ML20210L480

Technical Evaluation of Dcrdr for Prairie Island Nuclear Generating Station,Units 1 & 2

ML20210L480
Person / Time
Site:	Prairie Island
Issue date:	04/25/1986
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20210L485	List: ML20210L480
References
CON-NRC-03-82-096, CON-NRC-3-82-96 SAIC-86-1078, NUDOCS 8604290349
Download: ML20210L480 (58)

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SAIC-86/1078 TECHNICAL EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW FOR NORTHERN STATES POWER COMPANY'S PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 April 25, 1986

. Prepared by: v Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102 Under Contract to:

U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Contract No. NRC-03-82-096 86542993$9x 68jo

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FOREWORD This Technical Evaluation Report was prepared by Science Applications International Corporation (SAIC) under Contract NRC-03-82-096, Technical Assistance in Support of NRC Licensing Actions: Program III. The NRC previously reviewed Prairie Island Nuclear Generating Pl ant's (PINGP)

Detailed Control Room Design Review Program Plan submitted on May 27, 1983 and subsequently performed an on-site, in-progress audit during March 6-9, 1984. The results of the audit were transmitted to PINGP on July 17, 1984.

PINGP responded to the NRC's audit report by formally submitting a status report on January 31, 1985. On March 11, 1985, the NRC agreed to an exten-sion to the submittal date of PINGP's DCRDR Summary Report until January 1, 1986. PINGP submitted the Summary Report in December 1985.

This Technical Evaluation Report is based upon the information supplied in PINGP's Summary Report submitted in December 1985 as well as the previous information exchanges documented above.

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TABLE OF CONTENTS Egetion Pace BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 PLANNING PHASE . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

1. Preparation and Submission of a Program Plan . . . . . . . 3

2. Establishment of a Qualified Multidisciplinary Review Team ....................... 4 REVIEW PHASE . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

1. Operating Experience Review (OER) . . . . . . . . . . . . 6

2. System Function and Task Analysis (SRTA) . . . . . . . . . 8

3. Comparison of Display and Control Requirements With a Control Room Inventory . . . . . . . . . . . . . . . . . . 10

4. Validation of Control Room Functions . . . . . . . . . . . 12

5. Control Room Survey ................... 13 ASSESSMENT AND IMPLEMENTATION ................... 19

1. Assessment of HEDs . . . . . . . . . . . . . . . . . . . . 20

2. Selection of Control Room Design Improvements ...... 24 -

3. Verification That Improvements Will Provide the Necessary Corrections and Will Not Introduce Any New HEDs . . . . . . . . . . . . . ... . . . . . . . . . . 26

4. Coordination of DCRDR Effort With Other NUREG-0737 Supplement 1 Improvement Programs ............ 28

5. Proposed Schedules for Implementing HED Corrections ... 29 ANALYSIS OF PROPOSED CORRECTIVE ACTIONS AND JUSTIFICATIONS FOR HEDs LEFT UNCORRECTED ..................... 31

1. Proposed Corrective Action . . . . . . . . . . . . . . . . 31 i 2. Justification for HEDs To Be Left Uncorrected ...... 33 CONCLUSIONS AND RECOMMENDATIONS .................. 36 AGENDA FOR MEETING . . . . . . . . . . . . . . . . . . . . . . . . . 40 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 l APPENDIX A - HEDs With Corrective or Proposed Corrective Action .. 44 i

APPENDIX B - Justification for No Corrective Action ........ 49

.. 5 TECHNICAL EVALUATION OF THE DETAILED CONTROL R00N DESIGN REVIEW FOR NORTHERN STATES POWER CONPANY'S PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 This report' documents the findings of SAIC's technical evaluation of the Northern States Power Company's Summary Report of the Detailed Control Room Design Review (DCRDR) of the Prairie Island Nuclear Generating Pl ant,

, ' Units 1 and 2 (PINGP). The purpose of the evaluation was fourfold: (1) to determine whether the DCRDR conducted by PINGP as documented in the Summary Report is acceptable; (2) to recommend to the NRC whether an on-site, pre #

implementation audit or a meeting should be conducted; (3) to provide an audit or meeting agenda where appropriate; and (4) to provide a basis for feedback to PINGP. The requirement set forth in Supplement I to NUREG-0737, titled " Requirements for Emergency Response Capability" December 1982 (Reference 1), served as the basis of the Summary Report evaluation.

PINGP's DCRDR began with the submittal of the Program Plan to the NRC on May 27, 1983 (Reference 2). The NRC staff comments on the Program Plan were forwarded to PINGP on November 9, 1983 (R'eference 3). An on-site, in-progress audit was conducted at the Prairie Island Nuclear Generating Plant, Units I and 2 on March 6-9, 1984, and the findings of the audit were forwarded to PINGP on July 17, 1984 (Reference 4). Northern States Power Company submitted a PINGP DCRDR status report and response to the March 1984 in-progress audit (Re,ference 5). In response to the status report, the NRC agreed on March 11, 1985 to an extension of the completion date for the DCRDR with the Summary Report submittal due on January 1, 1986. The NRC received Northern States Power Company's submittal of the PINGP Sumn:ary Report in December 1985 (Reference 7). The findings of SAIC's evaluation of the PINGP Summary Report follows a brief overview of a discussion of the background requirements of the DCRDR process.

l BACKGROUND Licensees and applicants for operating licenses are required to conduct a Detailed Control Room Design Review (DCRDR). The objective is to " improve

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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.1). The need to conduct a DCRDR was confirmed' in NUREG-0737 and in Supplement I to NUREG-0737. The DCRDR requirements' in Supplement I to NUREG-0737 replaced those in earlier docu-ments. Supplement I to NUREG-0737 requires each applicant or licensee to conduct its DCRDR on a schedule negotiated with the NRC. Guidelines for conducting a DCRDR are provided in NUREG-0700 while the review and assess-ment processes for the NRC are contained in NUREG-0800 (The cited NUREG documents are References 8 through 10, respectively, except for Supplement I to NUREG-0737 which is Reference 1.)

A DCRDR is to be conducted according to the licensee's own Program Plan (which must be submitted to the NRC). According to NUREG-0700, the DCRDR program should include four phases: (1) planning, (2) review, (3) assessment ,

and implementation, and (4) reporting. The product of the last phase is a

, Summary Report which, according to Supplement I to NUREG-0737, must include an outline of proposed control room changes, their proposed schedules for

implementation, and summary justification for human engineering discrepan-cies with safety significance to be left uncorrected or partially corrected.

The purpose of this Technical Evaluation 1teport is to assist the NRC by providing a technical evaluation of the Prairie Island Nuclear Generating Plant DCRDR process and results.

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

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1. Establishment of'a qualified multidisciplinary review team.

2. Use of function ~and task analysis to identify control room operator tasks and information and control requirements during emergency operations.

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

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

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of human engineering discrepancies (HEDs) to determine  !

5. Assessment l which HEDs are significant and should be corrected.

6. Selection of design improvements that will correct those discrepan-cies.

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

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

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cies.

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

PLANNING PHASE I

1. Preparation and Submission of a Program Plan  :

The NRC staff reviewed Prairie Island Nuclear Generating Plant's and Detailed Control Room Design Review Program Plan submitted for Units I

2. The NRC staff reviewed the Program Plan with reference to the require-ment of Supplement 1 to NUREG-0737 and the guidance contained in NUREG-0700 and NUREG-0800, and, transmitted comments to PINGP by memorandum dated November 9, 1983. In summary, the NRC review found, "The NSP Program Plan to NUREG-addressed most of the DCRDR requirements stated in Supplement I 0737. It did not address verification that improvements will provide neces-sary correction of HEDs or verification that improvements will not introduce new HEDs. Other requirements were addressed, but the discussion did not As a result, allow full understanding of how they would be accomplished.

could the adequacy of the DCRDR proposed for Prairie Island Units I and 2 not be fully evaluated."

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PINGP DCRDR, provided The current - SAIC technical evaluation of the in below, is based upon all information available to date and is arranged I

order of the nine DCRDR elements identified in Supplement I to NUREG-0

2. Establishment of a Qualified Multidisciplinary Review Team Con-

] NRC in-progress audit team concluded that the Prairiedisciplines Island The l' trol Room Design Review Team was composed oftheanDCRDR adequate mix of ,

Moreover, team possessed that met the guidelines in NUREG-0800. to be authority to carry out their missions and appeared the appropriate assignments. The adequately organized to conduct the DCRDR and technical appro-task assignments and levels of involvement were also l

team members' priate.

As described in the Sumary Report, the DCRDR team consisted of aplant core l' comittee of specialists with expertise in human factors engineering,

instrumentation and controls engineering, operations, system engineering,

[ and training. Even though the presence of a qualified nuclear engineer had i all three of the project engineers possessed not been explicitly indicated, Four of the over five years of applied experience in the nuclear industry.

, PINGP and reporte, d directly to the Plant Mana-committee members were from and ger. Three were from the Nuclear Technical Services engineering group, 4

while located at the plant site, they reported to the Northern of States Nuclear Power (NSP) Company's general office management through the manager

The Human Interface Systems Department of the Honeywell Technical Services.

Center (HTSC) provided the expertise in human Inc. Technology Strategy factors engineering. Expertise in nuclear control room systems review and subcontractor. A task analysis were provid.ed by Quadrex Corporation as a and HTSC when supplemental group of specialists was available from NSP An examination of the resumes of the needed to assist the core comittee. the team l members confirms the adequacy and appropriate mix of DCRDR team o constituents.

the PINGP DCRDR, effort was In accordance with NUREG-0800 guidelines, conducted under the auspices of an NSP employee, the Superintenden Nuclear Technical Services. HEDs and recommendations to correct the dis-

< Plant crepancies were generated by the DCRDR Comittee andsupervisors presented to Operations Comittee which was composed of "on-site staff key 4

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O who acted as advisors to the plant manager." /,dequate interactions and comunication between the DCRDR and Operations Comittees were ensured by the fact that four members (two project engineers and two operations specialists) sat on both the comittees. In addition, any DCRDR Comittee member was free to raise issues to the Operations Comittee. In case of a disagreement between the recomendations of the Operations Comittee and the Plant Manager, the course of action determined by the Plant Manager to be the most " conservative" would be taken.

All but one of the DCRDR team members participated throughout the entire review process. One additional Senior Operations Specialist and a Superintendent of Quality Assurance from the plant were added to the DCRDR j Comittee after the Program Plan was submitted. An additional project engineer was added apparently after the in-progress audit. Despite this, it 4 is concluded that adequate continuity has been demonstrated for the DCRDR effort at PINGP.

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In conclusion, it is evident that the important prerequisites for establishing and supporting a qualified multidisciplinary review team, namely, the management and structure, team composition and member qualifi-

! cations, task assignments, levels of involvement and team support and inter-actions, are present in PINGP's DCRDR effort and therefore satisfies this requirement of Supplement I to NUREG-0737.

REVIEW PHASE l PINGP's review phase activities as listed in the Sumary Report include l the following:

i 1. Operating Experience Review (OER)

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2. Component Checklist Review l 3. Workspace Survey

, 4. System Review and Task Analysis (SRTA)

! 5. Verification of Control Room Activities i

6. Validation of Task Performance Capability I 7. Review of Remote Shutdown Capability i

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1. Operating Experience Review (OER)

A review of operating experience is not a requirement of Supplement 1 to NUREG-0737. However, such an effort is valuable in identifying events and HEDs which affect the safe operation of the plant, especially since PINGP has a ten-year operational history. In conformance with NUREG-0700 guidelines, the PINGP OER was comprised of two parts: operator question-naires/ interviews and a historical document review. First, a sample of operators were interviewed to identify problems. Desirable, as well as undesirable, system features were noted in the course of operations and in l

preparation for operations of the plant. Then, the archives of plant opera- l tional experience were gleaned for circumstances contributing to human performance problems. Relevant HEDs were unveiled as a result of the OER.

During the in-progress audit, the NRC audit team concluded that the PINGP OER was being performed in a manner which leads to a succeessful DCRDR ,

program.

Twelve of the thirty-six licensed operators at PINGP were interviewed.

Although the exact sampling method was not described, they represented a one-third sample of operators of different ages with diverse educational background and plant operating experience. The interviews (each took three hours on average) were comprised of structured, open-ended questionnaire and oral interviews. Each of the chosen operators was interviewed by a member

, of the human factors t,eam, and anonymity was maintained throughout the DCRDR process. The questionnaire consisted of detailed questions about the advantages, disadvantages, and operational history of control room com-ponents and control room ambience. In addition, a set of critical incident questions were incorporated into the questionnaires to allow discussions of anything that did not fall easily into the structured categories. The data were analyzed in two stages. First, the data were condensed into an inter-view transcription summary. Then, utilizing NUREG-0700 Section 6 listings 6

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as guides, relevant HEDs were extracted from the transcription summary.

This process resulted in the identification of 80 HEDs.

Review of plant operating experience included 647 reports of various l operating events that occurred during the period from preoperational testing in 1973 to the end of 1983. Two criteria had been adopted to identify an il event which warranted further consideration. First, the problem must appear i

potentially amenable to human factors engineering solutions. Second, the problem was either " operational or in an on-line maintenance activity linked to operations." The establishment of these criteria represents PINGP's i

attempt to derive operational guidelines from NUREG-0700 recommendations for

the identification of operating experience-related HEDs. There is a .

!- concern, however, that the incorporation of such criteria may exclude those HEDs which are less obvious and which are prohibitively difficult to correct. A closer examination of the actual DER procedure obviates this  !

concern. During the OER, a computer listing containing brief summaries of

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all Abnc,rmal Occurrence Reports, Reportable Occurrence Reports, Significant j l Operating Event Reports, and Unusual Event Reports was examined by human <

factors specialists to discard obvious cases of equipment failures, off-line i

maintenance errors, and externally caused disturbances (e.g., problems l caused by lightning strikes). All undiscarded reports were reviewed in their entirety, as were all Shutdown and Trip Reports. As a result, 244 of l the 647 reports had been thoroughly examined disclosing a total of 13 related HEDs.

i i In conclusion, the PINGP OER is extensive, thorough, and appropriately performed using technically sound methodology based on NUREG-0700. The effort identified a total of 93 HEDs. The OER would be more thorough, however, if the DCRDR team could peruse beyond the plant-spe:ific documents

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and include industry-wide reports (e.g., LER experiences with generic i applicability) as promulgated in the NUREG-0700 guidelines. Moreover, the l

NRC in-progress audit team also recommended development of a plan for keep-ing the operating experience surveys current even after the DCROR. Such a 4

suggestion would prove valuable throughout the operational life of the l plant.

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2. System Review and Task Analysis (SRTA)

The objective of PINGP's SRTA was to establish the traceability of the information and control needs for safe operation of the plant with sufft-t cient depth and detail to identify the specific operating and performance characteristics of instrumentation in the control room. To accomplish this objective, the generic Westinghouse Owner's Group (WOG) Emergency Response Guidelines (ERGS), High Pressure Version, Revision 1, April 15, 1983, was used as the basis for PINGP's plant-specific task analysis methodology. The plant-specific SRTA was structured to follow the generic WOG SRTA as closely

as possible. The foundation of the WOG's task analysis is based upon a l generic reference Westinghouse PWR. To determine the applicability of actions specified in the generic technical guidelines to PINGP, a comparison 1 j was performed between the reference plant and Units 1 and 2. Each of the 25

generic plant systems described in the ERG background documentation was

compared to the Prairie Island systems and a list of differences was l obtained. These differences were reviewed to determine whether they would  ;

! impact any significant safety consequences. As a result of the review, it

) was concluded that no safety-significant differences exist between Prairie i Island plant instrumentation and controls and those described for the l i reference plant.

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The development of plant-specific procedures involved the review of i

generic guidelines, supporting background information, existing plant emer-j gency, abnormal, and normal operating procedures, and other plant reference

{ material (Technical Specifications, Updated Safety Analysis Report, Flow and Logic Diagrams). Where the ERGS required plant-specific steps, they were i

• developed from a review of existing procedures, system drawings, or discus-l sion with plant operators. Appropriate task criteria were written and l l entered into the E0P. Consolidation of certain ERG steps was done in the l E0Ps to assist in operator performance of the tasks. Setpoints were also l researched using plant documentation, and a setpoint document was created j for use in the procedures development to ensure consistency and accuracy. A i total of 33 E0Ps were developed for PINGP and are identified in Table 39 (page 3-29) of PINGPs Sunnary Report.

! The plant-specific SRTA effort was performed on-site at PINGP by a

! consultant from the Quadrex Corporation. The consultant held a Senior 8

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Reactor Operator (SRO) license at a Westinghouse PWR plant and had nuclear power operations instruct *cn experience. The consultant helped to ensure the independence, accuracy and comprehensiveness of the SRTA process and was i

an attempt by PINGP to minimize the influence of any bias from plant- '

specific knowledge of operational tasks and equipment configurations.

The plant-specific SRTA was. structured by PINGP to follow the generic WOG's SRTA as closely as possible. Detailed operator task requirements were identified in Element Tables which provided an expanded treatment of the technical guidance that was developed in the E0Ps. .These tables identified the knowledge and skill requirements that are essential in the performance of the task or subtask decision and action requirements. This decomposition j

process was intended to identify special knowledge or training requirements 1

beyond a general knowledge of overall plant operations. Repeated tasks were identified and a tracking methodology using an identification number enabled the procedures personnel to improve consistency between procedures and by training personnel to identify common tasks between procedures.

A matrix was also developed by PINGP to identify required sequential relationships between guideline tasks. This information identified the plant systems that an operator must access to perform specific tasks.and was used by the procedures personnel to help in e' valuating the sequencing of  ;

tasks in order to optimize efficiency. .

In conclusion, PINGP has developed a system review and task analysis l that uses the Westinghouse Owners Group, Emergency Response Guidelines, I Revision 1, to develop plant-specific E0Ps. The information and control 1

needs were developed primarily from the ERG, Rev. 1, background documenta-tion in conjunction with a Subject Matter Expert (SME). To deternine the applicability of the information and control needs specified in the ERG

, generic guidelines, a comparison was performed between generic information j and control needs used in performing the ERGS and Prairie Island Units I and

2. This review indicated that there were no safety-significant plant-

. specific deviations. The SME then reviewed, independent of the control i room, the background materials and Step Description Tables of the ERGS to

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determine infomation and control needs. PINGP identified the information and control needs and associated characteristics separately in Element l Tables by task and subtask. The Instrumentation Requirements Table and the i

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Controls Requirements Table sumarizes the instrumentation and controls and operational characteristics that are used in the PINGP's plant-specific E0Ps.

A review of the Element Tables and the Instrumentation and ' Control Requirements Tables determined that there is inadequate documentation for the reviewers to identify how plant-specific information and control charac-teristics were derived from background documentation of Revision 1 ERGS or from plant-specific information. NUREG-0800, Appendix A. Section 2.2(3),

titled, "Use of Function and Task Analysis," is clear in describing the level of detail beginning with, " Analyze the operator tasks to' determine the characteristics of information and control capability needed to perform the task."- PINGP should provide the above information in a supplement to the Summary Report and be prepared to discuss the SRTA process at a meeting with the NRC in Bethesda, Maryland. The reviewers require an explanation of how needed plant-specific characteristics for operator information and control needs were developed and recorded (an auditable record) at the task and subtask level. e The explanation should specifically address item No. 4 from the NRC comments developed from the March 29, 1984 meeting between the NRC and the WOG (Reference 13). That is, "for each instrument and control used to.

implement the emergency operating procedures, there should be an auditable record of how the needed characteristics should be derived from the informa-tion and control needs identified in the background documentation of Revi-sion 1 of the ERG or from plant-specific information." This information is needed in order to draw a satisfactory conclusion to PINGPs SRTA effort and to meet the requirement of Supplement I to NUREG-0737.

3. Comparison of Display and Control ' Requirements with a Control Room Inventory The SRTA results provided the basis for comparing the information and control needs identified for effective monitoring and control of the power production process to an existing inventory of the control room. This comparison process determined if the neccessary control and displays were available in the control room and were suitable for accomplishing the 10

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identified SRTA system functions, tasks and subtasks. The control room inventory satisfies the requirement of Supplement I to NUREG-0737.

Verification of Task Performance Canability s

The process. used by PINGP to develop the control room inventory was only briefly discussed in the Summary Report and in PINGPs January 13, 1985, i

response to the NRC's in-process audit. However, ' the description of the verification process was described in enough detail to determine the ade-quacy of the control room inventory. The verification of task performance capability was accomplished by a multidisciplinary team with engineering, operations, and human factors expertise. The verification process involved two steps: '

o Verification of Availability - verification of the presence or absence of instruments and equipment that provide the information and control capabilities necessary to implement the task.

o Verification of Suitability - determination of whether the man-machine interfaces provided by the displays, controls, and other control room features are suitable to support task accomplishment

effectively. .

The basis of instrument and display availability and suitability at Prairie Island was the information and control needs associated with plant

' emergency operating procedures as defined in the Westinghouse Owners Group ERGS and supporting background material. Characteristics of instrumentation necessary for meetin'g these requirements were developed as part of the SRTA

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process, i.e., plant-specific Element Tables, Instrumentation Tables, and Control Tables. Worksheets were prepared by team members to record and j audit the information and control requirements, required characteristics, and the available control room instrumentation from the plant inventory for each task of the E0Ps.

First, the availability of displays and controls was checked for completeness by matching the instrument number for components in the control roc- with the SRTA information and control needs. Missing control room instrumentation and controls were documented as an HED.

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Second, the suitability of existing displays and controls was verified  !

by comparing. the SRTA information and control requirements and associated characteristics with the existing control room inventory.

In conclusion, the verification process generated a total of 44 HEDs.

, A . review of the individual HED descriptions provides support for a successful verification process. The types of discrepancies resulting from the comparison process for availability and suitability are indicative of a l thorough DCRDR verification. The SRTA was accomplished with sufficient

depth and detail to extract successfully some of the following examples of discrepancies

missing parameters or meter values, values not easily read, lack of required precision, inappropriate meter scale ranges or scale incom-patibility, or the absence of required displays. The verification process meets the requirements of Supplement I to NUREG-0737.

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4. Validation of Control Room Functions The validation of control room functions was undertaken to determine

,. whether the functions allocated to the control room operators can in fact be -

accomplished effectively within the stucture of the plant-specific emergency operating procedures and within the confines.of the present control room i design. The validation process was performed by a multidisciplinary team composed of engineering, operations, and human factors expertise. In addi-i tion, during the simulated event sequences, a senior simulator training instructor, with SR0 credentials, orchestrated the walk-throughs and talk-throughs for the selected event sequences.

The validation of control room functions for PINGP, Units 1 and 2 were

accomplished by using a functional, full-scale simulator with equipment l components identical to those used in the Unit I control room. Event-l oriented sequences were developed to cover the four principle work'tations s along the control boards for each Unit in the PINGP control room. PINGP was

careful to include both R0 and SR0 tasks and used a substantial portion of the E0Ps. The event sequences selected were

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o small Break Loss of Coolant Accident j o Inadequate Core Cooling o ATWS Followed by Loss of Off-Site Power j 12 i

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o Multiple Failures of Tubes in a Single Steam Generator and Tube Ruptures in More Than One Steam Generator.

The validation process generated 53 HEDs. Several discrepancies were I

identified because of the location of three systems outside the primary control room area, e.g., Reactor Vessel Level Indication System, Core Exit j Thermocouple Console, and Radiation Monitoring Panel. HEDs were also generated where personnel availability was judged to be inadequate and where the order of control usage following no natural sequence. Inadequate l display and control relationships were also identified as HEDs.

l l In summary, the validation of control room function was successful in generating a total of 53 HEDs. Overall, PINGP has provided a detailed l

description of what appears to have been a well-planned and executed valida-tion process. The process appears to be consistent with the guidelines of NUREG-0700 and that all control room workstations were exercised as part of the four event sequences that were utilized. Real-time exercises were not employed, however PINGP did employ applicable survey checklist items from

! NUREG-0700, Section 6, after each walk-through. PINGP should pay particular attention to the three tasks where inadequate operator staffing was identi-fied but no corrective action was deemed necessary. Cumulative effects may be of some concern due to 12 additional HEDs identified for the requirement of extreme interpanel movement and 16 HEDs on inadequate display / control relationships. A real-time simulated exercise of the three tasks using the 4

Unit I simulator on a dynamic basis should be performed prior to satisfying this DCRDR element. PINGP should reassess these HEDs in light of the results from the exercise.

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5. Control Room Survey '

As described in NUREG-0700, the objective of the control room survey is l "to identify any characteristics of instruments, equipment, layout, and ambient conditions that do not conform to precepts of good human engineering

, practice, regardless of the particular sy. item or task requirements." The i PINGP control room survey was comprised of a component checklist review and a workspace survey, and was found to be consistent with NRC guidelines l during the in-progress audit. '

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i The purpose of the component checklist review was to evaluate control room components for compliance with human engineering guidelines without I

reference to specific task performance and operating procedure. As described in the Summary Report, checklists were developed to check conform-ance using guidelines in Section 6 of NUREG-0700. Component information obtained from three sources was evaluated against the checklists. The three  ;

- sources included the control room, a black and white photomosaic (1

3 scale) ,

j of the control panels, and a full-scale color mock-up of the control room.

4 The actual control room was used only occasionally as a cross-check. In I all,159 HEDs were identified in the component checklist review.

A workspace survey was performed to supplement the component checklist review. NUREG-0700 indicates that control room workspace survey should address "the general layout, availability, and accessibility of operating equipment and materials; the anthropometric suitability of work stations; 4

coordination and separation in multiunit control rooms; availability a .d i

accessibility of emergency equipment; and environmental factors." Specifi-

cally, the PINGP workspace survey had examined the following aspects (the numbers of HEDs identified are shown in brackets)

o Communications (5) ..

o Annunciator warning system (20)*

l c Auditory environment and noise (0) o Illumination and emergency lighting (2) o Control room workspace (10)

, o Mirror-imaging of Units 1 and 2 (1) l  % o Panel layout and control-display integration (37)

! o Labels and location aids (11) l

• See " Selection of Design Improvements" in this report.

NUREG-0700 was referenced for guidance throughout the survey. However, i the elements of the PINGP workspace survey are depicted as separate from and  !

l independent of the section covering " control room workspace" in NUREG-0700. l

It is an area of concern when different groupings of elements result in a

{ less than comprehensive survey of control room workspace. Certain aspects

)

of the survey which are recommended in NUREG-0700 Section 6 appear to have I i been excluded from the survey. Those excluded were: emergency equipment l

1 I4 l

i_--___--____--

(6.1.4), temperature and humidity (6.1.5.1), ventilation (6.1.5.2), personal storage (6.1.5.6), and process computer (6.7). The present survey should be i extended to examine these areas. Moreover, the in-progress audit team was informed during its visit to PINGP that the DCRDR survey team "was comparing

the control room against NUREG-0700 guidelines with some quantitative

differences as recommended by INP0." NUTAC Control Room Design Review Survey Development Guidelines were also cited in the "PINCP In-Progress i Audit Report Concerns / Recommendations Response" to justify deviations from i NUREG-0700 guidelines. Despite these, only the NUREG-0700 was referenced for guidance in the PINGP Summary Report. It might be the case that the PINGP survey team had decided to turn to NUREG-0700 for guidance or that in l fact other guidelines were used in addition to NUREG-0700 and as a result a few areas of the control room survey may be inadequately addressed. These

concerns must be addressed u;th a supplementary submittal before the survey

requirement of Supplement I to NURE",-0737 can be satisfied.

Three other facets of the PINGP workspace survey warrant further

discussion. They include the mirror-imaging of Units 1 and 2, the remote

shutdown panel survey, aqd the review of differences between NUREG-0700 i guidelines and the PINGP checklist.

i l

Mirror-Imaaina of Units 1 and 2 The in-progress audit team had expressed concern about the potential problems related to mirror imaging of PINGP Units 1 and 2 control rooms

! during the visit to the plant. The team was then reassured by NSP that a l study would be performed to identify problems and remedial measures. Hence, l f

the extent and type of mirror-imaging of Units 1 and 2 was estimated, as was i

! the likelihood of its potential adverse effects on the operators' perform-I ance. It was disclosed that the control panels for the two units are l mirrt -imaged at the system level. However, the individual components withia the subsystems were found to be " cookie cuttered," meaning they were l

! arrarged in the same format and order within a panel on both units. Any j differences between the two control panels for Units 1 and 2 that deviated

! from this panel layout " rule" were identified as HEDs. Twenty-seven dis-

! crepancies were identified and found not to degrade the operators' perform-

{ ance. Another thirteen HEDs were corrected during the panel redesign

) efforts and one HED was improved by enhancement.

I i

15 i

l

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

o ..

o .

4 Remote Shutdown Panel Survey The objective of the review is to ensure that the remote shutdown functions are adequately supported by the " hot" shutdown panel. As

! recommended by the in-progress audit team, such a review was performed in the PINGP DCRDR effort using NUREG-0700 guidelines to evaluate the follow-i ing:

t j o Auditory environment and noise '

o Illumination '

4 o Workspace o Panel layout and control / display integration

. o Labels and location aids The deficiencies identified were improved by corrective actions followed by j

evaluations using a full-scale color mock-up. These were accomplished in 1983 before the formal DCRDR.

Review of Differences Between NUREG-0700 Guidelines and PINGP Convention jag.cifications An examination of the licensee's submittals reveals that PINGP used NUTAC (INPO) guidelines in developing its conventions specifications. The in-progress audit team advised that the PINGP conventions specifications should be checked against NUREG-0700 guidelines for differences. NSP con-

, curred with the suggestion and responded in the above-mentioned submittal with an " Evaluation of Design Conventions Specifications against NUREG-0700 Guidelines" in which 14 differences were noted from NUREG-0700. These HEDs and PINGP's exceptions to NUREG-0700 guidelines are examined in the ensuing paragraphs:

[1], [7), and [14): 6.3.3.5.d(3), 6.5.1.3.d(3), and 6.6.4.2.b(2) l The team concurred that NUREG-0700 Section 6.6.4.2.b(2) includes

, additional information which is inconsistent with 6.3.3.5.d(3) and l 6.5.1.3.d(3), and that the PINGP convention is acceptable.

l

, 16 l

1 N *

(2): 6.4.2.1 PINGP's convention is acceptable provided it will be used consistently within the same type of equipment while NUREG-0700 still applies to other prescribed areas.

(3): 6.4.4.5.d (1)(a)

As indicated in NUREG-0700, position indication for rotary selector controls can be either illuminated indicator lights, a line engraved both on the top of the knob and down the side, or a pointer shape. Control handle orientation alone would not suffice for positive position indication, especially for operations under stressful situations. Moreover, illuminated indicator light is not the only alternative to correct the deficiency, as

also alluded to in the rationale for this item. PINGP's convention is not acceptable.

(4): 6.4.4.5.d(1)(b) 4 Alignment of a colored dot with an engraved line may be used for control position indication provided the size,., color, and position of the j dot on the thumbswitches are appropriate. In general, the dat should be large enough for detection, but not unduly large making alignment with the

engraved line difficult. The color of the dot should enable the dot to be i

seen against the color of the background and the ambient illumination.

Positioning of the dot should enhance fine alignment with the engraved line.

PINGP's convention is acceptable.

[5] 6.4.5.1.d(2)(b)

It is noted that the proposed size of trough distance is almost two i

times the dimension recommended in NUREG 0700 (1 1/8 in. versus 0.45 - 0.75 in.). If there is a proportional increase in the diameter of the thumb-wheel, then it would be considered unduly large. PINGP's convention is not acceptable until information is provided on the prospective size of the thumbwheel with a full description and photograph. NUREG 0700 recommends that the diameter of the thumbwheel be 1.5 - 2.5 in.

, 17

[6] and (13): 6.5.1.3.c(1) and 6.6.4.1.b(1) i The PINGP convention of using white vinyl lettering on the black annunciator bezel for identification of annunciator rows and columns is

.: acceptable. l

) (8)6.5.1.6.c(2) l Again, the convention is acceptaole provided it will be used consis-tently within the same type of equipment while'NUREG-0700 still applies to other areas.

[9] 6.5.3.1.c(1)

The Summary Report review team decided that an indication of " motor j start not recommended" is considered to be a caution (probably also an importantone). Indicator illumination should be used. PINGP's convention is unacceptable.

[10) 6.6.2.1.a i

j The convention reads " labels are consistently placed below the indi-l cators to which they refer, and above the controls to which they refer with one exception: controllers have their label below the indicator and control." Basically, the convention is acceptable if it is consistently l I implemented as stated. Caution should be exercised, however, to avoid i .

redundant labels, and to include adequate spacing between unrelated labels i to avoid confusion. NUTAC Control Room Design Survey Development Guideline

) . (Appendix H, p. H-1) was cited in the PINGP conventions evaluation in

! support of this convention. i i  ;

[11)6.6.2.4.c

, l 1

This convention is acceptable provided it will be used consistently for l the same type of equipment throughout the control room. NUREG 0700 will still apply to other pertinent areas. However, there is some concern about l PINGP's intent with regard to " auto / manual" switches. PINGP should clarify f

J j 18 1

i

r if they intend to apply different label guidelines to this category of

switch, and what the differences in the convention might be.

[12] 6.6.3.8.a

, PINGP's convention is unacceptable as all control positions should be l positively identified.

i l In conclusion, three PINGP conventions are unacceptable (items 3, 9, and 12), two require further clarification before judgment can be made concerning their appropriateness (items 5 and 11), and the remainder of the items are acceptable. Several of the workspace survey checklists have not been addressed in an explicit and thorough manner even though some HEDs were

generated using these items. The deficient areas include emergency equip-j ment (6.1.4), temperature and humidity (6.1.5.1), ventilation (6.1.5.2),

i personal storage (6.1.5.6), and process computer (6.7). The concern is that

, the usage of guidelines other than NUREG-0700 may have resulted in an I

incomplete survey.

PINGP should resurvey areas affected by specific checklist items 3 identifiedaboveandprovidedocumentationand.pesultsoftheresurveyin a

{ supplemental submittal in order'to meet the requirement of Supplement I to j NUREG-0737 for this DCRDR element.

i 1

A55ES$NDIT AND INPLENENTATION i

i The assessment phase of PINGP's DCRDR was begun to determine (1) the j significance of the HEDs on the operators' ability to perform the necessary l tasks, and (2) the resulting consequences of an error on plant safety and j public safety. A systematic method was established by PINGP with the

] following three objectives:

i  :

o Assess the relative degree of degradation of operator performance

! caused by each HED.  !

I o Assess the effect on plant safety and public safety of each HED.

l 1  ;

j o Consider the possible interactions and cumulative effects of HEDs. l j -

I 19 l

l 4

l

The HED assessment methodology was comprised of five activities

which are described below. The work was led by a human factors specialist

'and performed by the human factors team together with the Control Rocm Design Review Committee. Each step of the process was subject to review and approval by the Committee.

i o Compilation of HEDs i o Initial Categorization j o Significance Rating of HEDs

o HED Priority Categories o Interactive and Cumulative Effects il l 1. Assessment of HEDs Based upon the guidance contained in NUREG-0800 and the requirements of l! NUREG 0737, Supplement 1, all HEDs should be assessed for safety j significance. In addition, the potential for operator error and the l consequence of that error, in terms of plant safety, should be j systematically considered as part of the HED assessment process. The

j purpose of classifying HEDs should be twofold: (1)todeterminewhichHEDs are significant and should be corrected, and,(2)to determine scheduling j priorities for implementing HED corrections. '

i j As a result of a recommendation from the NRC in progress audit l (Reference 4), PINGP created a computer-based data storage and retrieval i system using an IBM PC/XT computer and dBase !!! software. During the crea-

{  % tion of the data bast, information was reviewed for accuracy, completeness i and consistency. In addition, the HED descriptions were expanded, human

] performance information was added, and the list of affected components was reviewed to ensure that the data base contained a complete record of the l HEDs.

! At the beginning of the HED assessment process, certain HEDs were l extracted from the data base which dealt with:

1 l o Inconsistent nomenclature on labels in the control room j o Nonstandard location of information on labels j o Poor contrast and readability of labels i

j 20 i

o Scale values and gradu,ations for meters .

o Zone markings on meters _

o Nonstandard color coding practice

! o inconsistent direction of control movement I

o Lack of identification of discre'te control positions o Standardization of instrument and control relationships These HEDs were reviewed using PINGP documentation contained in

] " Prairie Island Human Engineering Design Requirements and Conventions l Specification,"(Reference 13). The human factors specialists and both the Chairman and Senior Engineer of the Control Room Design Review Committee extracted a list of 128 HEDs falling into the above categories and fully I

documented in Appendix C of PINGP's Summary Report. Their recommendations for corrective action were submitted directly to the DCRDR Review Committee

for approval in accordance with NUREG-0800, Appendix A (p. 18.1-A22).

l 7

However, in order to ensure that the 128 HEDs did not involve any unreviewed safetyquestions(perNUREG-0800), a review of these HEDs was  !

jl performed outside the normal assessment process, e.g., these HEDs were not l 1 prioritized. The results of PINGP's review of these HEDs were contained in l a study titled: " Evaluations of Design Conventions Specifications Against j NUREG-0700 Guidelines," datedNovember1984(heference12). Because the

{ convention specification was excluded from the Summary Report submittal, j SAIC has not been able to review this document.

In conclusion, since the 128 HEDs identified in Appendix C have not i been considered under PINGP's assessment methodology for a significance

! rating or HED priority categorization, either a review must be performed as j recommended in NUREG 0700, Section 4.2.1.1 titled, " Assessment for Safety 1 Consequences"; or PINGP should provide proper documentation, justifications l with safety consequences, if any, for excluding these HEDs from the

! remainder of assessment process. There are six reports identified on pp. 2-

,! 10 and 2-11 of the Sunnary Report (Sections 2.3.4, " Design Requirement and l Conventions Specifications" and 2.3.5 " Human Engineering Discrepancy Assess-l ment Results") that should be provided as part of this supplementary submit-i tal as supporting source documentation for the assessment process.

)l 21

Methodoloav for Sianificance R'atina 1.

The DCRDR team determined the significance of a design problem in the a

control room by assessing:

I o The probability of human error associated with the HED.

o The severity of consequences that may result from an error.

i This assessment was accomplished by modifying the questions contained -

in NUREG 0800, Appendix A (pp. 18.1-A18-Alg). The DCRDR team developed a '

five point rating scale format for the items organized under the following four topics:

1

! o Documented Event / Conditions - Whether an operator performance error j ,

or operating condition is documented in event reports or reported in operator interviews.

t

) o Operator Performance - The likelihood and impact of potential j , operator performance errors with respect to physical, sensory, perceptual, and cognitive performance ~.

1 o Emergency Systems / Functions - The consequences for public safety of potential errors induced by an HED. '

o Plant Operating Conditions - The consequences for plant operating i

conditions af potential errors induced by an HED.

{ HED Priority Cateaories i

1 i Once the rating of HED significance was completed, the DCRDR team

}

1 interpreted the data using the following steps:

j o Determine weighting of criticality and importance of each item on the HED rating form and compute weighted scores for each of the

four sections.

1

! 22 I i

i n . . _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ . _ _ . . _ . _ _ _ _ __ _ _ _

o Factor the weighted scores to create assessment scales for public and plant safety consequences.

o Determine distributions of assessment scales and classify priority 4 of HED/ instrument combinations.

PINGP used an elaborate assessment process to determine the placement of an HED into a priority category. PINGP's priority classification system was developed to determine a schedule for correcting HEDs based upon each HED's safety consequences. PINGP identified five priority categories as useful for planning correction schedules:

o Priority 1 - Prompt Correction o Priority 2 - Near-Term Correction o Priority 3 - Long-term Correction o Priority 4 - Optional Correction o Priority 5 - No Discrepancy The HED resolutions that were generated for each HED used these cate-gories as guidelines for the PINGP's correction schedule. Several assump-tions were used by the DCRDR team to help guide the team in makir.g these decisions. These assumptions were:

o Errors documented as recorded events should be an important criterion of high priority.

o Error conditions reported in interviews should be an important criterion of high. priority.

o High scores on the public safety consequences scale should be an s

important criterion of high priority.

o Scores on the plant safety consequences scale should be of lesser importance in establishing priority. '

The assessment of HEDs produced the following distribution of HED priority classifications:

23 .

-y , -- - .-. c w

o ..

O e

, PRIORITY NUMBER OF HEDS

1. Prompt Correction 5

2. Near-Term Correction 262

3. Long-Term Correction 788

4. Optional Correction 167

5. No Discrepancy _ 2 14 Total - 2,216 i

In conclusion, PINGP has used a systematic methodology in assessing HEDs. This integrated approach recognizes the interrelationships among HEDs and has attempted to group the HEDs into integrated control room packages by using a panel by panel approach. Such an integrated approach usually requires that many of the individual HED corrections be implemented at the same time regardless of classification. However, the schedule for imple-menting these corrections should be driven by the priority classification of the most significant HEDs. The 128 HEDs addressed by the " Design Require-ments and Convention Specification" listed in Table 4-1 (page 4-5) of the Summary Report, deviated from the DCRDR assessment process and were not .

prioritized but were reviewed separately for involvement in plant safety.

This review was not described in sufficient detail in the Summary Report.

PINGP is required to reassess and prioritize these 128 HEDs with the meth-odology described in the Summary Report or provide the rationale for using another assessment process in order to meet the requirement of Supplement 1 to NUREG-0737.

2. Selection of Control Room Design Improvements In selecting design improvements, the DCRDR team made good use of the Prairie Island control room mock-up where the layout of the proposed design changes were represented in full-scale color. A set of blueprints were also developed that documented the redesign as well as descriptions of full panel redesign for all the instrumentation and controls on panels A, B, C, D, E, F. The level of effort which PINGP has invested in this particular effort, both in terms of breadth and depth, should pay large dividends especially considering the magnitude of changes for the control room and control

-panels.

24 l

'o ..

The general methodology followed by the team was:

o Review proposed resolution of HEDs pertaining to old design and determine alternatives for implementation of corrections.

o Prepare preliminary concept design for retrofit of existing design.

o Implement design change on full-scale paper mock-up, o Conduct preliminary design review and modification involving the following team members:

Operating Staff Control Room Design Review Committee Human Factors Specialists o Implement design change on full-scale color mock-up.

o Conduct secondary design review and modifications.

Operating Staff ,

Control Room Design Review Committee PINGP has developed a technically sound process to develop design improvements paying attention to the need for an integrated and consistent control room (s'.j The DCRDR team has made extensive use of the full-scale mock-up, which was. stressed by the NRC audit team during the in-progress audit, to assess the integrated effect of the design improvements and enchancements. However, there is specific concern about the narrow focus of the HED integration effort especially related to the planned modifications of the annunciator / alarm warning system identified in Table 4-14 (pp. 4-34 and 4-35). There are approximately 10 annunciator / alarm HEDs (006-S through i

025-5) which are rated as category 5 but which should be integrated with the other annunciator HEDs (category 3) and evaluated for the potential for cumulative system effects (see Appendix B-4). In addition, there are several Labeling HEDs (080-C and 041-5) which should be included in the labeling and scaling conventions study because of the potential cumulative j effects that should be considered. There is also concern that design solu-25

tions for category 2 discrepancies should not be remedied by a total reliance upon the SPDS, which is not a category 1-E safety grade system (see Appendix A-6 of this report).

In conclusion, the licensee should review the HEDs in Appendix A-6 and B-4 for cumulative effects and provide detailed justifications for PINGP's prioritization, corrective action, and final resolution for each HED in a supplemental submittal. Conclusions regarding the licensee's satisfaction of this DCRDR requirement cannot be provided until such a submittal is reviewed.

3. Verification That Improvements Will Provide the Necessary Corrections and Will Not Introduce Any New HEDs A human engineering review of proposed redesigned panel sections was conducted for each panel individually; interpanel design effects were con-sidered together. This verification process examined HEDs in priority categories 1 through 4 and evaluated how existing HEDs are resolved by the redesign by the following steps:

o Perform human engineering review of de, sign concept by:

Component design review Workspace survey Verification of task performance capability Validation of control room functions.

o Prepare blueprints of final design concept and determine cost estimates of retrofit.

I o Assess safety consequences of unresolved discrepancies pertaining to the new design.

l o Obtain final design approval from plant management.

l

{

o Implement modifications on the PINGP Unit I simulator.

26

o Obtain a dynamic evaluation of the modified configuration during operator training and testing for all shifts and conduct survey with operators and instructors regarding the modifications.

o Implement modifications on the plant control boards.

o Resurvey operators when startup and testing occurs on the main control board.

, PINGP has put a substantial amount of effort into reviewing HEDs generated from the DCRDR Review Phase and has benefited from that effort by l focusing design solutions not only on individual HEDs but also on a panel by panel overview. The thoroughness of the HED review process for the control room . modifications was extensively documented in Section 5 of the Summary Report. In several instances, the validation process which was conducted on the full-scale color mock-up revealed that instruments on the F-Panel were not needed for successful completion of the E0Ps; therefore, several normal operating procedures were utilized to evaluate the panel effectively. In addition, reactor operators and instructors were surveyed during training exercises in the simulator to collect additional operating experience with the newly installed C-Panel redesign. .,

As a result of the thorough review of all design solutions, , the DCRDR team made a comparison of the HEDs generated from the process to verify HED solutions and those HEDs identified from the initial DCRDR Review Phase.

This comparison resulted in three categories of HEDs:

o Existing HEDs already documented - These discrepancies were HEDs already identified during the DCRDR.

o New potential HEDs - The discrepancies in this category were HEDs created by the introduction of the redesign in the control room (32 HEDs were identified) (see Table 5-15).

i o Existing HEDs not previously documented - This set of discrepancies pertains to the existing design but were not identified during the DCRDR (38 HEDs were identified).

l 27 l

. . _ . ~. _ _ ___ . _ _

o The review of all design solutions also resulted in the identifica-tion of HEDs that were: (1) fully corrected, (2) ' partially ,

corrected, and (3) not corrected by the redesign. Justifications I which proposed correction of these HEDs are given in Appendix D of the Summary Report.

These new HEDS were added to the data base in November 1985 after being assessed and prioritized, and having appropriate resolutions developed in accordance with the assessment process discussed in this technical evaluation.

In conclusion, PINGP has described a process and has provided results which not only verify the effectiveness of corrective actions but also is effective in identifying additional HEDs that were not apparent during the Review Phase. This effort meets the requirement of Supplement I to NUREG-0737.

4. Coordination of DCRDR Effort With Other Improvement Programs The NSP Program Plan indicated that the PINGP DCRDR effort would be integrated with other elements of the Emergency Response Capabilities as stipulated in NUREG-0737 Supplement 1. These elements include the Safety Parameter Display System, Regulatory Guide 1.97, Emergency Operations Procedures, and Emergency Response Facilities. An iterative procedure would be used to ensure that "all criteria are consistent with each other, all significant human engineering discrepancies are being resolved, and all necessary interfaces.with the other elements have occurred." However, the

, mechanics of the coordination were not fully described in the Program Plan and therefore the adequacy of the planned coordination could not be eval-uated in the NRC Program Plan review. PINGP has indicated that a mock-up would be used to assess the integrated effect of the design improvements, enhancements, and modifications affecting the control room and the simulator.

During the in-progress audit, it was established that members of the PINGP DCRDR team also served as responsible members for the other improvement programs. The audit team concluded that the overlap of team involvement in all programs would facilitate the coordination of these l

28 l

I

efforts. The team also advised that particular attention should be paid to coordinating control room and simulator modifications so that operator performance would be enhanced. The coordination of the various emergency-related improvement programs was not explicitly addressed in the PINGP Summary Report, apart from a terse statement indicating that the "SPDS modifications and Regulatory Guide 1.97 modifications will be performed in accordance with Generic Letter 82-33 confirmatory order dates."

NUREG-0737, Supplement I also indicates that the results of DCRDR should be applied to " train and qualify plant operating staff regarding upgraded E0Ps and modifications." It is important for the plant operators to become familiar with the modifications that will be made as a result of DCRDR. No such plan was projected in the PINGP Summary Report.

In conclusion, additional information is required in order to review the integrated approach PINGP is now using to ensure close coordination of the improvement programs for the Emergency Operating Procedures, Control Room Design Review, Regulatory Guide 1.97, Safety Parameter Display, Emer- ,

4 gency Response Facilities and operator training. That information should be '

provided in a supplement to the Summary Report. Conclusions regarding the licensee's satisfaction of this DCRDR require, ment cannot be provided until such a submittal is reviewed. -

5. Proposed Schedules for Implementing HED Corrections PINGP's proposed schedule for implementing DCRDR design improvements in the control room began in 1983 and will be completed by 1990. The implemented redesign solutions to the control room are detailed below:

o Installed control room carpeting in 1983.

o Installed new shift supervisors' office in 1984.

o Modified control boards on Units I and 2, and simulator for four systems on C-Panel and B-Panel in 1985:

NIS and Rod Control Reactor Cooling l 29

-er---, --.+-yi.-s .% g-- -,wm-y-

CVCS Make-up CVCS Letdown l

)

o Will modify Steam Generator System D-Panels on the simulator and on Units I and 2 in 1986.

The Control Room Design Review Comittee has evaluated and approved the l conceptual design for Panels A, E, F, and the remaining systems on Panel B.

These design solutions have been implemented on the Unit control board full-

. scale mock-up as part of the assessment and implementation process. However, final implementation schedules have not been established due to a yet to be conducted review of capital improvements that is scheduled for April 1986 for all expenditures occurring after 1986. J l

PINGP should provide implementation schedules for all HED corrective actions in order to satisfy the requirements of Supplement I to NUREG-0737.

Easier solutions should not be delayed while design solutions, procurement, and installation for more difficult problems are worked out and implemented. i Surface changes should proceed as quickly as possible, while intrinsic -

changes may have to wait for scheduled shutdowns. Correcting large groups of HEDs may extend to two refueling outages from submittal of the Sumary Report, but justification for that decision should be based upon a correc-tion schedule that implements solutions to HEDs with regard to the safety significance of the discrepancies upon operator performance.

In conclusion, PINGP should submit schedules for implementation and a

, sumary justification for HEDs with safety significance to be left uncor-rected or partially corrected taking into account the review of HEDs requested in this report (see Appendix A and B). PINGP should also identify each HED (a total of 2,216 HEDs were identified) grouped under the five priority categories listed on p. 23 of this report. The concern here is i that Appendix C and Appendix D of the Sumary Report identify 128 HEDs and i 391 HEDs, respectively. A table displaying priority by HED by resolution by implementation schedule date for all 2,216 HEDs would be extremely helpful.

30

,.-,.-,--,n, , - - . - - . - . - - . - - - , . , . - . - - . - - - , , , n._,

ANALYSIS OF PROPOSED C0RRECTIVE ACTIONS AND JUSTIFICATIONS FOR HEDS LEFT UNCORRECTED PINGP has documented 2216 HEDs in its Summary Report. Of these, 5 were designated for prompt correction; 262 were selected for near-term correc-tion; 788 were selected for long-term correction; 167 were designated for optional correction; and 994 were determined to be not discrepant. The SAIC staff reviewed all of the HEDs listed in Appendix D of the Sumary Report and found many, but not all, of the HEDs to be satisfactorily resolved by  ;

PINPG. Those HEDs for which corrective actions were proposed were found to fall into two basic groups: either the corrective actions were found to be satisfactory, or they were found to be lacking for a specific reason.

Appendix A of this report discusses these groups of HEDs. A second group of HEDs for which justifications for not taking corrective actions were pro- l vided was also divided into two groups: the justifications were adequate, or they were found to be inadequate. Appendix B of this report discusses these groups of HEDs.

{

! An additional group that warrants special attention involves 18 HEDs for which the proposed solution involves the use of the SPDS. The reviewers find that this solution is not adequate because the SPDS is not qualified as 1-E, e.g., a failure of the SPDS~ would require the operator to revert to the

uncorrected set of instruments or controls.

Below are the Appendix A and B group designations A-1 through A-6, and B-1 through B-10 for HEDs with and without proposed corrections, respec-tively. Examples of each type are given to illustrate the particular concern. Complete listings are given in Appendices A and B.

1. Proposed Corrective Action Appendix A of this report contains the complete list of HEDs for which corrective actions were proposed or already implemented by PINPG. Many of the actions were found to be u. equate, but some actions were found to be inadequate for one of several reasons discussed below:

A-1 The corrective action appears adequate (already implemented).

31

1 A-2 The proposed corrective action should correct the HED (correction has not been implemented yet).

A-3 The proposed corrective action is to comply with plant convention specifications which have not been provided as a part of the Summary Report.

HED-018-I: During operator interviews, it was reported that

" components are illogically arranged." The proposed corrective action to redesign panel B will conform with the plant convention specification. The reviewers have not been provided with a copy of this specification and therefore cannot assess the resolution.

A-4 The corrective / proposed corrective action does not appear to resolve the HED fully; more action may be needed.

HED-004-R: The HED concerns the resetting of a complicated diesel generator interlock. The corrective action deals with training as a fix rather than a change to the existing hardware. The fact that a training plan has been " routinely given since 1977" may provide a clue that operators still have a problem with this interlock and that training may not bit an appropriate solution.

1 A-5 The description of the corrective / proposed corrective action can-not be evaluated because the description is too ambiguous, brief or general.

' Description of HED is unclear and reviewers cannot HED-003-R:

determine the acceptability of the solution.  !

A-6 The proposed corrective action may not be adequate due to the non- l 1.E. classification of the SPDS.  ;

HED-001-V: The discrepancy involves what may be excessive l operator movement during various task sequences requiring RCS parameters. The proposed solution is to incorporate these para-meters on the SPDS rather than add more indication to the SI  !

panel. If the SPDS is not classified as 1-E, then this solution 32

\

is not adequate (also see " Validation of Control Room Functions,"

in this TER). l

2. Justification for HEDs To Be Left Uncorrected Appendix B of this report contains the complete list of HEDs for which justifications for not taking corrective actions were provided. Many of the justifications were found to be adequate, but some were inadequate as dis-cussed below. l B-1 Justification is adequate.

B-2 The justification for no corrective action is too ambiguous, brief or general to permit evaluation.

HED 006-V. The verification step of the DCRDR uncovered numerous rotary selections for controls used during emergency operations.

NUREG-0700 calls for distinctive enhancement techniques to distin-guish controls used during emergency from other controls. PINPG justified no corrective action by the fact that " emergency controls comprise more than 50% of the controls on the master control panels" and that " enhancement of these controls would promote confusion with present coding.'" There is no indication of what the present coding scheme is or why enhancement of emergency controls would be confusing. The fact that more than 50% of the controls are emergency related provides sufficient reason for corrections to be made. Further, it appears that a subset of controls iri this, and seven similar HEDs in Appendix B-2 have high public safety '(rating) concern, as well as high HED priority f (priority 2), and yet will not be enhanced. Without provision of

further explicit details, this kind of justification is unaccept-i able.

B-3 The justification for no corrective action is based on PINGP's plan convention specification, which was not submitted for review.

HED 409-C-01. The 01 correction code for this HED concerns the location of rotary selectors. PINGP has justified locating them 33

(

3 m .

on an upper panel in accordance with its convention specification.

Because the convention specification was not submitted, it is difficult to assess this justification.

B-4 Justification for no corrective action for individual HEDs may not have considered cumulative or interactive effects of other HEDs.

HED 10-S: The lack of any visual coding scheme for alarm priority levels appears to be a generic problem since no specific panel or annunciator is singled out in this HED. This is one of ten such HEDs, all of which have to do with discrepancies associated with Annunciator Warning Systems. Despite their interrelationships, no indication is provided to demonstrate whether consideration was given to the possibility that there could be cumulative or inter-active effects among these HEDs. This, plus the fact that each of these HEDs is also noted as having associated safety consequences, would indicate that their having been placed in Priority Category 5, "No Discrepancy," was inappropriate. .

B-5 HEDs undergoing additional study.

~

• t HED 029-I: The discrepancy involves nuisance alarms during a trip or startup which distract attention. PINGP will study the annun-ciator/ alarm system during 1986, hence the resolution of this HED is incomplete.

B-6 HEDs priorirtized as "no discrepancy."

HED 034-S: Operators should be well trained and accustomed to l

]

using of equipment. This HED, and many others in this Appendix, l

! have been resolved in the disposition of other HEDs which  ;

i enveloped the problems described. HEDs grouped in this Appendix  ;

i constitute legitimate justifications for no corrective action and l therefore, no additional PINGP action is necessary. I 34

B-7' The resolution does not address the problem / discrepancy.

i HED 034-V-02: The discrepancy discusses meter scales, whereas the justification for. no correction discusses the use of the meter, together with indicator lights, to verify that a system is in service. It is not clear that the meters associated with this HED have been adequately addressed.

B-8 Justification for no corrective action should be provided to address operational or behavioral factors.

HED 034-X: This HED is one example of many HEDs which involves the availability of personnel to deal with an emergency situation  !

in a single unit.- The resolution for this HED as with others is to pull operators off of the unit.which has no emergency and j assign them to the unit which has the emergency. Operational i l factors as they may effect both units do not appear to be

, addressed (see " Validation of Control Room Functions," in this ,

TER).

l

~

B-9 TheproposeddispositionisinconsisjentwiththeHED prioritiza-tion.

~

l l

l HED 010-X: This HED was discovered during the validation and  ;

deals with response time to a warning condition. The public 1 safety rating was 31, very close to the highest safety rating for all HEDs, -and yet no corrective action was taken.

B-10 Inadequate justification - faulty rationale.

HED 030-S: The HED concerns acoustical interference and status

representation for each unit. The justification for no action does not discuss the acoustical interference, rather it discusses status boards for each of the two units and common equipment. The results of the environmental and noise survey were not addressed in the Summary Report to show if acoustical interference is within NUREG-0700 guidelines.

35 4

, i

- \

i CONCLUSIONS AND RECONNENDATIONS Northern States Power Company's DCRDR conducted at Prairie Island Nuclear Generating Plant, Units I and 2 demonstrates a comitment towards  ;

meeting the requirements of NUREG-0737, Supplement 1. In general, it appears I that PINGP's DCRDR effort is one of the best initiatives being condacted by a utility. The extensive modifications to the control panels and to the overall control room layout are indicative of the high degree of comitment of the utilities management as well as of the capability of the DCRDR team. l The documentation reviewed, beginning with the Program Plan through the i Sumary Report, provided extensive discussisons of the planning, review, I assessment, and implementation activities being conducted to perform the DCRDR and indicates that Northern States Power Company basically will meet j most of the requirements. However, additional information is required from l the licensee to provide assurances that all the requirements as stated in NUREG-0737, Supplement I have been satisfied.

The following is a sumary of opens items, that ' require further infor-mation, explanation or DCRDR activities by PINGP review team. These open -

items are briefly sumarized below but have been described in detail under each of the DCRDR elements in this technical evaluation report.

t

1. System Review and Task Analysis o A review of the Element Tables and the Instrumentation and Control Requirements Tables determined there is inadequate documentation for the reviewers to identify how plant-specific information and control characterisites were derived from background documentation of Revision 1 ERGS or from plant-specific information. NUREG-0800, Appendix A, Section 2.2(3), titled, "Use of Function and Task Analysis" is clear in describing the level of detail begin-ning with, " Analyze the operator tasks to determine the charac-teristics of information or control capability needed to perform the task." PINGP should provide the above information in a sup-plement to the Sumary Report or be prepared to discuss the SRTA process at a meeting with the NRC in Bethesda, Maryland. The

reviewers require an explanation of how needed plant-specific characteristics for operator information and control needs were 36

--,-_.cw - - . _ , . .

developed and recorded (an auditable record) at the task and subtask level.

The explanation should specifically address item No. 4 from the NRC comments developed from the March 29, 1984 meeting between the NRC and the WOG (Reference 13). That is, "for each instrument and control used to implement the emergency operating procedures, there should be an auditable record of how the needed characteris- l tics should be derived from the information and control needs identified in the background documentation of Revision 1 of the ERG or from plant-specific information." This information is needed in order to finalize the evaluation of PINGP's SRTA effort and to meet the requirement of Supplement I to NUREG-0737.

2. Control Room Validation a During the validation of control room functions, several HEDs were generated involving inadequate perscnnel staffing, extreme inter-panel movement between tasks, and inadequate display / control rela-tionships. In addition, these HEDs involved three tasks in the E0Ps (See Table 3-17, NUREG-0737 guidelines 6.8.1.1.a. 6.1.1.2, 6.9.1.2.a. and 6.9.2'.2.a of the Summary Report). A total of 31 HEDs were identified. Twenty-one of these HEDs were identified as requiring "no corrective action" and seven HEDs were corrected by future SPDS implementation, which has been deemed an inappropriate solution. PINGP is to reassess the three E0P tasks under real-time dynamic conditions to evaluate fully the cumulative and interactive effects of these HEDs. All 31 HEDs should be resub-mitted with appropriate reassessment documentation and justifica-tions for corrective actions.

3. Control Room Survey o Workspace survey checklists for emergency equipment (6.1.4),

temperature and humidity (6.1.5.1), ventilation (6.1.5.2.), per-

, sonal storage (6.1.5.6), and process computer (6.7), have not been addressed in an explicit manner, although some HEDs have been generated on these items. PINGP should provide documentation to 37 v -

r e-wv-m- --,<-v.- -n, - - --,-------------------w

show that the above checklists or equivalent have been used. The concern is that the usage of guidelines other than NUREG-0700 may have resulted in a less than complete survey.

o A review of the differences between NUREG-0700 guidelines and PINGP conventions specifications revealed that three of the PINGP conventions are unacceptable (items 3, 9, and 12) and should be reassessed using corresponding NUREG-0700 guidelines (6.4.4.5.d(1)(a), 6.5.3.1.C(1), and 6.6.3.8.a). Two of the con-ventions specifications require further clarification before judgment can be made concerning their appropriateness (items 5 and 11; corresponding NUREG-0700 guidelines are 6.4.5.1.d(2)(b) and 6.6.2.4.C). The rest of the PINGP conventions specifications are acceptable.

o PINGP should resurvey relevant areas affected by specific check-list items identified above and provide documentation and results of the resurvey in a supplemental submittal.

4. HED Assessment ,

1 o The 128 HEDs identified in Appendix't of the Summary Report were ,

not considered under PINGP's assessment methodology for signifi- l cance ratings or priority categorization. PINGP should reassess  !

these HEDs or provide proper documentation and justification for ,

excluding these HEDs from the remainder of the assessment process.

How were ,these HEDs considered for cumulative and interactive l effects with other HEDs in Appendix D (See Appendix B-4 of this report for an example)? Also there are six reports identified on pp. 2-10 and 2-11 of the Summary Report (Sections 2.3.4 " Design Requirement and Conventions Specifications" and 2.3.5 " Human Engi- l neering Discrepancy Assessment Results") that should be provided l as part of this supplementary submittal as supporting source  !

documentation for the assessment process. I 38 i

. o. .

5. . Selection of Design Improvements o The concerns raised relate to the cumulative effects from HEDs developed from the use of annunciators and labeling which are identified in Appendix A-6 and B-4. PINGP's response should not only relate to specific HED corrective actions but should try to reassure reviewers' doubts about the adequacy of the solution ,

process and provide detailed justifications for PINGP's prioriti- l zation, corrective action and final resolution for each HED. i

6. Coordination of DCRDR Efforts o PINGP should describe its coordination efforts and how PINGP's Integration Plan developed in response to Generic Letter 82-33 is currently being integrated for all the control room elements, l- e.g., The Emergency Response Capability Plan, etc.). Also include how training is integrated within the coordination of these programs.

l

7. Schedules for Implementation of HED Corrections l

l o PINGP should submit . schedules for helementation and a sumary l justification for HEDs with safety significance to be left uncur-l rected or partially corrected taking into account the review of HEDs requested in this report (see Appendix A and B). PINGP i

should also identify each HED (a total of 2,216 HEDs were identi-fied) grouped under the five priority categories listed on p. 22 of this report. The concern here is that Appendix C and Appendix D of the Summary Report identify 128 HEDs and 391 HEDs, respec-tively.

L 39

AGENDA FOR MEETING

, l.. System Review and Task Analysis Discuss process used during the task analysis to (explicitly) identi fy information and control needs (as opposed to instrument and control capabilities that appear on the panels). Address how this was performed using the background documentation of Revision 1 ERGS or from plant-specific information. Provide a representative sample of the task analysis data forms that illustrate an auditable record.

2. Control Room Validation Discuss the 31 HEDs that resulted from the validation of control room functions and specifically the need to consider the cumulative effects of these HEDs during the assessment. Also discuss the proposed use of the SPDS to resolve HEDs for display of required information.

3. Control Room Survey -

a. Present the criteria and methodology used to conduct the workspace portions of the control room survey.

b. Discuss the criteria used for the control room survey and rationale for choosing to replace the criteria in Section 6 of NUREG with other criteria. Be prepared to demonstrate that NSP's preferred , criteria and methodology is an adequate substitute for Section 6 of NUREG-0700.

c. Discuss the conventions specification and its compatibility with Section 6 of NUREG-0700. Discuss the process to revise the conventions specification.

d. Discuss items 3, 9, and 12 of the conventions.

i 40

4. HED Assessment i

a. Discuss the rationale for exclusion of the 128 HEDs from the assessment process. Particularly the potential deficiencies from not subjecting these HEDs to an assessment for any cumulative or interactive effects with other HEDs.

i

b. Present any supporting documentation such as the six reports identified on pp. 2-10 and 2-11 of the Summary Report.

5. Selection of Design Improvements

a. Discuss reviewers' concerns related to the cumulative effects from HEDs developed from the use of annunciators and labeling identified in Appendix A-6 and B-4.

b. Discuss the types of reasons for needing more information from NSP l to evaluate the proposed design corrections and the justifications for leaving the HED uncorrected or partially corrected.

6. Coordination of DCRDR Efforts s

a. Update NSP's integrated plan for the emergency response capability plan which was developed in response to Generic Letter 82-33. y

b. Describe how training will be integrated with the implementation

, of control, room modifications.

7. Schedules for Implementation of HED Corrections.

a. Discuss need for the submittal of schedules for implementation of HED corrections. (See Appendix A and B HEDs.)

8. Miscellaneous

a. Discuss the rationale for needing more than two refueling outages to implement modifications.

41

, - - - - , - - , - - . . - - , , - - - - - ,w y.--..-% , - - . . , - , - . _ - , . . . - - - . , - - - - - - - , . . , - -

REFERENCES

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

2. Letter to Director, Office of Nuclear Reactor Regulation, U.S. NRC from D. Musolf, Manager, Nuclear Support Services, NSP.-

Subject:

" Supple-ment I to NUREG-0737, April 15, 1983, Response to Generic Letter 82-33 Control Room Design Review Program Plan Submittal," for Prairie Island Nuclear Generating Plant, dated May 27, 1983.

3. " Nuclear Regulatory Commission Staff Comments on the Prairie Island Nuclear Generating Plant Detailed Control Room Design Review Program Plan," U.S. NRC, November 9,1983.

4. "In-Progress Audit Report of the Detailed Control Room Design Review for Prairie Island Nuclear Generating Plant, Units 1 and 2," U.S. NRC, July 17,1984.

5. " Prairie Island Nuclear Generating Plant Detailed Control Room Design Review Status Report and Response to Marb.h 1984 In-Progress Audit,"

Northern States Power Company, January 31, 1985.

4

. 6. " Detailed Control Room Design Review Summary Report, Prairie Island Nuclear Generating Plant (Report Number 10188-PI-8000)," Northern States Power Company Nuclear Technical Services Department and Honey-well Inc. Technology Strategy Center, December 1985.

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

! 8. NUREG-0737, " Requirements for Emergency Response Capability," U.S. NRC,

' Washington, D.C., November 1980.

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

f I

42 4

e

- ,-- - - __,.,--__..m-_. _.,.m.,.,_,,,,,,,,-.,-,-.c~_.m. . _ y.,- - , _ _ . . . - _ , , . _ _ . , , - , _ , -m, . , _ , _, , _ _ , _ . . ,

'o ,

10. NUREG-0800, " Evaluation Criteria for Detailed Control Room Design Review," U.S. NRC, October 1981.

11. " Evaluation of Design Conventions Specifications Against NUREG-0700 Guidelines," Honeywell Inc. Technology Strategy Center, November 1984.

12. " Human Engineering Design Requirements and Conventions Regarding Component Design, Labeling, and Abbreviations," PING-678A, Revision 1.

Northern States Power Company, Prairie Island Nuclear Generating Plant, October 1985.

13. Memorandum from H. Brent Clayton, Section Leader, Procedures and Systems Review Branch, Division of Human Factors Safety, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission to Dennis L. Ziemann, Chief, Procedures and Systems Review Branch.

Subject " Meeting Summary - Task Analysis Requirements of Supplement I to NUREG-0737 - March 29, 1984 Meeting With Westinghouse Dwners Group Procedures Subcommittee and Other Interested Persons," April 5,-1984.

43

APPENDIX A HEDs WITH CORRECTIVE OR PROPOSED CORRECTIVE ACTION I

1 44

A-1 The Implemented Action Appears Adequate The corrective action implemented for these HEDs is satisfactory. No response is necessary from PINGP.

HED Code Number HED Code Number 024-C 057-I 025-C 058-I 084-C-01 060-I 084-C-03 '077-I 085-C 079-I-03 086-C-01 001-R-01 008-I-01 001-R-02 014-I 002-R 022-I-03 010-R 032-1 023-S 038-I 031-S-02 049-I 042-V-01 054-I 019-X O

45

O O A-2 The Proposed Corrective Action Should Correct the HED The proposed corrective actions for these HEDs shot 1d correct the discrepancy. No response is necessary from PINGP.

HED Code Number HED Code Number HED Coc'e Number 001-C 022-I-02 049-5-01 010-C 025-I 049 S-02 023-C 027-I 051 S 035-C 031-! 05?-S 036-C 036-I 058-S 037-C 039-I 068-S 038-C 045-I 070-5 084-C-02 056-I 072-S-01 085-C-02 059-I 072-S-02 085-C-04 061-1 078-S 086-C-03 . 066-I 096-S 086-C-04 067-I 020-V 086-C-05 075-I 030-V 093-C 079-I-01 '

035-V 130-C 079-I-02 038-V 131-C 006-R 043-V-06 003-I 008-R 044-V 004-I 009-R 001-X 008-I-02 013-R 009-X 008-I-04 . 024-S 014-X 015-I-02 027-S 021-X ,

020-I 031-S-01 022-X 022-I-01 037-5-01 023-X i

l l

46 1

i l

l

A-3 The Proposed Corrective Action Complies With PINGP's Plant Conventions Specification l SAIC has not reviewed the convention specification and cannot determine the adequacy of the corrective actions for these HEDs until PINGP supplies the appropriate documentation. This is an open item. l HED Code Number 046-C-02 144-C 017-I 018-I (See p.32 for example.)

Gl9-I A-4 The Corrective / Proposed Action Does Not Appear to Fully Resolve the HED Supplemental information is required for the justification of the '

corrective action. This is an open item.

HED Code Number ,,

004-R A-5 The Description of the Corrective or Proposed Corrective Action Cannot Be Evaluated Because the Description is too Ambiguous or General Additional informati.on is required to describe the solutions for these two HEDs in order to understand the corrective action and make an evalua-tion. This is an open item.

HED Code Number 003-R (See p. 32.)

507-V i

\

47 m-.,- = , ---- - ,-- - - - - - .---m.y - . - . --,,

A-6 The Proposed Corrective Action Is Not Adequate Due to the Non-IE Safety Grade Classification of the SPDS Alternative solutions are required for these HEDs to display the required information in the control room. This is an open item.

HED Code Number HED Code Number Oll-I 043-X 055-I 044-X 026-S 045-X 001-V (See p. 32.) 046-X 002-V 047-X 042-V-03 048-X 028-X 049-X 029-X 050-X 030-X 051-X 031-X 052-X 032-X 053-X 033-X r

d l

48

0 e

• es G G APPENDIX B JUSTIFICATION FOR NO CORRECTIVE ACTION r

O O

=

49

1 B-1 Justification for No Corrective Action Is Adequate The corrective action developed for these HEDs is appropriate. No response from PINGP is necessary.

HED Code Number HED Code Number HED Code Number 046-C-01 030-I 084-S 085-C 034-I 085-S  !

089-C 035-I 400-S 108-C 037-I 401-S 109-C 041-I 600-S 074-C 042-I 601-S 110-C 046-I 004-V 111-C 047-I 019-V 120-C 048-I 021-V 121-C 050-I 026-V 122-C 051-I 028-V 134-C 065-I-01 029-V-01 135-C 065-I-02 029-V-02 154-C 065-I-03 033-V-01 409-C-02 068-I 't 033-V-02 411-C 069-I 042-V-02 500-C 073-I 306-V 608-C 074-I 308-V 001-1 078-I 607-V 006-I 080-I 608-V

~

• 008-I-03 Oll-R 002-X 009-I 012-R 006-X 010-I 018-S 007-X 012-I 028-S 008-X 013-I 037-5-02 012-X 016-I 059-S 016-X 022-I-04 060-5 018-X 022-I-05 031-5 020-X 023-I 063-S 024-X 026-I 065-S 025-X 028-I 067-S 026-X 50

e .. .

x B-2 The Justification for No Corrective Action Is Too Ambiguous, Brief, or General to Permit an Evaluation Additional. information and/or justifications are required to assess these HEDs properly. This is an open item.

HID Code Number HED Code Number HED Code Number 047-C 007-R 016-V 048-C 006-V (See p. 33.) 017-V 128-C 007-V 041-V 129-C 008-V 043-V-04 007-I 009-V 500-V 033-I Oll-V 502-V 064-I 012-V 017-X 070-I 013-V 035-X 036-X B-3 No Corrective Action Is Justified in Order to Maintain Compliance With Plant Convention Specifications .

SAIC has not reviewed the convention specification and cannot determine the adequacy of the corrective actions for these HEDs until PINGP supplies the appropriate documentation. This is an open item.

HED Code Number 409-C-01 (See p. 33.)

502-C 604-C 605-C 609-C 057-S 51

B-4 Justification for No Corrective Action for Individual HEDs May Not Have Considered Cumulative or Interactive Effects With Other HEDs These Category 5 HEDs should be reviewed with the annunciator / alarm and labeling studies being pursued at PINGP as these HEDs may warrant a higher priority category rating because of cumulative effects. This is an open item until the review is complete.

HED Code Number HED Code Number 080-C 012-S 006-S 013-S 008-S 014-S 009-S 016-S 010-S (See p. 34.) 018-S Oll-S 041-S B-5 HEDs Undergoing Additional Study -

Please submit corrective actions upon completion of study. This is an open item.

HED Code Number 029-I (See p. 34.)

022-S 040-X 52

• *e o n. e 8-6 HEDs Prioritized as "No Discrepancy" These HEDs are considered adequately justified - no corrective action, and does not require a response from PINGP.

HED Code Number HED Code Number HED Code Number 003-C 002-S 083-S

, 007-C 003-S 087-S 009-C 004-S 088-S 029-C. 005-S 089-S 077-C 007-S 090-S 079-C 021-S 091-S l 080-C 025-S 092-S 083-C 032-S 093-S 094-C 033-S 094-S 095-C 034-S (See p. 34.) 095-S 098-C 035-S 005-V 100-C 036-S 010-V 101-C 038-S 014-V 145-C 041-S 018-V 148-C -

046-S 023-V 156-C 050-S 024-V 159-C 055-S 031-V 305-C 056-S 032-V 306-C 062-S 301-V 407-C ,

064-5 302-V 408-C 066-S 403-V 410-C 069-S 605-V 501-C 071-S 003-X 504-C 073-S 013-X 606-C 074-S 037-X 607-C 075-S 038-X 021-1 076-S 039-X 044-I 077-5 041-X 076-1 080-5 042-X 001-S 082-S 53 9

~

i .

g i, g.s.

B-7 The Resolution Does Not Address the Problem Discrepancy Additional information is necessary to make an evaluation of these j HEDs. This is an open item.  !

HED Code Number HED Code Number HED Code Number 026-C 034-V-01 043-V-01 086-C-02 034-V-02 (See p. 35.) 043-V-02 005-I 037-V 043-V-03 024-1 039-V 043-V-05 040-V 005-X B-8 Justification for No Corrective Action Should Address Operational or Behavioral Factors Additional information is necessary to evaluate the corrective actions.

This is an open item.

HED Code Number ,

043-1 005-R 015-X 034-X (See p. 35.)

• ~

4 B-9 The Proposed HED Disposition Is Inconsistent With HED Prioritization Corrective actions do net satisfy the safety priority assigned to these HEDs. This is an open item.

HED Code Number HED Code Number HED Code Number 040-1 003-V 027-V 053-I-01 004-V 010-X See (p. 35.)

053-I-02 022-V 011-X 005-R 025-V 027-X 54

l.l'

..g..

B-10 Inadequate Justification - Faulty Rationale The reviewers do not agree on PINGPs proposed solutions. They require additiona'l supporting documentation and information or revise present justi-fications. This is an open item.

HED Code Number HED Code Number HED Code Number 002-1 029-S-01 086-S 015-I-01 029-S-02 004-X 052-I 030-S (See p. 35.)

• t 9

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55

F . .

NOV 2 0198h Distribution, Copies:

et Docket Files;;'.

NRC PDR Local PDR PAD #1 r/f PAD #1 p/f TNovak, Actg. DD NThompson, DHFT OGC-Bethesda EJordan BGrimes JPartlow Glear PShuttleworth DDilanni ACRS (10)

LFMB (TAC #56154 and 56155)