ML20209F671

Evaluation of Dcrdr for Beaver Valley Unit 1, Technical Evaluation Rept

ML20209F671
Person / Time
Site:	Beaver Valley
Issue date:	01/22/1987
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20209F678	List: ML20209F671 ML20212Q804
References
CON-NRC-03-82-096, CON-NRC-3-82-96 SAIC-87-3003, NUDOCS 8702050167
Download: ML20209F671 (46)

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.v SAIC-87/3003 EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR DUQUESNE LIGHT COMPANY'S BEAVER VALLEY UNIT 1 Technical Evaluation Report January 22, 1987 Prepared for: '

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Contract NRC-03-82-096 Prepared by:

Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102 Q f V

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FOREWORD This Technical Evaluation Report documents the findings from a review of Duquesne Light Company's Detailed Control Room Design Review for its Beaver Valley Power Station, Unit 1. Science Applications International Corporation's (SAIC's) evaluation was performed in support of the NRC under Contract NRC-03-82-096, Technical Assistance in Support of Reactor Licensing Actions: Program III. SAIC previously participated in the review of the licensee's Program Plan and in an in-progress audit at the plant site *with the licensee. ' The licensee submitted the Summary Report for Beaver Valley Unit I (BV-1) on November 29, 1985. A review of this submittal indicated that a meeting with the licensee was required. This meeting was held at BV-1 on February 13, 1986 with the licensee and NRC representatives in atten-dance. This evaluation report is based on the Summary Report, the subse-quent meeting (February 13, 1986) and all previous information concerning the BV-1 DCRDR.

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l TABLE OF CONTENTS Section E191 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I DISCUSSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Establishment of a qualified multidisciplinary review team. . . . 3 System Function and Task Analysis . . . . . . . . . . . . . . . . 5 A Comparison of Display and Control Requirements With a Cont rol Room Invento ry. . . . . . . . . . . . . . . . . . . . . 6 Control Room Survey . . . . . . . . . . . . . . . . . . . . . . . 8 Review of Operating Experience. . . . . . . . . . . . . . . . . . 12 ASSESSMENT AND IMPLEMENTATION PHASE ................. 13 Assessment of Human Engineering Discrepancies (HEDs) to Determine Which Are Significant and Should Be Corrected . . . . . . . . . 13 Selection of Design Improvements. . . . . . . . . . . . . . . . . 16 Verification That Selected Improvements Will Provide the Necessary Correction Without Introducing New HEDs . . . . . . . 18 Coordination of Control Room Improvements With Changes From Other Programs Such As the Safety Parameter Display System (SPDS), Operator Training, Reg. Guide 1.97 Instrumentation and Upgraded Emergency Operating Procedures (EOPs). . . . ., . . 18 Analysis of Proposed Design Changes and Schedule For Implementing Design Changes . . . . . . . . . . . . . . . . . . 20 Justifications for HEDs To Be Left Uncorrected. . . . . . . . . . 22 CONCLUSIONS .

...........................22 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25  !

APPENDIX A: l NUREG-0700 Guidelines That Need to Be Addressed by DLC . 26 t APPENDIX B: HEDs With Corrective or Proposed Corrective Actions. . . 33 APPENDIX C:

APPENDIX D:

HEDs Still Undergoing Additional Study or Review . . . . 36 HEDs Referencing Simulator Exercise (SIMEX or SPDS. . . 38 APPENDIX E: HEDs Not Requiring a Corrective Action . .). . . . . . .

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? y R:p;rt Evaluation of the Detailed Control Room Design Review for Beaver Valley, Unit 1 BACKGROUND Licensees and applicants for operating licenses shall conduct a Detailed Control Room Design Review (DCRDR). The objective is to " improve the ability of nuclear power plant control room operators to prevent acci-dents or cope with accidents if they occur by improving the information provided to them" (NUREG-0660, Item I.D - Reference 1). The need to conduct a DCRDR was confirmed in NUREG-0737 and Supplement I to NUREG-0737 (Reference 2). DCRDR requirements in Supplement I to NUREG-0737 replaced those in earlier documents. Supplement I to NUREG-0737 requires each appli-cant or licensee to conduct a DCRDR on a schedule negotiated with the Nuclear Regulatory Commission (NRC).

NUREG-0700 (Reference 3) describes four phases of the DCRDR and provides applicants and licensees with guidelines for their conduct. The phases are:

1. Planning

2. Review

3. Assessment and implementation

4. Reporting.

The requirements of Supplement I to NUREG-0737 indicate the need to include a number of elements in the DCRDR. They are:

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1.

Establishment of a qualified multidisciplinary review team.

2. Function and task analyses to identify control room operator tasks and information and control

• requirements during emergency operations.

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

4.

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

5.

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

6. Selection of design improvements.

7.

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

8.

Verification that improvements will not introduce new HEDs.

9. Coordination of control room improvements with changes from other programs such as the safety parameter display system (SPDS), operator training, Reg. Guide 1.97 instrumentation, and upgraded emergency operating procedures (EOPs).

Licensees are expected to complete Element I during the DCRDR's planning phase, Elements 2 through 4 during the DCRDR's review phase, , and Elements 5 through 8 during the DCRDR's assessment and implementation pha Completion of Element 9 is expected to cut across the planning, review, and assessment and implementation phases.

A Summary Report is to be submitted at the end of the DCRDR. As a minimum it shall:

1. Outline proposed control room changes.

2.

Outline proposed schedules for implementation.

3. Provide summary justification for HEDs with safety signifi-cance to be left uncorrected or partially corrected.

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The NRC staff evaluates the organization, process, and results of the DCRDR.

Results of the evaluation are documented in a Safety Evaluation Report Report.

(SER) published within two months after receipt of the Summary Guidance contained in NUREG-0800, Section 18.1 (Reference 4) is provided to evaluate the acceptability of this Summary Report.

DISCUSSION 1

Duquesne Light Company (DLC) submitted to the NRC a DCRDR Program Plan for the Beaver Valley Power Station, Unit 1 (BV-1) on September 27, 1983 (Reference 5). NRC coments on that Program Plan were forwarded to BV-1 on December 7, 1983 (Reference 6). In addition, the NRC Project Manager for BV-1 arranged for an in-progress audit at the plant site conducted between July 23 and 26, 1984.

Results of the audit were forwarded to BV-1 on September 12, 1984 (Reference 7).

DLC submitted a Summary Report for BV-1 on November 29,1985 (Reference 8 and 9).

After a review of the submittal, the NRC recommended a meeting with DLC which was held on February 13, 1986. This Technical Report Evaluation is based on all information transmitted to the NRC at this time and is arranged in order of DCRDR elements identified in Supplement I to NUREG-0737.

Establishment of a Oualified Multidisciolinary Review Team One of the requirements of Supplement I to NUREG-0737 is the establish-ment of a qualified multidisciplinary DCRDR team.

review, The quality of the as well as the results of the DCRDR, depends on the credentials and structure of the team performing the review. According to NUREG-0803, the '

DCRDR leadership should be provided by the utility and the DCRDR team should be given sufficient authority to conduct the review. A core group of specialists in the fields of human factors engineering, plant operations, instrument and control engineering, and nuclear engineering are expected to  !

participate with assistance as required from other disciplines. Human factors expertise should be included in the staffing for most, if not all, technical tasks.

The team should receive an orientation to assist in the conduct of the DCRDR.

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f The NRC audit team concluded from the in-progress audit that the DCRDR team assignments were adequate for conducting a satisfactory DCRDR. Speci-fically, they found that the DCRDR team had the proper mix of disciplines recommended in NUREG-0800. The NRC's previous concern regarding the role and level of involvement of the human factors specialist (HFS) was satisfied  !

when DLC augmented the DCRDR team with a full-time HFS and allocated several activities to the HFS that had not been mentioned in the Program Plan.  !

A concern remaining from the in-progress audit is whether the review i

team (including the HFS) will be maintained throughout the entire HED assessment and resolution process. A review of the Summary Report found  !

that DLC has addressed this concern by indicating that the complete review team will participate throughout the HED assessment phase including the )

i development and evaluation of design improvements.

Another concer" from the in-progress audit has to do with management responsibility in the assessment and resolution of HEDs. Specifically, the role and level of involvement of DLC management in the review and approval of design change corrective actions was not clearly defined. Likewise, it was not clear whether management decisions regarding corrective actions were open to the audit, discussion among the DCRDR team members. During the in-progress reviewers were concerned that management would reject a correc-tive action and decide not to correct an HED without discussingalternative corrective actions as well as the consequences of no action.

A review of the ' Summary Report indicates that DLC had not adequately addressed this concern.

Therefore, more information on the role of management in the approval of HED resolutions should be provided.

In summary, review team assignments appear to be adequate for success-fully accomplishing most of the DCRDR activities.

In order to fully satisfy this requirement of Supplement I to NUREG-0737, DLC should provide informa-tion which clearly defines the role and level of management involvement in the review and approval of design change corrective actions. DLC should demonstrate that management receives adequate input from the DCRDR team when deciding on these corrective actions.

DLC should provide this information in a supplement to the Summary Report.

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, System Function and Task Analysis i

The purpose of the function and task analysis is to identify the control room operators' tasks during emergency operations and to determine the information and control capabilities the operators need in the control

, room to perform those tarks.

An acceptable process for conducting the function and task analysis is:

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Analyze the functions perfomed by systems in responding to transients and accidents in order to identify and describe those tasks operators are expected to perform.

2.

For each task identified in Item I above, determine the information (e.g., parameter, value, status) which signals the need to perform the task, the control capabilities needed 4

to perform the task, and the feedback information needed to monitor task performance.

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! Analyze the information and control capability needs identi-fied in Item 2 above to determine appropriate characteristics for displays and controls to satisfy those needs.

The System Function and Task Analysis (SFTA) performed at Beaver Valle I was based on the Westinghouse Owners Group (WOG) Emergency Response G lines (ERGS), Revision 1.

generic The WOG ERGS were the basis for developing i plant-specific Emergency Operating Procedures (EOPs) which were subsequently made to establish the Beaver Valley 1 E0Ps.

1 The reviews of the generic WOG ERGS and E0Ps for developing Beaver Valley 1 E0Ps were conducted primarily by the DLC E0P group, with the DCRDR team as participants during the E0P verification and validation phase.

In establishing the ERGS, WOG has identified specific accident and transient scenarios along with system functions and task requirements. The

!' task actions, development included the identification of operator tasks, operator

' information, and control and display requirements. Using the task requirements already developed by WOG, and subsequently customized to Beaver Valley 1, the HFS reviewed and documented the identification of characteris-tics and needed information and controls, thereby providing the necessary 5

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independence from the existing control room. At the July 1984 in-progress audit, the NRC review team observed the procedure used for collecting the needed characteristics of instruments and controls. It was determined that the function and task analysis was adequate as performed.

During the in-progress audit conducted at Beaver Valley 1, it was noted that tasks involving communication between the shift supervisor and opera-tors were not considered as part of the task analysis. While the Summary Report does not respond to the above concern, this issue was satisfactorily resolved at the February 1985 meeting. The licensee indicated that during the performance of the E0Ps, the shift supervisor's primary duty is the accomplishment of the emergency procedures while an administrative assistant performs the communications functions.

It appears that the licensee has performed an SFTA conforming to the guidelines of NUREG-0700. Additionally, the licensee has addressed the concern documented by the NRC team at the in-progress audit. In summary, the licensee has satisfied this requirement of NUREG-0737, Supplement 1.

A Comoarison of Disolav and Control Reouirements With a Control Room Inventory The purpose of comparing display and control requirements with a control room inventory is to determine the availability and suitability Vf displays and controls required for performance of the E0Ps. Success of this element depends on the quality of the function and task analyses and the control room inventory. Display and control requirements should be derived from analyses which are sufficiently detailed to support development of complete and technically adequate E0Ps. Characteristics appropriate to the task should be described for each display and control need identified by the function and task analyses. The control room inventory should be a complete representation of displays and controls currently in the control room. The inventory should include appropriate characteristics of current displays and controls in order to allow meaningful comparison with the results of the function and task analyses. Unavailable or unsuitable displays and controls should be documented as HEDs.

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The licensee did not establish a formal inventory of the existing instrumentation and controls in the control room. To accommodate this effort, the licensee has compiled a separate listing of instrumentation needed to implement the E0Ps.

l This list consists of the tag number, the type, the location, and the characteristics of the instrument.

During the " verification of task performance" activity, the avail-ability and E0P suitability of each instrument was checked as part of (1) the walk-through/ talk-through task, and (2) the real-time exercise of the E0Ps on the simulator. During the E0P walk-through efforts, the DLC reviewer / observer determined if any of the following problems existed:

o Inadequate instrumentation o j Incorrect hardware referenced o Inadequate control feedback  !

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Insufficient information to perform the step o

( Inaccurate information in procedure step o

1 Insufficient label / abbreviation o

Insufficient / inaccurate location information Using the above criteria, the reviewer / observer was able to system-atically establishedcompare the existing control room controls and displays with those by the SFTA task requirements.

recorded by the HFS and the DCRDR team leader.

Deviations were noted and walk-through, At the conclusion of each a debriefing of the observations made during the walk-through was held to discuss the problems, all deviations. and to formulate possible resolutions to As a result of this debriefing effort, discrepancies were identified as DCRDR related issues or procedural issues.

also To validate the ability of the control room to support the E0P, DLC has conducted real-time exercises on a simulator. Most scenarios, which include steam generator tube ruptures, (LOCA), small break loss of coolant accident +

anticipated transient without scram (ATWS),

inside and outside the containment, and steam line brea noted were covered during this effort. It i that the inadequate core cooling event was not exercised during the validation phase.

As pointed out on page 2-29 of the Summary Report, thi omission was probably a result of the limitation of software available the time the validation was conducted.

While the licensee did not indic 7

how this omission was resolved in the Summary Report, an explanation was provided during the February 1986 meeting at BV-1. It was explained that the inadequate core cooling system (ICCS) panel will~not be operational for

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BV-1 until after the fifth refueling outage (RFO-5). In order to ensure

. i that all operator tasks required in the E0Ps have been exercised during the validation of control room functions, the licensee should perform a validation check on the ICCS panel after installation. BV-1 should provide assurance in the supplement to the Summary Report that such a validation effort will be conducted with the ICCS panel and that the NRC will be provided with results.

E0P exercises were evaluated using the same methodology outlined for the assessment of the E0P walk-throughs. As a result, 25 HEDs out of 315 deviations were identified during the E0P walk-through effort, and 30 HEDS (out of 100 deviations) during the E0P validation on the simulator.

In summary, it appears that the licensee has developed a method for comparing the existing control room equipment with the needed instrumenta-tion identified during the SFTA without performing a formal control room inventory. This should satisfy the requirement of NUREG-0737, Supplement 1.

Although not required by Supplement I to NUREG-0737, a validation of control room functions similar to the guidelines of NUREG-0700 was also performed by the licensee. However, the licensee should provide assurance that all operator tasks required by the E0Ps are exercised during the real-tinie validation of E0Ps on the simulator.

Control Room Survey The key to a successful control room survey is a systematic comparison of the control room against accepted human engineering guidelines. One accepted set of human engineering guidelines is provided in Section 6 of NUREG-0700.

However, other accepted human factors standards may be chosen.

Discrepancies between the control room and human engineering guidelines should be documented as HEDs.

The NRC audit team's general findings from discussions with DLC and review of its documentation of the survey were that the survey was less than thorough and rigorous.

As discussed in the comments on the BV-1 Program 8

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Plan and in the in-progress audit report, the survey approach used was based on the CRDR Survey Development Guideline published by the Nuclear Utility lask Action Committees (NUTAC) on CRDR. From a comparison of the BV-1 checklist and Section 6 of NUREG-0700, the NRC audit team noted two general differences between the two checklists:

1.

Objective criteria provided in NUREG-0700 were omitted from the BV-1 survey checklist.

2. Objective criteria provided in NUREG-0700 were replaced with subjective criteria in the BV-1 checklist.

The NRC audit team was concerned that the use of the BV-1 checklists had resulted in a survey that was too lenient.

To determine the adequacy of DLC's application of the NUTAC-based survey, the NRC in-progress audit team conducted an abbreviated survey of the control room using NUREG-0700, Section 6 checklists. A comparison of the HEDs identified by the NRC audit team against DLC's findings revealed many instances where HEDs found during the audit were not documented by the licensee. Based on the NRC review of DLC's survey checklist and the find-ings of the NRC audit team, the NRC strongly recommended that the licensee reconsider using the guidance provided in Section 6 of NUREG-0700 in con-ducting the control room survey.

k In the Summary Report, DLC states that it " elected to perform a supple-mental survey in accordance with NUREG-0700 criteria.

contained All NUREG-0700 items in Section 6 that applied to control room survey were completed, with the exception of items that were exactly the same as those used in the NUTAC-based control room survey" (Reference 9, p. 2-22). Although DLC has taken some action to improve its control room survey, more information is needed to obtain a clearer understanding of how it was improved. While DLC provides a sample of the NUTAC-based control room checklists, neither a  !

sample of the supplemental checklists nor a list comparing and describing the differences between the two checklists is provided. In the Appendices we found examples where it appears that NUREG-0700 was not entirely used, a,nd we are concerned that the survey is incomplete.

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At the meeting with the licensee, the NRC questioned DLC about the supplemental checklists and how they differ from Section 6 of NUREG-0700.

DLC assured the NRC that the supplemental checklists cover all NUREG-0700 items except those items that were completely redundant with the NUTAC-based checklists. However, a review of Appendix U (HED records sorted by NUREG-0700 guideline) raised several questions concerning the application of NUREG-0700. Problems identified during the Operating Experience Review (OER) were not substantiated during the conduct of the control room survey.

I While the OER can identify certain problem areas, the review team needs to confirm the problem and quantify the extent to which there is a deviation from human factors guidelines. Furthermore, a quantitative control room review can identify additional problems that the operators may not raise as a result of their acclimating to the existing control room. DLC was furnished, at the meeting, with the list of 21 NUREG-0700 guidelines in Appendix A, Section A-1 associated with HEDs identified during the OER. DLC should consider rechecking and quantifying the extent to which these items in the

! control room deviate from the criteria of Section 6 of NUREG-0700.

Any items not rechecked or quantified 'should be justified in the supplement

[ to the Summary Report.

Another question raised concerning the application of NUREG-0700 was the meaning of "N/A" which was placed beside 48 guidelines listed in Appendix U of the Sumary Report, such as those applicable to CRTs.

DLC informed the NRC that CRTs were not present in the control room at the tiine of the survey, but rather were introduced later with the SPDS. However, DLC i

3 did not offer evidence that the CRTs were surveyed subsequent to their introduction into the control room. During the February meeting, the NRC team visited the BV-1 control room simulator and the following two problems associated with the SPDS CRT were identified:

o Glace on the terminal shield o

Inappropriate location of the keyboard with regards to the CRT terminal

, DLC should provide assurance that the CRTs and associated equipment will be surveyed. Appendix A, Section A-2 represents the list of 48 NUREG-0700 guidelines labeled as "N/A." DLC should provide assurance to the NRC that 10

each of these guidelines has been appropriately addressed during the control

, room survey.

In addition to the above examples of NUREG-0700 guidelines that need to be clarified by the licensee, the following categories, listed in Appendix A, will require further justification:

o Guidelines listed but no action taken (Section A-3) o Guidelines that still remain to be checked (Section A-4) o Guidelines missing from BV-1 checklist presented in Appendix U of the Summary Report (Section A-5)

At the time of the in-progress audit, it was understood from the licensee that the control room survey was complete with the exception of the noise, lighting, and communications surveys. However, from an examination of the Summary Report, it appears that the control room environment including such items as humidity, heating, ventilation, and air-conditioning was not surveyed. At the February 1986 meeting the licensee confirmed that the control room environment was not yet surveyed. DLC explained that presently a temporary wall exists that separates the Units I and 2 control

! rooms. As Unit 2 becomes operational, this wall will be removed and the combined control room environment will be surveyed. While this approach was acceptable to the NRC review team, DLC should provide assurance in the supplement to the Summary Report that DLC's survey will be conducted as described and the results submitted to the NRC.

I The communications survey was conducted through an operator interview technique to determine if any HEDs existed. At the meeting, the NRC review team informed Beaver Valley's human factors consultant that such an approach is less reliable than a survey approach conducted by a human factors specialist.

It was recommended that the Beaver Valley human factors consultant complete a survey of the communications systems using criteria in NUREG-0700, Section 6.

DLC reports that portions of the control room survey were completed using a half-scale photomosaic. The Summary Report does not indicate 11 l

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t whether the half-scale photomosaic is in color and is a complete image of l the control room, or how the DCRDR team addressed limitations of the photo- I mosaic. At the meeting, DLC responded to the NRC's concern by indicating that only one aspect of the survey, the control-display relationship, was performed on the half-scale photomosaic. This use of the photomosaic was acceptable to the NRC review team.

In summary, DLC has taken some action to improve upon its survey.

However, more information is needed to obtain a clearer understanding of those corrective actions. Specifically, all lists contained in Appendix A of this evaluation should be addressed in the supplement to the Summary Report.

In addition, DLC should provide evidence that it has completed or will complete all control room environmental surveys as well as communica-tions, the CRTs, and SPDS. In order to satisfy the control room survey requirement of Supplement I to NUREG-0737, DLC should address these concerns in the supplement to the Summary Report.

Review of Ooeratino Evoerience While not a requirement of Supplement I to NUREG-0737, a review of operating experience was performed consisting of a review of plant histort-cal documentation and a survey of operating personnel by questionnaire and interview.

As part of the historical document review, the licensee reviewed all documents related to the plant operating history, including Incident

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Reports (irs) and Licensee Event Reports (LERs). All of the irs were ini-tially screened by the DCRDR team in order to eliminate documents unrelated to the purpose of the DCRDR.

Following the initial. screening, 390 irs, as well as any related LERs, were submitted to the DCRDR team for further review. No information is provided in the Summary Report on how many of these irs were written as HEDs. While this review was fairly extensive in covering the plant incident documentation of Beaver Valley 1, no effort was made to review industry-wide documente, such as Significant Operating Event Reports (50ERs).  ;

In order to receive the fullest possible benefit from this historical review, DLC could expand the scope of its review to include industry-wide documentation as suggested by the guidance of NUREG-0700.

A questionnaire was administered to control room operators in order to t obtain information from the operators regarding problem areas in the control i

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} The human factors specialists (HFS) conducted a review of the I responses tion to the questionnaire through operator interviews. to determine areas requiring further explo follow-up interviews, 69 As a result of both the questionnaire and highlighted HEDs were identified and 46 problem

! areas were for further review during the control room survey.

There were two areas that were not clear from a review of the Summary Report:

o The 46 problem areas highlighted during the operatingexperience review (OER) were not identified as HEDs.

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' The Summary Report does not provide any indication of the number of operators queried or of the number of responses received.

areasAt the with themeeting HFS. with the licensee, the NRC team discussed the 46 pro team concluded that After reviewing several of the problem areas, the NRC the 46 problem areas should be written assessed by the DCRDR team. as HEDs and to the Summary Report a record of these new HEDsThe licensee s including the proposed solution or the justification for leaving an HED uncorrected.

questioned The NRC also questionnaires. the licensee concerning the administration and collection of the tors were queried.DLC indicated that 16, or approximately half, of the opera-visors, and 4 shift foremen.This number included 6 nuclear operators, 4 shift i

All 16 operators returned the questionnaire.

i In summary, more thorough, although the historical document review could have been the DCRDR. The it appears that the OER provided valuable contributions to provision of the requested information concerning the 46 problem areas and the questionnaires will further ensure was that the OER conducted in a manner that supports the DCRDP 3Fh rt.

ASSESSMENT AND IMPLEMENTATION PHASE Assessment of HEDs To Determine Which Are Sionifica Corrected

, Based I to NUREG-0737, on the guidance of NUREG-0700 and the requirements of Supplement all HEDs should be assessed for significance. The poten-tial for operator error and the consequence of that error in terms plant of 13

.o safety should be systematically considered in that assessment. Both the individual and aggregate effects of HEDs should be considered.

The result of the assessment process is a determination of which HEDs should be correc-ted because of their potential impact on plant safety. Decisions on whether HEDs are safety-significant should not be compromised by consideration of the means and potential cost of correcting those HEDs.

Cost of corrections is more appropriately addressed in the selection of design improvements.

The Summary Report provides a description of the process and criteria used for assessment of HEDs. Appendix F contains HED assessment docu-mentation and forms. According to the Summary Report, the entire DCRDR team was involved in the assessment process.

A total of 443 HEDs resulted from the review phase of the DCRDR and entered the assessment process.

That process, summarized on page 2-34 of the Summary Report, includes the follow-ing considerations:

1. Potential operator error identification

2. Potential consequences of error identification

3. Error / consequence analysis

4. Error recognition, auto recovery 5.

HED corrective action identification

6. Corrective action analysis

7. Recommended resolution B. Resolution categorization .

9. Schedule prioritization Figure 2-1 of the Summary Report provides the HED Assessment flow chart which ind.icates that the assessment activity is one part of a larger pro-cess. The process is the same as the one indicated during the in-progress audit which was found to address HEDs in terms of the potential for operator error and the potential consequences of the error for plant safety. How-ever, the assessment and design selection process should result in the categorization of the HEDs according to their impact upon plant safety and the establishment of a schedule to implement corrective actions that will give priority to safety-significant HEDs.

audit, At the time of the in-progress reviewers expressed concern that the schedule for implementing cor-rections did not sufficiently distinguish Priority 1, 2 and 3 HEDs, nor reflect the safety significance associated with the HED. All specific 14 I

s implementation dates for each priority of corrective a defined.

of Supplement As such the process is unacceptable accordingents I to NUREG 0737.

to the r This concern is_still apparent inacti the Summary Report - the schedule priorities for corrective HED on based on the define separate priorities for HEDs according

y. Page 2-40 of clearly the Summary Report defines the priority schedule  :

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Priority 1 HEDs are to be completed no later than issue of all design outputs. after 18 mon o

Priority 2 HEDs will be completed as soon as practical .

o Priority 3 HEDs have no specific implementation e to be date but scheduled after Priority 1 and 2 corrections are complete o

Priority be implemented. 4 HEDs include those for which no corrective acti on is to o

Enhancement HED corrections will be complete as soonpossible as but no later than the end of refueling outage 6 .

Also mentioned is DLC's intention to implement all Priority 2, 1, corrective actions by the end of refueling outage 7and .

(Fall .3 1989 As presented, following reasons: the reviewers find the schedule unacceptable the due to x

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' 1. Priority I should HEDs are presumably of a safety-significant and kind basis). therefore It be corrected promptly (at least on a next refueling outage.would be reasonable to expect the resoluti to be As these HEDs stand now, the correction is implemented no later than 18 months aftere the of issuanc j all design outputs - with no schedule for design outputs .

2. Priority 2 and 3 HEDs are yet to be scheduled. I

! commitment that The only firm I completion can be gathered from the Summary Report is the of all corrections by Fall 1989, which is not within j 15

l two refueling outages from the submittal of the Summary Report, as recommended by the NRC.

Based on the Summary Report and information provided during a meeting with DLC on February 13, 1986, the reviewers found that the assessment process has not been applied in an acceptable manner. Although the process considers both operator error and the safety significance of HEDs, another purpose of the assessment is to prioritize HEDs in order to correct first those of critical impact on plant safety. Presently, safety-related HEDs fall into Priority 1, 2, or 3, and DLC has not developed a firm schedule for corrective action associated with the priority of the HED. While these issues were not resolved during the February 1986 meeting, DLC was made aware of the need to specify a schedule based on safety significance of HEDs.

This schedule should be documented in a supplement to the Summary Report.

Furthermore, the licensee was informed at the February 1986 meeting of the unacceptability of correcting HEDs by the fall of 1989. The NRC expects all corrections to HEDs to be completed within two refueling outages after the submittal of the Summary Report.

Selection of Desian 1morovements The purpose of selecting design improvements is, as a minimum, to correct safety-significant HEDs. Selection of design improvements should include a systematic process for development and comparison of alternative means for resolving HEDs. Furthermore, according to Supplement I to NUREG-0737, the licensee should document all of the proposed control room changes.

The Beaver Valley 1 Summary Report described a process for development and selection of alternative means for correcting HEDs. For each HED assessed as a problem, the DCRDR team developed corrective actions using control room improvement techniques,such as enhancements, equipment and panel modifications, control room features redesign, procedure changes, and training. Each of these potential HED resolutions was then evaluated for its impacts on system safety, operational effectiveness, plant availability, consistency with the overall control room, compliance with regulatory requirements, control room staffing, and consistency with other emergency upgrade programs. l 4

16

. 1

.o After the various potential corrective actions for the HED had been identified and analyzed for their impacts, the licensee then selected one of these proposed actions to be the final HED resolution, based on its merits.

In addition, when there was more than one corrective action that apper. red to have " equal benefits," the selection of the appropriate resolution technique included a " cursory cost-benefit" analysis. During the February 1986 i

meeting, DLC indicated that this cost-benefit analysis was produced

' primarily for addressing management questions regarding the different methods for correcting the HEDs.

The licensee further indicated that management did not reject any HED corrections proposed by the DCRDR team as a result of cost.

The selection of the design improvements process was conducted by the DCRDR team with the full participation of the HFS.

The tools available for the development and recommendation of corrective actions included the use of a half-scale photomosaic and cutout drawings of all control panels which served as a means for trying out the proposed control board modifications.

However, DLC did not provide information on the process for tracking HED resolutions, i

from the development phase to the implementation stage. Addi-tionally, during the in-progress audit, the NRC team indicated that informa-tion on the review and approval mechanism for the design improvements selected by the DCRDR team should be provided for further review. This information was not included in the Summary Report.

At the February 19,86 meeting, DLC was made aware of the NRC's need for additional information to permit an adequate review of the HED resolution tracking process. The licensee provided a brief description of the system that is currently used at BV-1 to process modifications to plant equipment. While this information addresses the NRC's concern, it is recommended that the licensee submit to the NRC a detailed description of this process for tracking HED resolutions.

In summary, the licensee has developed a process for selecting HED i

resolutions. However, DLC still needs to provide additional information on the process for tracking HED resolutions to satisfy this requirement of NUREG-D737, Supplement 1.

17

- .- . -.- .. - - - - . - -.- - .- ..-.s. -

Verification That Selected Desian Imorovements Will Provide the Necessary Correction Without Introducina New HEDs A key criterion of DCRDR success is a consistent, coherent,- and effective interface between the operator and the control room. One good way to satisfy that criterion is through iteration of the processes of selection -

of design improvements, verification that selected design improvements will not introduce new HEDs. According to NUREG-0800, techniques for the verification process might include partial resurveys on mocked-up panels, applied experiments, engineering analyses, environmental surveys, and operator interviews. NRC staff believe that each iteration of the selection and verification processes should reduce inconsistencies in the operator-control room interface while increasing the coherence and effectiveness of that interface. The consistency, coherence, and effectiveness of the entire operator-control room interface is important to operator performance. Thus, evaluation of both the changed and unchanged portions of the control room is necessary during the verification processes.

A review of the Beaver Valley 1 Summary Report indicates that the

{ licensee

' did not have a separate process for verifying the HED resolutions.

However, as described in the selection of design improvements phase, these i requirements were included as criteria used in the analysis of corrective 1

actions (page 2-37).

In addition, the licensee indicated that a half-scale photomosaic and cutout drawings of control room panels were available for

" verifying the appropriateness of the proposed resolutions" (page 2-41).

Through these statements, it appears that the licensee has satisfied this requirement of the Supplement I to NUREG-0737. However, a review of the HED l

summaries indicates that many HEDs are still being studied; therefore, this verification process should be continuously applied until all HED resolu-tions are developed. ,

Coordination of Control Room Imorovements With Chances From Other Proaram Such As the Safety Parameter Disclav System (SPDS).

Reaulatory Guide 1.97 Instrumentation. Doerator Trainino.

and Uooraded Emeraency Ooerating Procedures (E0 Psi l

The DCRDR is part of the post-Three Mile Island Emergency Response Initiatives which impact the control room, and as such requires integration i

18 i

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

1

-l with other programs. All modifications can be integrated with respect to design overlap and scheduling overlap as they affect the control room operations.

The DCRDR can be performed in such a way that changes are reviewed and implemented in a fashion that least disrupts operators- and their activities. The exact means of accomplishing this is dependent on the plant's own programs and schedules. The result of successfully meeting this requirement should be the integration of control room changes to maintain a consistent, coherent, and effective control room for the operators to perform their tasks.

NUREG-0800 provides further guidance to assist in meeting these objectives.

DLC has described the integration of the DCRDR with other emergency response initiatives on pages 2-41 through 2-43 of the Summary Report. That description indicates that the integration includes the following programs:

1. SPDS

2. Emergency Operating Procedures

3. Regulatory Guide 1.97 Instrumentation

4. Emergency Response Facility DLC indicates that integration act'ivities have been completed in several areas.

considerations. The DCRDR team has reviewed the SPDS for human factors The SPDS is a Westinghouse System and was also reviewed for integration with the E0Ps.

The task analysis has been used to generate and validate

the E0Ps in addition to serving as a basis for verifying operator task capabilities in the control room. E0Ps were validated in the simulator with participation from both the E0P development team and the DCRDR team.

Regulatory Guide 1.97 instrumentation was integrated by providing a flow of information from the DCRDR team to the Regulatory Guide 1.97 team. This effort was for the purpose of evaluating the information requirements against existing control room instruments.

! The results of the DCRDR have been provided to the Emergency Response facility (ERF) project personnel for their use.

In conclusion, a review of the Summary Report indicated that DLC has conducted activities that are associated with the integration of the DCRDR with other programs.

Further activities should be considered during this i

effort; these include the implementation of control room changes in a manner 19

that least disrupts operators.

Because of the nature and amount of poten-tial changes, the programs should be scheduled such that they are accom-panied by training of operators.

This is crucial in order to least disrupt an operating plant. DLC has not specifically addressed this aspect of the requirement.

During the February 1986 meeting, DLC indicated that the design change program includes training considerations. Operators are-exposed to changes on the simulator before it is installed in the control room during the next outage.

The reviewers Westinghouse design. also note that the E0Ps and SPDS are derived from

,the It is not clear how the SPDS has been integrated with new E0Ps and how that iras evaluated by the DCRDR team.

The reviewers also require more information regarding the extent to which the E0Ps and training elements are to be used to re, solve HEDs. Also, if these elements are to be modified, what is the expected date by which the SPDS, for a

example, will be fully implemented? Completion' dates for the programs would provide greater assurance that this requirement is being satisfied.

4 Such information should be provided during a meeting and in the supple-ment to the Summary Report.

This information should include the schedule by which the upgraded programs including training were integrated. Until this information is provided, DLC's compliance with this requirement cannot be fully evaluated.

' Analysis of Chanaes Prooosed Desian Chances and Schedule for Irelementino Des Accor. ding to Supplement I to NUREG-0737, a Summary Report should out-line proposed control room changes and proposed schedules for implementa-tion, and provide summary justification for HEDs with safety significance to be left uncorrected or partiall,y corrected.

3 DLC Appendices has provided a record of all HEDs documented during the DCRDR in G through U of the Summary Report and has included a brief description of the HED, the guideline source, review source, location, l priority, and the proposed solution.

the In addition to these documented HEDs, licensee should reclassify the 46 " problems" discussed in the section for OER as HEDs.

A description of these 46 HEDs should be submitted to the 20 2

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' NRC in disposition.enough detail to permit evaluation of the appropriateness Furthermore, their of should be addressed as suggested in the control paper.

this ro NRC for Any review.HEDs resulting from this process should also be e subm of Of those documented HEDs submitted as part of themany ,

Summa the proposed solutions cannot be evaluated because of the descriptions that are provided for the HED and its resolution or incomplete associated with the HEDs. studies February Discussions with the licensee at the 1986 meeting helped to resolve many of the questions review team had regarding the HEDs. NRC that th Appendix B, that are acceptable Section B-1 lists those HEDs that haveactions corrective corrective to the NRC review team.

Those HEDs with proposed Appendix B. actions that Appendix C, were not acceptable are presented in Section B Sections I and 2 list those HEDs identified in the Su=ary Report as undergoing further study such as the LMD study. DLC identified HEDs from the simulator exerciseHowever, the . (SIMEX)

HEDs were not presented in the SummaryeseReport Appendix D.

these HEDs.

DLC should submit those guidelines that areThese HED associated with Presently, DLC fall of 1989. proposes to complete all HED corrective actions by the proposed schedule was unacceptable.The NRC informed this DLC to HEDs to be completed within two (2) refueling of the Summary report. submittal outage proposed In conclusion, the licensee should provide descriptions e of above. solutions This in greater depth addressing issues suchraised as those j Report. information should be provided in a supplement to the!!

i 1

21 r-- . _ - , , - - . -

Justification for HEDs To Be left Uncorrected All HEDs for which no corrective action will be taken, listed in Appendix T, were discussed at the February meeting in detail with the reasons or justification for DLC's decision not to take action.

The NRC found the majority of DLC's explanations to be adequate, and these HEDs are listed in Appendix E, Section E-1. However,  !

there remain nine (9) HEDs, listed in Section E-2 of Appendix E, that need to be readdressed by the licensee.

This information should be provided in a supplement to the Summary Report.

CONCLUSIONS An evaluation of DLC's Summary Report for the DCRDR of Beaver Valley Unit I has been conducted. The NRC has conducted an in-progress audit of Beaver Valley I and provided recommendations to improve its DCRDR. Some of those have been reflected in the Summary Report.

In other areas of the Summary Report, the reviewers could not find confirmation that recommenda-tions from the audit were considered. For example, the control room survey criteria and methodology have not been described sufficiently to permit the reviewers to draw conclusions. Many other areas of the Summary Report have omitted detailed discussions which has limited the reviewers' capability to draw final conclusions, such as the brief descriptions of the HED corrective actions.

Additionally, because many HEDs are still being studied, the proposed design solution has not been provided. The following are items of concern that should be resolved in a supplement to the Summary Report:

1.

Establishment of a Qualified Multidisciplinary Review Team o Provide information which clearly defines the role and level of management involvement in the review and approval of design change corrective actions.

2. Control Room Inventory o

• Provide assurance that a validation effort will be conducted with the ICCS panel and that the NRC will be provided with the results.

22

3. Control Room Survey o

Address all the concerns associated with the guidelines presented in Appendix A. Any HEDs resulting from this process should be submitted to the NRC for review along with descriptions of proposed resolutions.

o Conduct a survey of the control room environment after the wall that separates Units 1 and 2 is removed. Results of this survey should be forwarded to the NRC.

o Conduct a survey of the communications system using the criteria presented in Section 6 of NUREG-0700. Results of this survey should be forwarded to the NRC.

4. Review of Operating Experience o

Convert the 46 problem areas identified into HEDs and process these HEDs accordingly, including descriptions of proposed resolutions.

5. Assessment of HEDs o Present a schedule to implement HED design solutions that is acceptable to the NRC.

6. Selection of Design Improvements o

Provide a detailed description of the process to be used for tracking HED resolutions.

7. Coordination of Control Room Improvements With Changes From Other Programs o

Provide information as to how, and on what schedule, the SPDS

- is being integrated with the new E0Ps and the operator training program.

23 l

8. Analysis of Proposed Design Changes and Justification for HEDs left Uncorrected o

Provide results of ongoing studies for those HEDs still being examined as listed in Appendix C.

o Provide detailed descriptions of the resolutions.for all HEDs listed in:

Appendix B, Section B-2 Appendix D Appendix E, Section E-2 i

l J

l 4

24

REFERENCES 4

1. NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," May 1980, Revision 1, August 1980.

2. NUREG-0737, Supplement 1,

" Clarification of TMI Action Plan Requirements," U.S. Nuclear Regulatory Commission, December 1982.

3. NUREG-0700,

" Guidelines for Control Room Design Reviews," U.S. Nuclear Regulatory Commission, December 1982.

4. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 18.1, Revision 0, September 1984.

5. " Program Plan for the Control Room Design Review for Beaver Valley, Unit 1," Duquesne Light Company, September 27, 1983.

6. Review Beaver of the Control Room Design Review for Duquesne Light Company's Valley Nuclear Power Plant, Unit 1 Safety, U.S. NRC, December 27, 1983. Division of Human Factors

7. Results of In-Progress Audit at Beaver Valley Power Station, Unit 1, Division of Human Factors Safety, U.S. NRC, September12, 1984.

8. Letter from J.J. Carey, Duquesne Light Company, to Hugh Thompson, I Division Detailed of Licensing, U.S. NRC, transmitting the Summary Report of the Control Room Design Review for Beaver Valley Nuclear Station, Unit 1. Duquesne Light Company, November 29, 1985.

9. Control Room Design Review for the Beaver Valley Unit 1 Nuclear Power Station Summary Report, prepared by the Beaver Valley Control Room Design Review Team, Duquesne Light Company, November 1985.

25 i

APPENDIX A NUREG-0700 Guidelines That Need to Be Addressed by DLC 26

'A1 NUREG-0700 Guidelines checked in the Ouestionnaires/ Interviews in of the Survey 6.2.1.4A(1) 6.2.1.6A(1) 6.2.2.63 i 6.2.2.6C 6.3.1.5A 6.3.2.1A 6.3.3.3F 6.3.4.1C(1) 6.3.4.lC(2) 6.3.4.1C(3) 6.4.4.40 6.5.1.1C 6.5.1.1E(1) 6.5.1.1E(2) 6.5.1.lf 6.5.1.3A 6.5.1.3B(1) 6.5.1.3B(2) 6.5.1.3B(3) ,

6.5.1.5B 6.5.5 GEN l

27 h

A-2 Sun,3rv 48 NUREG-0700 Reeort Guidelines marked N/A as listed in Accendix U 6.1.1.3F(2) 6.1.1.3F(3) 6.1.2.3A(1) 6.1.2.3A(2)

, 6.1.2.3B 6.1.2.3C 6.1.2.3D(1) 6.1.2.3D(2) 6.1.2.3E(1) 6.1.2.3E(2) 6.1.2.3F(l) 6.1.2.3F(2) 6.1.2.3G 6.1.2.3H(1) 6.1.2.3H(2) 6.1.2.3H(3) 6.1.2.4A 6.1.2.4B 6.1.2.4C 6.1.3.2A 6.1.3.2B 6.1.5.5C 6.2.1.2E 6.3.1.2A(2)

6.3.1.5B(1) 6.3.1.5B(2) 6.4.2.2C(l) 6.4.2.2C(3) -

6.4.2.2C(4) 6.4.3.lA 6.4.4.28 6.4.4.4E(1)

- 6.4.4.4E(2) 6.4.4.4E(3) 6.4.4.4E(4) 28

. - - s

j e

A2 48 NUREG-0700 Guidelines marked N/A as listed in ADoendix U of the Summary Recort (continued) 6.4.4.4E(5) 6.4.5.2A 6.4.5.2B(1) 6.4.5.2B(2) 6.4.5.4A 6.4.5.4B 6.4.5.4C 6.4.5.4D 6.4.5.4E 6.5.1.6D(2) 6.5.5.1A(2) 6.7.1.2A(1) 6.7.1.2A(2) 29

A3 i

NUREG-0700 Guidelines listed but no action taken 6.1.2.2F 6.2.1.BB 6.2.2.5A 6.2.2.5B 6.2.2.6A 6.4.1.lA(1) 6.4.1.lA(2) 6.4.1.lB(1) 6.4.1.lB(2) 6.4.1.lB(3) 6.4.4.5B(1) 6.4.4.5B(2) 6.5.1.lB 6.5.1.lt 6.5.1.lD 6.5.1.lE(1) 6.5.1.lE(2) 6.5.1.2A

6.5.1.2C 6.5.1.4E 6.5.3.3B(5)

I i

t 8

i 30 0

A4 NUREG-0700 Guidelines that still remain to be checked 6.1.5.5A 6.1.5.58 6.5.3.1D e

31

i A-5 Accendix NUREG-0700 U of the Summary Guidelines Reoort missino from BV-1 Checklist as cre i 6.1.2.2E(la) 6.1.2.2E(lb) 6.1.2.2E(2) 6.4.2.2A 6.4.2.2B 6.5.4.1C 6.6.1.1 3

6.6.1.2 6.6.2.1 6.6.2.2 6.6.2.3 6.6.2.4 6.6.3.1 6.6.3.2 6.6.3.3

6.6.3.4 6.6.3.5 1

! 6.6.3.6 j 6.6.3.7 6.6.3.8 6.6.3.9 .

i 6.6.4.1 6.6.4.2 6.6.5.1

6. 6.5.2 6.6.6.1 6.6.6.2 6.6.6.3 6.6.6.4 i

32 e

, - - . _ , _ ..-..-my, ,, - - , - - -w ,----..--_--_--c._,_. - , , - ---_m-___.-._--_r___.---,. ,-- . _-__..-__ , m , .---.- -

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

l APPENDIX B HEDs With Corrective or Proposed Corrective Actions S

33

B-1 The proposed corrective action appears to be adequate.

as they appear in each appendix. HEDs are listed Appendix G: 26, 30, 179, 225, 229, 334, 335, 337, 344, 348, 255, 374, 411, 434, 51, 52, 324, 329, 338, 358, 341, 343, 384, 385, 386, 392, 394, 403, 43), 442, 347 Appendix I: 4, 7, 422, 260, 47, 156 Appendix J: 157, 164, 166, 362, 112, 116, 210, 92, 93, 94, 105, 171, 172, 173, 178, 187, 182, 189, 326, 401, 443, 444, 395, 375 Appendix K: 12, 35, 39, 261, 36, 37, 43, 3, 42, 41, i

40 Appendix L: 34, 380, 153, 379, 201, 381, 165, 410, 413, 414, 415, 417, 419, 420, 426, 428 Appendix M: 320, 309, 377, 310, 313, 314, 315, 317, 321, 312, 319 Appendix N: 441 .

Appendix 0: 45, 50, 79, 200, 16, 18, 204, 363, 370, 106, 110, 104, 99, 100, 378, 9, 424, 425, 10, 15 Appendix P: 119, 433, 311 Appendix Q: 214, 217, 216, 219, 218, 215, 220, 221, 222, 223, 247, 248, 249, 196, 271, 418, 397 409,

~

1 34

1 B2 The description of the corrective action cannot be evaluated because the descriptien is too brief, ambiguous, or general.

HED 208:

The discrepancy here is that the green status panel lights (622 & 623 status panels) do not appear on. The licensee's response there is improved. no problem but that the organization of the panels should be While DLC addresses an apparent problem with discrimination of lights from adjacent indications, the HED refers to a concern about light intensity that was not resolved. Additional information regarding the light intensity concern should be presented.

see The licen-should provide the results of measuring light intensity, using a spot photometer, to determine if the light output meets the guidelines (see 6.5.3.2b).

HED 163:

This HED refers to inadequate scale increments that do not allow operators required by the E0P. to read steam generator pressure values to the The licensee proposes to resolve the discrepancy by revising the procedures.

HED prevents A lack of a complete description of the a valid evaluation of the resolution to be made. The licensee should provide more information describing whether the increment addressed (200 psi) is a minor, intermediate, or major increment and what the impact will be from revising the E0Ps to fit control room instrumentation.

The following is a list of the remaining HEDs that are in this ca and should be addressed in a similar manner by the licensee:

0, 14, 38, 55, 56, Ill, 150, 158, 198, 259, 359, 424, 432, 153 325, 1

35 1

1 APPENDIX C HEDs Still Undergoing Additional Study or Review t

O 36

~

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C-1 HEDs listed in Appendix R that are being addressed in the Label, 2

Mimics, and Demarcation (LMD) study.

54, 57, 58, 60, 61, 62, 63, 67, 69, 71, 72, i 73, 74, 75, 77, 81, 82, 83, 84, 86, 87, 113, 114, 118, 445, 199, 212, 213, 174, 330, 372, 263, 264, 265, 266, 1

267, 268, 269, 270, t

271, 272, 273, 274, 275, 276, 277, 278, 279, 280, 28), 282, 283, 284, 285, 286, 287, 288, 289, 290, 291, 292, 293, 294, t

295, 296, 297, 298, 299, 300, 301, 302, 303, 304, 305, 391, 396, 399, 401, 421, 437, 440 C2 HEDs requiring further study that are listed in the Appendix S. order shown in 8, 64, 68, 70, 76, 85, 95, 120, 159, 162, 185, i 231, 318, 345, 346, 352, 353, 354, 356, 430, 435, 439.

4 I

37 l

1

.=

APPENDIX D HEDs Referencing Simulator Exercise (SIMEX) or SPDS 0

l l

38 i

e

l I

' I These HEDs reference Simulator Exercise (SIMEX) or SPDS, yet p a guideline criteria violated. number from NUREG-0700, Section 6 nor a description o i

I 407, 409, 410, 4)), 412, 4]3 414, 415, 416, 417, 418, 419 420, 421, 422, 423, 424 425 426, 427, 428, 429, 430, 431 4 432, 433, 434, 435, 436, 438, 437'

439, 44]

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39

P APPENDIX E HEDs Not Requiring a Corrective Action d

e e

40

y

/,*

j l

+.

E-1 HEDs where the justification for taking- no satisfactory. corrective actic- is T of the Sumary Report.These HEDs are listed pendixin the 1, 177, 244, 239, 115, 160, 32, 28, 21, 23, 24, 27, 65, 53, 59, 22, 80, 91, 96, 29, 31, 121, 33, 48, 49, 44, 126, 128, 130, 127, 129, 138, 132, 133, 134, 135. 136, 137, 147, 148, 149, 168, 169; 170, 175, 176, 180, 181, 184,, 191, 183, 188, 195, 123, 6, 2, 5, 11, 13, 19, 20, 17, 203, 205, 206, 207, 103, 142, 209, 224, 226, 211, 228, 233, 230, 234, 240, 245, 235, 236, 237, ae 238, 227, 232, 241, 242, 124, 125, 243, 246, 252, 253, 250, 254, 255, 194, 190, 192, 193, 197, 251, 262, 255, 144, 202, 167, 306, 307, 308, 316, 322, 327, 342, 376, 331, 332, 333, 339, 350, 351, 349, '

364, 361, 366, 360, 367, 369, 97, 109, 108, 406, 387, 146, 139, 145, 416, 143, 140, j41, 107, 101, gg, i 102, 151, 89, 122, 88, 152, 407, 412, 423, 429, 436, 388, 389, 390, 393, 404, 402, 398 1

G P

41 '

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E-2 HEDs where the justification for taking no corrective action is inadequate.

HED 161:

The discrepancy is that the E0P required that RCS pressure was to be read at 1585 PSIG; due to the scale incrementation, this task could not be accurately performed.

The licensee changed the E0Ps to require 1590 PSIG to resolve the HED.

4 However, due to the size of the scale on the meter face, 1590 PSIG cannot be read from the distance required while standing at the bench board.

i HED 66:

that are notThe problem here is that there are 30 green annunciator tiles

" dark' during normal operations.

perceive this The licensee does not as a problem in that the green lights are addressed by training and in the procedures.

The NRC review team considers that the function of the annunciator system is to alert the operators to abnormal conditions.

The licensee should consider regrouping or removal of these status lights to a more appropriate location such as a designated status board.

HED 90:

The discrepancy is that the throttle MOV switches have the same type controls as open/close MOV switches. {

The licensee response is that the valves have dual independent lights, flow indication, and )

alarm. However, these two MOV switches are identical in appearance.

The licensee should make the switches appear different or provide some unique indication on the label.

HED 78:

in the The problem is that the annunciator controls are not arranged same order on all locations. The licensee response is the operators recognize the controls and enhancements will be added. At the time of the meeting, DLC was unable to describe the kind of enhancement to be used.

The licensee should provide information that explains how this HED will be resolved.  ;

i HED 117: The discrepancy is that the turbine and reheater status 1ights and pushbuttons are identical in design.

DLC does not consider

" this to be a problem, citing that the legends are clear. The review team position is status lights and pushbuttons should be visually different.

The licensee should take action to ensure that the 4

42

4

?a-operators lights.

pushbutton are able to visually differentiate between status and HED 400: This building HED addresses the LW-TK-7A-B pump in the Auxiliary control room. and the need to have a related tank level indication in the DLC's response was that there is no problem since the pump is in the auxiliary building. This response did not address the need for a tank level indicator in the control room.

with From discussions %

DLC at the February meeting, it is the NRC review team's under-standing room. that a tank level indication is to be installed in the contro An additional question that DLC should address is the possible need for controls to this pump to be moved to the control room.

HED 383:

The HED indicates that indicator lights for steam controllers and selector switches are on status panel 622.

that The licensee indicates the 18 valve position indicators need to be on the and that there is no problem. status panel Examination of this panel containing both pushbutton switches and status lights suggests the poss display / control relationship confusion.

this HED for possible resolutions to this problem.The licensee s There are two guidelines (6.5.3.1A(2),

T of the Summary Report that are violated. 6.5.3.la(1)) listed in Appendix The descriptions are as follows:

o No bulb test capability o

Dual filament bulbs get used Neither of these items has an HED number assigned to it.

The licensee indicated boards at theduring discussions that operators perform a walk-dow start of the shift to note any bulb discrepancies.

The licensee needs to address how the operators account fo* bulb during failur the balance of the shift.

The NRC staff does not consider administrative procedures problem. The for board walk-downs 'as a satisfactory resolution to this j

filament bulbs guideline 6.5.3.1A(1) and its associated statement of ' dual get used" is too brief and vague to be evaluated. This concern

" absence should be described in detail and the related DLC response of of light not used as status" should be expanded to justify the D position of not requiring correction.

43

.. - --- - . ..  : -