ML20236D381

Technical Evaluation of Dcrdr Info Supplementing Summary Rept for Fort St Vrain Nuclear Generating Station

ML20236D381
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/24/1986
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20236D367	List: ML20236D363 ML20236D374 ML20236D381
References
CON-NRC-03-82-096, CON-NRC-3-82-96 TAC-56125, NUDOCS 8707300430
Download: ML20236D381 (21)

Text

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ENCLOSURE 3 TECHNICAL EVALUATION OF THE DETAILED CONTROL ROOM DESIGN REVIEW INFORMATION SUPPLEMENTING THE

SUMMARY

REPORT FOR FORT ST. VRAIN NUCLEAR GENERATING STATION September 24, 1986 l

Submitted to:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Submitted by:

Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102 Contract NRC-03-82-096 8707300430 870721 0 PDR ADOCK 05000267 P PDR

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. INTRODUCTION l A total of nine submittals of supplementary information on Public Service Company (PSC) of Colorado's DCRDR have been reviewed,. The last submittals date'd June 16, 1986; July 15, 1986; August 18, 1986; and August

- i 19, 1986; have been reviewed recently and the results are discussed in the j

present report. Other submittals dated October 29. 1985; December 3, 1985; March 18, 1986; April 18, 1986;- and May 16, 1986 had been reviewed previously and the findings were documented in NRC's Technical Evaluation Report (TER) dated January 24, 1986 and SAIC's Informal Technical i Communication (ITC) dated June 20, 1986 and July 3, 1986. As is true of previous findings, PSC's proposed control room improvements, as described in its June, July, and August 1986 submittals, were found to be generally acceptable. However, PSC's proposed resolutions for some specific HEDs either need to be clarified, further explained, or made responsive to the concerns of the NRC as described in the attached pages.

In conclusion, PSC has performed an extensive, comprehensive, and detailed job in the human factors improvements of the Fort St. Vrain Nuclear Generating Station control room. Only seventy-seven items identified by the These, however, constitute only a NRC remain to be further clarified.

small fraction of the 848 HEDs discussed in PSC's Summary Report and supple- ]

In order for PSC to progress toward successful closeout of these j mentals.

few remaining DCRDR activities, it is suggested that a meeting be held in {

Bethesda, Maryland, between the NRC and PSC in the near future during which each of the HEDs will be resolved on line and agreements reached in real i time. The minutes of this meeting could serve as official documentation of l l

these agreements.

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REVIEW 0F PANEL DESIGN PACKAGES AND HED RESOLlJTIONS 1

Panel I-13 Desian Improvement Packaae A review of the material describing the methodology, resolution of HEDs, and proposed modification of panel I-13 found PSC's plan to be the generally acceptable, With the exception of the HEDs cited below, PSC should resolution of individual HEDs was found to be acceptable.

respond to the concerns discussed below:

HED 270 (Category 1), HED 275 (Category 1), HED l HED 257 (Category 1),

276 (Category 1), HED 277 (Category 1), HED 341 (Category 2), and HED 587 (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 l the handswitches is too small, whereas it should be 5/32" tall; and l there are no instrument / function tags for the instruments. The planned l disposition involves relocation of the equipment affected to the Rx building, as its function is not required in the control room.

Apparently, no other action is deemed necessary by PSC. However, it is strongly advisable that established human factors engineering guide-lines 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 adequate labeling according to the guidelines set in its design directives.

HED 384 (Category not listed, probably I as indicated in 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 385 (Category not listed, probably I as indicated in the " Design Improvement Package for I-14;" RIS-73437-1, RR-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, and RIS-93250-4) - The discrepancy is that the instruments are "either too high or too low on panel s . " 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 2

. evaluation of this HED. Moreover, PSC should indicate whether the i I

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 mot prevent

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reading at the required accuracy).

i HED 656 (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 q by " Graphics Display on 1-04." It is unclear what kind of graphics  !

display will be used. If the display is safety-related (which is very  !

l likely in this case), a Class 1E seismic-qualified instrument should be used which would exclude any computer-driven displays. PSC should l clarify the nature of the graphics display and whether seismic qualification is needed.

1 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 I-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 l control circuit configurations will provide a method by which faulty bulbs are routinely detected and repl aced. Discrete condition j indicators will be replaced on all boards with legend indicators which have a test feature. It appears that much effort will be undertaken to l correct these problems. However, PSC should provide additional infor- )

mation which explains (a) how often (routinely) operators are supposed l to check for and replace faulty bulbs, and (b) whether all the safety- l related indicating lights will have a means by which they can be verified for functioning.

HED 819 (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 have opened. PSC has proposed to investigate further the possibility of entering the valve 3

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- position into the data logger or some other recording device to resolve j 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.

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- Panel 1-14 Desion Improvement Packaae A review of the material describing the methodology, resolution of HEDs, and proposed modification of panel I-14 found PSC's pl,ans to be generally acceptable. With the exception of the HEDs cited below, the l PSC ;hould resolution of individual HEDs was found to be acceptable. ,

respond to the concerns discussed below:

l HED 347 (Category 1), HED 348 (Category 1), and l HED 346 (Category 1),

HED 350 (Category 1) - The discrepancy described is that the lettering f The j on the monitors is too small, whereas it should be 7/16" tall.

resolution described is that the monitors will be relabeled per DD-LAB- l 1 and relocated on I-14 to follow height guidelines "more closely" per l PSC should provide more specific information on how closely j DD-CBL-1.

it will follow PSC's DD-CBL-1, especially these are Category 1 HEDs. ]

l Moreover, PSC should indicate whether the accuracy with which these instruments must be read at for normal or emergency operations is j

easily 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).

l (Category 1) - The discrepancy is that functional instrument i

HED 349 tags are missing for the listed instruments. The resolution proposed is to " relabel other P.B. switches to show actual 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 l 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 i the safe and smooth operation of the plant, especially when a Category 1 HED is involved.

I HED 359 (Category 4) and HED 360 (Category 4) - The discrepancy described is that the illuminated pushbuttons and rotary switches do not meet the " location spacing of ERDA-76-45-2." The proposed resolu-tion is to provide location aid 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 should explicate the nature of the spacing problem and 5

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- the potential human errors involved (e.g., accidental activation and ,

I error ofidentification), and indicate how PSC's proposed resolution could mitigate such potential human errors. 3 HED 364 (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 push-buttons to read "0N" per DD-LAB-1. Other than that, no further action f l

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 available 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 p. roper 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.

i HED 384 and 385 (both Category 1) - The discrepancy cited is that the l 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- 1 machine interface and viewing angle of these instruments. l o

j HED 588 (Category 2) - The discrepancy described is that all BIN / MODULE indicators of panel I-10 and I-14 have too small letter size for numeral s, " 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  ;

l them for " verification.") Moreover, due to space constraints on panel

- I-14, the letter size on the labels cannot be changed; only scales with errors will be changed. However, it is strongly advisable that sound human factors engineering practices be applied to all extant human- l machine interface to support the smooth and safe operation of the j 6

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 performed.

first place, and the kinds /results of the investigation 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 less space-demanding (e.g., by enhancing the luminance contrast of the lettering).

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- Controller Operatina Conventions Desian Improvement'Packaae i A review of the material describing the- methodology, resolution of ):

HEDs, and proposed modification-of controller operating conventions found PSC's plans t'o be generally acceptable. PSC mentioned that controller operation will- be OPEN/ INCREASE to the right and CLOSE/ DECREASE to,the left )

while setpoint dials will function such that the " numbers increase as .the dial is rotated counter-clockwise," apparently opposite to the way con- ,

trollers are operated. PSC should provide illustrations ,of a controlleg and ]

a setpoint dial for a more confident appreciation and evaluation of the l J

related conventions. Moreover, PSC should explain why the operating conven-tions for setpoint dials and controllers are different and why the conven-tion for setpoint dials appears to be contrary to guidelines like that I stipulated in' NUREG 0700 (Section 6.4.2.1). In addition, PSC should respond to the concerns discussed below:

1 HED 636 (Category 2) - The discrepancy is that several controls "do not conform to plant stereotypes for directional selection." PSC indicated that for instruments TDIC 2227-1 to 6, TDIC-2228-1 to.6, PC-2267, and PC-2268, the directional control labels will be charged to "incr-decr" i (increase-decrease), the control direction

• standardized," and new  ?

dials installed by CN-1890. It is unclear which convention these l instruments are designed to follow,4 'and apparently increasing to the- ]

left is counter to generally accepted human factors engineering guide-  !

lines (like NUREG-0700).

HED 701 (Category 2) - The discrepancy is that the ' control knob for setpoint works backwards (increase to right)." PSC indicated that the discrepancy has been reevaluated, anct no action was needed because

" controller convention is dependent on control'ler that is by-passed and' therefore, subject to change." PSC further stated that " Bypass Controllers are current sources only and are not labeled or 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, an illustration 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. tho related displays and controls complies with established human faci'ers engineer-ing principles. For instance, the control directions of the setpoint 8

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. dial should be consistent with PSC's convention and other similar dials in the control room. Labels could be enhanced to identify better the 1

nature of the parameters and direction being controlled.

HED 704 '(Category 2) - The discrepancy is that all delta pressure controllers work opposite to other controllers. The resolution j described is that controllers PDC-2548 through PDC-2555 will be placed I on the remote panel of I-48 and operated from " panel I-9310 local setpoint." The other discrepant controllers are to be labeled with l parameter control positions (such as "INCR," "DECR) and circuit changes )

will enable the parameter to be increased by pressing the drive to the

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right. In its response to NRC's first TER (response dated 8.19.1986), j PSC further explained that the operations involving PDC-2548 through l PDC 2555 are the primary responsibility of nonoperating personnel. j These instruments were relocated outside the control room and are now

" considered as blind controllers (setpoint selector placed in remote), 1 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."  ;

i Thus, it appears that PSC has designed and labeled PDC-2548 through PDC-2555 to conform to the applicable Design Directives even though I these contr611ers are not used by the control room operators. Other-wise, it is strongly advisable that sound human factors engineering principles be applied to the design of " operable" as well as "non-operable" controls whenever human-machine interface is required to support the safe and smooth operation of the nuclear generating plant.

HED 738 (Category 2) - Part A of the problem descriptions indicated that five controllers have setpoint 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 i

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[. ,' h i Recorder Scale and Paper Desian Improvement Packace l

A review of the riaterial describing the methodology, resolution of HEDs, and proposed r,3 codification of recorder scale and paper 'found PSC's plans to be generally acceptable. PSC mentioned that the Design Directives l

used were DD-AAS-1A, DD-LAB-18, DD-AIS-1, and DD-RSN-1. All except DD-RSN-]

As a

(" Recorder Selection") habe been submitted by PSC and reviewed.

the present evaluation has been performed without the beneficial  !

result, knowledge of DD-RSN-1. With the exception of the HEDs cited below, the resolution of individual HEDs was found to be acceptable. PSC should respond to the concerns discussed belvi. .

I HED 507 (Category 2; MR-9306/7), HED 653 (Category.1; MR-9306), HED 654 (Category 1; MR-9306/7), HED 655 (Category 1; MR-9306), and HED,657 (Category 1; MR-9306) - The resolution is that the instrument .i Is (CN-1871). PSC

" subject" to removal by a non-DCRDR change notice should provide the final disposition of this instrument.

HED 655 (Category 1) - The discrepancy is that the recorder scales are not clearly readable and resolvable from the operating position. To correct the problem, PSC proposed to modify the front cover on TR-5153. .

PSC should c'.arify how modifying the instrument cover would improve L recorder scale readability and resolvability.

HED 656 (Category 2) - The discrepancy is that recorder scaling and ,

markings do not follow preferred human factors engineering principles.

PSC indicated tnat the function of TR-2227 and TR-2255 will be replaced by " Graphics Display on 1-04." It is unclear what kind of graphics display will be used. If the display is safety-related (which is very  !

l likely in this case), a Class 1E seismic-qualified instrument should be used which would exclude any computer-driven displays. PSC should clarify the nature of the graphics display and whether sr.ismic qualifi- l cation is needed.

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Panel 1-9349/B (Secondary Coolant Monitorinal Desian Improvement Packace A review of the material describing the methodology, re, solution of be HEDs, and proposed modification of panel I-9349/B found PSC's T1ans to generally acceptable.

With the exception of the HED cited below, the PSC should respond resolution of individual HEDs was found to be adequate.

to the concern discussed below:

HED 490 (Category 3) - The discrepancy is that the recorder traces are is not legible because there is no ink in the blue pen and the red pen

" 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.

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. Panel I-09 Desian Improvement Packaae I

A review of the material describing the methodology, resolution of I HEDs, and proposed modification of panel I-09 found PSC's '1Llans to be '

generally acceptable. However, PSC mentioned that the Circulating Water /

Service Water mimic would be deleted even though "certain operators utilize this graphical representation as a quick reference to system status" (p. 4 ]

of Attachment 6b-21). PSC jusGned deleting the mimic by referring to the l

" perceived disadvantage" with transitioning between the pictorial represen-tation and the control switches located below. PSC also maintained that "the available board space and the conditions for use of these controls do not justify an extensive modification to. incorporate a true mimic." If quick reference to system status is needed (as some operators have found the mimic beneficial), and if another mechanism is unavailable to the operators for such purpose, then a well-conceived mimic appears essential. PSC should clarify whether the need for a "true mimic' exists. In addition, PSC should respond to the concerns discussed below:

HED 184 (Category 1) - The discrepancy is that several indicating lights do not follow PSC's established convention (DD-ILS-1A). Each of the north and south reset switches has 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 function. For instruments HS-7377-1 to 20, the indicating lights are positioned backward (i.e., red on 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 indica-tions consistent with plant convention.

HED 185 (Category 1) and 186 (Category 1) - The discrepancies are that indicating lights do not follow the established convention,- the func-tion of white lights is not clearly defined, and individual light's location with respect to switch varies. PSC asserted that while "indi-  ;

cating 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 13

position in general in its DD-It.S-1A (p. 5). However, it appears  !

unclear how that convention is applicable to the legend light location problem in this particular case. i HED 281 (Category 1), HED 282 (Category 1), HED 283 (Category 1), and HED E84 (Category 1) - The discrepancies are that for the instruments l (fuses) involved, no function tag is shown, lettering on the instrument tags is too small (height should be 3/16"', and numbering is displayed l from right to left, contrary to PSC's convention. PSC indicat d that the fuses will be relocated behind the control board on a fuse panel and are not used by the operator. Even though the fuses are used only by support (such as maintenance) personnel, it is strongly advisable that adequate human-machine interface should be designed by applying sound principles of human factors engineering to' support the safe and smooth operation of the nuclear generating plant. Especially in light of the fact that this involves Category 1 HEDs, PSC should indicate how the discrepancies are corrected by relocating the fuses or should present adequate justification for no action. ,

HED 384 (Category 4) - The discrepancy is that the listed instruments )

are placed "either too high or too low" on the panel. PSC indicated i 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.

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 button lights 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 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 indi-cators 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 14

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will be checked using the testable features. .

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- The Annunciator System (Alarm Functional Groupina) Desian improvement I Package A review of the material describing the methodology, rholution of HEDs, and proposed modification of alarm functional grouping found PSC's pians to be acceptable.

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t The Annunciator System (Alarm Initiatina Circuits) Desian Improvement Packaae A review of the material describing the methodology, ruolution of HEDs, and proposed modification of alarrr initiating circuits found PSC's plans to be acceptable.

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. REVIEW OF PSC'S RESPONSE TO NRC'S TER OF JUNE 13, 1986 I

A review of the material describing PSC's response to NRC's concerns (13 items in total) found PSC's explanation generally acceptable, with the l exception of 'the HEDs cited below. PSC should respond to the concerns discussed:

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Panel I-01 Desian Improvement Packaae  !

HED 698 (Category 2) - PSC mentioned that:

"It is a fact that HV-11214 does not respond correctly to control signals in the lower 30-40% of the , control range. l l 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 er.sure and support the smooth and safe operation of the pl ant. I Improving the human-machine interface in support of plant operation l (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.

HED 704 (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 in the remote panel of I-48 and operated from " panel I-9310 local se+.aint." 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 the present response to NRC's TER, 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 1-10." PSC stated that:

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"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."

It appears that PSC has designed and labeled PDC-2548 through PDC-2555 to conform to the applicable Design Directives even though these controllers are not used by the control room operators. ;0therwise, it is strongly advisable that sound human factors engineering principles be applied to the design of " operable" as well as "non-operable" controls whenever human-machine interface is required to support the safe and smooth operation of the nuclear generating plant.

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