ML18033B756

Responds to Crdr Portion of post-implementation Audit of TMI Action Plan Items I.D.1 & I.D.2 Conducted on 890613-16. Implementation of Reactor Coolant Pump Temp Indication Project Rescheduled for Refueling Outage 14 in 1992

ML18033B756
Person / Time
Site:	Robinson
Issue date:	03/02/1990
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TASK-1.D.1, TASK-1.D.2, TASK-TM GL-89-06, GL-89-6, NLS-90-016, NLS-90-16, NUDOCS 9003140279
Download: ML18033B756 (8)

Text

ACCELERATED DI HURON DKMONSTR TION SYSTEM REGULATO INFORMATION DXSTRIBUTION STEM,(RIDS)

.ACCESSION NBR:9003140279 DOC.DATE: 90/03/02 NOTARIZED: NO DOCKET FACIL:50-261 H.B. Robinson Plant, Unit 2, Carolina Power a Light C 05000261 AUTH. NAME .. AUTHOR AFFILIATION CUTTER,A.B. Carolina Power 6 Light Co.

RECIP.NAME RECIPXENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to CRDR portion of post-implementation audit of TMI Action Plan Items I.D.l 6 I.D.2 conducted on 890613-16.

DISTRIBUTION CODE: A003D COPIES RECEIVED:LTR TITLE: OR/Licensing Submittal: Suppl 1 Z ENCL ( SIZE:

to NUREG-0737(Generic Ltr 82-33)

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 7 7 LO,R 1 1 INTERNAL: NRR/DLPQ/LHFB11 1 1 NUDOCS-ABSTRACT 1 1 OC/LFMB 1 0 E~IL Ol 1 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 D

NCtZE 'LO ALL>>RIDS" RECIPIENTS:

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TOTAL NUMBER OF COPIES REQUIRED: LTTR 17 ENCL ,16

CML Carolina Power & Light Company P.O. Box 1551 ~ Raleigh. N.C. 27602 SERIAL: NLS-90-016 NR 08 $ 90 A. B CUTTER Vice President Nuclear Services Department United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 RESPONSE TO DCRDR AUDIT OPEN ITEMS Gentlemen:

The Nuclear Regulatory Commission (NRC) conducted a post implementation audit of TMI Action Plan Items I.D. 1, Control Room Design Review (CRDR); and I.D.2, Plant Safety Parameter Display System (SPDS) at Carolina Power & Light Company's (CP&L) H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR2) during June 13-16, 1989. Carolina Power & Light Company responded to the SPDS portion of this audit on August 15, 1989 in conjunction with its response to Generic Letter 89-06, "TMI Action Item I.D.2 Safety Parameter Display System 10CFR50.54(f)." This letter responds to the Control Room Design Review (CRDR) portion of that audit and notifies the NRC of a delay in implementation of one of the commitments made in the CRDR Final Summary Report dated September 1986.

This letter also discusses a discrepancy associated with the corrective actions taken for DCRDR Item 6.2. 13, Meter Scale Replacement Project, which had been implemented as committed by the end of 1988.

Dur ing the subject audit, the NRC noted 32 Human Engineering Discrepancies (HED) in the Control Room walkdown and 10 HEDs in the remote shutdown panel portion. Corrective actions which had already been taken in the Control Room on 14 HEDs and proposed actions for the 10 remote shutdown panel HEDs were found acceptable by NRC. The 18 HEDs which remained open at the end of the audit and the corrective actions CP&L is taking are addressed in the attachment to this letter. The number identifying each open HED corresponds to the item number on NRC's list at the end of the audit.

Five of the HEDs noted in the attachment; 16, 17, 20, 21, and 28 relate to the configuration of the modules on the RTGB. They must be modified concurrently to assure appropriate resolution. As such, the implementation of appropriate demarcation, labeling, etc. has been scheduled to be completed by the end of Refueling Outage 14 (1992). This schedule is necessary due to the complexity of the effort. The HBR2 control board (RTGB) underwent a comprehensive evaluation as part of the original CRDR project in 1986. Changes were implemented as a result of the original evaluation. However, the miniature design of the RTGB created an additional degree of complexity which impacted the evaluation. In the miniature design, the faceplates of the existing

'7t003140279 900302 PDR ADQCK 05000261 P PNU LL

Document Control Desk (NLS-90-016) / Page 2 switch modules are in such close proximity that a means of permanently affixing demarcation/labeling, etc. could significantly impact the maintainability of these modules. Additionally, this miniature design severely limits our ability to reconfigure these modules without major modifications to the RTGB. Therefore, our resolution of these HEDs must revisit the original CRDR and factor in the limitations imposed by the minia-ture design. Resource requirements also contribute to the completion schedule established.

During a review of licensee events involving personnel errors, the audit team considered the corrective actions associated with LER 89-005, "Reactor Trip Due to Inadvertent Closure of Main Steam Isolation Valve," to be inadequate and requested further evaluation of this item. Corrective actions will be evaluated in conjunction with the project to incorporate demarcation and implemented as appropriate during Refueling Outage 14.

As discussed with the CRDR audit team and in accordance with our commitment in our Detailed Control Room Design Review Final Summary Report, dated September 23, 1986 NLS-86-345, CPAL hereby notifies NRC of a necessary schedular change in implementation of the Reactor Coolant Pump Temperature Indication Project, Item 6.2. 18 of the report. This project, originally scheduled for completion during Refueling Outage 13 in 1990, has been rescheduled for Refueling Outage 14 ( 1992). This change is necessary due to implementation of higher priority projects in the 1990 Outage.

As committed in the CRDR Final Summary Report, the meter scale replacement project was completed by December 30, 1988. Following implementation of this project, a discrepancy was found related to the ability of the existing instrumentation to hold its calibration using the new expanded meter scales.

The calibration of these meters was found to drift primarily at the upper and lower ends of their scale range. Of the 48 indicators involved, 37 were found out of tolerance. These out-of-tolerance meters were evaluated both indivi-dually and collectively, and it was determined that no operational concerns existed during the period the meters were out of tolerance. To assure instrument accuracy until permanent corrective actions can be taken, the original meter scales (those replaced by the meter scale replacement project) were returned to service. This resulted in the meter scale replacement project having to be redone, which will be accomplished during Refueling 13.

Should you have any questions regarding this information, please contact Mr. R. M. Prunty at (919) 546-7318.

Yours ry tr y, A. B Cutter ABC/JSK/ecc (589CRS)

Attachment cc: Mr. S. D. Ebneter Mr. L. Garner (NRC HBR)

Mr. R. Lo

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ATTACHMENT CORRECTIVE ACTIONS FOR HEDs

2) Switches too close to the edge of the RTGB (Control Board) panel could lead to inadvertent operation.

Various types/styles of guard rails available are being evaluated.

If suitable for the HBR2 RTGB design, a guard rail will be installed during Refueling Outage 14. This schedule is necessary due to the need to perform seismic reanalyses of the RTGB to assure accept-ability of the appropriate guard rail.

4) Electrohydraulic Control digital displays obscure the component labels for the display.

The labels for the displays have been moved to ensure readability.

5) Lack of meter zone coding.

The RTGB meters will be evaluated to determine where meter zone coding is appropriate for use. Where appropriate, meters will be modified by Refueling Outage 14.

7) Meter scales are too small and contain too many graduations.

Due to the miniature design of the RTGB and its associated panels, the size of the existing meters cannot be increased. Meter graduations are presently designed to support both normal and emergency operation. Specific problems with meter scales identified during the Control Room Design Review were corrected in the meter scale replacement project. As noted in the cover letter, the meter scale replacement project will be redone; however, no fur ther enhancements other than those originally identified are considered appropriate and further enhancements are not planned.

8) Hierarchical labeling is inconsistently applied.

The hierarchical labeling standard, which is included in the Human Factors Design Guide, RNPD Engineering Guideline 3-05, will be evaluated and changes made as required to assure consistency in its application. The RTGB labeling will be evaluated based on the revised standard and changes made as appropriate during Refueling Outage 13.

9) Recorder labels are missing the engineering units associated with the indicated parameters.

The recorder labels have been replaced and the associated engineering unit designations have been provided.

(589CRS)

11) The indicating lights for the Turning Gear and the Seal Oil Backup Pumps on the Turbine Startup Panel are not provided with labels.

Appropriate labels have been provided.

12) Keyed switches are oriented such that when the keys are inserted the key notches are oriented to the top of the RTGB for some keys and to the bottom for others.

There are no manipulations associated with the key switches for which timing is critical. Reorientation of these switches to provide a uniform orientation would require complete replacement of the associated control module. No further actions are planned regarding key switch orientation.

15) The RTGB Incore Monitor Recorders are missing functional labels.

Functional labels have been provided.

16) In general, the labels used for naming/identifying components and component positions throughout the RTGB are too small.

Enhancements relative to label readability and association with specific components will be evaluated in conjunction with the project to incorporate demarcation. Appropriate enhancements will be installed during Refueling Outage 14.

17) The configuration of the system controls and indications on the RTGB does not follow a mimic pattern.

Enhancements will be evaluated and installed as part of the project to incorporate demarcation during Refueling Outage 14.

18) The present lighting configuration of the Control Room produces glare on several indications/meters.

A complete upgrade of both normal and emergency lighting in the control room is being implemented by the end of 1990 under Modification 1010, "Emergency Lighting in Unit 2 Control Room Project."

19) An annunciator cross-reference index is not used.

An annunciator cross-reference index, i.e., an annunciator grid location system, will be implemented as part of the Annunciator System Project during Refueling Outage 14.

20) Hierarchical labeling is not incorporated in the RTGB labeling for some components.

As part of the project to incorporate demarcation, enhancements will be evaluated and installed as appropriate during Refueling Outage 14.

(589CRS)

21) Some <unctional labels used above meters do not include the parameters being measured for the associated meters.

Enhancements will be evaluated and installed as par t of the project to incorporate demarcation during Refueling Outage 14.

24) Component labels are not appropriately located to ensure proper associa-tion with the HVH 1-4 Vibration Reset push buttons.

These labels will be relocated to assure proper association during Refueling Outage 13.

27) Controls and indications are located too high on the RMS panel.

The controls are located 6-9 inches above and the indicators are located 1-11 inches above the 70-inch criteria. Operational experience has shown this not to be a problem. Due to panel design/space limitations, no further actions are planned.

28) Demarcation has not been incorporated on the RTGB.

Demarcation schemes will be evaluated and appropriately implemented during Refueling Outage 14.

(589CRS)

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