ML20214E916

Forwards List of Guidelines for Which Plant Found to Be in Compliance w/NUREG-0700,per NRC 861118 Review of Util Control Room Survey Conducted as Part of Dcrdr.Util Responses to Discrepancies Identified Also Encl

ML20214E916
Person / Time
Site:	Farley
Issue date:	05/14/1987
From:	Mcdonald R ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-NUREG-0700, RTR-NUREG-0737, RTR-NUREG-700, RTR-NUREG-737, TASK-1.D.1, TASK-TM NUDOCS 8705220316
Download: ML20214E916 (21)

Text

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, A!:bama Power Comp:ny .

~ 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 352914400 il Tetephone 205 250-1835 -

Xg;;,T,,,n, AlabamaPower the sournem ewirc system i l

i May 14, 1987

' Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 l

l Gentlemen.

Joseph M. Farley Nuclear Plant - Units 1 and 2 Supplement 1 to NUREG-0737, Item 1.D.1, i Control Room Design Review l On November 18, 1986, members of the NRC Staff conducted an audit of the Control Room Survey as conducted by the Alabama Power Company Control Room Design Review. The audit was conducted to verify the adequacy of the Control Room Survey conducted under the guidelines developed by an INP0 Nuclear Utility Task Action Committee (NUTAC).

Alabama Power Company believes that the Control Room Survey, conducted using NUTAC guidelines, provided coverage for all of the human factors issues addressed by the NUREG-0700 guidelines. The NRC audit supports this position. The NRC audit consisted of surveying the Farley Nuclear Plant i simulator using sixty-two NUREG-0700, Chapter 6 Guidelines, which the NRC Staff felt were not adequately addressed by the NUTAC surveys. Out of the sixty-two guidelines utilized, the Farley Nuclear Plant simulator was in complete compliance with forty-five. Of the remaining seventeen, all issues were covered by the NUTAC survey and most items were already documented as discrepancies. Based on the NUTAC documentation and the NRC audit Alabama Power Company maintains that its Control Room Survey was thorough and .

l complete in regards to covering NUREG-0700 human factors issues.

Attachment 1 contains a list of guidelines for which the Farley Nuclear l Plant simulator was found to be in compliance with NUREG-0700. Attachment 2 j contains descriptions of the seventeen guidelines which had discrepancies identified and the Alabama Power Company response to each discrepancy.

~* 8705220316 870514 PDR I

ADOCK 05000348 y P pop q L

F, U. S.- Nuclear Regulatory Comission. 1987 Page 2 If. there are any questions, please advise.

Respectfully . submi tted, ALABAMA POWE fANY g &  ;

R. P. Mcdonald RPM / REM: dst-D-T.S.7 Attachment cc: Mr. L. B. Long Dr. J. N. Grace .

Mr. E. A. Reeves-Mr. W. H. Bradford i

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Attachment 1 Page 1 Forty-five NUREG-0700 Guidelines

• Used During the NRC Audit For Which the Farley Nuclear Plant Simulator Is In Compliance For Main Control Board Panel A

1. 6. 4 . 3.1. a Push-button Control Position

2. 6.4.3.1.c Push-button Control Surface

3. 6.4.4.1.a,b c Rotary Control Specifications-4 6.4.4.3.a,b,c,d,e,f,g Key Operated Controls

5. 6.4.4.4.a,b,c Rotary Control Specifications

6. 6.8.3.3 Mirror Imaging

7. 6.7.2.6.a(1),b f,1,j Process Computer CRT Displays

8. 6.9.2.1.a Control Display Integration; Functional Integration

9. 6.5.1.6.c Meaning of Color for Displays,

10. 6.7.2.3.2 Meaning of Color Consistency

11. 6.4.2.2 Coding of Controls

12. 6.5.4.1. a.c,d,e,f,g h,1,j,k Graphic Recorders 13, 6.1.4.1.b.c,d.f.h,1 Operator Protective Equipment

14. 6.9.3.1.c(2) Dynamic Control / Display Response Time Lag

15. 6.8.3.2.d(1) Strings / Clusters of Similar Components in Matrices

16. 6.9.1.1.a,b Control-Display Position Relations

• The NRC Staff felt that the NUTAC surveys did not address these NUREG-0700 criteria.

Attachment 2 Page 1 NUREG-0700 Guideline Discrepancies 1

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Attachment 2 Page 2 Guidelines 6.6.6.3 and 6.6.6.2.a Demarcation lines were not used to enclose functionally related displays or controls. As an alternative. colors are used to group the system controls; however, colors were repeated for

.several systems.

Alabama Power Company Response:

A total main control board re-labeling scheme has been developed and will be implemented. The re-labeling will result in the addition of demarcation lines where appropriate. Colors will continue to be utilized in the main control room for the demarcation of systems. Color coding will not be utilized except for red, green, amber, and avhite indicating lights. This issue was originally identified under HED-167.

The number of colors used will be limited to a reasonable number as suggested.by the NRC in an earlier Control Room Human Factors and Operations Review. This will require colors to be repeated on the main control board. However, since this is color demarcation and not color coding, this is not a problem unless identical colors are used side by side. This system has been implemented on the Farley Nuclear Plant units since 1981.

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Attachment 2 Page 3 Guideline 6.6.1.2.a and 6.6.1.2.b The-labeling scheme for the boards does not use hierarchical labeling to show system, subsystem, and component demarcation.

However, one'section is under evaluation using color, label size..and demarcation lines for AFW, MFW, and MSIVs on the main control board.

Alabama Power Company Response:

The re-labeling of the main control board will i nclude hierarchical labeling. This problem was originally identified in HED-166.

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Attachment 2 Page 4 Guideline 6.1.2.5.b(2)

Frequently used displays (reactor coolant pump shaft seal flow rate), including one row of about. thirty displays, exceeded the 65 inch maximum height on the vertical section of the board.

Alabama Power Company Response:

Guideline 6.1.2.5.b(2) is applicable to vertical panels, as illustrated by Exhibits 6.1-13 and 6.1-14. Since the panels reviewed in the audit are stand-up consoles, these specific dimensions are not applicable.

The indicated displays are well within the visual field of the 5th percentile female, and the angle of the line of sight to the face plane is greater than 45 degrees as required by Guideline 6.1.2.2 for display height and orientation for stand-up consoles.

Anthropometric data for the height of displays on the main control board was checked in the NUTAC Control Room Survey and was determined to be adequate.

Finally, in the associated area of improving readability of displays and controls, Alabama Power Company is developing a main control board re-labeling scheme which will improve label readability, including annunciator windows, implement improved demarcation, and implement hierarchical labeling. In addition to re-labeling, new meter faces are being developed for those meters which are difficult to read, and the fifth row of meters on the main control board will be tilted downward to reduce glare and improve readability.

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Attachment 2 Page 5 Guideline 6.1.2.5.a(2)

Several emergency controls are higher by about 6 inches than the 52 inch maximum height for the controls on the vertical boards.

Examples include Containment Isolation, Phase B Containment Spray Actuation, Phase A Actuation , SI Actuation, and Reactor Trip.

Y Alabama Power Company Response:

Guideline 6.1.2.5.a(2) is applicable te vertical panels, as illustrated by Exhibits 6.1-13 and 6.1-14. Since the panels reviewed in the audit are stand-up consoles, these specific dimensions are not applicable.

Control height for stand-up consoles is addressed under Guidelines 6.1.2.2.b(1) and 6.1.2.2.d(2) which are addressed under a later audit finding.

Anthropometric data for the height of controls and displays on the main control board was checked in the NUTAC Control Room Survey, and the Farley Nuclear Plant main control board is in compliance with the NUTAC requirements. Additionally, an operator's questionnaire item requested operators to identify controls which were difficult to adjust. These controls were not identified in the responses.

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Attachment 2 Page 6 Guideline 6.5.5.1.a(3)

Service Water Dilution Flow Totalizer does not have commas or spaces to group each three orders of magnitude (e.g. 1,000; 1,000,000; or 1,000,000,000) .

Alabama Power Company Response:

The referenced totalizer does not provide the groupings as required by NUREG-0700. The Service Water Dilution Flow Totalizer has six digits with no commas.

While developing the NUTAC approach, the development team considered this guideline to be an item which should not be

, evaluated unless a reasonable doubt about conformance existed.

i For the purpose of establishing reasonable doubt, an operator questionnaire item addressed the instruments which were "hard to use." No Farley Nuclear Plant operators indicated difficulty in reading the digital indicators referenced.

. Additionally, a review of reference documentation for this l Guideline revealed that it is based on a 1964 publication. The t information has not been incorporated into any later publications which Alabama Power Company could locate. In fact, MIL-STD-1472C, a later edition which was not available when NUREG-0700 was issued, states that commas should not be used on counters.

Consequently, Alabama Power Company does not consider the use of

< commas in counters to be a commonly accepted human factors practice and will not modify the counters solely to include Commas.

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Attachment 2 Page 7 Guideline 6.5.4.1.b Scale on the recording paper and recorder scale differ on intermediate values (end points are the same). Nine other recorders checked had proper paper / scale compatibility.

Alabama Power Company Response:

Proper paper has been installed on the indicated recorder.

Recorder paper / scale mismatches were identified under HED-194.

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Attachment 2 Page 8 Labels above the annunciator panel are too small. The letters on the panel labels are smaller than the characters on the tiles themselves.

Alabama Power Company Response:

All' labels will be replaced during the re-labeling effort.

Label size problems were originally identified under HED-164.

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Attachment 2 Page 9 Guideline 6.3.3.2.b 4 Fastest annunciator flash rate is 2 per second, and some are slower. Guideline calls for 3-5 per second.

Alabama Power Company Response:

The annunciator flash rate provided to the NRC during the on-site audit was in error. The technical manual for the i annunciator system installed at Farley Nuclear Plant indicates that the flash rate is approximately three per second. Actual timing of the annunciators resulted in a flash rate of approximately 3 per second.

4 The slower annunciator flash rates are associated with the clearing of the alarm. Guideline 6.3.1.5, for cleared alarms, states that cleared alarms should flash at a rate of 1/2 the normal flash rate. Cleared alarms at Farley Nuclear Plant flash at an approximate rate of 1 per second.

Consequently, annunciator flash rates at Farley Nuclear Plant meet the NUREG-0700 Guideline criteria.

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Attachment 2 Page 10 Guideline 6.3.3.3.d(2)

Tiles within annunciator panels are not grouped by subsystem, functions, etc. throughout the main control room.

Alabama Power Company Response:

Annunciators are still under review to develop an integrated solution to several problems identified in the Control Room Design Review. Functional grouping was originally identified under HED-157.

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-_L Attachment 2 Page 11 Guideline 6.6.2.1.a Labels should be placed above the display panel elements they describe. Instrument number labels appear above the display but instrument description labels are below.

Alabama Power Company Response:

Alabama Power Company, as recommended by the NUTAC guidelines, prefers to insure that labels are placed consistently above or below the labeled item. At Farley Nuclear Plant, control labels are placed above the control to prevent covering the label while operating. For displays, a numerical label, e.g., FI-343, is placed above the display and a descriptive label, e.g., AFW Flow, is placed under the display. The emergency procedures contain the numerical descriptions of the display to be used.

Although not specifically identified in a HED since the placement of labels is consistent as discussed above, the issue of label placement has been discussed with members of the Operations Department at Farley Nuclear Plant, the design engineer for developing and implementing the main control board re-labeling scheme, and a human factors consultant. The best, most consistent method for placement of the labels will be developed and implemented in the re-labeling effort.

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Attachment 2 Page.12 Guideline 6.1.2.2.d(2)

Controls on vertical panels are greater than 25 inches from the

front of the benchboard panel protective bar. Note that the bar was installed as a barrier to protect controls near the front edge of the panel.

Alabama Power Company Response:

This problem was originally identified under HED-217.

As stated in the discrepancy, the protective railing around the main control board was installed to prevent accidental actuation l of control switches, as suggested by the NRC in an earlier 3

Control Room Human Factors and Operations Review. The main control board benchboard is 26 inches deep with an additional 5 i inches added by the protective railing resulting in a total j depth of 31 inches. The upper edge of the main control board

protective railing is 30 inches high.

The NRC's 25 inch absolute standard is based on the 25.2 inch l' functional reach for the 5th percentile adult female. This value is based on MIL-STD-14728 and is " measured from wall to tip of right index finger, with right arm extended horizontal to

floor, both shoulders against wall." Consequently, this value

! does not take into account the ability of the operator to rotate I and extend his shoulder toward the control or the ability of the operator to bend at the waist toward the control. Both of these i actions provide the operator added reaching distance.

, . Based on EPRI Special Report NP-1918-SR, Anthropometric Data ,

Base for Power-Plant Design, using a 1968 survey of Air Force women, the thumb tip reach extended for a 5th percentile female is 29.9 inches. A 10th percentile extended reach is 30.6 inches. The Human Factors Design Handbook, by Wesley E.

Woodson, provides a forward reach (standing, without extension 4

of the shoulder) of 29.7 inches for the 5th percentile female and states that the active reach and grasp across a typical I workbench is limited to about 36 inches. Consequently, the main control board vertical panel, with a 31 inch horizontal panel

attached, is reachable for all but the smallest females in the population of plant operators.

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Attachment 2 Page 13 The Control Room Design Review human factors consultant was asked to determine the height that could be reached over a 31 inch deep horizontal panel at a height of 30 inches. This specific measurement is not available in any of the commonly used anthropometric databases. Using the NASA anthropometric database, it was determined that a 5th percentile female could operate switches located 66 inches high on the vertical panel which is higher than any control on the Farley Nuclear Plant main control board.

Based on these dimensions, Alabama Power Company believes the indicated controls are well within the reach range of the 5th percentile female, based on allowing the operator to rotate a shoulder toward the control board and bend at the waist.

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Attachment <2 ,

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Guideline 6.4.3.1(b);

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- Push-buttons-'do'not have positive stop such as a snap or

. integral-light.. Examplescinclude Containment Isolation Phase B

' Reset, Train A and B Containment Isolation-Phase A Reset, Train

A a'nd B Containment' Ventilation Isolation Reset, and Train A and B'SI Block Reset.-

Alabama Power Company Response:

Because'it is-extremely difficult to test the action of push-buttons while units:are at power, the NUTAC approach relied.

on.the operator questionnaire-to-indicate problems with these controls. The questionnaires' indicated that Farley Nuclear

. Plant-operators do not have problems with actual feedback of these-push-buttons. ,

, First,'the_ push-buttons are' simple to bottom out which does provide a method of feedback.

' Secondly, the~following indications are-available to the operators which provide confirmation of the required action. .

SI Block Reset.............................. Monitor Light Box Bypass and Permissive Light Box t L . Containment " Isolation Phase A Reset. .. . .. ... Monitor Light Box

. Containment Isolation Phase .B Reset.... . . . .. Monitor Light Box Annunciator Containment Spray Reset..................... Annunciator

' Containment Ventilation Isolation Reset.....None I

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-Note:

1.. - For-the Containment Ventilation' Isolation Reset push-button, the main control room controls affected by

, the reset.are. located beneath the push-button..

Although these controls will not indicatesif the isolation.has been reset, an i ndication of the reset push-button.not being pushed would be that the controls would not operate-the associated equipment.

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2. A review of the main control board revealed one other similar reset push-button, the Feedwater Isolation Reset on main control board Panel B. The push-button actuation is indicated by g an annunciator.

! It should be noted that none.of these push-buttons actually activate any equipment. They simply provide the ability to initiate an action, i . e., two operator actions are. required to operate equipment controlled by these switches. The operator ,

must first reset the -push-button and- then operate control

switches for the specific equipment.

Operator training emphasizes the use of available monitor light

- box and/or annunciator indications to verify reset of the' SI, Phase A, Phase B, and Containment Spray actuation signals. The ,

- Emergency Response Procedures also-make use of the monitor light box indications'to verify reset of the SI, Phase A, and Phase-B

, actuation signals.

Reset of the containment spray system and containment ventilation isolation is not highly time-dependent. Failure to obtain proper reset of these signals will result in the inability of the operator to reposition specified valves.

Should this occur, the operator has sufficient time to repeat his reset of the containment spray signal or containment

' ventilation isolation signal. Additionally, no use of the Containment Ventilation Isolation Reset in the Emergency Response Procedures has been i dentified. The only identified i

use of the Containment Ventilation Isolation Reset is during the recovery from an accident which required isolation of the l containment ventilation.

Consequently, Alabama Power Company does not intend to modify the design of the reset push-buttons because sufficient positive indications of signal reset are readily available in the main control room, and training and procedures direct the operators to use these indications.

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' Attachment 2 Gu i del i n e : 6.4. 2.~1 The. speed?and voltage adjustments for-the diesel generator- ~

governor and voltage regulators rotated counterclockwise to increase.vice clockwise. This applies to each of the five diesel generators. Note that the convention for the main generator voltage adjust is clockwise.

4 Alabama Power Company Response:

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Design convention surveys and general panel surveys conducted on  ;

the. Emergency Power. Board failed to~ document this discrepancy..

The Farley Nuclear Plant convention is for increase to be clockwise. Another' problem of this nature was discovered on'the main control board during the initial surveys and is being fcorrected.' Additionally..another walk-down of the main. control board was conducted to determine if any-additional _ discrepancies i of this nature had been overlooked. No new discrepancies were-discovered. This discrepancy is being added to the HED database--

as HED-270 4

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Attachment 2 Page ,17 o

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Guideline 6.3.1.5 The auditory signal for annunciator cleared alarms was the same

- as-for alarming-annunciators on ESF panel C and MFW panel J.

4 Alabama Power Company Response:

NUREG-0700, Appendix A, states that this'is'a. preferred practice of the NRC's Division of Human Factors Safety, Human Factors o Engineering Branch, and provides no reference material for the

, guideline. Alabama Power Company considers this guideline t'o-state a " preferred design" rather a than human engineering.

design principle.

I- Additionally, NUREG/CR-3217, Near-Term Improvements for. Nuclear Power Plant Control Room Annunciator Systems, defines ringback.

as a design sequence feature that provides a distinct-visual or auditory indication, or both, when-the process or system

. condition returns-to normal. This is also referred to as a L " cleared signal." The Farley Nuclear Plant annunciator system provides both-a visual and audible cleared signal.- The visual signal is unique in that the flash rate varies for alarming and

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cleared annunciators. The audible signal is not unique,Jas stated in the discrepancy, but the combined use of visual and

- audible cleared signals is adequate. Consequently, this situation was not identified as a HED.

Finally, Alabama Power Company does realize that a unique audible ringback would enhance the operation-of the annunciator system. Discussions concerning modifying the ringback feature were held by the-Control Room Design Review Team, and a Farley Nuclear Plant design organization was directed to investigate a unique audible ringback alarm in April 1986. A preliminary investigation has revealed that either an extensive modification to the entire annunciator system or a complete replacement of the annunciator system would be required. This item will continue to be investigated in the annunciator review currently in progress.

Attachment.2 Page 18 Guideline 6.3.1.5(a)

~There was no auditory signal for the " Accumulator 1 A Pressure Hi-Lo" annunciator clearing. The only indication of cleared alarm was the annunciator tile went from steadily lighted to out.

Alabama Power Company Response:

This discrepancy was originally identified under HED-134.

Alabama Power Company is currently conducting an annunciator review as stated in the Control Room Design Review Summary Report. This item is being considered and a resolution will be developed.

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