ML20236D374
| ML20236D374 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/20/1986 |
| From: | SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY |
| To: | NRC |
| Shared Package | |
| ML20236D367 | List: |
| References | |
| CON-NRC-03-82-096, CON-NRC-3-82-96 TAC-56125, NUDOCS 8707300428 | |
| Download: ML20236D374 (21) | |
Text
__
' ENCLOSURE 1
.i
, i-
.]
I
.I
- . j TECHNICAL EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW .4 INFORMATION SUPPLEMENTING THE
SUMMARY
REPORT FOR ~ q 1
FORT ST. VRAIN NUCLEAR GENERATING STATI0N I
t
.h
/
l
- l June 20, 1986 Submitted to:
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
Submitted by:
Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102 i
l Contract NRC 03-82-096 k050$$$67 PDR
I 1
l The Annunciator System (Alarm Functional Groupinal Desian Improvement Packaae
~
A review of the material describing the methodology, resolution of HEDs, and proposed modification of the annunciator system found PSC's plans to be acceptable. With the exception of the HEDs cited below, the resolu-tion of individual HEDs was found to be acceptable. PSC should respond to
-l the concerns discussed below:
HED 337 (Category 2) - The discrepancies described are that two func-tionally unrelated alarms are combined on panel 1-01A and that they are not located with the appropriate systems. The disposition proposes to relabel the alarms and relocate them to panel I-03A. This appears to l solve the location problem but not the combination problem. PSC should j provide more information as to how two unrelated alarms are " combined" (e.g., an alarm with multiple inputs) and how their undesirable combi-nation is resolved by the projected di'sposition. s HED 340 (Category 4) - The discrepancy cited is that the alarm is a function of ambient temperature (load) and the function is " irrelevant" since the operator cannot alter outside temperature. Therefore, the instrument will be deleted. A::parently, the monitoring of ambient temperature is related to the rate of water influx. If the alarm in l question is a function of temperature only and condition of low water flow is adequately monitored by, other viable means, then PSC's disposi-tion of this HED would appear adequate. Otherwise, the resolution will not be deemed acceptable.
HED 366 (RAH-93250, RAH-93267, Category 1) and HED 393 (NAH-1131, NAH-1133-1, Category 3) - In both cases, the resolution of the HEDs If the original individual involves the combination of two alarms.
alarms are redundant anditney monitor basically the same area and function, then their combination would be deemed acceptable. Other-wise, PSC should provide adequate justification'for. the disposition 1.
especially since one of the HEDs_is classified under Category HED 369 (PAL-23111, Category 3; PAL-2187, Category 1) - The _discrepan-cies described are that the alarms are not functionally gtouped and I f me
legends are not descriptive. The planned disposition involves relocat-ing the alarms from panel 1-01C to I-13C and functional grouping. This appears to solve the grouping problem but not the one concerning nonde-scriptive legends. PSC should clarify how the legends would be made more descriptive especially when the HED involving instrument PAL-2187 is classified under Category 1.
HED 406 (Category 2) - The discrepancy indicates that the cluster of "Ist In alarms on I-05A/D are generally functionally located with Circ Speed control, however any reaction with controls on I-02 may require operator running between 1-02 & I-05 for resetting alarms." PSC main-tained that the present arrangement is "a resul,t of the original arrangement philosophies (due primarily to the use of cold reheat steam as motive power for circulator drive) and this arrangement offers I certain operating benefits and is not subject to change as a redesign effort." Therefore, no further action was deemed necessary. To afford a more thorough evaluation of this Category 2 HED and proposed resolu-tion, PSC should explicate the " original arrangement philosophies" and '
the "certain operating benefits" provided by the existing arrangement.
HED 411 (LAL-9111-2, LAL-9112-2, Category 3; PAL-9137, PAL-9138', Cate-l l
gory 1) - The discrepancies are that these alarms are not functionally grouped and that the legends on alarms PAL-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-l 9137 and PAL-9138 to the dedicated hy&aulic 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 more descriptive. PSC should clarify this remaining concern, especially in light of the fact that Category 1 HEDs are involved.
l HED 412 (Cate' gory 1) - The discrepancy is that the label on each of the two alarms (TAL-9373 and TAL-9374) does not indicate all conditions associated with the alarm. PSC indicated that each alarm has "both delta T between loops and low temperature per loop qualified by ISS in power position." Furthermore, " qualifying conditions are not stated on l
alarm legends;" therefore, the existing nomenclature is deemed ade-quate. However, it is quite possible that operators may be confused by 2
1
i an inadequately labelled dual-input alarm concerning the nature of the alarmed conditions. The presence of confusion would be obvious, par-ticularly if the HED was identified during operator intervi4w/ question-naire. Al so, in view of the fact that this is a Category 1 HED, PSC i should address this concern and provide a clear justification for no action. Furthermore, PSC should indicate how the generality of the )
i labelling is compensated for by training.
I J
HED 453 (Category 3) - The discrepancies are that seven of the alarms on panel I-13A are not functionally grouped with the appropriate and one of them (PDAH-21401, " Emergency Backup Boiling Water j systems, Strainer") requires the operator to dispatch an outside operator to {
swap the strainer. To resolve the problems, PSC indicated that the l alarms will be relocated and functionally grouped on various panels. I However, the proposed resolution does not address how the problem of f 1
requiring an outside operator to swap the strainer would be mitigated. ;
PSC should explicate the nature of this HED and its planned dispo- (
i sition.
HED 454 (Category 3) - The discrepancies are that four alarms (one on panel I-13C and three on panel 1-13A) are not functionally grouped with the related sysiants and that an operator has to be dispatched to i
replenish oil residue for alarm LAL-6391. Moreover, alarms PDAH-21399 and PDAH-21395 require the operator to dispatch an outside operator to swap the strainers. PSC proposed to relocate the alarms to achieve functional grouping. However, the indicated disposition does not address how the remaining problems of requiring the operator to i replenish oil residue or to swap strainers would be ameliorated. PSC should clarify the nature of this HED and its related disposition.
i HED 473 (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 1-13 board despite the fact
- that it is not an assigned duty. Third, the delta p controller and/or l piping system does not respond at a rate sufficient to compensate for PCRV pressure changes during step power alteration. The NRC is referred to GSAR 792 for a description of PSC's disposition. The l
3 l
L.__________.. _ _ . _ _ _ _ _
7 m
+.
l
'N ,
n apparent resolution proposed for the problems as r
indicated on the appending pages to the HED Evaluation sheet comprises the f'ollowing:
o Fix the delta p alarm I-13C 5-1.
o Consider improving the control response and vent control for 1
interspace pressurization.
o 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 explain and confirm PSC's i plans, PSC should provide more specific information on how th'i pro- l jected remedial measures would be hilpful. l I
HED 551 (Category 3) - The discrepancies are that the sound levels from j the alarm 'on panel I-70 are found to be 6.1 dBA on everage above background noise which is lower than the nominal value of 16 dBA recom-I mended by NUREG-0700 (Section 6.3.2.1)'. Moreover, an alarm horn on the shift supervisor'sl alarm panel is. raported to be out of operation.
PSC's disposition indicates that sound absorption treatment will be )
provide:' in the control room via CN-1899 to reduce background noise j level, and the alarm noise levels from I-70 will be reevaluated after l i
the noise treatment. The inoperable alarm on the shift supervisor's alarm panel will be ieferred to " operations'for maintenance action by GSAR-767.' Apparently, the disfubctioned alaYttwill be repaired by the 1 e n be om 1 t d n fr n on e s re n and reevaluation of the I-70 alarm noise levels is made available to j the NRC for review. l s
HLfC 598'(Category 1) - The discrepancy indicated is that the startup, wide rantje,, tnd power instruments .are maiked in arabic numerals while ;
,the corresponding references on panel I-03 are in Roman numerals. To correct this problem, PSr. proposed to group functionally the alarms and relabel them using Roman numerals. However, as recommended in NUREG-0700 (Section 6.6.3.4.e), the use of Roman numerals in labels should be ,
a"oided. PSC should provide justificat. ion indicating why Roman (and j
<10 t arabic) numerals are used in this"hase or relabel the applicable l components .using arabic numerals. ,
j 4 q I
4
( l
___-____________w
HED 678 (Category 2) - The discrepancy indicates that too many alarms triggered during transient affect communication and concentration.
Moreover, alarm horns are not discernible between panels. PSC proposed a "mul t i- f acet ed" approach to mitigate these problems "as much as l
possible." Solutions include the installation of noise damping mate-rials (via CN-1899), the deletion of unnecessary or redundant al arms ,
and 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 the final disposition and results of mitigating actions should be provided before this HED and PSC's resolution could be confidently and conclusively evaluated.
l HED 679 (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 l problem appears to be that temperature control within a certain range !
is desirable in the control room, but there exists nn administrative measure to ensure compliance. However, it might also be the case that a.ppropriate means for adjusting the con +.rol room temperature is lack-l ing. Moreover, there is no information on the specifics of the final l resolution for the HED. Both the definition of the problem as well as the proposed disposition require further clarification before the HED l and related resolution could be fully appreciated and evaluated.
HED 722 (Category 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 1-05 instead (see HED 406). Similar to the proposed disposition for HED 406, PSC maintained that the present arrangement is a result of the " original arrangement philosophies" and "this arrange-ment offers certain operating benefits and is not subject to change as a redesign effort." Therefore, no further action was deemed necessary.
l i
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 arrangement.
5 l
l l
~
1 i
Review of Panel Design Packages and HED Resolutions
' l Panel-105 Desian Improvement Packcae j 1
A review of the material describing the methodology, resolution of l l
HEDs, and proposed modification of panel I-05 found PSC's plan to be acceptable. With the exception of HEDs cited below, the resolution of individual HEDs was found to be acceptable. PSC should provide responses to the concerns dis ussed below:
HED 101 (Category 1); HED 102 (Category 1); HED 110-2 (Category 1); HED 136 (Category 1) HS-2217; HED 137 (Category'1) HS-2215 - The discrepancies described are that 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 l
switch is used to test valve stroke and requires local surveillance, l
It is not clear from the description of the resolution whether the discrepancy concerning the fading of letters will be corrected. i I
HED 112 (Category 1) HS-22182, HS-22183, HS-22184, HS-22185 - The i
discrepancy described is that there are too many instruments in one place causing difficulty in associating instruments with related labels; the instruments should be labeled better. In addition,
{ indicating lights on riS-22182 thru 22185 do not follow convention; that .
is, the red lights are on the left and green lights are on the right, l opposite of convention. The resolution indicates that HS-9105-1 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 thru 1
HS-22185, (the switches are used to test valve stroke and require local surveillance), it does not mention relabeling. Also, it is not clear from the description of the resolution whether the discrepancy con- l I
cerning red lights on the left and green lights on the right has been l resolved by PSC.
l HED 116 (Category 1) - One of the discrepancies described is that there are no function tags for MI-9306 and MI-9307 among other instru-i l
ments. The resolution described for hl-9305/9307 is that these l
6 l
\
l instruments .are subject to relocation. PSC does not indicate whether function tags will be provided for these indicators.
.The discrepancy described is that klare is a HED 485 (Category 2)
PSC problem on the indicators listed in the HED evaluation form.
states that the operator is required to shift or realignThe positions to resolution l avoid glare when reading different scale values .
j described is that glare will be minimized by the installation of an l
indirect lighting system. 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.
HED 487 (Category 1) - The discrepancy described is that switch position changes were made after the survey by control room personnel The resolution that do not follow the established convention.
described- appears to be that the discrepant switches will be func-tionally grouped and relabeled. PSC's' explanation of the resolution of the discrepancy concerning the switch position changes by functional PSC grouping and relabeling does not seem to address the discrepancy. {
should provide a clearer explanation of how functional grouping and j relabeling corrects this discrepancy.
HED 495 (Category 3) - The discrepancy described is that instrument l failure is not apparent to the operators. Although PSC cites in the i
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 instru-l ments the operators will use for those tasks and whether and how indi- l cator failure can be detected by operators.
HED 580 (Category 2) ME-9306, ME-9307; HED'592 (Category 2) ME-9306, ME-9307; HED 614 (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 chang ~e notice. PSC should state the final disposition for these HEDs.
7 L.
HED 642 (Category 1) PAHL-2267, PAHL-2268 - The HED described consists of labeling discrepancies for several components. The resolution described does not address the above components. .,
HED 653 (Category 1) HR-9306; HED 654-(Category 1) MR-9306/9307; HSED 655 (Category 1) MR-9306; HED 657 (Category 1) MR-9306; HED 758 (Category 3) MR-9306/9307 - 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 provide final solutions to these HEDs.
HED 691 (Category 2): The discrepancies described are that "(1) No lamp test method exists, (2) Lamp repl acemen't for Westinghouse minalites is a problem -_ glass breakage - bases sticking in holder, (3) {
Lamp repl acement for turbine Panel is difficult and bulbs are l interchangeable, and (4) PHC XFER & Reset Button lights difficult to f change." PSC's resolution for the 1-05 components is, " Bulb replace-ment aids to be addressed by CN-1900. Valve and breaker control cir-cuit configuration provide a method by which faulty bulbs are routinely detected and repl aced. Discrete condition indicators are being replaced .on all boards with legend indicators which have a test feature." PSC should provide additional information which explains (a) how often (routinely) operators are supposed to check for and replace faulty bulbs; and (b) how many of the safety-related indicating lights wil'1 not have a means by which they can be detected for malfunc-tion.
HED 699 (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 informational record, it did not provide its rationale for not taking corrective action.
8
4 .
HED 749 (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 the valves and valve PSC sizing. Also, controller range may be over range 0-50k vs. 0-90k.
states that no action is required, the control range is acceptable, and !
see the response-by E. Moyer. No such response was found attached to PSC needs to provide its rationale'for the controller )
the HED forms. 1 range to be acceptable.
I j
i c
9
l Panel 1-06A Desian Improvement packaoe .
A review of the material describing the methodology, re, solution of HEDs, and proposed modification of panel 1-06A found PSC's plans to be generally acceptable. PSC indicated that "a review of the turbine EHC opportunities for improvements to enhance panels identified additional "will operability other than those cited by specific HEDs," and the panels be researched thoroughly during the detailed change notice (CN) design" (p.
In the future, DCRDR research findings and final 4 of Attachment 6b-14). review.
. design of HED disposition should be made-available to the NRC for
.Moreover, with the exception of the HEDs cited below, the resolution of PSC should respond to the <
individual HED was found to be acceptable. I concerns discussed below:
HED 485 (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 as well as how )
it would eliminate glare and affect control room lighting levels. 1 HED 585 (Category 2) - The discrepancy is that a compound vertical edge indicator shows increase in both upward and 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 l not require any action." As a result, apart. from relocating the To in e aent r to panel 1-063, no other action was deemed necessary.
enable a more thorough evaluation of this HED and PSC's resolution, information is required. PSC should explicate, with the l additional '
help of a picture or diagram if possible, the nature and function of the existing compound vertical display. Moreover, it is unclear as to Since it is generally recommended why the scale is deemed acceptable.
that vertical scales should increase upward (e.g., NUREG-0700, Section
~
6.5.2.1.b) and in view of the fact that this involves a Category 2 HED, a more precise and thorough justification for no action should be provided.
10
l.
HED 665 (Category 1) - The discrepancy is that functional legends on two condensate pump discharge switches do not reflect circuit opera-tions. PSC indicated, with the aid of two accompanying disgrams, that i the multirow display controls will be relabeled according to DD-LAB 1 and D-SWI-1. Specifically, " EMERGENCY" and " NORMAL" will be relabeled "EMERG HDR" and " NORM HOR" respectively. "DISCH" will be renamed-
"EMERG" and " BYPASS" renamed " NORM." The illustrations show that the upper and lower labels of the redesigned mutirow display were swapped.
This may introduce a new HED wherein the labels of the multirow display fail to correspond to the switch positions. Findings based on human !
l engineering research (such as NUREG-0700) suggest that the label indi-cating "EMERG HDR" should be placed on top of that showing " NORM HDR" to match with the control positions of "EMERG" and " NORM." As recom-mended in Section 6.9.2.2.c of NUREG-0700, "muti-row displays should be ordered left to right and top to bottom (in normal reading order), and matched to controls ordered left to right." Moreover, " controls and !
I displays should have corresponding labels." 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 provide justification for such l deviations.
HED 691 (Category 2) - The discrepancies cited are that (1) no lamp !
test method exists, (2) lamp replacement for Westinghouse minalites is f difficult, (3) lamp replacement for turbine panel is difficult and i
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 j for panels 'I-01 and I-02 which include the installation of testable j status lights where bulb malfunction is not otherwise determined. Bulb l replacement aids will be addressed by CN-1900. Valve and breaker control circuit configurations will provide a method by which faulty j bulbs are routinely detected and replaced. Discrete condition indica-tors will be replaced on all boards with legend indicators which have a i
test feature. It appears that much effort will be undertaken to (
j 11 l
i l
correct these problems. However, it is unclear whether these changes will cover all the safety-related instruments associated with this HED and how often (routinely) the lamps will be checked using fhe testable features.
HEDs 774 and 844 (Category 4 and 3 respectively) - Instrument HS-3221 is involved in both of these HEDs. While the other accompanying instruments will be removed in both cases, HS-3221 will be left on the panel pending " additional investigation." Although it is recognized that the likelihood of these two HEDs causing errors is low (Categories 3 and 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 concerning HS-3221.
HED 795 (Category 2)'- The discrepancy is that the recorder TR-5153
" lacks fast speed for use during turbine rollup." The disposition l proposed includes functional demarcation and labeling which do not appear to affect the speed of the recorder. On the other hand, Attach-ment A (" List of All 1-06A HEDs & Copies of I-06A HEDs," p. 14) of Attachment 6b-14 indicates that TR-5153 will be changedout and func-tionally grouped. PSC should clarify whether the recorder will be l replaced by one which would provide a fast speed for use during turbine j roll up. If only demarcation and labeling are employed, the disposition 1 does not appear to correct the HED.
l l
12
/
j Panel 1-06B A review of the material describing the methodology, rdsolution of 1
HEDs, and proposed modification of panel 1-06 found PSC's plans to be acceptable. With the exception of HEDs cited below, the resolution of individual HEDs was found to be acceptable. PSC should provide responses to the concerns discussed below:
HED 485 (Category 1) - The discrepancy is that because of glare (indirect) at various 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 correc-tive action, it should describe the indirect lighting system to be installed and how it will minimize glare and affect control room light-ing levels.
HED 486 (Category 2) - The discrepancy described is that due to
~
l l
decreased color discrimination under emergency lighting conditions, the l l 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.
HED 505 (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 posi-tion lights to local Aux. Boiler Control Panel per tN 1892. PSC should also indicate whether it will provide appropriate labeling in order to correct this HED sufficiently.
HED 691 (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 HED involves all panel boards. To resolve these problems, alternate lamp function test methods will be provided for panels 1-01 and 1-02 which include the installation of testable 13
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 indica-tors will be replaced on all' boards with legend indicators which have a test. feature. It appears that much effort will be undertaken to cor-rect these problems. However, PSC should provide additional informa-tion which explains. (a) how often (routinely) operators are supposed to check for and replace faulty bulbs and (b) how many of the safety-related indicating lights will not have a means by which they can be verified for functioning. PSC's disposition is unclear in how the pl ant's system features compensate for or mitigate the discrepancy l
cited.
HED 776 (Category 3) - The discrepancy described is as follows: " Flows to four coolers is controlled with single inlet valve. Manual valves i exist on outlet of coolers which can be used to restrict flow, however back pressure on coolers is undesirable. Operator cited unusual j i operating characteristic, actual problem may be system." The resolu-of a tion cited is as follows: " Generator is designed for removal heater without affecting performance. A High Temperature alarm is l l
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.
HED 777 (Category 1) - The discrepancy cited is that (1) switch HS 3127 is not clearly labeled according to the function, and (2) switch posi-The tions are entitled " EMERGENCY" and " NORMAL" instead of the source.
planned disposition involves relocation of switches to local Aux.
Boiler Control Panel per CN-1892. PSC should a' iso indicate whether it will provide appropriate labeling.
14
. . . . . . . . , . . p
Panel 1 15 Desian Improvement Packaae A review of the material describing the methodology, retolution of HEDs, and proposed modification of the annunciator system found PSC's plans to be generally acceptable. With the exception of the HEDs cited below, the resolution of individual HEDs was found to be acceptable. A concern remains, however, regarding the relocation of recorders that may be needed for- plant operations. Specifically, the concern is for recorders related to controls and displays on panels other than I-09 that may need to remain with and these components in order to maintain or establish. functional grouping support plant operations. PSC should indicate if any recorders needed to support plant operations on panels other than 1-09 have keen moved to I-09, and if so, how operations will be conducted satisfactorily in each case. In addition, PSC should respond to the concerns discussed below:
HED 485 (Category 1) - The discrepancy is that because of glare at various indicators, the operator is required to shift (indirect) 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.
HED 486 (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 used and how this system will improve color discrimination.
HED 626 (Category 1) - The discrepancy is that for switch HS7S42, 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 order to sufficiently correct this HED.
15
]
HED 658 (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 acceptable as a sole justification for taking no corrective action.
PSC should either resolve this HED or provide more acceptable rationale ;
for not taking corrective action.
HED 691 (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 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 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 l
have a test feature. It appears that much effort will be undertaken to l correct these problems. However, it is unclear whether these changes will cover all the safety-related instruments and how often the lamps l will be checked using the testable features. ;
HED 778 (Category 3) - The discrepancy quoted is that "TR-92105 (which is on panel I-15) is the feedback required with TIC-4253 located on I- 3 06." PSC maintained that a "HIGH TEMP" alarm is available to alert operator of high cooler temperature and that individual temperature l from each cooler is available on TR-92105 (which will be relocated to I-09 per CN-1878) for. diagnostic purposes. Other than that, no further corrective action is deemed as necessary by PSC. However, PSC does not j describe what feedback will be available for TIC-4253 and where it is located relative to TIC-4253. Moreover, relocating TR-92105 from panel I-15 to I-09 appears to place the instrument farther away from I-06 than'before.
1 I
16 , j i
1
HED 791 (Category 2) - The discrepancy is that the listed switches on panel I-15 are not functionally grouped with other turbine controls and indicators. PSC maintained that " physical constraints dn 1-06A & B make relocating with other 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 resolu-tion should be based on operational and behavioral factors rather than on physical constraints alone. For instance, the proximity and group-ing 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.
)
1 17
I ENCLOSURE 2 l
- Panel I-10 (1-9310) Control Board Desian Improvement Packaae A review of the material describing the methodology, resolution of HEDs, and proposed modification of panel 1-10 found PSC's plans .,to be gener-ally acceptable. With the exception of the concerns cited below, the reso-lutions of individual HEDs were found to be acceptable. PSC should respond to these concerns:
I-
- 1. PSC stated that miniature meters installed in the NIH bins of 9310 are primarily used in surveillance and maintenance. Critical j
parameters displayed on the NIM bin miniature indicators are also shown on the main control boards for operator use. Thus, no addi- {
l tional changes are planned for those HEDs citing meter scale problems on I-9310. PSC should ensure that' All safety-related Moreover, displays will be duplicated on the main control boards.
such displays should be functionally grouped with related controls and displays on the main control boards.
1 be
- 2. PSC indicated that "all nuclear instrumentation channels are to labeled with Roman numerals for consistency, in accordance with industry convention." This decision affects the instruments quoted in HED 597 (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 label s should be avoided. PSC should provide justification indicating why Roman (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 used for surveillance (operating and recording of data) and maintenance (repair and testing) only. The HEDs involved are:
Category 1 HEDs - 319 320 321 322 361 362 363 364 Category 2 HEDs - 403 562 563 568 572 573 578 581 583 588 589 590 1
i
- from the human' factors / systems operation point of view, surveil-lance and maintenance are important-functions which ensure the safe and smooth operation of systems. Sound human factors engineering Also,. l principles should be applied to cover those areas as wejl.
in light of the fact that this decision involves Category I and 2 HEDs, PSC should either take-corrective actions to resolve the HEDs or provide adequate and precise justifications for no action.
t 4. HEDs 384 and 385 (both Category 3) - The discrepancy cited is that the instruments involved are' located either too high or too low' on the panel. PSC indicated that "those devices required by operators 1
in emergency situations will be labeled or demarcated to enhance l-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 due to controls and displays located too high or too low (e.g. , reach difficulty, acccidental activation, parallax, l poor readability). PSC should provide illustrations showing the existing as well as the proposed panel layout to enable a more thorough evaluation and understanding of panel space constraints.
Panel 1-7507X (HVAC) Desian Improvement Packaae A review of the material describing the methodology, resolution of HEDs, and proposed modification of panel 1-7507X found PSC's plans to be generally acceptable. Under conceptual design, PSC stated that " investigations failed to establish a need for filter high temperature alarms other than those which exist." 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 Moreover, with place, and the kinds /results of the investigations performed.
the exception of the HED cited below, the resolutions of individual HEDs were found to be acceptable. PSC should respond to the concerns discussed f below:
h (Category 2) - The discrepancies cited are that (1) no lamp HED 691 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 2
L . .
This HED involves all panel boards. To resolve
- difficult to change.
these problems, alternate lamp function test methods will be provided for panels 1-01 and 102 which include the installation of testable Bulb status lights where bulb malfunction is not otherwise determ_ined.
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 indica-tors will be replaced on al1~ boards with legend indicators which have a test feature. In particular, a lamp test button will be insta11ed'on panel 1-7507X. It appears that much effort will be undertaken to correct these problems. For panel 1-7507X, if all indicating lights are then PSC's resolution i.s acceptable. PSC should indi-made testable, Furthermore, PSC should indicate how cate whether this is the case. ,
often the lights will be tested. i 1
Imorove- j The Annunciator System (Miscellaneous Alarm Modifications) Desian ment Packaoe, A review of the material describing the- methodology, resolution of HEDs, and proposed modification of the annunciator system found PSC's plans to be acceptable. 3 l
l l
3
.