size louvers, modifying light configuration, or changing wattage of light bulbs.
The location of the meter is adequate for readability if the glare is eliminat.ed.
NRC/SAIC COMMENT:
The licensee should describe which of the options presented will be used to correct this HED.
This category 1B HED should be addressed during the first refueling outage.
CECO CLARIFICATION:
The complexity of solving lighting problems is such that there are no straightforward solutions.
In addition, the retrofits may require facility alterations, and consideration must be given to acoustical and ventilation concerns.
The response given the NRC commits to resolving the issue by completion or the second refueling outage, but it will require analysis and examination to determine the most viable options.
NOTE:
This item remains open pending the assimilation of additional information.
This information will be forwarded per our discussion with the NRC on 12/11/86.
I I
CWE 91-611-17-03 5-41 l
1 i
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0406 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
Two instrument air compressors are normally "on" to maintain pressure.
The white indicator light indicates standby com-pressor.
Operator training is in progress to emphasize this fact.
NRC/SAIC COMMENT:
This HED appears to be contrary to control room color coding where white indicates activation.
CECO CLARIFICATION:
On OCB04, the instrument air compressor white indicator lights de-energize when the compressor auto starts.
Equipment status should be indicated by illuminated indicators.
Two instrument air compressors are normally on to maintain pressure.
The white indicator light indicates standby com-pressor.
A label will be provided to clarify the meaning of the indicator by the completion of the first refueling outage.
NOTE:
This item remains open pending the assimilation of additional information.
This information will be forwarded per our discussion with the NRC on 12/11/86.
CWE 91-611-17-03 5-42
v NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0147 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
In the past, the feedwater isolations and reset (safeguards) were used to throttle flow.
Procedural efforts have been made to ensure that no false signals are present.
In addition, there has been an increase in the reliability of the valves to isolate flow.
Therefore, the operators no longer rely on the feedwater safeguards.
NRC/SAIC COMMENT:
If operators no longer rely on this system to throttle flow, what do they use to perform this function?
If the operators sti]1 use this system to throttle flow, this equipment should be functionally grouped.
CECO CLARIFICATION:
The feedwater isolations and reset (on CB12) may be more appropriately associated with the rest of the feedwater system on CB05.
The FW Reg Valves have been repaired so that the FW isol valves are no longer required or used for throttle control.
SG level control is accomplished on the FW panel.
The FW isol reset pushbuttons are ESF related and are currently functionally grouped with other ESF reset pushbuttons.
I CWE 91-611-17-03 5-43
NRC COMMENTS ZION STATION 19 DECEMBER 1986 I
ISSUE 5 E
HED #s:
0273 CATEGORY:
2 LEVEL:
C CECO RESPONSE:
The control positions for the cited rotary control will be standardized between units.
I NRC/SAIC COMMENT:
If reactor operators are scheduled to work at both units, it is recommended that this HED be corrected by the first refueling outage.
CECO CLARIFICATION:
Control positions on the CB12 safeguard system panels for Units 1 and 2 are not consistent.
Four discrete rotary controls (OT-2S) on Unit 1 have a left position of " unblock" and a right position of " block;" on Unit 2, the positions are reversed.
These OT-2 switches turn only to the " block" position and spring return to the mid-position.
They can only turn in this direction.
These controls are used to block safety system I
actuations during normal plant shutdown; therefore, their use is not time-critical.
However, the control positions will be standardized between units, so that actuate will be to the right, by the completion of the second refueling outage.
As an interim measure, labels are provided to the operators to ensure proper identification of components.
They will be coordinated I
into a systematic engineering modification to integrate all HFE concerns for this pane!..
1 4
}
l
)
CWE 91-611-17-03 5-44
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
D HED #s:
0025 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
The character styles used are very similar.
However, a display standard has been developed which specifies consistent character styles and will be implemented on all new displays.
NRC/SAIC NMMENT:
The display standard being implemented should be used correct these HEDs.
Additionally, the replacement display;
.n the photograph appear to be covering label informatic..
CECO CLARIFICATION:
There are twenty-one character styles used for letters and numbers on displays in the control room.
Thc character styles used are very similar.
Guideline 5.1. 3. I 2-1 states " Type styles should be consistent":
use of " styles" (plural) indicates that more than one style is acceptable (i.e.,
styles do not have to be identical).
Also, the guideline refers to I
printing on the display itself, not the label.
Correcting differing type styles on displays may require using a single vendor for all displays and even then might not be achievable.
I Completely standardizing all print on displays is not called for by the guideline which will be implemented on all new displays.
I I
I CWE 91-611-17-03 5-45
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0023 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
There are five meter styles which have graduations which do not subtend 15 minutes of visual angle.
Graduation heights of.118 inches are requred to subtend the viewing distance.
NRC/SAIC COMMENT:
The display standard being implemented should be used to correct these HEDs.
CECO CLARIFICATION:
There are five meter styles which have graduations which do not subtend 15 minutes of visual arc.
The discrepant graduations range from.063 to.078 inches.
The operators are able to determine critical parameters on displays by the current I
instrument banding.
However, a display standard specifying graduation height has been developed and will be implemented on all new displays by the completion of the first refueling outage.
I I
CWE 91-611-17-03 5-46
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0024 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
There are nine character styles used on display faces which do not subtend a visual angle of 15 degrees.
The required character height to subtend the 15 degree angle is.118 inches.
The cited character styles have character heights ranging from
.047 to.109 inches.
NRC/SAIC COMMENT:
The display standard being implemented should be used to correct these HEDs.
CECO CLARIFICATION:
There are nine character styles used on display faces which do not subtend a visual angle of 15 minutes.
The required character height to subtend the 15 minute angle is.118 inches.
The cited character styles have character heights ranging from
.047 to.109 inches.
The.047 inch height corresponds to scales on controllers.
These are non-time-critical and easy to read.
The other displays are only slightly deviant from the criteria and pose no I
operational difficulties.
However, a display standard has been developed which specifies a.118 inch character height and will be implemented on all new displays.
I CWE 91-611-17-03 5-47
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0026 CATEGORY:
3 LEVEL:
C CECO RESPONSE:
There are eleven different stroke widths used on displays which do not meet the criteria for stroke width-to-character height ratio of 1:6 to 1:8.
NRC/SAIC COMMENT:
The display standard being implemented should be used to correct these HEDs.
CECO CLARIFICATION:
There are eleven different stroke widths used on displays which I
do not meet the criteria for stroke width-to-character height ratio of 1:6 to 1:8.
The existing ratios range from 1:3 to 1:13.7.
This difference does not affect operator readability.
However, a display guideline specifying a stroke width-to-character height ratio of 1:6 to 1:8 has been developed and will be implemented on all new displays.
I I
CWE 91-611-17-03 5-48
NRC COMMENTS ZION STATION 19 DECEMBER 1986 HED #s:
0319 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
The hydrogen monitoring post accident status light supplies indication for the valve to ensure containment isolation.
NRC/SAIC COMMENT:
What was meant by "all of the safety injection valves" on the operator survey, and will the hydrogen monitoring post-accident status light resolve this discrepancy?
CECO CLARIFICATION:
An independent review by an HFS and SME discerned that the only SI containment isolation valves whose status is not displayed in the Primary operating area via a " sugar cube" status light array are the Hydrogen Monitoring Containment Isolation Valves.
Though individual valve status lights are located on the back panels with their respective valve control switches, valve position status lights for these valves will be added to the Fhase A containment isolation valve status light array box on I
the safeguards (CB12) panel by the completion of the second refueling outage.
CWE 91-611-17-03 5-49
I NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0122 CATEGORY:
2 LEVEL:
C CECO RESPONSE:
Sound-powered phones are a convenience to the operators and are not used during normal plant evolutions.
In addition, redundant communication systems are available in the control room.
NRC/SAIC COMMENT:
(This)
HEr refers to problems with communications.
While the sound-powered phones are not used during normal plant evolutions, the discrepancies described could complicate the communications during abnormal evolutions.
CECO CLARIFICATION:
Sound-powered phones are a convenience to the operators and are not used during either normal or abnormal plant transients.
These phones are typically used during testing and maintenance activities which are not time-critical or safety-related activities.
In addition, redundant communication systems are available in the control room.
I CWE 91-611-17-03 5-50
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0305 CATEGORY:
2 LEVEL:
C I
CECO RESPONSE:
Redundant communication systems (telephones, radios, public address system, intercoms) are available to control room operators.
NRC/SAIC COMMENT:
HED 305 does not address the problem of noise in the plant.
CECO CLARIFICATION:
Operations has redundant communications systems (telephones, radios, public address system, intercoms) available for use.
Should noise interfere with communications in any one system, another system can be used.
The problem with noise is inherent in the operations of the plant, and cannot readily be eliminated.
i i
l CWE 91-611-17-03 5-51
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0133. 0322. 0391. 0134 CATEGORY:
2 LEVEL:
C CECO RESPONSE:
All cited annunciator tiles are located close to the functional control and displays groupings.
Redundant cues (visual and auditory) are present to alert the operator to an alarming condition.
NRC/SAIC COMMENT:
The review team needs to know which annunciator tiles are referred to in this HED and how close they are to the related control and displays.
CECO CLARIFICATION:
HED index #s 133, 322, and 391 cite 65 unique annunciator tiles that are not located directly above related controls and/or displays.
A subsequent and independent review of these alarms by an HFS and SME identified three tiles that, for reasons of safety significance and/or time criticality, should be relocated.
These tiles are:
1) the " System Frequency Low" alarm on the unit 1 CB01 panel which shculd be in window box
- 22; 2) the " Excess Letdown Heat Exchanger Temperature High" alarm on the CB10 panel which should be on the CB07 panel in I
window box 5 or 6; and 3) the " Low Auto Stop Oil Press or Turbine Stop V1vs Closed" alarm on the CB08 panel which should be in the # 13 window box.
These three tiles will be relocated to the indicated locations by the completion. of the first refueling outage.
j HED index # 134 cites 72 unique annunciator tiles that are not optimally grouped within the box in which they are located.
These tiles were also subsequently and independently reviewed by an HFS and SME.
All 72 tiles were determined to be above related controls and displays.
Because these tiles are in the window boxes they should be in, no further action is warranted.
NOTE:
Subsequent investigation has determined that relocation of the
" Excess Letdown Heat Exchanger Temperature High" alarm to window box 5 or 6 is unacceptable. Further study will be required to resolve this item.
This item remains open pending the assimilation of additional information.
This information will be forwarded per our discussion with the NRC on 12/11/86.
CWE 91-611-17-03 5-52
NRC COMMENTS ZION STATION 19 DECEMBER 1986 HED #s:
0326 CATEGORY:
2 LEVEL:
C CECO RESPONSE:
The operators can determine if the standby pump has auto started by observing the indicator light adjacent to the respective control switch (on CB03).
NRC/SAIC COMMENT:
The review team is concerned that the standby pump auto start may not be an adequate redundant indication of EHC pressure status.
If the auto pump fails to start, how would the operator determine that pressure is too low?
CECO CLARIFICATION:
The operators can determine if the standby pump has auto-started by observing the indicator light adjacent to the respective control switch (on CB03).
The computer printout is available at the same time that the existing annunciator alarms.
- However, insufficient time exists before a unit trip if the other pump fails to auto start.
The unit trip is therefore sufficient indication of this.
I CWE 91-611-17-03 5-53
NRC. COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0098. 0099. 0100 CATEGORY:
2 LEVEL:
C CECO RESPONSE:
The light of all legend lights, pushbuttons, and non-legend lights is discriminable from the surrounding panel due to the bright light contrasting to the painted panel.
NRC/SAIC COMMENT:
The licensee should identify any of these lights that are required during the EOPs.
These lights should then be corrected.
CECO CLARIFICATION:
The operators have expressed no concerns whatsoever and have not indicated any problem with viewing the lights.
The light of all legend lights, pushbuttons, and non-legend lights is discriminable from the surrounding panel because the bright light contrasts with the painted panel.
Contrast levels will be verified for those sections of the panel that receive background shading.
1 l
CWE 91-611-17-03 5-54
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0244 CATEGORY:
1 LEVEL:
C CECO RESPONSE:
The cited switches are easy to operate and the deviation in height does not cause any difficulties in operator performance.
NRC/SAIC COMMENT:
The reviewers are concerned that these category I valve control switches are only one-half
(.31")
of the recommended height of
.625", and suggest replacement.
CECO CLARIFICATION:
The switches cited are OT-2 switches, which are standard in the industry for valve control.
The surface area of the switch is adequate for actuation and is easy to manipulate.
Operating has provided no indication that this control type is a problem during normal operation.
I CWE 91-611-17-03 5-55
NRC COMMENTS ZION STATION 19 DECEMBER 1986 I
ISSUE 5 E
HED #s:
0346 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
Inches of water is easier to detect for the operators than psig.
NRC/SAIC COMMENT:
The meter and technical specifications for I
both units should be consistent if these specifications are used by operators.
CECO CLARIFICATION:
The containment differential pressure meter (on OCB05) uses different units than those stated in the technical specifications.
The meter is in units of inches of water, which is easier for the operators to detect.
The meter is not used to determine whether tech spec limitations are exceeded.
Other independent indication is used for this function.
The meter that uses inches of water is used for venting the containment under conditions significantly lower than tech spec limits.
I I
C;!E 91-611-17-03 5-56
I I
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0307 CATEGORY:
3 LEVEL:
B CECO RESPONSE:
Each replacement fuse is appropriately labeled.
Only like-for-like replacements are made for fuses.
NRC/SAIC COMMENT:
While each replacement fuse is appropriately labeled, the licensee should address the need to label the equipment in order to prevent the delays that have occurred.
(
CECO CLARIFICATION:
Each replacement fuse is appropriately labeled.
Operating practice dictates that only like-for-like replacements are made for fuses.
At present, fuse size is indicated on electrical prints.
A labeling program is in progress to replace fuse size labels on equipment in the aux electric equipment room and control room.
NOTE:
This item remains open pending the assimilation of additional information.
This information will be forwarded per our discussion with the NRC on 12/11/86.
CWE 91-611-17-03 5-57
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0424 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
The distance between CB10 and CB07 is minimal.
In addition, the annunciators provide redundant cues (visual and auditory) to alert the operators to a problem.
NRC/SAIC COMMENT:
What is the distance between CB10 and CB07?
If this is a time-critical task, these items must be close enough to permit required operator actions.
CECO CLARIFICATION:
There are four Boron Injection Tank (BIT) annunciators on the CB10 panel associated with temperature, pressure and flow.
The BIT instrumentation and controls on the CB07 panel, 11 1/2 feet away, are clearly labeled and differentiated.
The most time-critical task arising from any of the alarms' actuation gives the operator one hour in which to respond in order to meet technical specification requirements.
Therefore, while the arrangement is not optimal, it is also not operationally problematic and no additional action is necessary.
CWE 91-611-17-03 5-58
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0394 CATEGORY:
1 LEVEL:
B CECO RESPONSE:
The cited AFW pump instrumentation are infrequently used and are not time critical.
They are normally in the open position and closed only during an accident.
Therefore, their current location is adequate.
NRC/SAIC COMMENT:
Further explanation is needed as to why these auxiliary feedwater pump 1A steam supply stop valves are closed during an accident.
CECO CLARIFICATION:
The cited AFW pump instruments are frequently used and are not time-critical.
They are normally in the open position and may be closed during a faulted SG accident condition in accordance with EOPs.
Therefore, their current location is adequate.
CWE 91-611-17-03 5-59
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0425 CATEGORY:
1 LEVEL:
C CECO RESPONSE:
In its present location, abnormal alignment of blowdown is easily identifiable since it is the only status light lit.
NRC/SAIC COMMENT:
Finding and response are contradictory as to whether abnormal alignment of blowdown is easily identifiable.
Without additional justification that indicates that the present location is appropriate, the licensee should relocate this status light.
CECO CLARIFICATION:
In its present locati;n, abnormal alignment of blowdown is easily identifiable because it is the only status light lit within that group of status lights.
The status light for BD 17 is grouped with the rest of the Phase A isolation valve status lights because it has to be verified closed during a Phase A isolation, as do the other valves with which it is grouped.
Since the SG blowdown isolation occurs with a Phase A,
this indicator is appropriately grouped.
Verification of the other SG blowdown isolation valves is not time-critical.
I I
CWE 91-611-17-03 5-60
I I
NRC COMMENTS 1
ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0316. 0411 CATEGORY:
2 LEVEL:
B CECO RESPONSE:
The CB08 and CB10 panels are located close to each other.
In addition, redundant annunciator cues (auditory, visual) are present to alert the operator to any problems.
NRC/SAIC COMMENT:
The operator survey finding indicating that the location of the alarms and gauges are not close together is contradictory to the CECO response.
The licensee should provide additional clarification.
CECO CLARIFICATION:
There are four RWST alarms located on the CB10 panel which are eleven feet from the RWST level indicators on the CB08.
Only one of the alarms is somewhat time critical, specifically, the low-low level one.
When this alarm actuates, the operator has at a minimum 20 minutes to realign the RHR System to take a suctio1 from the containment pump.
However, a low-level alarm would actuate before its low-low level one, giving the operator forewarning of the impending task.
Therefore, while the arrangement is not optimal, it is also not problematic and no additional action is warranted.
I I
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E
HED #s:
0259 CATEGORY:
1 LEVEL:
C I
CECO RESPONSE:
There is no need for redunant indication of pump C on Unit 2.
The ammeter will be removed.
I NRC/SAIC COMMENT:
No date is set for the corrective action in the response.
CECO CLARIFICATION:
The ammeter will be removed by the completion of the second refueling outage. This will be accomplished in conjunction with 39 other changes to the control panel.
I I
I I
I CWE 91-611-17-03 5-62
NRC COMMENTS ZION STATION 19 DECEMBER 1986 HED #s:
0182 CATEGORY:
2 LEVEL:
C CECO RESPONSE:
Recorders are verified daily by the operators and ink and paper are replaced as necessary.
I NRC/SAIC COMMENT:
Photographs support need to correct since green ink is not visible.
CECO CLARIFICATION:
Examination of the photograph reveals the ink to be visible.
The particular pen was pegged to the left and not active at the I
time of the photograph.
I g
CWE 91-611-17-03 5-63
NRC COMMENTS ZION STATION 19 DECEMBER 1986 ISSUE 5 E,
HED #s:
0225 CATEGORY:
2 LEVEL:
A CECO RESPONSE:
The consequences of inadvertently actuating one of the cited pushbuttons are minimal since the system will go into manual.
An annunciator is in place to alert the operator to this condition.
NRC/SAIC COMMENT:
No "H"
series photographs were included in the notebooks.
CECO CLARIFICATION:
The "H"
series photographs were provided to the NRC staff during the December 11, 1986 meeting with the NRC.
I I
l I
CWE 91-611-17-03 5-64
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