ML20236C690
| ML20236C690 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/20/1987 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Calvo J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| References | |
| P-87357, TAC-56125, NUDOCS 8710270298 | |
| Download: ML20236C690 (114) | |
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- =ts._,. j O Public .16805 WCRService'"
19 1/2, Platteville, Colorado 80651 .j October 20, 1987 Fort St. Vrain l Unit No..'1 P-87357-U./.S. Nuclear Regulatory Commission g
. ATTN: -Document Control Desk l ' Washington, D.C. 20555
~ ATTN: Mr. Jose A. Calvo Director, Project Directorate IV-Docket No. 50-267 ;
SUBJECT:
Technical Evaluation Reports @
(TERs) of the Fort St. Vrain-' '
Control Room Design Review R c Submittals C$
a M1
REFERENCE:
NRC Letter (G-87244)
Heitner to Williams M C7 Dated 07/21/87 @ l
' o j O '
Dear Mr. Calvo:
The purpose' of this letter is te provide you with Public Service -j i Company's . response to the request for " specific information" i contained in the Science Applications International Corporation's j
-Technical Evaluation' Reports transmitted by.the above reference.
-If- you have questions, please contact Mr. M. H. Holmes at 4 (303) 480-6960. j Very truly yours, j k O. /Yas en-l i D. W. Warembourg i Manager, Nuclear l Engineering Division j DWW:DJG/1s i
Attachment 4
cc: Regional Administrator, Region IV ATTN: Mr. T, F. Westerman, Chief Project Section B
'2 Mr. R. E. Farrell Oj Senior Resident Inspector D Fort St. Vrain 8710270298 871020 ADOCK 050002 7 1(I DR e
_______u_____-._________ _ __ _ _ _ i
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L- Attachment to h P-87357 Public Service Company's Response ,
to the-Concerns Addressed by the Nuclear' Regulatory Commission's
. TECHNICAL EVALVATION REPORTS OF THE DETAILED CONTROL ROOM DESIGN SUBMITTALS On April 30, 1985, Public Service Company (PSC) submitted a Summary l Report (SR) of the Detailed Control Room Design Review (DCRDR) as required by NUREG-0737. PSC staff members met with the Nuclear Regulatory Commission (NRC) staff in Bethesda, MD, on July 16, 1985, to discuss this SR. A NRC letter dated August 27,1985, (D. R.
Hunter to 0. R. Lee), requested a Supplemental Summary Report and provided minutes of the July 16, 1985 meeting. An included summary listed the documentation considered "necessary to complete NRC ;
review". A telephone conference was held between PSC and NRC staff a members on September 19, 1985, to clarify these requests.
'PSC submitted, by letter dated October 29, 1985, the supplementary information requested by the NRC. Due to the integrated approach to making modifications to panels and resolving Human Engineering Discrepancies (HEDs), PSC has submitted to the NRC, proposed design packages for each separate panel or panel section where changes will occur, on a schedule corresponding to the completion of each proposed panel redesign.
By letter (P-86005) dated January 17, 1986, PSC requested advance approval of four (4) proposed changes to the Fort St. Vrain (FSV)
Control Room. In further discussions with the NRC staff , these changes were limited to the following three (3) items:
Circulator Brake and Seal Indication Changes (CN-1984)
Control Room Furnishings and Arrangement (CN-1899) l Control Room Lighting (CN-1898)
A NRC letter dated June 13, 1986, (K. Heitner to R. F. Walker) l indicated that the staff had reviewed the changes and found them j acceptable and that PSC could proceed with the implementation. In i addition, a request for specific information relative to thirteen (13) items addressed by various HED's was included in the attached .
Science Applications International Corporation's (SAIC) Technical l Evaluation Report. PSC submitted by letter (P-86528) dated August 19, 1986, the specific information requested by the SAIC report.
On July 28, 1987, PSC received a letter (G-87244) which provided Technical Evaluation Reports (TERs) of the remaining design submittals. These reports requested additional information, ,
clarification, or justification of certain items addressed by 85 l HEDs.
Page 1 of 113
h; Attachment to I P-87357 k-
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This response will address each item for which additional information ,
was requested. The format of this response will include the SAIC comment and provide PSC's response to that comment. .
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" ~ The Annunciator SidenL(Alarm Functional Grouping)-
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SAIC COMMENT, ,
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'!HED-0337 '(Category 2) -1 The ' di screpancies described are that two; functionally unrelated alarus are combined on panel I-01A-and _ that f they are not located with. the' appropriate systems.
Y(j The disposition proposes to rebbel the alarms and relocate- _M.
'them to- panel I-03A. This' . appears to solve the'locati r,
_ problem but not the combination problem. PSC:should provide 'i f information as<>t.o how two unrelated alarms are
-more-A
" combined"-(e.g'., an alarm;:with multiple inputs) and- Low 4 f their undesirable' combinstioni is resoMed by the projected disposition." .;
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- PSC RESPONSE w '
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HED-0337, was initiatedt '
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alarm window I-01A, 1-9; 'as-a;resultofthedual~legendon,/s ThirJdual lageti implied that thisi i alarm-' performed dual,(two unique' andNaouate) function, /
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when in fact- this alarli, serves as a summaryc plarm ' initiated -
Tl by._ local alarm units'.bn reserve shutdown pane 4 1-21A, B,' C, .
and D.- 7 1
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^ 0 This. dual legend represents tne Control' Rod Purge function
~
a.nd the Reserve Shutdown' function, both of.which are local toi .
- I-21A, B, C, and D. Any corrective action relative to either d the " Reserve Shutdown" or the " Control Rod Purge" System is performedz locally (remote to the' Control Room), and as such, !. ,
is a Dispatch Function. A ; "Di spatch Function" is, one' of t6
(
~ directing an equipment operator or other personne,1 to'a 4 remote location. . Considering the fact that I-0M, 3-9 initiates a singular Dispatch Function (and not g Dual ;
Function alarm or a Dual Dispatch Function) it will r u i% as is and be functionally grouped on I-03A (window 3-J) with other Control Rod alarms. The window will be ralabdied 'f*
" Acknowledge I-21A, B, C, D Alarm" to reflect the single Dispatch Function. (See Attachment C, Page 6, of Attachment 6b-12, transmitted under cover letter P-86088, dated March 18, 1986, t ,
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1 Page 3 of 113 I
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'5AICCOMMENT[S ,
'"HED-0340dCategory 4). -The discrepancy cited is that the.
. a f. ;
m if ' alarm . ige function of ambient temperature (load) and the !
r :y functioh\j s " irrelevant" since .the - operator.cannot alter -
outsideptmperature. Therefore, the. . instrument will. be 9 deleteil ' Apparently, the monitoring of ambient temperature
.n y Li'7 / related to the rate.of water influx. If thsJalarm-in i.EM!{.h ~
o : question is a function'.of temperature'only and condition of low water flow is ' adequately. monitored by' other viaMe means, LthenPSC's disposition - of this HED would appear Adequate. '
1 Otherwise,' the. res'olution will- not be ' deemed 'acriptable." i
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PSCIRESPONSE .M .m ff hh 4671 (no-safel related)-alarms'on a low'(700 gpm)'ori fiji h h3Oh (2 ) (16) .different heat exchangers.(or coolers) f Return Header.
"M f A Q . %s',800,.gpm) flow in the Service
- exhaust
. Water a
~i' y tQbt Return Header. 'The -
desired process temperature is j 4 Q ,j U,[ water: gnaintained. flow through that cooling -water flow thro 4 .
at gnr1 each cularexchanger the' Return,' Header (or'
% changer. Therefore, _
will varycooler) ty contro the:
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'according to'the load on ec individual heat exchanger, the l
.g fp( number'of exchangers in serv ce or."dpergting,t and the outside. ,'
air temperature which affects the ef ficiency of j the se(vice water cooling tower.
37 e process ' flow temperatures are <the criticals and
, J'dp. trolling ' ' parameters. . The Return Header flow isi the 4, 4
A
*A dependent' variable and may ~ routinely (and normally) vary from minimum -(zero)' flow ;to. the -maximum design flow; This results 1
j
'z > W the FAHL-4671.being a nuisance alarm. The disposition of j
%. ,/- HED-0340 remains valid.
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l a HED-0366 and HED-0393 .
L?i *: SAIC COMMENT-
"HED-0366. (RAH-93250, . RAH-93267,. Category ,1) and HED-0393 (NAH-1131, NAH-1133-1, Category 3) -
In b6th cases, the
, resolution lof.:the HEDs . involves. the combination of two
(' ' alarms.' If the original-individual alarms are redundant- and they monitor basically the same area and function, then their-combination .would be Jdeemed acceptable. Otherwise,. PSC l should provide adequate. justification L for the ' disposition !
especially:since one of the HEDs is classified under Category .l l'. '[ l
<. PSC RESPONSE.
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'As a 1 : pt'ef a ce L to the discussion of RAH-93250 and RAH-93267, PSC's; philo' sophy relative to radiation alarms is provided: '
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-" Radiation monitoring equipment alerts the operator- O E cf radiological hazards.or. conditions in or around ;
the.. plant, and, in some cases, the monitoring !
. equipment initiates automatic action to minimize the. spread of. contamination. In general, alarms associated with the radiation monitoring equipment .t should be ' incorporated 'into the Control Room-as' l' follows:
- 1. Radiological alarms associated ~with monitoring equipment that provide automatic contr,1 l actions or with . monitoring equipment that !
require manual operator control. actions should I be individually ela % d and the' alarm should I be functionally grouped w i t.h its associated instruments, f
- 2. Radiological alarms which alert the operator of radiation hazards for which there is no control response, may be combined into a single multipoint general alarn in the Control ,
Room that directs the operator e attention to j Panel I-14 where specific information may be {
obtained. This multipoint alarm must l-r3 flash / retransmit all alarms. j Page 5 of 113
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' Attachment-to P-87357
- 3. IRadiation_ module / equipment- failure signals should be combined into a ' single, 'multipoint general alarm in the Control Room that directs
~the operator's attention'to panel - I-14 where-s . specific-ifailure information may be obtained.
This'multipoint alarm must reflash/ retransmit all failure conditions."
-c RAH-93267 is presently-comprised of combined trip and failure contact from_five-(5) separate radiation' monitor switches,.
. RIS-6314-1,--RIS-6314-2, .RIS-9301, RIS-9302, and RIS-21251-
. (see" Figure 1, Page 8).- On'a."High Activity" condition, RIS-6314-1 and/or- 6314-2 automati_cally reconfigure HV-6304-l',
7
' HV-6304-2 and provides an_inpututo Summary Alarm RAH-93267.
~'
HV-6304-1 and HV-6304-2 divert:the flow of gas' waste from the .
Gas Waste B'.ower.to the Gas Waste; Vacuum Tank.
- On a_ "High Activity" condition, RIS-21251_ provides_ a "High Activity" alarm , ( ow Pressure: Separator Outlet) I-02A, 5-6, ,
reconfipJres- the separator outlet flow path,'and provides_an input to Summary Alarm. RAH-93267 On a "High Activity" condition, .RIS-9301Jand/or RIS-9302 which monitors primary coolant activity, provides'only an finput to Summary Alarm
. RAH-93267. -<
The above combined alarm (RAH-93267)'is unacceptable in that operator _ actions ~ differ between verifying system
- configuration _ changes -and determining the _ basis for high primary coolant activity. In accordance-with the previously-stated -philosophy, the actual high radiation condition of :
RIS-21251 and RIS-6314-1/RIS-6314-2 will be alarmed l
- individually (see Figure 2, Page 9). The high radiation condition of RIS-9301 and RIS-9302 will be alarmed as "High a Activity" 'in -Summary Alarm RAH-93250. The " Module Failure" condition'for the above five (5) modules will be included in RAH-93267 and will direct the operator to 1-14 where specific
' information may be obtained.
RAH-93250 is presently a summation alarm with twenty (20) module inputs. Each input consists of a "High Radiation" and a " Module Failure" condition. The "High Radiation" conditions do not perform automatic control actions or require the operator to perform immediate manual control actions. The required action (s) is/are the determination of area (s), signal amplitude and the dispatch of Health Physics personnel (and if required, the evacuation of personnel).
Subsequent manual or dispatch actions may be required
' depending upon the results of a preliminary assessment. The determination of area (or equipment) and relative signal strength is accomplished at I-14 control board, therefore, a ,
Summary Alarm which directs the operator to the I-14 board is acceptable for this group of monitors.
Page 6 of 113 L-_______________--__- - __ __
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( Attachment to l' P-87357 l
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L The intent of the disposition of HED-0366, though not explicitly' worded, is to reconfigure those alarm conditions ,
in accordance with the above stated philosophy. '
NAH-1131 (Source Range. Rate High) and NAH-1133-1 .
(Intermediate Range Rate High) originate from separate !
detectors (not redundant), monitor the same parameter (flux),
have identical setpoints, and have identical operator action ;
requirements: " verify flux rate and adjust (insert) control -l rods". Both of these high rates of neutron flux are used as a rod withdrawal prohibit when the interlock sequence switch is in the start up position. The combination of these two alarms is considered acceptable based on these facts.
"f Page 7 of 113
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.3 d ' Attachment to P-87357 HED-0369'
- SAIC COMMENT "HED-0369 (PAL-23111, Category 3; PAL-2187, Category 1)L-'The' discrepancies described are that the alarms are not functionally: grouped land legends are not descriptive. 'The planned disposition involves relocating the alarms from panel I-01C to .I-13C and -functional grouping. This~ appears to solve ithe.. grouping problem but: not- the. one concerning :
nondescriptive.-legends. .PSC should. clarify how the. legends
- would ber. made more. descriptive. especially when the HED
' involving instrument 1-PAL-2187 :is classified under Category 1."
PSC RESPONSE:
'The disposition of.HED-0369 indicates that PAL-23111 and PAL-
?2187:will be relocated to the "Back-up Bottle Pressure"
. grouping on Panel: .I-13C. -(PAL-23111 will be located on I-13C, 3-5, and:. labeled '" Purified Helium Header- Pressure Control".)- PAL-2187l will be ~1ocated on I-13C, 1-5, and' labeled "He Circulator Isolation Control". See Attachment "C" (Proposed Alarm. Panel Layouts) to Attachment 6b-22 transmitted by letter P-86407 dated June 16, 1986, l
Page 10 of 113
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Attachment to P-87357. , . 'l 4- ,
HED-0406 4
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'SAIC' COMMENT. i
'"HED-0'406 -(Category 2) .The~ discrepancy' indicates that the ~
cluster of 'Ist in' alarms' on I-05A/D are generally-functionally ' located. with' Cire ' Speed control, Lhowever any.-
reaction with controls on I-02 may require operator running
. between .I-02 & I-05 for resetting alarms'. PSC maintained-that the present arrangement is ;'a ' result of: the original arrangement philosophies (due primarily to the'use.of cold reheat steam as motive. power for circulator drive) :and thisL arrangement < offers certain operating. benefits and:is not i
subject to change. as'La redesign .e f f o rt ' '. -Therefore,1 -no .I further action was ' deemed necessary. To afford a more. !
thorough evaluation of this Category '2 HED and proposed j resolution, 'PSC should explicate,the ' original' arrangement- l philosophies'.and the !certain operating benefits' provided by the-existing arrangement."' j
.PSC RESPONSE ;
See PSC Response to SAIC Comment for HED-0722, Page 26 of i this document, i
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Page 11 of 113
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~ Attachment to 1
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4 HED-0411 SAIC COMMENT i 1
l "HED-0411 (LAL-9111-2, LAL-9112-2, . Category 3; PAL-9137, PAL-
'< 9138, Category 1) - The discrepancies are that these alarms are not' functionally. grouped and that the legends on alarms LPAL-9137 and PAL-9138 are not descriptive'enough. To. resolve the problems, PSC proposed to delete . LAL-9111-2 and ' LAL-9112- !
2.which are not' required and to relocate PAL-9137 ~and PAL- j 9138 .to the dedicated hydraulic alarm panel (I'06J). While-
.the proposed measures' appear to resolve the grouping problem, there is no- indication as.to how the legends would be made
~
4 rore descriptive. PSC should clarify this remaining concern, .i especially in light of the' fact that Category 1 HEDs are
~
involved.." ;
PSC RESPONSE ,
l The. disposition of HED-0411 indicates that alarms PAL-9137' and PAL-9133 will be relocated' to the dedicated -Hydraulic. l Alarm Panel. I-06J,. windows 3-1 and 3-3 respectively. 'These alarms will be labeled " Accumulation Nitrogen Pressure Low",
[See Page .16 of Attachment C' (Proposed Layouts.of Alarm Panels) to' Attachment 6b-12, transmitted under cover of letter P-86088 dated March 18,1986).
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i Attechnent to P-87357-HED-0412
.SAIC COMMENT ~
1 "HED-0412 (Category 1) - The discrepancy.is that the label on
. i each of the two a.larms (TAL-9373 and TAL-9374) does not _.
indicate all conditions ~ associated with -the alarm.
~
, 1ndicated;that.each alarm has 'both delta T between loops and-
- low temperature lper loop qualified by ISS in power position'.
,Furthermore, ! qualifying conditions are not stated on alarm- u' legends';- therefore, the existing nomenclature..is deemed adequate. However, it.is quite possible.that' operators may be confusedLby an inadequately labeled dual-input alarm 1 concerning ;the nature .o f the alarmed conditions. The. j presence of confusion would be obvious, particularly if the j HED was identified during.cparator interview / questionnaire.
Also.: 'in view of: the fact that this is a Category 1 HED,' PSC should address:this concern and provide a clear justification
-for no action. Furthermore, PSC should indicate how the generality of the labeling is compensated for by training." l
,q i
PSC RESPONSE HED-0412 was initiated as a result of an operator indicating that I-05A,.4-6 (I-05D, 4-6) had more than one input. This occurred during operator assisted reviews of the alarm panels and res~ulted in this alarm being cited as a potential problem. Assessment activities and categorizations were based on. the potential for operator error and the consequences of such an error under the qualifier that the HED presented'an actual problem. Given the possibility of l
-operator ' confusion with a dual input alarm, an in-depth
' evaluation-(see Attachment 6b-12, transmitted by letter P-86088 dated March 18,1986) considered the validity of the H ED ', . functional aspects of the ' alarm cited, functional grouping, adequacy of labeling, operator actions, etc.
]
A low superheat header (main steam) temperature trip (and subsequent alarm) is to protect the steam generator from a floodout transient. Low superheat header temperature in a j loop is indicative either of a feedwater valve or controller .l failure yielding an excessive loop teedwater flow rate or a )
deficiency of helium flow and a loop shutdown is in order. A required coincident high differential temperature between loops functions to prevent the loop from tripping during normal operation at low main steam temperatures such as in
)
-l plant shutdown. The trip is only active when the interlock '
sequence switch is in the power position.
The above mentioned in-depth investigation of TAL-9373 and TAL-9374 and plant design showed that this alarm does have Page 13 of 113
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<, P-87357 three. ,(3) qualifying inputs but. notl in an either/or configuration. _This alarm is'one'of.the initiating. symptoms 4
in _PSC's existing Emergency Procedures (EP-C). Operator-response to this' alarm is ' covered in procedure and Plant Protective' System training. (See excerpt included as Figure '-
3, Page - 15)'. The . Operator Actions- giv'en. are those of~
ensuring automatic ~' actions.
The- existing. alarm legends " Main: SteamL Temperature Low"
.adeqijately describes.the condition. which constitutes these
~
alarms.
The disposition :of HED-0412 should have more clearly- !'
indicated that.two interrelated conditions: (plus ISS) were required to initiate the alarm and that it was not a true multipie:-input; alarm.
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Page 15 of 113
Attachment to P-87357 HED-0453 SAIC COMMENT "HED-0453 (Category 3) - The discrepancies are that seven of the alarms on panel I-13A are not functionally grouped with the appropriate systems, and one of them (PDAH-21401,
' Emergency Backup Boiling Water Strainer') requires the operator to dispatch an outside operator to swap the strainer. To resolve the problems, PSC indicated that the alarms will be relocated and functionally grouped on various panels. However, the proposed resolution does not address how the problem of requiring an outside operator to swap the strainer would be mitigated. PSC should explicate the nature of this HED and its planned disposition."
PSC RESPONSE The HED listing included in this package lists one classification code.for HED-0453 (and HED-0454). This "8b" classification is defined by Attachment B, Part 3, of PSC's
" Control Room Design Review Summary Report" as " Alarms, Location" (functional grouping).
HED-0453 and HED-0454 were initiated as a result of the following Survey Checklist question:
"Is alarm above associated system controls and/or indications?"
The problem is one of alarm location and not one of operator dispatch activities. The task of dispatching an o u t s i c' ,
operator to swap " Bearing Water Strainer" is a work load consideration assessed during walk-through talk-through activities.
The alarms cited are presently located on I-13A, a back side board, remote to the Helium Circulator indicators and control on Main Control Board I-02. The explanatory information included on this HED is of use in functionally grouping the circulator and circulator system alarms. This type of dispatch activity has not been found to present operating problems, therefore, there are no plans to improve this process.
Page 16 of 113
- n. s; - 3 sy
2 Attachment;to lP-87357 HED-0454
- SAI'C COMMENT ,
, I"HED-0454- (Ca'tegory 3)' ~ The - discrepancies are that four
" alarms (one on panel 11-13C and three on. panel'I-13A) are: =not'
< functionally grouped with_ the. related systems and that an-operator has:to be dispatched to-replenish Loil ' residue; for alarm i LAL-6391. .Moreover,' alarms PDAH-21399.and PDAH-21395
- g. '. require the operator to' dispatch-an outside operatorfto . swap
- L/ :, the strainers. PSC-. proposed to relocate 'the alarms to cachieve functio ~ . grouping.. .However, .the, . indicated disposition dou, not address how the remaining.problemsLof- 1 Erequiring- the' operator -to replenish oili residue ' or to ' swap strainers: would be'. ameliorated. . PSC should clarify <the ' '
natureiof this HED and itsirelated disposition =."
cPSC' RESPONSE See.PSC'sJresponseLto HED-0453 on Page'16 of this document.
1 I
l 1
'a
-l i
i Page 17 of 113
Attachment to P-87357 HED-0475~
SAIC COMMENT "HED-0475 (Category 2) - This discrepancy involves three problems, First, the alarm (PAL-11226) setting is out of spec (approximately 5.0 psi vs. 3.6 listed set point).
Second, the east -end operator has historically assumed responsibility for the I-13 board despite the fact that it is not an assigned duty. Third, the Delta P controller .and/or piping system does not respond at a rate sufficient to i compensate for PCRV pressure changes during step power alteration. The NRC is referred to GSAR 792 for a description of PSC's disposition. The apparent resolution proposed for the problems as indicated on the appending pages to the HED Evaluation sheet comprises the following:
- Fix the Delta P alarm I-13C, 5-1.
- Consider improving the control response and vent control for interspace pressurization.
- Consider a different alarm scheme for high flow alarm FAH-11263. '
These proposed measures would seem to correct the problems.
However, since GSAR-792 is not available for review to l explain and confirm PSC's plans, PSC should provide more specific information on how the projected remedial measures would be helpful."
PSC RESPONSE Investigative efforts which encompassed the intent of GSAR- j 792 resulted in the initiation of two (2) Design Change Action Requests (DCARs).
The first, DCAR-1121 requests the installation of a 0-20 psid switch in parallel with the existing 0-150 psid transmitter.
The Alarm I-13C 5-1 presently driven via an alarm bistable will be driven directly from the new 0-20 psid switch. The existing alarm bistable has a hystersis greater than the acceptable alarm tolerance. The proposed 0-20 psid switch range provides an acceptable degree of resolution for this alarm and should result in the alarm actuation and reset values being consistent with the monitored parameter value.
DCAR-1204 proposes to dampen the output signal of FT-11263.
This dampening is designed to prevent alarming on flow perturbations caused by varying system demands, and allow alarming on a steady state flow value. By this filtering process, spurious alarms will be eliminated.
Page 18 of 113 L____-________-__
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P-87357-
> -i a:- . ,
While HED-0475-did not: cite interspace pressurization control
, response as,a prublem, discussions . relative' to .this HED raised the issue, w
The system- design. is based on the need- to . maintain a. ,
prescribed differential between reactor _ pressure and' ;
interspace pressure levels. Due to -the high . volume and=
relatively high differential during . initial pressurization
. activities,- the flow' rates are correspondingly higher. _These
. higher rates result in a . valid high. flow . alarm. The- '
+ controller- (PDC-23111) a' accomplishes. the design'. intent by-
. responding to this high' differential pressure. .This:' system does' respond adequately to reactor pressure changes _during normal power operation.
'I 6
l Page 19 of 113 I
n., .
ll- L Attachment to P-87357 HED-0551 -
l
. SAIC COMMENT I "HED-0551 (Category 3) - The discrepancies are that the: sound 3 levels from the alarms on panel I-70 are found to be 6.1' -dBA
.on ~ average above- background noise which is. lower than the 'q nominal value of 10'dBA recommended by NUREG-0700 (Section ;
6.3.2.1). Moreover, an alarm horn on the shift supervisor's-alarm panel'is reported to be out of operation.- PSC's ;
disposition indicates that sound absorption treatment will be provided in the Control. Room via CN-1899 to reduce background noise ' level, and the alarm noise levels'from I-70 will be-reevaluated after the noise treatment. Thel inoperable alarm
. on- the . shift supervisor's alarm panel:Will be~ referred to
' operations forfmaintenance action by GSAR-767'. Apparently, the disfunctioned alarm will be repaired by the maintenance.
personnel. However, the evaluation of this HED and related resolution cannot be completed until information on the noise treatment and reevaluation of the I-70 alarm noise levels is made available to the NRC for review."'
PSC RESPONSE Extensive sound _ absorption treatment as installed by CN-1899 has resulted in reduced background noise levels. The in_telligibility- of Voice Communications shows a marked i improvement and.is considered to be excellent by the Control Room operating staff. The_I-70 alarm level is such that the operators can reliably discern the signal above the ambient control room noise. j
'The' summary on Page 21 represents the results of a sound
l level survey taken in the Fort St. Vrain Control . Room on October 10, 1987. Current plant conditions and equipment status prevents the acquisition of sound level values .
suitable for accurate comparison with the results of levels 9 recorded prior to modifications. However, present audible ,
alarm levels are sufficiently above background levels to t unmistakably alert and get an operator's attention.
i The horn within the shift supervisors alarm panel was inactivated due to the excessive audio level interfering with ,
other communications. (This device is not adjustable.) The r horn activating relay serves to alert the shift supervisor of an alarm condition. CN-1925, (Miscellaneous Alarm Modifications) will include the installation of an audible device set to unmistakably alert and get the shift supervisor's attention.
Page 20 of 113 t__1_ _ - - _ - - _ - - -
I Attachment to P-87357 i
Summary of 3 Sound Level Survey '
Conducted After Sound Absorption Treatment 1
A' sound level survey was conducted on 8 October,.1987 between the I hours of 0900 and 1100 AM. The plant was in a shutdown mode. Major l rotating equipment items including heating and ventilation fans were operating. Alarm activity was minimal. Paging and conversational activities were normal. It was noted'that the Alarm Horn level was significantly reduced and subject to replacement, a periodic maintenance activity.
Background sound pressure levels for "A", "B", and "C" weighted readings were recorded for specific locations (both operator and non-operating positions) on Form 344-24-4238, " Control Room Plan View".
1-70 Annunciator system ale m levels, while reduced, were recorded for operator positions. These alarm levels were not taken for "B" weighted values. The previously recorded Alarm levels are included as being more characteristic of normal horn operation.
Sound levels Average Background - SPL, A" weighted = 56.3 Average level (1987) with Alarm - SPL, "A" weighted = 59.5
' Average level (1984) with Alarm - SPL, "A" weighted =
69.0(db)
Average Background - SPL, "B" weighted = 62.8 db Average Background - SPL, "C" weighted = 68.4 db Average level (1987) with Alarm - SPL, "C" weighted = 70.2 db Average level (1984) with Alarm - SPL, "C" weighted = 75.8 db Average level with Scram Horn at operators desks, "C" weighted = 75 db Average Page level above Background, "A" weighted = 2 to 6 db Average Conversational level above Background, "A" weighted = 2 to 4 db Shift Supervisor SPL, "A" weighted = 58 db Shif t Supervisor SPL, "B" weighted = 62 db Shift Supervisor SPL, "C" weighted = 66 db Due to the fact that the turbine was not operating at the time of this "af ter modification" survey, the results may be compared with the "before" survey on a qualitative basis only. Turbine operation results in a 6 db ("A" weighted) increase in sound level pressure as measured in the Shift Supervisor's office. This office is a concrete block structure located outside the Control Room on the turbine deck.
It is expected that the effect of turbine operation on the Control l Room background noise level will be in the order of a 2 db increase.
1 Page 21 of 113 I L_ _ l
r , ;
L l .
. g Attachment to 4
- < P-87357 i
i
.HED-0598 1SAIC COMMENT.'
"HED-0598 (Category 11) - The discrepancy indicated is that the startup, wide range, and power instruments are marked in a Arabic numerals ~ while the corresponding references on panel- !
I-03 are in Roman numerals. To correct this.. problem, ;PSC '
proposed. to. group functionally the alarms and relabel them m, using Roman numerals. However, as recommended in NUREG-0700 (Section_'6.6.3.4.e), the use' of Roman numerals.in labels should ~be avoided. PSC should provide Justification ~
indicating .why P.oman (and'not Arabic) numerals are used in this case or relabel the applicable components using Arabic-numerals."
y PSC' RESPONSE
" Specific Information. Item #4", (PSC's Response to SAI Comment relative to'HED-0597) transmitted by letter P-86528 l dated August 19, 1986 specifically addressed the above comment, The pertinent. portions of that response are as follows:
"NUREG-0700, Section 6.6.3.4e states: 'Use of Roman numerals should be avoided.' This
' Guideline' . appears to~ be based only in the
. difficulty o f. interpreting a series of Roman numerals, such as the year MCMXXCVI. The use of .
Roman numerals'I through X does not present this l difficulty and is not subject to the same argument.
Public Service Company identifies-eight (8) nuclear channels with Roman numerals I.through VIII. The use of Roman numerals to identify.a specific group of components, functions or channels should not be confused with the instrument number identification scheme which identifies -each component with an alpha-numeric designation. !
A valid argument does exist for the use of unique symbols (such as Roman numerals) to differentiate between certain functions. While an in-depth discussion of this argument will not be presented in -this response, it is based on the fact that there are eight (8) neutron channels, three (3)
Plant Protective System (PPS) input channels, and two (2) PPS output channels. However, the fact 1 remains that there is no justification for eliminating certain simple types of symbols or characters on the basis that interpreting a series Page 22 of 113
- - _ _ _ _ - __=
l I
Attachment to L P-87357 l I-l-
1 of these symbols is difficult. Tests conducted )
during operator interviews established a 100% i accuracy rate in the recognition and interpretation I of Roman numerals I through VIII.
The continued use of Roman numerals in this l particular application has been evaluated and is considered acceptable."
1 l
l Page 23 of 113
- ______________.________o
- e. .
(
r Attachment to -l c P-87357- ;
F l
HED-0678' 4
SAIC COMMENT l "HED-0678 .(Category 2) - The discrepancy indicates that too i many alarms triggered during t'ransient. affect communication 4 and concentration. Moreover, alarm horns are'not discernible between panels. PSC proposed a ' multi-faceted' approach to-mitigate these problems' 'as much as possible'. Solutions include the installation'of noise damping materials (via CN-- .
1899), the deletion of unnecessary or redundant alarms, and I the qualification or relocation of . alarms. Changing :the
' tones of the alarm horns will also be considered. It is evident that PSC has a commendable grasp of the problem as well as - the ~ general ' remedial approach. However, more complete and specific follow-on information concerning thei final disposition and results of mitigating actions should he I provided before this ,HED and PSC's resolution -could be confidently and conclusively evaluated."
PSC~ RESPONSE
. Generally, the design packages which address a particular set of design improvements are submitted for staff review and concurrence prior to implementation. The final "results of- i mitigating actions" are not available until after s'uch
-implementation.
Other aspects of the " multi-faceted" approach are presented in' the following previously submitted design packages: -
- - "Alarm Functional Grouping", Attachment 6b-12, transmitted by letter P-86088 dated March 18, 1986
- " Miscellaneous Alarm Modifications", Attachment 6b-~
19, transmitted by letter P-86366 dated May 16, 1986 Alarm Initiating Circuits", Attachment 6b-26, transmitted by. letter P-86505 dated August 18, 1986
- " Alarm Functional Grouping", Attachment 6b-22, transmitted by letter P-86407 dated June 16, 1986 i The results of a recent noise level survey is included as Page 21 (for HED-0551).
J Any pre-implementation evaluation will need to be based on the above information and on results of any improvements completed to date.
Page 24 of 113
_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ l
Attachment to P-87357 HED-0679 SAIC COMMENT "HED-0679 (Category 4) - The discrepancy is ' lack of administrative control on temperature control' in the Control Room. PSC will refer this problem to operations presumably for appropriate action. The problem appears to be that
+emperature control within a certain range is desirable in the Control Room, but there exists no administrative measure to ensure compliance. However, it might also be the case that appropriate means for adjusting the Control Room temperature is lacking. Moreover, there is no information on the specifics of the final resolution for the HED. Both the definition of the problem as well as the proposed disposition require further clarification before the HED and related resolution could be fully appreciated and evaluated."
PSC RESPONSE The problem cited by HED-0679 is the " lack of administrative control on temperature control in the Control Room" and not a "means for adjusting the Control Room temperature".
Appropriate means does exist for adjusting the Control Room temperature.
More explicitly, the Operating staff is comprised of some thirty (30) individuals, each with certain metabolic differences and preferences of dress. Individual preferences are a fact and result in the temperature control being adjusted. While individual comfort is important, maintaining a reasonably acceptable environment for the entire staff must be given a high priority. Given this fact, it then becomes necessary to determine an optimum setting, and control that setting by administrative measures or other means.
HEG-0679 was transmitted to the Operations department via GSAR-1084 for disposition. The disposition cited Technical Specification Surveillance Procedures, SR 5.4.7-A and SR 5.4.7-M as governing. SR 5.4.7-A i s entitled " Control Room Temperature Calibration" and is completed annually. SR 5.4.7-M is entitled " Control Room Temperature Functional Test" and is completed monthly.
While the temperature control can be adjusted, the Operations department has established the policy whereby control setting changes are coordinated to ensure an acceptable comfort zone.
I Page 25 of 113
v iL Attachment to-P-87357 L
HED-0722 !
SAIC COMMENT 1
.HED-0722. (Cate' gory 3) - The discrepancy is that.there is no He Circ ' Auxiliaries . Trip- alarm at .. panel . I-02_ .(Circ Isolating). -The alarms are- located on panel I-05 instead (see HED-0406). ;Similar to the proposed disposition:for HED-0406, PSC maintained that the'present arrangement'is a result of ,the original ' arrangement philosophies' and 'this arrangement offers- cer.tain operating benefits and is'not- ,
. subject to change as a; Therefore, no
~
redesign effort'.
further ' action was deemed necessary. To allow a more thorough and confident evaluation, PSC should explain .in more
- detail, the '. original arrangement.. philosophies' and 'the ,
'certain ~ operating benefits' afforded by' the existing 1
' arrangement."
PSC RESPONSE HE0-0722 was initiated as a result of the following survey question:
l
" List any system or subsystems you operate in which
~
a particular control or display is too far away from others you have to use with it, or is on another panel."
This problem description should not be construed to mean that j
'the absence of this alarm causes a system operating problem; '
but may be interpreted to be one of proximity for acknowledgement purposes.
The assessment sheet for HED-0722 was marked to show.a low-probability of error, with " additional steps required" as a result of any error.
The particular alarm cited by HED-0722 (Circulator Auxiliaries Trip Alarm) is one of a "first-in" group on I-05.
" Fi rst-i n" alarms are after-the-fact and historical in nature. (A record of what tripped the circulator as opposed to alarming a condition capable of causing a trip). From a
" task" perspective, this status is more appropriately associated with assessing heat transfer status as opposed to circulator operation.
Page 26 of 113
((
bi 4' . Attachment'to H 1
L <
P-87357
.:i" l
I-02 and I-05 Control Boards'are' orientated at a right angle !
(90 ).-and are approximately ten (10) feet- apart at J
centerlines.
Control Board- I-02 is.a vertical bench board measuring 82" >
i
- long and is comprised of the controls and indications for the
< following subsystems _(or. auxiliaries):
- those' common to all circulators
- those associated with a loop (two (2) circulators)
- those associated with a single circulator These auxiliaries include the Bearing Water, Buffer. Helium, Bearing Water Return and Steam / Water i
Return Heliumsystems..
/WaterReturj,
!s tarting"(orself-turbining)acirculator- j
' entails establishing the buffer helium supply and. return
~
flows, admitting b. earing water and establishing the required
. pressure differentials. This starting process res'ults .in a .l circulator 'self-turbining at approximately-two' hundred (200) ;
rpm. !
. i '
The alarm panels'above I-02 include alarms which direct the operator to those' conditions .which require corrective or follow-up . actions on the I-02 panel. Certain conditions associated with the I-02 controls which result in a ,
circulator trip also provide inputs to the first-in alarm (s) group (s) on I-05.
Control Board I-05 is ' a vertical bench board measuring ninety-three (93) inches long' and is comprised of the
-controls and indications for the primary and secondary heat transfer functions.
The basic elements are:
- circulator speed control'(Primary Coolant Flow)
- steam generator temperature and flow controls (Secondary Coolant)
The " task" to be performed at Control Board I-05 is to ,
establish the correct relationship between primary and secondary heat transfer. This is accomplished by the control of circulator speed and feedwater flow to effect a predetermined steam temperature.
The advantage in this particular division of controls is that circulator speed is controlled from I-05 where the effect of that parameter is manifest in the heat transfer process.
Page 27 of 113
Attachment to P-87357 The alarm panels above I-05 contain those alarms necessary to direct the operator's attention to those conditions requiring corrective or follow-up activities on the I-05 panel. In addition, the "first-in" group for each circulator, previously discussed, is included.
These "first-in" trip indications may provide the operator with information useful in determining what resources are available for maintenance of core cooling, a task associated primarily with I-05. (It should be noted that "first-in" type alarms do not require specific corrective actions, but may aid in assessment and subsequent restoration actions.)
This "first-in" information, while displayed on I-05, is central to Main Control Board I-06A, feedwater and steam control; other functions related to heat transfer.
'PSC's alarm control philosophy states that while the audible i alarm may be silenced from any front control board, b acknowledgement must be from the control station with which j the alarm is associated. From a " task" perspective,_ this "first-in" information is more functionally associated with managing a set of resources (I-05 activities) than with operating the particular resource equipment (I-02).
1 I
Page 28 of 113
Attachment to i P-87357 {
l l
l Panel I-05 Design Improvement Package !
0 j HED-0101, HED-0102, HED-0110-2, HED-0136 and HED-0137 f SAIC COMMENT "HED-0101 (Category 1); HED-0102 (Category 1); HED-0110-2 (Category 1); HED-0136 (Category 1) HS-2217; HED-0137 j (Category 1) HS-2215 - The discrepancies described are that l lettering on switch plates are fading and should be reengraved. The resolution described cites relocation of HS-2215, HS-2217, and HS-2218 local to valve, and states that the switch is used to test valve stroke and requires local ;
surveillance. It is not clear from the description of the resolution whether the discrepancy concerning the fading of letters will be corrected."
PSC RESPONSE PSC chose to categorize all " Labeling" HEDs as Category 1 due to the relative simplicity in applying appropriate labels and the difficulty in evaluating the significance of labeling HEDs (See last paragraph of Section 4.5.2 and the fourth paragraph of Section 4.5.6 of PSC's CRDR Summary Report, transmitted by letter P-85142 dated April 30, 1985). The process utilizing this method did not provide for a retroactive recategorization of those HEDs following system analysis activities.
As a good practice, PSC does provide adequate labeling of system components outside the scope of the Control Room Improvement effort. In this case, the switch escutcheon engraving will be detailed and included in the Design Change j Package that accomplishes the switch relocation.
l 4
Page 29 of 113
\
Attachment to
-P-87357
" j HE0-0112 SAIC COMMENT f
"HED-0112 (Category 1) HS-22182,.HS-22183, HS-22184, HS-22185 ,
.The discrepancy described is that :there are too many .i instruments in one. place causing difficulty in. associating- !
instruments with related labels; the- instruments should be l labeled .better. . In. addition, indicating. lights on HS-22182 through HS-22185 do not follow convention; that;is, the red .
lights 'are' on the- left and green lights are on the right,-
opposite of convention.. The resolution = indicates that- HS-9105-l' will be relocated and relabeled. Although PSC mentions relocation from local to valves HV-2224, HV-2223, HV-2254',..and HV-2253, for'HS-22182.through.HS-22185,(the swi.tches are.used~to. test valve stroke and require local .
surveillance),lit does:not mention relabeling. Also, it is I
.not clear-from the description of the resolution whether 'the
. discrepancy' concerning red lights.,on the left and green
~
-lights on the right has been resolved by PSC."~ 1 PSC RESPONSE !
HS-22182, HS-22183, HS-22184, and HS-22185 will be' labeled in accordance with Design Directive DD-LAB-1.
The final arrangement of the indicating lights associated with.the relocation of HS-22182 thru LHS-22185 will be in )
accordance- with plant convention (and DD-ILS-1). . This convention places the " Green" light on the left and the'" Red" light on the right. !
.i I
Page 30 of 113
- _ _ _ _ = = _ .
- m. p 1
Attachment to l P-87357 t
y
/
HED-0116 SAIC COMMENT "HED-0116 (Category- 1) - One of the discrepancies described 'g 4 is that'_there are no function tags for MI-9306 and MI-9307 among other instruments. The resolution described for MI-
-9306/9307 is that these instruments are subject to relocation. PSC does not indicate whether function tags will be provided for these indicators."' ;
PSC RESPONSE, !
CN-1871 (a non-CRDR change notice) proposed changes to the- l
' analytical moisture. measurement system, the deletion. of certain components and the relocation of others. This CN has !
been cancelled.
1 The functional and operational aspect of those components !
cited by the above referenced Human Engineering Discrepancies (HEDs) have been reevaluated as a centrol room improvement activity. Thi s reevaluation considered the design basis i established for CN-1871 and the problems cited.
The present configuration (see Figure 4, Page 32) includes i local indicating transmitters ( MIT-9306/ 07) , analog indicators (MI-9306/07) on control board I-05, data logger inputs (points 446 & 447), an alarm on I-058, and a recorder channel which may be used to record either MIT-9306 or MIT-9307 (selected via HS-9306).
The revised configuration (see Figure 5, Page 33) will eliminate the selector switch (HS-9306) and the recorder l channel (MR-9306/07). The control board indicators MI-9306/07 will be changed to digital indicators and relocated to a " primary coolant" grouping on I-03 Control Board. The alarm MAH-9306 (along with three (3) primary coolant moisture 4 equipment alarms) will be relocated to I-03A.
The new indicators MI-9306/07 will be selected, grouped and labeled in accordance with the applicable Design Directive.
(Function tags will be provided for these indicators.)
HED-0116 has been redispositioned to reflect the above described design intent.
l Page 31 of 113 ;
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HED-0485'
.-SAIC COMMEN_T "HED-0485:(Category. 2). 'The discrepancy described is the.t glare is'a problem- on the indicators listed ;in. the. HED
-evaluation-form; PSC states thatuthe' operator is required to shi f t- or . real.ign_ positions to avoid ' glare when reading' ,
different ? scale . values. Th'e . resolution described :is that V glare will be'mi.nimized by the-installation of 'an indirect
~
lighting system. . Although'PSC is taking: corrective action, it should: describe the -indirect ;1ighting isystem~ to- be-installed and how it will minimize' glare and affect.contro1~
~
room lighting levels."
PSC RESPONSE' :
' Attachment 6b-10,. " Summary of the Control Room Improvemer,t -
Design Process as Applicable to .. control ' . room : Lighting" transmitted :by letter P-85454 -dated December 3, 1985, i provides more-information on the nature of the indirect-lighting . system, glare reduction, and lighting levels. This submittal was' reviewed. andi found acceptable . (see 'SAI .
Technical Evaluation dated January 24, 1986, and' transmitted by letter-Heitner to Walker, dated June 13,1986)'.
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Page 34 of 113
f 'W Attachment'to.
j;c., m P-87357: 1-
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~SAIC' COMMENT-
^
HED-048)
'"HED-0487 -(Category: -1); - The discrepancy described is that' switch position-changes:were.made after the survey by-control 4:
room: personnel-that:do not follow the established c'onvention.
The resolution described appears to be .that. the discrepant
--switches' will be functionally grouped and. relabeled. PSC's Explanation,of..the resolution of the discre'pancy: concerning the1 switch ; position changes. by functional. grouping -and relabeling;does not seem to address the ~ discrepancy. PSC- J
.should .-provide al' clearer Explanation of how functional.
l grouping and relabelieg corrects.this discrepancy." j
~
PSC RESPONSE f
4 HED-0487,..e'ntitled; " Switch Positions Labeled In-correctly" '!
cites:the factithat sevan (7) switches have- position labels :
that 'are incorrect. -The " Problem Descriptions" section of. !
$this HED provides information a's to -the~ source and- time; The disposition of this HED, period relative to these labels.
indicates that the switches will. be " relabeled. per. Design-
~
Directives ,DD-SWI-1 & DD-LAB-1". This " relabeling" will correct the discrepancyicited.
'PSC: has'. implemented an ongof_ng?-design control program to I ensure that the design baseline established as a result of. ;
, the' Control: Room . Design Review (CRDR) activities is
-maintained. See Section'4.4 of.the PSCs " Control Room Design Review Summary Report" transmitted by letter P-85142 dated ,
1 April 30, 1985.
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l Attachment to P-87357 L
HED-0495 SAIC COMMENT l "HED-0495 (Category 3) - The discrepancy described is that instrument failure is not apparent to the operators.
Although PSC cites in the disposition that there are other, more direct means of verifying valve function, it appears the instruments used by the operators in the_ core cooling task analysis (the source of the HED) were those for which failure was not apparent. PSC should clarify to the NRC which instruments the operators will use for those tasks and whether and how indicator failure can be detected by operators."
PSC RESPONSE HED-0495 (Category 3) was generated during the paper and pencil phase of Table Top Task Analysis activities (see Attachment C to the Fort St. Vrain Control Room Design Review (CRDR) Summary Report). The fact that this HED was generated during this activity, does not imply that "the instruments used by the operators in the core cooling task analysis were <
those for which failure was not apparent". The only accurate conclusion relative to the origination of this HED is -that ,
the listed valve position indicators were suspected of ;
indicating mid-scale upon failure.
As a basis for further discussion of this HED, the objectives ;
of Task Analysis efforts (as excerpted from PSC's CRDR Summary Report, Section 4.2.1) are being restated: ;
"The objective of the task analysis was to identify the instrumentation and control requirements of the control room crew for emergency operation and to ensure that required systems could be efficiently and reliably operated under the conditions of emergency operation by available personnel.
The presence or absence of i n s t ru..ient s and ;
equipment to support emergency operation was determined and the human engineering suitability of available instrumentation was determined.
The desired output of task ana'ysis as a CRDR activity is a list of controls and displays used by control room operators to accomplish all the required steps in an emergency procedure.
Page 36 of 113
Attachment to 4 P-87357
'This information is necessary to determine if all controls and- displays required for emergency operation- are, .in fact, present in the Control Room. Additionally, instrument and control locations are required for evaluating the operator's ability to perform the procedural steps in the sequential and time frame requirements." i The valve functions associated with those indicators cited by HED-0495'are as follows:
ZI-2105, 2111, 2106 & Analog positions of the cold ,
2112' reheat steam admission control '
valves to the circulator (A, B, C, & D) drives (Steam provides motive power ,
to turn circulators) !
ZI-2243 & 2244 Analog pos4. ion of the pressure control valves which control cold reheat steam pressure to loop circulators (bypass cold reheat to reheater modules)
ZI-2205 & 2206 Analog position of the flow valves
- which control feedwater flow to the six (6) steam generator modules in each loop ZI 2229 & 2230 Analog position of the pressure control valves which control main steam pressure (Bypasses main steam to main steam 3 desuperheaters)
PSC's task analysis efforts were directed toward emergency conditions which challenge Critical Safety Functions (CSF's)
(see Section 4.2 of PSC's CRDR Summary Report and Attachment A to this Summary Report). This task analysis effort was also conducted using a " function oriented" approach as opposed to a " diagnostic" approach. (See NUREG-0737, Supplement 1, Paragraph 7.la.) The argument thus presented is that of verifying a function as opposed to verifying an operable (or malfunctioning) component.
Page 37 of 113
q
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Attachment to- ']
P-87357- ;
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Based .upon the> " function oriented" approach,- PSC's-Information and Control Requirement's document lists . those -
tasks or .' steps ' required to maintain (or ' establish) plant I
- CSF's. The following are excerpts from the Information and
~ Controls : Requirements' list generated by the " Ensure Core-
- Cooling task analysis.
l
]
- Task / Step Information & Control InstrumendControl. l
" Requirement l
i Verify Helium? ' Helium Flow' Rate FI-1157-1 (Typical)
' Circulator : -Circulator Speed SI-2105/09-(Typical)-
Verify Secondary -Feedwater Flow FR-2205/6 Flow ,
4 i
Set Back'Pr' essure -Back Pressure Control PC-2229-1 (Typical) to EES (Econo- -Back Pressure: Indica- PR-22129 mizer/ Evaporator- .' ti o n
/Superheater)
' Verify Steam as -Steam Pressure at PI-2243-1,'PI-2244-1.-
Source of.Circu-' Circulator Turbine lator Power Inlet
. (Not a technically
- viable alternative under emergency con-ditions - no heat source available)
)
A review of the "Information & Control Requirements" document [
failed to' produce a single incidence of.ZIs (analog position .{
indicators) being required in the process of ensuring 1 i
adequate core cooling.
In summary, the presence (or absence) of essential functions are determined or verified by a dyramic performance measure,
- and not by valve position. Failure of any component within a particular system, under a " function oriented" approach, requires _using the next preferred resource.
Page 38 of 113 l
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f .Under' ia' '" diagnostic f app' roach"., , valve position < indication-4
?! -: ' failure"may be_ determined byfsimply making a minute control Jchange~ (via' the. flow or p'ressure ~ controller) and' checking. for an: indicated.. positions change while verifying ' a, parameter
' valve change.'
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Page 39 of 113 I LL
Attachment to P-87357 g SAIC COMMENT HED-0580, HED-0592, and HED-0614 "HED-0580 (Category 1) ME-9306, ME-9307; HED-0592 (Category
- 2) ME-9306, ME-9307; HED-0614 (Category 1) HS-9306 - The resolution described for the above components for these HEDs are that they are. subject to removal by a non-DCRDR change notice. PSC should state the final disposition for these HEDs."
PSC RESPONSE See PSC's response to HED-0116 on Page 31 of this document.
The alarms being relocated and functionally grouped will be located and labeled in accordance with the applicable Design Directives.
HED-0580, HED-0592, and HED-0614 have been redispositioned to reflect the above referenced design intent.
Page 40 of 113
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$ .HED-0642 e
SAIC COMMENT:
"HED-0642 ,(Category. 1) PAHL-2267, PAH'L-2268 - ~ The HED
- described consists 'of labeling . discrepancies for several compone'nts. ..The iesolution' described does not address the-above components."
'PSC RESPONSE.
PAHL-2267 ~ and ' PAHL-2268 will. be ' relabeled "H0T RHT.STM PRESSURE'HIGH-LOW"'per PSC's Design Directives 1 DD-APL-1l and-
.DD-AAS-l' and functionally grouped per DD-ASP and: DD-CBL-1..
by,CN-1880.
See. page.9 (window I-05B 3-2)-and page 10 (window I-05C 3-5)
'of Attachment C to Attachment 6b-12, transmitted by letter P-86088 dated March 18, 1986.
s v
Page 41 of 113
Attachment to P-87357 l-
[ HED-0653, HED-0654, HED-0655, HED-0657, lnd HED-0758 SAIC COMMENT "HED-0653 (Category 1) MR-9306; HED-0654 (Category 1) MR-9306/9307; HED-0655 (Category 1) MR-9306; HED-0657 (Category
- 1) MR-9306; HED-0758 (Category 3) MR-9306/07 -
The
^ resolutions described for the above components for these HEDs are that they are subject to removal by a non-DCRDR change notice. PSC should p.' ovide final solutions tc these HEDs."
PSC RESPONSE See PSC's response to HED-0116 on Page 31 of this document.
HED-0653, HED-0654, HED-0655, HED-0657, and HED-0758 have been redispositioned to reflect the above referenced design intent, i
Page 42 of 113 l
_ _ _ _ _ _ _ _ . _ _ _ _ _ J
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h HED-0691 x .
SAIC COMMENT
.1
' "HED-0691 (Category 12) The' discrepancies's described are. that
'(1) No lamp test method ' exists', :(2) ~ Lamp- replacement for-WestinghouseRminalites is-a problem --glass breakage - bases sticking,in holder,l(3) Lamp replacement:for turbine panel is
' difficult and bulbs:are interchangeable, and (4) PHC XFER &' i
-Reset Button lights difficult to change.'- PSC's resolution :
~ f o r. the :I-05~ components is, ' Bulb replacement: aids to be '
l addressed by CN-1900. Valve .and' breaker control circuit
-configuration provide a ; method byL which faulty _ bulbs are
~
routinely . detected and replaced. Discrete condition- .
. indicators are being repic~9d on 'all boards with legend i indicators which have a test feature.' . PSC should . provide-
~
- l additional information which explains- (a) how_ often i
'(routinely) operators are supposed to! check for <and replace afaulty bulbs; and- (b) how many' of the ' safety-related; indicating lights'will not have a means by which they.can be detected lfor malfunction."
PSC RESPONSE-
_ Bulb checks (and replacing- faulty bulbs) are routinely-performed once each work shift in accordancefwith procedures
~ SOAP-4 andLSOAP-5. ,
a All safety.Lrelated indicating -lights--required for'" safe shutdown cooling" will have a means1by which 'they' can be a
' verified for functioning.
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Page 43 of 113
Attachment to P-87357
) l
'HED-0699
.SAIC COMMENT "HED-0699 (Category 3) - The discrepancy described is that there is-insufficient control resolution for the control process and that it is possibly difficult to align loops and place the functions in auto. PSC has then provided its detailed description of the problem in its attachments.
PSC's disposition is that the discrepant components have been determined not to be a problem and that no corrective action is required. Although PSC has provided a detailed description of the discrepancy in the HED evaluation form and attached an Investigative Information Record, it did not
. provide its rationale for not taking corrective action."
PSC RESPONSE HED-0699 was initiated as a result of an operator response to the following question:
"Li st any controls that are difficult to adjust as precisely as they need to be adjusted."
This HED then initiated subsequent investigations which provided the following information:
The Control Resolution of FC-2205/FC-2206 is adequate for the control process. Perturbations occurring during the transition from manual control to automatic are caused from the system not being balanced close enough prior to the transition or due to a system fluctuation during the transition. This is a matter of technique and not one of instrument resolution.
The function of PC-2229/PC-2230 is to maintain main steam pressure during steady state operation. The control resolution of PC-2229/PC-2230 is adequate for this purpose.
During start up operations, the main steam line is bypassed to the Preflash Tank until the boil-out transition is accomplished. This bypass operation is normally controlled by PC-22129-1 and PC-22130-1. The control resolution of PC-22129-1/PC-22130-1 is adequate for the control process.
On occasion during start up, PC-2229 and PC-2230 may be used to bypass the main steam line to the Decuperheaters. This may occur only during those times when maintenance activities are being performed on the Page 44 of 113
?t Attachment to
,n '
, P-87357-
-flowf pathT to the . Preflash Tank; While this mode of
- '" c operation is..not . preferred, .ith canObe utilized :with-plant management approval.
t The . reason Efor the-Insufficient control resolution: ~ noted' in' 'the. THED 'is ~
because of the: abnormal operational mode discussed above 1 and the difficulty iricontrolling'the;back-pressure due to the; system configuration. .i
'l The: control" : resolution of' PC-22129-1/PC-22130-1 is- ,
adequate forithe control;; process. .The problem ~-is a
~
1
-result of valvei= leakage Lwhich makes it-difficult to l control back1 pressure in the system. Valve; maintenance 1 is accomplished as required during' plant' shutdowns. .
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HED-0749 SAIC COMMENT "HED-0749 (Category 3) - The discrepancy described is that
'the controls are difficult to operate as precisely as needed.
PSC states that indications are that the problem may be with i the valves and valve sizing. Also, controller range may be over 0-50k vs. 0-90k. PSC states that no action is required, ;
the control range is acceptable, and see the response by E.
Mayer. No such response was found attached to the HED forms.
PSC needs to provide its rationale for the controller range to be acceptable." !
PSC RESPONSE HED-0749 (Category 3) was initiated as a result of the following survey question:
"Li st any controls that are difficult to adjust as precisely as they need to be adjusted." :
One licensed operator cited FC-22119 & FC-22120 in response to the above survey question. (This operator listed 30 days of Control Board experience at the time of the survey).
Flow Controller FC-22119 and FC-22120 are the means by which operators place the cold reheat steam attemperation system into operation. This operator action occurs during the rise-to power at the 50-55% level. This operation consists of manually increasing the flow to the point which-corresponds to the demand signal and placing the controller into the !
automatic control mode. The object is to complete this transition in a smooth and "bumpless" fashion to preclude ,
plant transients. Operation below the attemperation program !
line results- in a high Cold Reheat temperature and a corresponding decrease in reactor power. Operation above the attemperation program line results in a low Cold Reheat steam temperature and a corresponding increase in react;r power.
Page 46 of 113 2
gy .. _ ,- - - - - - - - -
- - = - - - - - - - -- ------
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P-87357-vv v,
'As; a 'resulti of1;HED-0749','a. system functional analysis was conducted which included 1the following:
- ' . An evaluation of system Flows and Valve Sizing.
~
- A review of applicableLoperating procedures.
- ~ a4 review of.the applicable. instrument Data Sheets
-and anLevaluation of thezcontrol range and;r~esolution.
- . Discussions ~withother. operators.
.. f
.The. evaluation essentially: states that the system flows and valve
- size are correct..'(0-60K.lbs/ hour' normal &:up to .90K lbs/ hour on i trip and turbine Runback). A review.of the control . instruments shows thatlthe range,. span ~and resolution are correct.. ,
- Operating' procedure'-S0P-93-02 formerly provided (at the' time-of the.
survey) a single step.with: regard'to placing the' attemperation- flow l control into' operation'. The' subsequent current issue provides'a more.
detailed set of instruction ~as follows:
, > 3.1.2.2.1" Loop.Feedwater flow must be' sufficient for the reheat
-attemperation program, Appendix III, to enable (JSL-22237. reset) spray control to be placed in
. auto.' Normally at approximately150 to 55% rower.
3 3.1.1.1.1 Prepare the reheat attemperation per lineup of 50P 22-01.
3.1.2.2.3 Manually adjust FC-22119 (FC-22120). until :the deviation meter is nulled.
13.1.2.2.4 Place FC-22119 (FC-22120) transfer' switches from
" MANUAL" to "AUT0".
The operator action required by step 3.1.2.2.3 requires -small
-incremental changes in control action to reach the null point. All operators interviewed indicated that the controls do have adequate resolution and that this task requires careful attention to ensure that' the null is reached before the controller is placed in automatic. A major dav'ation does have the potential for cycling reactor power and if such cycling exceeds the protective trip points, a scram.is initiated. The Operators also indicate that the potential for inducing transients serves to be intimidating, but that actually o performing the steps overcomes this concern. The Training Department alsoE indicated that presentation methods have been altered to a more effective approach.
Page 47 of 113
._E___.__._____.___..
- ,g s , -
,..I Attachm'ent to P-87357: ,
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' In summary, the attemperation f' low control system is correctly sized,
-i
- the control components 'have the correct . operating range - and.
!acce'ptable resolution, . The applicable procedure and the associated
~
u training <have-been altered to' reflect 'a. more--precise method.of-initiating attemperatio'n flow. The probability of an operator making
, 'a gross error and tripping the plant is.no greater than for.any-.other primary or secondary flow' control' task. Plant protectiye measures-
.areJa, compromised and remain as the: ultimate safeguard.
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Page 48 of 113 i.
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. Panel I-06A Design Improvement Package HED-0485-e O SAIC COMMENT-
"HED-0485 - (Category: 2) - The discrepancy is that because of'
' glare (indirect)<at various scales, the operator is' required to shift. reading: positions- . PSC proposed to minimize =the glare' by._ the installation of, indirect lighting system per CN-1898,- 'More information should be provided on the nature of:
- the~ indirect- lighting' system a s' well as how it would-
~e liminate. glare and affect control room lighting:les 1s."-
'PSC RESPONSE
,, Attachment. 6b-10,' " Summary of.the Control Room Improvement
-Design Process a s' Applicable 'to control. room Lighting" transmitted ~by letter P-85454; dated December 3,._ 1985, provides more.information~ on the1 nature of the ' indirect lighting' system, glare reduction, and lighting levels. This o' submittal was . reviewed and-'found acceptable SAI (see .,
Technical. Evaluation dated January. 24, 1986, and transmitted- :)
'by letter Heitner to Walker, dated June 13,1986). !
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'Page 49 of 113 m-_-u__ __Elu __ _ _ 1___ h
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1 HED-0585 l
L SAIC COMMENT "HED-0585 (Category '2):- The discrepancy is that a compound
. vertical Ledge -indicator shows' increase in both upward and y)
. downward directions from zero. PSC indicated that 'this HED is issued only as a means of tracking the Control. Room Survey questionnaire on indicators and will not require any action'. ,
As a; result, apart from relocating the instrument to panel I- i 06B, no-other action was deemed necessary. To enable a more. j thorough- evaluation o f.. this HED and PSC's resolution,.
additional. information is required. PSC should explicate, with the help of a picture or diagram if possible, the nature and ; function of ~the; existing compound vertical' display.
Moreover, it is' unclear as to why the scalet.is deemed acceptable. Since.it is generally recommended that vertical 1 scales should increase upward (e.g., NUREG-0700, Sect' ion 1 6.5.2.1.b) and. in view of the fact that this involves a -i Category -2 HED, a more precise and thorough justification' for 3 no action should be provided." ;
t PSC RESPONSE i
'HED-0585- was initiated- as a result of a "No" answer to the i following survey question:
"Do all vertical edge type. indicators show i
Increase' with the upward motion of. the meter !
pointer?"
Survey.' personnel were required to record a "Yes" or-"No" answer to the above question. l From a numeric perspective, pressure indicator PI-5120 does not comply with the above survey question (see Figure 6, Page 51). From a' parameter perspective, it does comply in_that a pressure increase is shown from bottom to top (a sub-atmospheric pressure of 30" Hg to 100 psig above ;
atmospheric). ]
PI-5120 is an indication of Hydrogen pressure for Turbine Generator Stator Cooling. Further investigation has shown that the Fort St..Vrain Turbine Stator Cooling operates above atmospheric and that the lower portion of PI-5120 is neither ,
used or required. Therefore, PI-5120 will be rescaled for 0-100 psig.
Page 50 of 113
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Attachment to P-87357 COPY OF PI-5120
-(Cited by HED-0585)
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Attachment to-P-87357 HED-0665 i
SAIC COMMENT, l "HED-0665- (Category' 1) - The discrepancy is.that functional
-legends on two condensate pump discharge switches- do not reflect . circuit operations. PSC indicated, with the~ aid of two accompanying diagrams, that the multirow display controls 1 will. :be' relabeled according to ;DD-LAB-1 and DD-SWI-1. :
Specifically, ' EMERGENCY'- 'and ' NORMAL' will be- relabeled
'EMERG HDR' and ' NORM HDR' respectively. 'DISCH' will be renamed 'EMERG' and ' BYPASS' renamed ' NORM'. The i illustrations show that the upper and lower labels of the redesigned multirow display were swapped. This may introduce a new HED wherein the labels of the multirow display fall to ,
correspond to the switch positions. Findings based'on human ~
engineering _research- (such as NUREG-0700) suggest that the ;
r label indicating 'EMERG HDR' should be placed on top of that showing' ' NORM HDR'. to match with'the control positions of
'EMERG' and-' NORM'. As recommended in Section 6.9.2.2.'c .of NUREG-0700, ' mul ti-row displays should be ordered left'to -
i' right and-top to bottom (in normal reading order), and matched to controls ordered left to right'. PSC's resolution for the present -HED does not appear' - to satisfy' these guidelines. PSC should correct the HED according to these recommendations or provide adequate -justification for the present- ' proposed disposition. It should also indicate whether any similar guidelines exist in plant stereotypes or conventions. If there are any discrepancies between plant conventions and NUREG-0700 guidelines, PSC should "rovide i justification for such deviations." i PSC RESPONSE l
The condition cited by HED-0665 is one of improper labeling.
The ' switch position corresponding to emergency header- !
operation is labeled as " discharge". The lower set.of lights 1 which corresponds to this " discharge" position are labeled
" normal". The switch position corresponding to normal header operation is labeled " Bypass". The upper set of lights which corresponds to this " Bypass" position are labeled
" Emergency". The disposition of HED-0665 consists of relabeling both sets of lights and the switch escutcheon to reflect the function performed by each switch position.
There are no circuit changes or physical relocations associated with this disposition.
The redesigned multirow display for the two (2) condensate pump discharge valve switches was based on PSC's Design Di recti ve ,- DD-ILS-1. (See Figure 7, Page 54). This directive was previously supplied and reviewed. (See SAIC Page 52 of 113
Attachment to P-87357 b
] Technical Evaluation dated January 24, 1986 and transmitted by letter, K. Heitner to R. Walker dated June 13, 1986 l
determined that the twelve Design Directives either met or exceeded that given in NUREG-0700). Design Directive DD-ILS-1- incorporates certain elements of NUREG-0700, ERDA 76-45-2 and MIL-STD-14272D. The preparation of all Design Directives considered existing plant conventions and subscribed to predominate conventions where such practice possessed a low probability for misoperation. The potentially adverse effects of making extensive changes in order to comply with the suggestion contained in NUREG-0700, Section 6.9.2.2.c was also considered along with a high level principle which supports " consistency" in hardware arrangement. This
" consistency" consideration is based in the original placement of indicating lights and with switches in general.
A single function switch will have one set of lights located immediately above. 'A dual function switch will have the second set of lights mounted above the first set and a three function switch will have the third set of lights mounted immediately above the second set.
While the top-down, left-to-right principle is preferred for new designs, the benefits are perceived as minimal when compared to the potential for operator error and training impact resulting from a change of this magnitude.
Page 53 of 113
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P-873571
.HED-0691
-SAIC COMMENT .i "HED-0691'(Category:2) .The discrepancies cited are that (1) l no lamp Etest method ex i sts ,- (2) . lamp . replacement: for
.E Westinghouse minalites is difficult,.(3) lamp replacement for turbine panel. is difficult and bulbs are interchangeable, and
.(4) PHC XFER and reset buttons are difficult to. change. This HED involves.all panel boards. To resolve.~these problems, alternate lamp _ function- test methods will be provided.for panels I-01 and. 1-02 which include-. the installation of-testable- status- ~1ights where' bulb , malfunction is not
-otherwise determined. Bulb- replacement aids will be i
- r. addressed by 'CN-1900. Valve and breaker control circuit, configurations will provide a method by which. faulty bulbs .I are troutinely detected 'and. replaced. Discrete condition indicators will .be replaced on all boards with legend indicators which have a test feature. It appears that much effort will be undertaken to. correct these problems.-However, it is unclear whether these changes will cover all th'e safety.
related instruments associated with this HED and -how often 3 (routinely) the .lsmps' will be checked.using the testable features."
PSC RESPONSE See PSC's' comment to HED-0691 on Page.43 of this documen't.
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)
m111_ - ~-
gypf 4
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p Attachment to'-
L- : c/ P-87357, 1
4
'HED-0774 and HED-0844 1
SAIC COMMENT-
]
"HEDs-0774':and 0844' (Category : . 4 x and 3 -respectively) -
L nInstrument HS-3221 is involved in both of these HEDs. While 1 the ,other ~ accompanying . instruments.will be removed in both- i cases, HS-3221 will-be left on'the panel pending ' additional, l
investigation. . Although it. is. recognized that- the 1
< likelihood of. these two HEDs causing errors is~ low j
((Categories-3 a'nd 4), the eventual disposition of.HS-3221.may: ,
- have~ an effect on the final panel layout. Thus, the' NRC should be kept abreast of the results of future investigation-and resolution conce;nirg HS-3221."
PSC' RESPONSE-Further.' investigation has shown that HS-3221 can be used as
'an option for draining the Flash Tank to the Condenser. On a a turbine trip, :HS-3220.' control circuits are- electrically !
configured 'as' if this switch was in . Position 3, however the
. switch: will , physically; be in Position 1. Before the Main
.TurbineLTrip Signal: Relay is reset it 'may- be necessary to.
drain.!the Flash Tank by placing HS-3220 in Position 2. To accomplish the" circuit reconfiguration, the furbine Trip-Signal --Relay' is. overridden by a " Bypass Switch"L(HS-3221),
which permits' ' control 'by HS-3220 in Position 2. .While present 'and routine operational procedures do not uti.lize y this: option, the function should be maintained. HS-32fl will be. retained .on I-06A, functionally grouped with other R
" DRAINS" controls and_-labeled appropriately.
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3 K
Attachment to
.P-87357 y
HED-0795
?SAIC COMMENT .1
- "HED-0795 (Category 2) - The' discrepancy is'that the recorder !
- TR-5153 ' lacks; fast speed for . use during turbine rollup'. l
'The ' disposition proposed' includes functional demarcation and
- 1abeling which do not appear to affect the speed of' the recorder. On the other hand, Attachment A (' List of all I-06A'HEDs & Copies of I-06A HEDs'., page 14) of: Attachment 6b-14, indicates that TR-5153 will be. changed -out and functionally grouped. PSC should clarify whether the recorder gwill be replaced by one which would provide a fast speed"for use during turbine rollup. If only demarcation and 1 labeling ?are employed,- the disposition does not appear to correct the HED."
PSC RESPONSE HED-0795 was dispositioned incorrectly, Originally TR-5153 was going to be replaced as part of a
' change-out of the turbine supervisory equipment, however that work has. been cancelled, therefore, HED-0795 requires a reevaluation.
The discrepancy identified by HED-0795 is valid and the disposition is being revised to read as follows:
.TR-5153 will be replaced with a new' recorder, Molytec Model
'2702, which has a faster scan rate and the capability of i shifting into a fast mode.
In replacing the recorder, an appropriate scale will also be .
. provided to resolve the discrepancy identified in HED-0655.
.The Molytec Recorder also has the capability of bypassing unused points thereby correcting the discrepancy of HED-0659.
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y.-- .
B is p gN , f m .. .
Attachment to.
4" '
4 P-87357' u;.
Panel I-06B.
HED-0485 SAIC' COMMENT'
~"HED-0485-(Cate' gory 1)f- The._ discrepancy.is:that because of-
- glare (indirect) at- vario'us scales, the ' operator is ' required -
-to . shift reading positions. PSC proposed to' minimize glare
-by the installation of indirect lighting. system per CN-1898.
~
Although PSC is taking correcti'<e action, it: should describe:
-the indirect;1ighting system to be installed and how'it will: -
- minimize glare and affect' c'ontrol room lighting' level's."
' PSC R'ESPONSE-
- j. =See PSC's response to HED-0485 on Page 34 of this document.
Y
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_ _ _ _ _ _ _ _ _ _ __________-___-___.___-__a
Attachment to P-87357 HED-0486 SAIC COMMENT "HED-0486 (Category 2) - The discrepancy described is that due to decreased color discrimination under emergency lighting conditions, the operator is unable to define and recognize the details of the controls in the Control Room.
PSC proposed to provide an indirect lighting system and increase light level per CN-1898. PSC should provide more information as to what kind of indirect lighting system will be installed and how this system will improve color discrimination."
PSC RESPONSE b See PSC's response to HED-0485 on Page 34 of this document.
Lighting measurements and visual inspections taken on February 18, 1987 (subsequent to the implementation of CN-1898), showed emergency lighting levels to be in the twelve (12) to fourteen (14) footcandle range at all control stations within the primary operating area. This represents a three hundred percent (300%) improvement over the original levels and results in good color discrimination.
Page 59 of 113
i I
Attachment to P-87357 m
HED-0505 SAIC COMMENT "HED-0505 (Category 1) - The discrepancy cited is that there is no descriptive label at valve position indicating lights for 'Deaerator Function'. The planned disposition involves relocating the valve position lights to local' Aux. Boiler Control Panel per CN-1892. PSC should also indicate whether it will provide appropriate labeling in order to correct this HED sufficiently."
PSC RESPONSE See PSC's response to HED-0101, HED-0102, HED-0110-2, HED-0136, and HED-0137 on Page 29 of this document. 4 I
t i
I Page 60 of 113
Attachment to P-87357 HED-0691 SAIC COMMENT "HED-0691 (Category 2) The discrepancies cited are that'(1)'
no lamp test method exists, (2) lamp replacement for Westinghouse minalites is-difficult, (3) lamp replacement for turbine panel is difficult and bulbs are interchangeable, ond (4) PHC XFER and reset buttons are difficult to change. This HED involves all panel boards. To resolve these problems, alternate lamp function test methods will.be provided for panels I-01 and I-02 which include the installation of testable status lights were bulb malfunction is not otherwise determined. Bulb replacement aids will be addressed by CN- <
1900. Valve and breaker control circuit configurations will i provide a method by which faulty bulbs are routinely detected and replaced. Discrete condition indicators will be replaced i on all boards with legend indicators which have a . test feature. It appears that much effort will be undertaken to !
correct these problems. However, PSC should provide I additional information which explains (a) how often i (routinely) operators are supposed to check for and replace !
faulty bulbs and (b) how many of the safety related l indicating lights will not have a means by which they can be verified for functioning. PSC's disposition is unclear in ;
how the plant's system features compensate for or mitigate l the discrepancy cited." 1 PSC RESPONSE See PSC's response to HED-0691 on Page 43 of this document, i
I Page 61 of 113
1 Attachment to P-87357 H u
HED-0776 SAIC COMMENT j i
"HED-077'6- (Category 3) - The ' discrepancy described is as j follows: ! Flows to_four coolers is controlled _ with sMgle
~
1
. inlet - valve. Manual valves exist on outlet of coolers wnich can belused to restrict _ , flow,- however, back pressure _ on q coolers'. L is _ undesirable. Operator cited' unusual.Loperating i characteristic,_ actual' problem may' be system.' The !
resolution' cited is as follows: .' Generator is designed for removal of a._ heater without affecting performance. A high temperature -alarm- is available to alert operator of High H2 temperature, and individual. temperature from each H2 cooler is available on .I-15 for diagnostics. The controller is adequate for :the- intended purpose. No further . action required .per CN-1892.' PSC should- provide more specific information on the discrepancy and its rationale- for not correcting the controller."
PSC RESPONSE HED-0776 and HED-0778 were initiated as a result =of an operator response to the following survey question:
" List any control or displays that work together in unusual' ways." o Comments entered on the HED form were a result of some preliminary investigative efforts and- were based on .the .
assumption that' problems were experienced when using correct operating methods. An indepth investigation of the- i equipment, procedures, and operating methods reflect certain j differences and interpretations as to system requirements.
The turbine installed at Fort St. Vrain has both a hydrogen and a water cooling system for Stator cooling. Control requirements for turbines having only a hydrogen cooling system are somewhat more restrictive. Operations personnel ,
have indicated that there are some differences in !
interpreting operating requirements as applicable to the Fort St. Vrain installation.
The manufacturer of this Fort St. Vrain turbine specifies the design hydrogen temperature. Water (to the hydrogen cooler) ,
is used to maintain the required hydrogen temperature. The '
manufacturer recommends one of the following two methods of controlling this hydrogen temperature:
- 1. Using a temperature element placed at the outlet of each of four (4) coolers. These four (4) temperatures may be Page 62 of 113
y
"^ Jo s AttachmentLto P-87357~
averaged 'and the' hydrogen temperaturesicontrolled'by' 73 this average temperature.
- 2. Using, a temperature' element placed in a common cold gas :
. region-near.the center of the generator. If. such an
. element is ~used for control, a' correction must be made because gas in this region has passed through the. fan-
.and~ experienced a temperature rise.
Fort St. Vrain. uses -the second method to control service water through the hydrogen coolers. :A common gas temperature is- sensed, by~ TE-4253 which is the " measurement" signal-for
- TIC-4253. Contrary- to the implication of HED-0778, TR-92105 !
is .not required has feedback for TIC-4253. TIC-4253 controls j
.TCV-4253 which /is the control valve for . service water in the !
main header that supplies the four hydrogen coolers. -The' !
amount of. service' water. flowing through 7 the ' individual- ~i hydrogen coolers is' controlled by manual ' valves at each
-cooler. TR-92105'is used as the feedback for adjusting these manual valves.-iThese manual valves are located near the
. turbine and. remote:to the Control Room.
LThe hydrogen temperature at .the outlet of the coolers is
' recorded on TR-92105 and alarmed at I-9306. Note: There -
will be~approximately five (5) degrees difference between TR- l 192105 indications.and TIC-4253. l J
The system as designed is adequate for the intended purpose. !
While'this system may have been cited as: operating in an i unusual manner,_ it was. not cited as presenting an actual i
-problem. Training' personnel have indicated some changes in presentation methods which are intended to create a better ;
system of understanding. !
i Page 63 of 113
l Attachment to l P-87357 )
l i
HED-0777 SAIC COMMENT.
"HED-0777 (Category 1) - The discrepancy cited is that (1) switch HS-3127 is not clearly labeled according to the i function, and (2) switch positions are entitled ' EMERGENCY' ,
and ' NORMAL' instead of the source. The planned disposition involves rolocation of switches to local Aux. Boiler Control Panel per CN-1892. PSC should also indicate whether it will provide appropriate. labeling."
PSC RESPONSE See PSC's. response to HED-0101, HED-0102, HED-0110-2, HED- ,
0136, and HED-0137 on Page 29 of this document.
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Page 64 of 113 l
I
k' Attachment to P-87357 Panel I-15 Design Improvement Package HED-0485 SAIC COMMENT "HED-0485 (Category- 1) - The discrepancy is that because of glare (indirect) at various indicators, the operator is required to shift -reading positions. PSC proposed to minimize glare by the installation of indirect lighting system per CN-1898. Although PSC is taking corrective action,.it should describe the indirect lighting system to be installed and how it will minimize glare and affect control.
room lighting levels."
PSC RESPONSE See PSC's response to HED-0485 on Page 34 of this document.
?
Page 65 of 113
3- .
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- )y _ l \
gl 9
' Attachment to.
< .P-87357 o , -
9 I
HED-0486-i SAIC COMMENT "HED-0486 1(Category 2) ,The discrepancy described is that Jdue to decreased color ~: discrimination ~ 'under- emergencyf ,
lighting conditions, the, operator is unable to define and recognize.the' details of-the controls in the Control Room.
PSC._ proposed 'to provide an indirect lighting system and
' increase light' level per CN-1898. PSC 'should provide more information as to what kind'of indirect lighting-system will be- used' and how this -system. will improve color-Discrimination."
PSC RESPONSE See'P3C's response'to:HED-0485 on Page 34 of this document. :
' Lighting measurements and visual -inspections-'taken on February 18,'1987 (subsequent to the implementation -of CN-1898), showed ' emergency lighting levels to be in the-twelve' (12)1to - fourteen- (14) .footcandle range 'at- all control i stations ;within_the' primary operating area. This represents R
.a three hundred percent'(300%) improvement over the' original !
levels' and results in goodLcolor discrimination.
d Page 66 of 113
i l' Attachment to P-87357 HED-0626 SAIC COMMENT "HED-0626 (Category 1) -'The discrepancy is that for switch HS-7542, the instrument number and tag location do not conform to DD-SWI-1. The resolution described is that HS-7542 will be relocated to a local panel per CN-1893. PSC ;
should. indicate whether it will provide appropriate labeling in ordar to sufficiently correct this HED."
PSC RESPU'jSE t See PSC's response to HED-0101, HED-0201, HED-0110-2, HED- ,
0136, and HED-0137 on Page 29 of this document.
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r Page 67 of 113
Attachment to .. j P-87357 '
1 HED-0Q8 SAIC COMMENT "HED-0658 (Category 2) - The discrepancy indicates that the recorder _(TR-92105) has more than six points or channels being recorded. PSC states in its resolution that although ,
TR-92105 is used to monitor plant parameters from which plant '
adjustments are made, it. is not required on a continual basis. Citing frequency of use in this case is not accept.ble as a sole justification for taking no corrective i action. PSC should either resolve this HED or provide more ,
acceptable rationale for not taking corrective action." i PSC RESPONSE The disposition of HED-0658 should have indicated that trend !
type information (not exact values) is required on an infrequent basis. The more important function of this recorder is its alarming function. Temperatures which reach a pre-determined value, initiate an alarm which results in operator investigative and corrective actions.
The range of this existing recorder (0-100 C) and the separation between recorded points does provide for a resolution consistent with the use of this recorder. j Attachment 6b-7 transmitted under cover of letter P-85454, ,
dated December 3, 1985 was not explicit in stating that certain recorders, including TR-92105 were to be replaced with new recorders which by design or specification (see Attachment E to Attachment 6b-7) remedied certain problems inherent in the existing recorders. This new type recorder has the standard option of selecting and digitally displaying any single recorded point.
l Page 68 of 113 e___-______-_
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3 ,-
h ".
^
, Attach' ment to- ~
P-87357 -.
HED-0691.
d '
.SAIC COMMENT-
,. "HED-0691 (Category 2) -: The discrepancies cited are that:(1)-
<no 71 amp testi method' exists, (2) lamp replacement for.
- Westinghouse'minalites.is difficult, (3). lamp replacement for turbine, panel:is' difficult-and bulbs are. interchangeable, and-(4) PHC XFER and reset buttons are difficult lto change. This HED involves all panel boards. -To resolve these . problems, alternate lamp function test methods will:be,provided for panels I-01 'and: I-02 'which . incl ude the installation of 4
, testable- . status . lights where -bulb malfunction is 'not. ll ,.
otherwise determined. Bulb ~ replacement.. aids. ;will be, i addressed. by~ CN 1900. Valve and ' breaker control circuit configurations will' provide a-method by- which faulty bulbs are. routinely detected and replaced. 01screte' condition q indicators -wi.11_ be : replaced 'on all boards with legend' i Vindicators which have.a test feature. It appears that much effort will. be ' undertaken to correct these problems. !
However,_..it-.is. unclear.whether these changes will cover all ;j
.the safety-r' elated instruments and how often the . lamps will .l be checked.using the-testable features."
'PSC RESPONSE j See PSC's-response to HED-0691 on Page 43-of'this document. ;
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Page 69 of 113
7; B
Attachment.to P-87357 1
'].,
d H HED-0778 i i
- SAIC COMMENT
-l
' "HED-0778 1(Category 3) - The ' discrepancy ~ quoted is that . 'TR - I 92105 (which is on panel I-15) is the feedback required with .)
TIC-4253 located on I-06. .PSC maintained'that'a 'HIGH TEMP' alarm is ':available to alert : operator >of. high- cooler -
i
' temperature ~ r and that individual' temperature from,each cooler !
is:available-on TR-92105 (which will be relocated to I-09 per CN-1878)i;for diagnostic purposes. no !
.further' corrective. action is deemed as . necessary Other thanbythat, PSC. a However, .PSC 'does' not describe what feedback. will be
- i
- available~.for TIC-4253 and where it is' located relative to
~ TIC-4253.
'Moreover, -relocating TR-92105-from panel I-15 to :
1-09 appears to place the instrument farther away from I-06 l than before." l PSC RESPONSE See also .PSC's response to HED-0776 on Page 62 of this i
' document for a complete discussion of the Hydrogen Cooler
. System-. operation. 'After further investigation. of system ;
operation, it has been determined that 'HED-0778 is invalid and that TR-92105 is not the required feedback for TIC-4253. j l
.The _ temperatures monitored by. TR-92105 are the hydrogen 1 temperatures out,of the individual coolers which are j controlled by local manual valves.
I 1
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Attachment to i P-87357 I l
I HED-0791 l SAIC COMMENT "HE0-0791 (Category 2) - The discrepancy is that the listed switches on panel I-15 are not functionally grouped with j other turbine controls and indicators. PSC maintained that ;
' physical constraints on I-06A & B make relocating with other i turbine controls unfeasible'. Therefore, the switches will be left on panel I-15 and functionally grouped. PSC's justification for not grouping the switches with other turbine controls and indicators is unacceptable.
Justification for the resolution should be based on operational and bebavioral factors rather than on physical constraints alone. For instance, the proximity and grouping of related instruments should be contingent upon the degree of interdependence and frequency of interactive operational / behavioral requirements among the instruments.
PSC should provide information/ data on these variables and their possible effects on operator performance and errors."
PSC RESPONSE The disposition of HED-0791 did not delineate the evaluative process nor were the considerations applicable to the !
conclusion included.
Sound human engineering practice recognizes that space limitations are a reality and that analysis tools are employed to datermine which controls are essential and which are non-essential at a given location. This process includes consideration of operational and behavioral factors, j PSC has conducted a functional analysis of this system and the procedures using these switches. The following is a brief description of this system and PSC's basis for not locating these switches with other turbine controls.
The five (5) switches cited provide for opening and closing the turbine vent and drain valves.
The function of the turbine vent and drain valves is to convey the various turbine generator vapors to atmosphere and fluids to the condenser or waste drains during start up and shutdown. All five valves are operated at one time either open or closed. Open for start up, closed after initial loading, and open for shutdown.
l Any failure to follow the operating procedure steps applicable to the opening and closing of these valves has the same potential as the failure to follow other turbine start Page 71 of 113 1-l
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+
/
Attachment to l P-87357 t l
up instructions, namely thermal shock or as a minimum reduced efficiency. The basic differences between these' controls and other turbine controls' is that these switches control discrete functions (open or closed) and do not require monitoring or that incremental changes be made.
As is evident .in the above description, the frequency of operation is low and the time required to complete the task l 1s short. Given the fact.that relocating and functionally. t grouping all turbine controls together on I-06A is not an i option, the existing location of these five (5) switches is justified due to the infrequent use, and the discrete function nature of these controls, i
i
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a a:.e , - ;
s
, Attachment.to.
s.. :
P-87357:
t y
Panel,I-10'(I-9310) Control'Ceard Design _ Improvement Package S5ICCOMMENT "PSC stated 'that miniature meters installed in the NIM bins 1.
- of I-9310 are primarily used in surveillance and' maintenance.
Critical: parameters ' displayed. on the NIM bin . miniature indicators are also.shown on the main control boards for operator use.' _ Thus, no additional changes are planned for VJ those:HEDs citing meter scale problems on I-9310. PSC should-ensure that a3 safety-related. displays will be duplicated on-the main control boards. Moreover, such displays should be-functionally ; grouped with related controls and displays on:
the main control. boards." u
- 2. "PSC indicated.that 'all nuclear instrumentation channels are to be labeled with Roman numerals for consistency, in ,
accordance with industry convention' . This decision affects '
.the instruments quoted in HED-0597 (Category 1). However, this . resolution . appears to counter generally accepted
-recommendations such as those in NUREG-0700 ~(Section -
6.6'.3.4.e) which state' that the use of Roman numerals in labels should be avoided. PSC should provide justification indicating why RomanL .(and not Arabic) numerals are used in this case or relabel the applicable components using ~ Arabic numerals."
- 3. "PSC cited a number of HEDs for which the justification for no action is that they involve displays and controls 'which
~
are.not used by the operator. Presumably the instruments are .i used for surveillance (operating and recording of data) and maintenance - (repair and testing) only.
The HEDs involved are:
Category 1 HEDs -
319 320 321 322 361 362 363 l 364 Category 2 HEDs -
403 562 563 568 572 573 578 581 583 588 589 590 From the human factors / systems operation point of view, surveillance and maintenance are important functions which ensure'the safe and smooth operation of systems. Sound human factors engineering principles should be applied to cover those areas as well. Also, in light of the fact that this decision involves Category 1 and 2 HEDs, PSC should either take corrective action to resolve the HEDs or provide adequate and precise justifications for no action."
Page 73 of 113
{
L _ - - - -
.1 -Attachment to.
c o P-87357
~1 J
L 4', "HED-0384 'and 0385 (Both: Category 3) - The discrepancy'is that the instruments.involv'de are. located either too high~'or j
too ~ low. on :the panel. PSC indicated thatthose devices a required by' operator in ' emergency situations will be labeled-
' ]
or demarcated 'to. enhance . location'. Other than'that, no
.further action will be taken by PSC to correct the HEDs .due-to existing space constraints. . It is~ unclear ~how '. location' aids' such as~ labels and demarcation would' resolve -problems j due- to controis- and displays . located too high.or too low. 1 (e.g., reach-difficulty, accidental activation,- parallax, 4 poor readability). PSC should provide illustrations showing I the existing.as well as the proposed panel layout to enable a -i more thorough evaluation- and understanding of panel space l constraints,"
PSC RESPONSE
- 1. PSC has . identified the instruments and control: required, l determined the suitabi'lity of these- devices. and 'the. j suitability of the' physical location of these devices to !
support the maintenance of plant critical safety functions. j See Section 4.2 of PSC's Control. Room Design Review Summary i Report and.PSC's response'to HED-0588 on Page 92 of this document.
i' Response transmitted by'1etter P-86528, Warembourg to Berkow, dated August 19, 1986. Also, see PSC's comment for HED-0598, Page 22 within this document.
l
- 3. For an extensive discussion relative to these concerns see [ '
PSC's comment to HED-0588, Page 92 within this document.
' Surveillance and maintenance activities are conducted in ,
accordance with plant approved procedures. From a control J room ' design review point of view, these activities are non- !
operating activities and not includec' in the scope of the i CRDR except where such activities have the potential of effecting the mitigation of challenges to critical safety .
functions. 1 1
i
- 4. The statement included in the disposition of HED-0384 which
. indicated the addition of location aids is irrelevant to the vertical placement of these devices.
PSC provided illustrations of the existing and proposed panel layout as Attachments B2 and D2 (page 1 & 2) to Attachment 6b-20 transmitted by letter P-86407, Warembourg to Berkow, dated June 16, 1986. Attachment B2 shows the lower tier of j !
modules to be on an approximate centerline of twenty-eight Page 74 of 113
]
i
}
Attachment to '.
P-87357
.(28) inches above floor level. Attachment 02 shows this lower tier removed, with a portion of the individual components.being relocated within the second and third tiers.
One complete Bin is. being relocated to the left end of I- .;
9313. This' reorganization results in the lower- tier >
centerline being approximately thirty-nine-(39) inches above floor level. See PSC's response to HED-0384 and HED-0385 on Page 90 of this document for a discussion of non-compliance j with DD-CBL-1.
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1 Page 75 of 113 I
[ g Attachment to '
P-87357 l Panel I-7507X (HVAC) Design Improvement Package l
HED-0691 SAIC COMMENT ,
"HED-0691 (Category 2) - The discrepancies cited are that (1) i no lamp test method exists, (2) lamp replacement for 1 Westinghouse minalites is difficult, (3) lamp replacement for I turbine panel is difficult and bulbs are interchangeable, and !
(4) PHC XFER and reset buttons are difficult to change. This HED involves all panel boards. To resolve these problems, alternate lamp function test methods will be provided for !
panels I-01 and- I-02 which include the installation of !
testable status lights were bulb malfunction is not otherwise I determined. Bulb replacement aids will be addressed by CN- 1 1900. Valve and breaker control circuit configurations will {
provide a method by which faulty bulbs are routinely detected ]
and replaced. Discrete condition indicators will be replaced on all boards with legend indicators which have a test feature. In particular, a lamp test button will be installed on panel I-7507X. It appears that much effort will be undertaken to correct these problems. For panel I-7507X, if a_ll i indicating lights are testable, then PSC's resolution is acceptable. PSC should indicate whether this is the case.
Furthermore, PSC should indicate how often the lights will be tested."
PSC RESPONSE See PSC's response to HED-0691 on Page 43 of this document.
A lamp test pushbutton will be added to I-7507X for damper position indicator testing, since bulb integrity for these indications cannot be determined by other means.
Page 76 of 113
Attachment to P-87357 i
i Panel I-13 Design Improvement Package I HED-0257, HED-0270, HED-0275, HED-0276, HED-0277, HED-0341, and HED-0587 j 1
SAIC~ COMMENT "HED-0257 (Category 1), HED-0270 (Category 1), HED-0275 (Category 1), HED-0276 (Category 1), HED-0277 (Category 1),
HED-0341 (Category 2), and HED-0587 (Category 1; PIS-2324-1/2, PIS-2324-3/4, and PI-2523) - The discrepancies described are that the lettering on the- switch plates of the handswitches is too small, whereas it should be 5/32" tall; and there are no instrument / function tags for the I instruments. The planned disposition involves relocation of the equipment affected to the Rx building, as its function is not required in the Control Room. Apparently, no other l action is deemed necessary by PSC. However, it is strongly advisable that established human factors engineering guidelines be applied to all extant human-machine interface which support the safe and smooth operation of the plant. As a minimum, PSC should indicate whether it will provide I adequate labeling according to the guidelines set in its design directives."
PSC's RESPONSE See PSC's response to HED-0101, HED-0102, HED-0110-2, HED-0136, and HED-0137 on Page 29 of this document.
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Page 77 of 113 a-__ _ - _ _ - _ _ _ _ .
Attachment to P-87357 i l
t HED-0384 and HED-0385 4 SAIC COMMENT j "HED-0384 (Category not listed, probably 1 a's indicated in i the ' Design Improvement Package for I-14'; RR-73437, RIS-73437-1, RIS-73437-2, RIS-93252-12, RIS-93251-12, RIS-93252-
.7, RIS-93251-6, RIS-93251-5, RIS-93250-12, RIS-93251-9, RIS-93251-7, RIS-93250-4, RR-93537, RR-93538, RR-93539, and RR-93540) and HED-0385 (Category not listed, probably 1 as indicated in the ' Design Improvement Package for I-14'; (RIS-73437-2, RR-73437-2, RIS-93252-12, RIS-93251-12, RIS-93252-7, RIS-93151-6, RIS-93251-5, RIS-93250-12, RIS-93251-9, RIS-93251-7, and RIS-93250-4) -
The discrepancy is that the instruments are 'either too high or too low on panels ' The corrective action for the listed instruments is that they will be relocated to panel I-13 to be 'more closely' within height constraints as stipulated in DD-CBL-1. It is unclear how 'more closely' they will be located according to plant conventions. PSC should provide the height of these instruments for a more confident evaluation of-this HED.
Moreover, PSC should indicate whether the accuracy with which these instruments must be read at for normal or emergency operations is easily allowable by the height at which the instruments will be located (e.g., parallax effects do not prevent reading at the required accuracy)."
PSC's RESPONSE NOTE: RIS-73437-2 was incorrectly shown on the HED Continuation Sheet for HED-0385 as RR-73437-2. This device is listed correctly in the Survey Checklist.
Attachment A2 (Li st of all I-14 HEDs) to Attachment 6b-20 transmitted by letter P-86407 dated June 16, 1986 does in j fact show HED-0384 as Category 1 for the listed instruments. j Attachment B2 (Section of Elevation Drawing - I-14) to Attachment 6b-20 also transmitted by letter P-86407 shows the existing configuration. Attachment D-1 and D-2 (two pages) provided under the same transmittal show the proposed layouts.
The space envelope (proposed) for the RIS devices and RR-73437 is between thirty-four and one-half (34 1/2) inches and sixty-six (66) inches. This places the center of the meter scales at forty-one (41) inches. Recorders RR-93537 through 93540 are to be located between thirty-eight (38) inches and sixty-nine and one-half (69 1/2) inches. These locations provide optimum vertical placement within the available space.
Page 78 of 113 1
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! i I i l- -Attachment to P-87357 i
The proposed location of the listed instruments will allow !
reading to the required accuracy. ;
i For a discussion relative to the non-conformance nature of this vertical location see PSC's comment for HED-0384 and HED-0385, Page 90 of this document.
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t Page 79 of 113
< 'l.
. Attachment to I P-87357 1
HED-0656 l SAIC COMMENT "HED-0656 '(Category 2) -
The discrepancy is that recorder scaling and markings do not follow preferred. human factors i engineering principles. PSC indicated that the function of TR-2227 and TR-2255 will be replaced by ' Graphics Display on { l I-04'. It is unclear what kind of graphics display will be {
used. .If the display is safety-related (which is very likely 1 in this case), a Class 1E seismic- 4ualified instrument should )
be used in which would exclude any computer-driven displays. .l PSC should clarify the nature of the graphics display and ,
whether seismic qualification is needed." !
-PSC's RESPONSE The disposition of HED-0656 also indicates that TR-2227 and TR-2255 will be changed-out to a new style recorder, moved to I-09, relabeled, and rescaled in CN-1878. (See Attachment 6b-7, transmitted by. letter P-85454 dated December 3, 1985.)
TR-2227 and TR-2255 are not safety related and the new graphics display will not be safety related, which means that
" Class 1E Seismic qualified instruments" will not be i required. The following is a brief description of the graphics display:
CN-1887 will install a Cathode Ray Tube (CRT) monitor in the I-04' Control Board for the purpose of displaying Steam Generator and Core Graphics information at a location convenient to the controls used in performing boil out and heat transfer tasks.
Pushbutton switches located immediately below the Steam l Generator / Core Graphics CRT display monitor will allow the operator to select one (1) of five (5) screens. Four (4) of these screens display Steam Generator information as follows:
- 1. Main Steam temperature and rate-of-change for each I module, typical of all Steam Generator displays, except !
rate-of-change values are not displayed for Cold Reheat temperatures and Feedwater Flows.
- 2. Hot Reheat Steam temperatures and rate-of-change for each module.
- 3. Cold Reheat Steam temperatures for each module.
i Page 80 of 113
U l: v
Attachment:
to:-
w 'P-87357.
. , x
(
- 4. :Feedwater Flow for each module.
g ,
The . fifth,- the Core Graphics screen,'will. display 'a single composite ;
' situational display.. showing:. the ~ core. . configuration and, utilizing .
(color changes .to show temperature _ deviation between core.. regions.
' This display will.' graphically or numerically depict the.-following:
- 1. Core.-Region irelative~. temperatures' (graphically) -'and.'
' average region temperature.(numerically).
2.- Nine'(9)-most closed' orifices (graphically).
J3. . Circulator Inlet temperatures. numerically).
4.. Main and Hot Reheat Steam temperti.ures (numerically).
- 5. Average. Circulator Inlet Main ~ and Reheat Steam
.temperaturesby' loop (numerically).
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Page 81 of 113 1
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Attachment to P-87357 HED-0691 SAIC COMMENT "HED-0691'(Category 2) - The discrepancies cited are that (1)
.no lamp ' test method exists, (2) lamp replacement for
. Westinghouse minalites is difficult, (3) lamp replacement for turbine panel is difficult and bulbs are interchangeable, and (4) PHC XFER and reset buttons are difficult to change. This l HED involves all panel boards. To resolve these problems, alternate lamp function test methods will be provided for panels I-01 and I-02 -which include the installation of i testable status lights where bulb malfunction is not otherwise determined. Bulb replacement aids will be addressed by CN-1900. Valve and breaker control circuit configurations will provide a method by which faulty bulbs are routinely detected and replaced. Discrete condition indicators will be replaced on all boards with legend indicators which have a test feature. It appears that much 'k effort will be undertaken to correct these problems.
However, PSC should provide additional information which explains (a) how of ten (routinely) operators are supposed to !
check for 'and replace faulty bulbs, and (b) whether all the )
safety related indicating lights will have a means by which l they can be verified for functioning." ,
a PSC's RESPONSE I j
See PSc's response to HED-0691 on Page 43 of this document, j j
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l Page 82 of 113
1 p
h Attachment to l P-87357 i
i HED-0819
.SAIC COMMENT I "HED-0819 (Category 2) - The discrepancy described for the !
listed Pressure Relief Valves under this HED is that there is no indication available to the operators that these valves j have opened. PSC has proposed to investigate further the j possibility of entering the valve position into the data ;
logger or some. other recording device to resolve this problem. It is evident that PSC has a grasp of the problem as well as the general remedial approach. However, more complete and specific follow-on information concerning the final disposition and results should be provided before this HED and PSC's resolution could be confidently and <
conclusively evaluated." l PSC's RESPONSE A position indicating switch will be installed on each of the !
listed relief valves and will be set to actuate any time the !
valve is not closed. This switch will operate a holding i relay and a common alarm on I-13. The holding relay will i illuminate a legend light to identify the relief valve which !
opened and will require a manual resetting. 1his arrangement I provides an audible alarm and provides a means of idenitfying the relief valve which opened.
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Page 83 of 113
j- re-4 i , ,
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Attachment to P-87357-m '
l3 4
Panel'I-14DesignImprovementLPackage HED-0346, HED-0347, HED-0348; and HED-0350
.SAIC COMMENT. ,
"HED-0346'- (Category 1),. HED-0347 . (CategoryJ .1), HED-0348
.(Category 1), and HED-0350 (Category .1) -
The ; discrepancy.
. described .is' that the lettering on' the monitors is:too small, whereas it should be 7/16" tall.' The resolution' described is
>- that the monitors will be relabeled per. DD-LAB and relocated on I-14 to follow height guidelines 'more closely' pe r . . . DD-CB L-1. PSC should provide,more specific information on how. closely it Jwill follow PSC's DD-CBL-1, especially a since these- are l Category: 1 HEDs. Moreover, PSC should indicate whether the accuracy.with which .these. instruments must be read'at'for normal or emergency operations.is easily
- l. allowable'by the letter size as.well as the height at- which' the instruments ~will be located (e.g.,' parallax effects do not' prevent reading at the required accuracy)."
PSC's _ESPONSE. R The space envelope (proposed)-for RIS devices and RR-73437 is betwe_en 34 1/2" and 66". .This places the center'of the meter scalesat 41". Recorders RR-93537 through 93540 are to be
~
located between 38" and.69 1/2". These locations provide:
. optimum' vertical' placement within the available space..
The. proposed location of the listed instruments will allow 4 reading to the required accuracy.
For a discussion relative to the non-conforming nature of this location, see PSC's comment to HED-0384 and HED-0385',
Page 90 of this document.
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Page 84 of 113
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Attachment to P-87357 >
l HED-0349 i SAIC COMMENT "HED-0349 (Category 1) - The discrepancy is that functional instrument tags are missing for the listed instruments. The resolution proposed is to ' relabel other P.B. switches to show actua1' function per DD-LAB-1 on CN-1896'. Moreover, PSC has reevaluated this HED and found space constraints prohibiting labeling of actual instrument numbers on the panel for all the related instruments except HS-7325-1 which had been removed. PSC should clarify whether instrument numbers are required in any operating and supporting tasks (such as those in E0Ps) to ensure the safe and smooth operation of the plant, especially when a Category 1 HED is involved."
i PSC's RESPONSE The decision to utilize the available space for function l legend labels (as opposed to instrument numbers) was based on function analysis effort activities, j The eight (8) pushbutton switches listed (except HS-7325-1 which has been. removed) are functionally grouped (immediately under) the associated module which is labeled with a corresponding numeric identifier; e.g. RIS-6212. See i Attachment D2 to Attachment 6b-20 transmitted by letter P- l 86407, Warembourg to Berkow, dated June 16, 1986.
These seven (7) modules perform automatic actions on a high radiation trip. These actions alter the plant ' configuration by changing valve positions. Each module and the associated sensory equipment has the provision for performing an end-to-end test. A solenoid operated checksource (operated from the module) is mounted on the detector adjacent to a beam . port.
When actuated, the solenoid moves the checksource close to the detector and causes the module (RIS) to indicate a high radiation value and perform its trip function. The cited switches prevent the actual trip action from occurring.
A functional legend label provides for a more positive identification of this switch and explains its functional relationship with the module than that provided by an I instrument number, especially since the switch is functionally grouped with its associated module. The i functional label is consistent with the test procedure. These switches are not used in an operational perspective.
Page 85 of 113
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Attachment to P-87357-HED-0359 and HED-0360 SAIC COMMENT
'"HED-0359 _(Category-.4) and HED-0360 (Category 4) - The discrepancy described is that the illuminated pushbuttons and rotary switches do not meet.the ' location' spacing of ERDA '45-2'.l The propos'ed resolution is to provide' location aids )
for operator controls only. PSC should explain the nature of ERDA-76-45-2, its specifications concerning ' location spacing', and. how they compare with NUREG-0700 guidelines.
Moreover, PSC shouldl explicate the nature _of the spacing.
problem' and. the potential human errors involved- (e.g.,
accidental. activation and error of identification),- and .
~
i; indicate how. PSC's proposed resolution could mitigate such i
potential human errors."
PSC's RESPONSE i
Appendix' II of the Energy Research and_ Development Administration document, ERDA-76-45-2 contains the same basic information-(inspection shows the same material sources) as NUREG-0700. The value of using ERDA-76-45-2 is with the fact that it is more comprehensive in its coverage of switches, handles and_ operators, as well as graphically depicting recommended spacing between switches.
Excerpts from Appendix II of ERDA 76-45-2 were supplied to survey personnel along -with survey forms which contained specific "yes" or "no" type questions. Survey personnel were instructed to answer the yes - no questions and were not to attempt to svaluate applicability of a survey question, the adequacy (or inadequacy) of any particular device _ or the extent of operator interface with a particular device. Any-non-conforming item was to be listed on a HED form for later assessment and evaluation.
All devices cited by HED-0359 and HED-0360 are located on electronic equipment Racks I-9310 and I-9314 which are described in detail by PSCs response to HED-0588 on Page 92 of this document.
The non-conformities cited by HED-0359 and HED-0360 are: (1) pushbutton switches being 0.6 inch apart while the recommended minimum is 0.625, (2) Rotary Selector switches
~being .625 or .75 inch from other components while the recommended " sweep area" measurement is 0.9 inch (minor axis), (3) recessed pushbuttons which measure 0.6 inch on minimum dimension as opposed to the .75 inch recommended t minimum and (4) pushbuttons having a diameter of 0.469 inch compared to the recommended 0.5 inch diameter.
Page 86 of 113 i
o ap I
~ Attachment to. '
- P-87357 l l
The_ major portion _ ofi the' devices located on-I-9310 are not classif_1able as ; controls, where . controls are- defined- as devices; used by the operators in. controlling plant systems.
The; primary. use 'o f these indicators, switches, _ lights, potentiometers,. etc. .is .for calibration and testing the-cmodules and system components.
Through' task analysis, system functional analysis-and various investigative _ activities, PSC has identified those- switches,
- lights and indicators 1on I-9310 and I-9314 used by the operators'in assessing . plant status or controlling -plant systems. [See " Conceptual ' Design" (Page 4), of-Attachment 6b-18 transmitted by letter P-86366, dated May 16, 1986].
Problems cited relative to these required instruments and !
- controls ~ are being. addressed through relocations:(I-9314) and enhancement techniques on. both Racks. In. addition PSC has-identified certain modules- that provide diagnostic information 'for routine activities and has ~ designed enhancements for these indications. '(See Attachments C to l Attachment 6b-18).
Surveillance, calibration and maintenance activities are conducted in accordance with validated procedures by -trained and skilled personnel which mitigates the potential for human errors.
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4 Page 87 of 113 1
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Attachment to P-87357 HED-0364 SAIC COMMENT "HED-0364 (Category 1) - The discrepancy cited is that when the light is illuminated for the listed pushbutton switches, it indicates 'no failures'. The proposed decision is to relabel the illuminated pushbuttons to read 'ON' per DD-LAB-
- 1. Other than that, no further action will be taken by PSC to correct the HED as it involves controls which are not used by the operator. PSC should indicate whether a lamp test capability is ava',lable for these lights and how often will lamp tests be conducted. Also, in light of the fact that it is a Category 1 HED, PSC should ensure that there exists a proper procedure or mechanism to ascertain the cause of a
' light off' condition (e.g., bulb failure, system status changes) before appropriate action is taken. It is strongly advisable that sound human factors engineering practices be applied to operator-used as well as nonoperator-used instruments to support the safe and smooth operation of the plant."
PSC's RESPONSE HED-0364 was not explicit in defining the applicability of the cited problem. The two (2) disposition statements are equally vague in defining the applicability or non-applicability of corrective action.
As a result of corrective actions taken for other HEDs, all items cited by HED-0364 are subject to relabeling or other enhancements. First, there are fourteen items listed for Rack I-9310, six of these are radiation modules which will be alarmed in accordance with the philosophy presented by PSC's response to HED-0366 and HED-0393 on Page 5 of this document.
The green "No-Fail" light will be relabeled as "0N" for consistency with other (I-9314) radiation modules. There are eight (8) reset switches listed (listed on HED-0364 as CC-2B2, typically) that are operator used and will be provided with label / location aids. See Attachment C (Details B & C) to Attachment 6b-18 transmitted by letter P-86366, Warembourg to Berkow, dated May 16, 1986.
All other devices listed by HED-0364 for I-9314 will be provided with a special label as shown by Attachment F to Attachment 6b-20 transmitted by letter P-86407, Warembourg to Berkow, dated June 16, 1986.
A Lamp test provision is included on I-9314 for the modules listed. See Attachment D2 (page 1) to Attachment 6b-20 referenced above.
Page 88 of 113
i Attachment to P-87357 Bulb checks (and replacing faulty. bulbs) are routinely l performed once each work shift in accordance with procedures
. SOAP-4 and SOAP-5.
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Page 89 of 113
Attachment'to P-87357 l
HED-0384 and HED-0385 SAIC COMMENT "HED-0384 and 0385 (both Category 1) - The discrepancy cited is that the instruments involved are located either too high or too low on the panel. PSC indicated that RIS-93250-8 and RIS-93250-6 will be relocated ' higher' on panel- I-14.
Especially in light of the fact that these are Category 1 HEDs, PSC should indicate how closely the height of these instruments conforms to plant conventions. If it fails to comply fully, PSC should indicate whether the reading accuracy required of the displays / controls involved is adequately supported by the human-machine interface and viewing angle of these instruments."
j PSC's RESPONSE Note: RIS-93250-6 should be shown as RIS-93252-6 Attachments 82 and D2 of Attachment 6b-20 transmitted by-letter P-86407 (dated June 16, 1986) provides elevation drawings. for (rear) control board I-9314. Attachment 82 shows RIS-93250-8 and RIS-93252-6 presently located with the ,
horizontal centerlines at 28", which places the indicator centerline at 30". Attachment D2 shows RIS-93250-8 and RIS-93252-6 relocated to centerlines of 39", which places the indicator centerline at 4!" PSC's Design Directive DD-CBL-1 for display height specitits that displays be located in an area between 41 inches and 70 inches above the floor. The non-compliance exists with the fact that the meter scale is centered at 41 inches instead of being between 41 inches and
- 70 inches. The .469 inch diameter bright green "no-fail" light, also used by the operators is centered at approximately 40 inches. These locations are slightly below those specified by DD-CBL-1. This location is acceptable for the green "no-fail" light due to the fact that it is clearly l
i visible from any position in front of this Rack. While this l location improves the accessibility, visual angle and overall I readability of the indicator, it does not address the l problems of resolution and marking size addressed by other HEDs. Relative values may be easily determined from these indicators in the proposed locations, which is sufficient for
[ preliminary dispatch responses. Subsequent assessment l activities do require more precise values. As stated in the i
next paragraph, a selectable digital display will be provided for reading more precise values.
Due to the small size of the existing vertical scale indicators, the scale cannot be made to comply with DD-ILS-1.
! The space limitations imposed by the module structure prevent l
Page 90 of 113 L____-_.
' Attachment to P-87357 replacing the indicator within the module proper, .therefore, a selectable radiation indicator will be provided for operator use when exact value readings are required. [See Attachment D2 (Page 2 of 2) to Attachment 6b-20 transmitted by letter P-86407,_Warembourg to Berkow, dated June. 16, 1986.]
Also, see PSC's comment for HED-0384 and HED-0385, Page 73 included under the "I-9310 Control Board ..." section of this document.
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l Page 91 of 113
Attachment'to
, P-8/357-HED-0588 SAIC' COMMENT
'"HED-0588.'(Category. 2) - The. discrepancy described is that-all-BIN / MODULE indicators of panel I-10 and. I-14 have too small letter size for numerals, ' process, or engineering units' per guidelines of DD-LAB-1. PSC's disposition cites justification for no. action, as they are 'not operator used meters'.. (But PSC later indicated.that operators 'used .them.
for ' verification'.) .Moreover, due to. space constraints on panel I-14, the letter size on the labels cannot be changed; However, it is-only scales with errors will be changed.
.strongly advisable .that- sound human factors engineering practices be applied.to all extant human-machine interface to :
support the smooth and safe operation of the ~ plant. To afford a. better understanding of the potential problem and evaluation of the. justification.for no: action, PSC should explicate the nature of the original concern, how the concern was identified in the first place, and the kinds /results of-the investigations' performed. Moreover,. PSC should also.
illustrate.how limiting the space is'in prohibiting adequate corrective actions. PSC should consider the potential human ,
errors involved and alternate remedial measures which are j less space-demanding-(e.g., by enhancing the luminance contrast of the lettering)."-
PSC's RESPONSE Note: PSC's Control . Room Design Review Summary Report Section 4.5.6 and Attachments 6b-18 (I-10) and 6b-20 (I-14)
. provide .information relative to the content of the above comment. Attachment 6b-18 was transmitted by letter P-86366 ,
dated 05/16/86 and Attachment 6b-20 was transmitted by letter !
P-86407 dated 06/16/86.
HED-0588 like most other HEDs applicable to I-9310 and I-9314 originated out of Control Room surveys. Survey personnel were instructed to record a negative answer if any difficulty i was experienced in reading or interpreting a scale, or if the survey question could not be answered affirmatively. Survey personnel were not to attempt to evaluate applicability of a Survey question or the adequacy (or inadequacy) of any !
particular device.
Assessment activities grouped " Labeling" HEDs as Category 1 and meter " scaling" HEDs as Category 2 due to the relative ease of " fixing" and the difficulty in assessing any potential negative impact on plant operations. (See PSC's i
" Control Room Design Review Summary Report", Section 4.5.6).
This practice of correcting labeling and scaling Page 92 of 113
I Attachm:nt to i P-87357 discrepancies continues for all main control boards used by i L. Operators in the conduct of normal and emergency activities.
In order to understand the structure and arrangement of these Racks the following is provided.
I-9310 and I-9314 while located within the Control Room are in reality Instrument Racks. These Racks are located to the rear (or behind) the Control Boards. I-9310 consists of ,
twelve (12) bays (vertical separations), each housing six (6)
NIM bins. (See Attachment C to Attachment 6b-18). Each NIM bin nss provision for up to twelve (12) single width ;
electranic modules. This structure contains the signal i acqui,ltion; monitoring, processing and control circuitry of the Flant Protective System (PPS).
The face panel of a typical module has a 2" vertical scale indicator, a test / operate switch, two (2) or more test jacks j (up' to ten) and one (1) or more calibration potentiometers '
(up to six). Certain modules may also have two (2) vertical k scale indicators, test and trip lights, reset pushbuttons and fuse holders.
I i The major portion of the devices located on I-9310 are not classifiable as controls, where controls are defined as devices used by the operators in controlling plant systems.
The primary use of these indicators, switches, lights, potentiometers etc. is for calibration and testing the modules and system components.
Through task analysis, system functional analysis and various investigative activities, PSC has identified those switches, lights and indicators on I-9310 and I-9314 used by the t operators in assessing plant status or controlling plant systems. (See Page 4 of Attachment 6b-13 under the heading of " Conceptual Design".)
I-9314 consists of four (4) bays, each housing three tiers of NIM bins and one recorder. (See Attachment B2 of Attachment 6b-20.) Each bin houses either 4 cr 6 Radiation Modules.
The face panel of these radiation modules typicallly have a 2" vertical scale indicator, a trip light / reset switch, a no-fail light, nine (9) adjustment potentiometers and a test switch.
These indicators, lights, switches and adjustments are primarily for use in calibration and testing of these modules and related equipment. There are four items on these modules used by the operators following a high radiation or module failure alarm. (For more infon.cotion on alarm responses see PSC's response to HED-0366 and HED-0393, Page 5.)
Page 93 of 113
Y T
' Attachment to P-87357 The alarmL conditions and the corresponding operator actions
- are:
- 1. Module- failure. alarm - check for failed module (s)
- i (No-fail light extinguished).
- 2. High Radiation Alarm - Verify automatic actions, if applicable, (Main Control Board), determine which module tripped (trip light 1111uminated), determine relative. radiation level (vertical scale indicator) and reset module if applicable (Reset pushbutton).
Attachment D2 (page 2 of-2) to Attachment 6b-20 transmitted by_ letter P-86407, Warembourg to Berkow, dated June 16, 1986
-shows the~ addition of a selectable radiation indicator.
Attachment E2,' item 4 lists the addition of this selectable
-indicator as does the disposition for HED-0579 included as part of the above submittal. This addition will provide for the reading of' more exacting radiation values than are 4
obtainable from the 2" vertical scale indicators.
The addition of labels and demarcation mediums will provide
- aids to locating and identifying the indications ~and reset
- pushbuttons.
PSC does recognize that " sound human factors engineering
. practices" serve "to support the smooth and safe operation of the. plant". PSC a' Iso recognizes that human factors engineering, as an applied science does acknowledge the reality of constraints and that applying preferred human engineering practices "to all extant human-machine interface" is impossible within the scope of an upgrade. NUREG-0737, Supplement 1, Section 5.lc requires the licensee to: " assess which human engineering discrepancies are significant and should be corrected". PSC has through task analysis, functional analysis and other investigative activities identified those instruments and controls on I-9310 and I-9314 which are required for the maintenance of critical
. safety functions. Problems cited relative to these required instruments and controls are being addressed through relocations -(I-9314) and enhancement techniques on both Racks. In addition PSC has identified certain modules that provide diagnostic information for routine activities and has designed enhancements for these indications. (See Attachments C to Attachment 6b-18.) ;
1 Page 94 of 113
- -s.4-.L--e ~ + .- +. ._.m-- _a -- - - - - - - .----- --------------------------------o------------'-
- ---- W
-Attachment ~to
~P-87357 Controller Operating Convention's Design Improvement. Package HED-0636 SAIC COMMENT "HED-0636 (Category 2); - The discrepancy is that several controls.'do not conform to plant stereotypes _for directional selection'. PSC indicated that-for instruments TDIC-2227 to 6,_TDIC-2228-1 to 6, PC-2267, and PC-2268, the directional control labels will be: changed to 'incr-decr' . (increase-decrease),the . control direction ' standardized',' and .new dials installed by CN-1890. It is unclear which convention these instruments are designed to follow,.and apparently increasing to the left is counter to generally accepted human factors engineering guidelines (like NUREG-0700)."
PSC RESPONSE The manual- activated level switches on the above listed controllers are currently labeled to indicate the position of the valve they control, open to the left and close to the' right. The control is being relabeled to indicate the sense i of the parameter measurement.
TDIC-2227 through 6 and TDIC-2228 1 through- 6 will be relabeled such thatdecr' is on the-left and 'incr' .i s on the right, which is a generally accepted human . factor principle. By operating the controller in the increase direction the affected valve will close causing the AT to !
increase. Operating the. control in the decrease direction will cause the affected valve to open causing the AT to decrease.
PC-2267 and PC-2268 will also be relabeled such that 'decr'
~
is on the left and 'incr' is on the right. These controllers sense the pressure in the hot reheat steam line, which is upstream of the controlled valve. Therefore by taking the control to the 'incr' position the valve moves in the closed direction causing pressure to increase. When the controller is operated in the 'decr' direction the valve goes in the open direction causing the pressure to decrease, therefore, for the controllers in question the 'open' label will be replaced with 'decr' and the 'close' label will be replaced with 'incr'.
Page 95 of 113
__:____=-_______
q,
Attachment:
to-P-87357 HED-0701 SAIC COMMENT J
"HED-070'1 (Category 2) - The' discrepancy is that the ' control- j knob for'setpoint works backwards (increase to .right)' .
PSC, indicated that the discrepancy has been reevaluated, and no I action was needed because ' controller convention is dependent 1 on icontroller Ethat. is by passed and therefore, subject to j change'.- PSC further stated that ' Bypass Controllers 'are:
current. sources only and are not labeled o' r scaled for a particular control. application'. Current output. increase may represent .an increase of parameter in. some . cases and a
' decrease in others. As mentioned before, anEillustration of the setpoint dial will. be most helpful for a better, )"
evaluation of the HED. As this is a Category 2 HED, PSC' should. ensure- that the design.of the related displays and controls complies _with established human factors engineering.
principles. .
For- instance, the control directions of the setpoint dial'should be consistent with PSC's convention and other .similar dials in the Control. Room. Label's could be enhanced to identify'better the nature of the parameters and' direction being controlled."
'PSC RESPONSE To ' expand on the HED disposition, these controllers are Foxboro manual bypass controllers. Their function is to substitute a control signal-for an existing controller that must be taken out of service for maintenance. The . bypass
-controller has a retractable plug that is plugged into the mounting of the controller being bypassed, allowing the j output of the manual bypass controller to serve as the output
.for'the affected controller. See Figure 8, Page 98 for an illustration of a bypass controller.
These " bypass controllers" are essentially plug-in, manually controlled current sources.and are reserve type devices used in a short-term substitution mode during maintenance or replacement activities. These controllers 'may be used to bypass any controller equipped with the receptable. Some of which are current increase to' increase the parameter and some of which are current increase to decrease the parameter. The .
very nature'of this " bypass" function requires the latitude I to. bypass any controller (so equipped).
One characteristic of the bypass controller which differs from other controllers is that the manual adjustment is accomplished 'by rotating a knob clockwise (increase current output) or counterclockwise (decrease current output). This is accomplished on other controllers by moving the Page 96 of 113
1 I
1 Attachment to P-87357-manual / auto switch left or 'right. HED-0701 characterized' this control knob as a' setpoint. dial solely on physical
-configuration' without the benefit of a-functional analysis.
A deviation meter on the Bypass Unit shows1the difference between the output of the controller and the output of- the-signal generator _ within the Bypass . Unit. The operator-adjusts'the control knob either right: or left to null (center) .the deviation indicator. ;(Note: Clockwise on the knob results in the output and . deviation . indicators moving right). With the deviation-indicator: centered on.the. Bypass Unit the'two position transfer switch;is-placed in the " CONT"
.(controller); position. By this' simple transfer procedure,-a:
bumpless1 transfer either way is assured. Subsequent. changes e to the control setting is made by- small incremental
-adjustments: to the control knob while' observing more direct indications of the parameter value.
There .are no displays or controls'specifically associated with any one. bypass controller.
,An . evaluation 'of marking options for the control knob on
! :these bypass ' controllers shows that labeling this knob
'" increase to the right" then creates discrepancies between c'urrent ' increase and- parameter increase or decrease, depending on.the controller (and system configuration) being-bypassed. Marking of this component may introduce operating
. problems where ' problems do _not currently exist. Those operators interviewed, demonstrated an' understanding of the bypass controller function and indicated that the training.
received was sufficient and that they had experienced no operational problems.
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Page 97 of 113
Attachment to P-87357 1
I BYPASS CONTROLLER Deviation Indicator 1
l Manual Current Source Adjustment Current increases clockwise - Parameter -
being controlled may increase or decrease r .. Bypass Control f Output Current Source Selector (ResidentControlleD-or Bypass Station)
FIGliE 8 Page 98 of 113
[= j L Attachment to j P-87357 l-HED-0704 SAIC RESPONSE "HED-0704 (Category 2) - The discrepancy is that all delta pressure controllers work opposite to other controllers. The resolution described is that controllers PDC-2548 through PDC-2555 will be placed on the remote panel of I-48. and operated from ' panel I-9310 local setpoint'. The other discrepant controllers are to be labeled with parameter control positions (such as 'INCR', 'DECR') and circuit changes will enable the parameter to be increased by pressing the drive to the right. In its response to NRC's first TER !
(response dated 8/19/1986), PSC further explained that the operations involving PDC-2548 through PDC-2555 are the primary responsibility of nonoperating personnel. These instruments were relocated outside the Control Room and are now ' considered as blind controllers (setpoint selector placed- in remote), with the primary setpoint controls on I-10'. PSC stated that:
'As non-operable controls, these controllers are not subject to the controller convention established for the Control Room. This setpoint ,
control, while not an operator control, was designed and labeled to conform to the applicable Design Directives.'
Thus, it appears that PSC has designed and labeled PDC-2548 l through PDC-2555 to conform to the applicable Design Directivos even though these controllers are not used by the Control Room operators. Otherwise, it is strongly advisable ,
that sound human factors engineering principles be applied to i the design of ' operable' as well as 'non-operable' controls l whenever human-machine interface is required to support the '
safe and smooth operation of the nuclear generating plant."
PSC RESPONSE Resolution of the HED conformed to the applicable Design Directives.
Page 99 of 113
.____-_____-_______-__-_-_____--____m
p . , .
1 Attachment to T <
P-87357~
HE0-0738 SAIC' RESPONSE-
"HED-0738-(Category 2) - Part A of the problem-descriptions
. indicated .that 'five (5)- controllers have setpont dial directions not-. conforming to' PSC's. convention. PSC's resolution involves. changing the, controller labels and circuitry to ' enable increasing the' parameter by pressing-the drive'to .the ~right'.. .Again,' it is . unclear. with which convention -these instruments will be designed to comply as-setpoint dial and controller are referred to- simultaneously; PSC .should clarify this concern using illustrations."
PSC RESPONSE Attachment.6b-23 transmitted by letter P-86434, Warembourg to Berkow,' dated July -15, 1986 defined the controller conventions adopted for use in the' Fort St. Nrain Control
' Room. See Figure 9, Page 101~ for an illustration. of a typical controller.
HED-0738 did not address the concerns .of set point dial convention and will be redispositioned appropriately.
The five' controllers in question actually had two problems concerning convention. Fi rst , the manual adjustment was labeled such that it indicated the _value position being controlled instead of the parameter. The manual adjustment will be relabeled to indicate the sense of the parameter, (in this case differential pressure, increasing to the right and decreasing to the left). The second problem is t!.at the-set point dial does not conform to the defined convention. The ,
set- point dial circuitry will be revised such that the I numerical value of the set point increases as the dial is rotated counter clockwise and dial itself will be renumbered 4 to indicate this, j i
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Page 100 of 113 l
_ _ _ _ - _ _ _ _ _ _ _ _ _ . _ . _ . _ A
Attachment to P-87357 CONTROLLER CONVENTION 7
Deviation Indicator (Shows Deviation \
between Parameter N Measurement and Set-pointValue)
Z1--T_w.
[
Note: Correlation a!!!!'l1111lilllIllll 1 between indicator scale and setpoint dial scale.
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^' :1 1 Setpoint Dial / g (Numerical value G.
of setpoint in-creases as dial is
' [ Output Indicator (Controller output rotated counter #
increases to right.)
clockwise.) ; l lillj lolliAl:lulrll llll:.2 e -
MMbiFJ3G .?
ECR .INCR
[ Manual Adjustment (Controlled parameter MANuAt increases with deflec-tion of lever to the right and decreases with deflection of lever to the left.)
x ~ . .. - . n s 1 C-MfIAfSRMEG_-Q u p A Legend Label FIGUE 9 Page 101 of 113
Attachment to P-87357 I
Recorder Scale and Paper Design Improvement Package HED-0507, HED-0653, HED-0654, HED-0655, and HED-0657 SAIC COMMENT "HED-0507 (Category 2; MR-9306/7), HED-0653 (Category 1; MR-9306), HED-0654 (Category 1; MR-9306/7), HED-0655 (Category 1; MR-9306), and HED-0657 (Category 1; MR-9306) - The ,
resolution is that the instrument is ' subject' to removal by .
a non-DCRDR change notice (CN-1871). PSC should provide the "
final disposition of this instrument."
PSC RESPONSE See PSC's response to HED-0116 on Page 31.
HED-0507, HED-0653, HED-0654, HED-0655, and HE0-0657 have been redispositioned to reflect the above design intent. ,
Page 102 of 113
[fi
- g-Attachment to.
P-87357
.HED-0655-t SAIC COMMENT "HED-0655 (Category 1).- The discrepancyLis t..at:the' recorder ;
, scales-are not clearly readable and resolvable fromthe i operating position. .To correct the problem, PSC proposed to
. modify the front cover on TR-5153. PSC 'should clarify how modifying the instrument cover would improveLrecorder scale readability and resolvability " j PSC RESPONSE !
As a result of reevaluating HED-0795, the disposition'of-HED-0655'is.no. longer. valid.
TR-5153~will be replaced with a new recorder, a Molytec Model !
2702,.which by design has a scale; that will be clearly readable and. resolvable from the operating postion.
.HED-0655 will be re-dispositioned to read as follows:
TR-5153 will be replaced with.a new recorder, Molytec q Model- 2702, having a scale that is readable and resolvable from the operating position. ,
i i
Page 103 of 113
- - _ - _ - - _ _ - _ _ _ _ - _ . __. - _ _ __ ._. A
j I
Attachment to P-87357 HED-0656 SAIC COMMENT "HED-0656 (Category 2) - The discrepancy is that recorder scaling and markings do not follow preferred human factors engineering principles. PSC indicated that the function of TR-2227 and TR-2255 will be replaced by ' Graphics Display on I-04'. It is unclear what kind of graphics display will be used. If the display is safety-related (which is very likely in this case), a Class IE seismic qualified instrument should be used which would exclude any computer-driven displays.
PSC should clarify the nature of the graphics display and whether seismic qualification is needed."
PSC RESPONSE See PSC's response to HED-0656 on Page 80 of this document.
)
i Page 104 of 113
i Attachment to P-87357 i
Panel I-9349/B (Secondary Coolant Monitoring) Design Improvement Package HED-0490 ;
SAIC COMMENT "HED-0490 (Category 3) - The discrepancy is that the recorder traces are not legible because there is no ink in the blue pen and the red pen is ' wicking'. The disposition is that
' maintenance item referred to results'. It appears that this >
HED will be attended to by PSC's maintenance personnel. The '
PSC DCRDR team should be kept abreast of the status of this HED, and should ensure that it is corrected."
PSC RESPONSE i'
A visual inspection of NR-1131 indicates the discrepancy resolved.
To ensure future operability, the turbine side Equipment Operator verifies recorder operation daily. Any discrepancies are forwarded to the Results Department via a.
maintenance request for correcti .
I Page 105 of 113
Attachment to I i P-87357 ,
l 1
1 Panel I-09 Design Improvement Package j I
-q HED-0184 ;;
SAIC-COMMENT l "HED-0184-(Category 1) -
The discrepancy is that several- j indicating lights do not follow PSC's established convention 1 (DD-ILS-1A). Each of the north and south reset switches has l; one white light while each_of.the switches HS-7378-1 through
-20 and HS-7376-1 through -3 has a single green light.without !
clearly defined functions. For instruments >HS-7377-1 to -20, the indicating lights are positioned backward (i.e.,. red on 'J
..left.and green on right)-compared with PSC's convention. To ;
. correct the problems, PSC proposed to change the indicating, lights to legend lights to better indicate their functions.
This . appears to resolve-the discrepancy related to lack of functional identification. However, PSC did not address whether the- legend lights will' provide position indications consistent with plant convention."
PSC RE,$_P0 HSE Per :00-ILS-1 indicating lights provide discrete . visual information to the operator as to plant and equipment functions or status. Specifically, legend light-indicators are used where a . single position or state for a single function is required.
The indicating lights cited by HED-0184 did not meet the criteria set forth by DD-ILS-1 and are to be replaced with legend indicating lights as presented in Attachment 6b-21, transmitted by letter P-86407, dated June 16, 1986.
The existing single white light associated with the north and ,
south reset switches indicates that the bus potential transformers are in a ' trip' state, which is a condition rather than a physical position. The existing single green light associated with HS-7376-1 through HS-7376-3 indicates that " normal" differential pressure exists between the Reactor and Turbine buildings. The existing green light associated with HS-7378-1 through HS-7378-20 indicates that a pressure control solenoid is electrically energized.
The existing red and green lights associated with HS-7377-1 through HS-7377-20 were cited as not conforming to PSC's Design Directive DD-ILS-1 due to physical arrangement. An investigation showed that these lights were, in fact, a 3~
misapplication in that each light indicated a unique condition not associated with a valve or breaker position.
Fage 106 of 113
Attachment to P-87357 The green light indicates that adequate . louver closing pressure (either compressed air or nitrogen) exists. The red light indicates the admission of backup. nitrogen (as a closing pressure source) to each louver group.
The new, legend light replacing the green light will be ,
connected to- indicate compressed " air" as .the closing '
pressure source. The new legend light replacing the red
-light will continue to indicate " nitrogen" as the. closing pressure source.
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Page 107 of 113 l
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f .
I l Attachment to P-87357 HED-0185 and HED-0186 SAIC COMMENT "HED-0185 - (Category 1) and HED-0186 (Category 1) - The discrepancies are that indicating lights do not follow the established convention, the function of white lights is not clearly defined, and individual light's location with respect to switch varies. PSC asserted that while " indicating lights do follow convention', all white lights will be changed to legend lights and functionally grouped according to DD-ILS-1 and DD-CBL-1. This appears to ameliorate the functional identification but not the location of the lights. PSC has addressed indicating light position in general in is DD-ILS-1A (p. 5). However, it appears unclear how that convention is apolicable to the legend light location problem in this particular case."
PSC RESPONSE To clarify the disposition of HED-0185; the red and green indicating lights follow the established convention set forth in DD-ILS-1, however the white indicating light does not.
As indicated in Attachment 6b-21 transmitted by letter P-86407, Warembourg to Berkow, dated June 16, 1986, the white light is used to show a system status, "a low suction pit level". This function will be indicated on a legend indicating light and functionally arranged such that it is not mistaken for a valve or breaker position disagreement light. (See DD-ILS-1, Figure 1 for an illustration of the disagreement light convention).
Page 108 of 113
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~ '
Attachment to u
'P-87357 i
HED-0281, HED-0282, HED-0283, and HED-0284' SIIC COMMENT-
'"HED-0281-(Category 1), HED-0282 (Category 1), HED-0283.
'(Categoryf1),s and HED-0284 (Category 1) - The : discrepancies-
,E are that forith9 instruments.(fuses): involved,L no function
-tag is shown, letteiing on the instrument tags is ;too :small (height' should: be .5/16"), and numbering is dis' played from
- right"to lef t,. contrary to PSC's convention.-- 'PSC' indicated that the-fuses"will be-relocated behind the control board on' a fuse panel and are not.used by the operator. . .Even thought the fuses are' used ..only by support (suchf as maintenance) .
-personnel',.it is :strongly : advisable' that adequate human-
~
machine'. interface should be designed' by applying sound principles ~of> human' factor.s engineering to support 'the.-safe -
and smooth operation .of the . nuclear. generating Lplant.
Especially in' light'of the fact that-this involves Categoryfl.
HEDs, PSC should indicate how the discrepancies are corrected' by relocating the ' fuses or should present adequate justification for no action."
' PSC RESPONSE The- fuses listed on HED-0281, 0282, 0283, and 0284 will be
. ordered left to right and appropriately labeled as part of the relocation activitiy.
r Page 109 of 113
e l Attachment to. l P-87357 i HED-0384 SAIC COMMENT "HED-0384 (Category 4) - The discrepancy is that the listed ;
instruments are placed "either too high or too low" on the f panel. PSC indicated that instruments MI-11155/6 and MI-11173/4/5/6 'are not used under the present operating philosophy' and they should be -removed from the existing panel."
PSC RESPONSE It is unclear w' hat information fs being requested by the above comment.
An investigation into the functional intent shows that the devices do have a use in certain diagnostic activities and should be retained.
M1-11155/6 and M1-11173/4/5/6 will be functionally grouped near the center of the " LEAKAGE RELIEF" sub-heading on I-9314. See Attachment D1 (pages 1 & 2) to Attachment 6b-20 transmitted by letter P-86407, Warembourg to Berkow, dated June 16, 1986.
These indicators will also be rescaled and labeled in
-accordance with the applicable Design Directives.
l Page 110 of 113
.y
?"-
Attachment to.
-P-87357 i:
4
(.-
.HED-0691
( ,
SAIC COMMENT i "HED-0691 (Category 2) - TheLdiscrepancies cited;are that (1) l no. lamp- test method exists,- (2) lamp . replacement for
-Westinghouse'minalites is difficult, (3);1 amp replacement for
,H
. turbine panel ;is difficult'and bulbs are interchangeable,; and (4): PHC XFER and: reset. button lights are difficult to change'.
( ,
This' HEDf involves alli . panel .-boards. To resolve 'these problems, alternate? lamp -function: test. methods will: be provided .for panels I and' I which. include the.
. installation ' aof testable status ' lights were bulb malfunction is not otherwise determined. Bulb.-replacement-aids will be-
- addressed by CN-1900. Valve and ' breaker control circuit-Configurations will; pro ~ vide a method by which faulty bulbs are -routinely ' detected and , replaced. . Discrete condition
- i- ' indicators will, be . replaced on. all boards withL legend- J
- indicators whi have:a test feature. It appears that much .;
effort' will. be undertaken to correct; :these problems.
However, it is unclear-whether these changes will cover all
.the safety-related instruments-and how often the lamps will-be checked'using the testable features."
1PSC RESPONSE
'See PSC's' response to HED-0691 on Page 43 of this document.
.i l
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Page 111 of 113 f
m---
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s 9_
Attachment to P-87357 e.
Panel I-01 Design Improvement. Package HED-0698 iSAIC COMMENT-
"HED-0698 (Category 2) - PSC mentioned that:
'It,-is a fact that HV-11214 does not rcspond' correctly-to control signLis in the lower 30-40% of '
.. the. control. ~ range'. This ~ may. be either a maintenance or design consideration 'and is being
- pursued by a General Services Action Request. . This-
~ action. request is outside the scope of the Control Room' Improvement activity.'
It is strongly advisable that this discrepancy.be adequately corrected to. ensure and support the smooth'and safe operation-of .the plant. Improving the human-machine interface in support of plant operation (e.g., maintenance work) should be-considered. an integral part of the Control Room' Improvement program' PSC'should keep the NRC informed of the disposition of this HED."
t PSC RESPONSE The problem was determined sto be of a maintenance nature.
Station Service Request (SSR) 8650401500 indicates that adjustments were made to the valve stroke and that the valve was;1 eft operating satisfactorily.
.. :l i
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i Page 112 of 113 Y' '!
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.n , md t s Py ;; qd "HED-0704 (Category 2) - The discrepancy ,is that allLd '
~y
</ 1 ~ . pressure controllers work opposite to other fcont'rqllqs. % /_4L,Q 4 *
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.(. PDC-2555 resolution described will be:pla:ed
' operated' from. ' panel I-9310' local.'setpoint'.
fjs that in thel Mcontro1%rs remote panel PDC-25% of- I d84 throub The other land [
N~ .. discrepant. controllers are to be labeled. with parameter
,J ,Y control / oositions' (such a s ' INCR' , '6FCR';), and circuit !
.g y' changes +tilenabletheparametertobeincreassfbypressing the 'dri'v e to thM right. In.the present res90nsette,the NRC's j
g TER, PSC ,furthef pxplained that the operat bns /en'volving PDC- ?
2548' thredfhP3C-2555 are the primarfQrespcnsibilityof- :
,' nonoperatins) personnel. These instrn envi were relocated )1 ~ %1 S
got{tside (the Control Room: and are %( 'considred as bi,ind. q ]' if '
y g :ontrollar,$ (setpoint selector placed M rcsote),4 with the -
t' T primary,sstpoint controls onJI-10'i St; stated thati l i v .J s e 'As $ner[-operable controls, these controllers at4 3- p' .[
nct ii.oblToct to the controllers convention ' i j istablOhdd for the Control Room. ~ This :letpoin[ ,
}
- .I cohtrol , " while not an operator jcontrol, Ans I '
,j.
.I designed and labeled to conform to the applicable-a Design Directives.' 7' "
l .> A. ii
[" N appeardth'at"MC has designed and labeled PDC-2548 through PDC-2555jtb conform ti the applicable Design Directives [evan t s
. though phese' controllers arp j not) used by the Control Rodm ; k; 2 3 l
0- operators Otherwise, 8 is atrongly advisable that- sound , j i human factors engineepjng principles be applied to c ithe j design ofg operable' Jas well ast 'non-operable' controls
. 'i Te wheneverhuman-machino interfWes is required to support the
[imooth operation of the }!vc) ear genereting std.1on."
safe and ,
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lPSCRESPONSE '
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Rese,lution of the ED conformed tp the ap'plicable Design i Directives.
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