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{{#Wiki_filter:REGULA'lOY INFORMATION DISTRIBUTIOTOTEM (RIDS)ACCESSION NBR:8509180073 DOC~DATE: 85/09/13 NOTARIZED:
{{#Wiki_filter:REGULA'lOY INFORMATION DISTRIBUTIOTOTEM         (RIDS)
NO DOCKET" 0 FACIL:50-400 Shearon Harris Nuclear Power Planta Unit]<Carolina 05000400 AUTH'AME AUTHOR AFFILIATION CUTTERFA,BE Carolina Power 8 Light Co.RECIP,NAMEt RECIPIENT AFFILIATION BENTON',R, Office.of Nuclear Reactor Regul ationA Director SUBJECT;Forwards-"CRDR Fina)Summary Rept" in response to SSER]E Open Item]4<Subpart
ACCESSION NBR:8509180073             DOC ~ DATE: 85/09/13 NOTARIZED: NO             DOCKET" 0 FACIL:50-400 Shearon Harris Nuclear Power Planta Unit ]< Carolina                 05000400 AUTH'AME             AUTHOR   AFFILIATION CUTTERFA,BE           Carolina Power 8 Light Co.
].D.]reer rept Suppl 1 to NUREG-0737 8 Reg Guide 1.97.Chronology of util CRDR efforts 8 util*responses to requirements of SSER]<Section 18 also encl+DIS TRI BUT ION CODE: A003D COP IES RECEI VED: L TR ENCl SIZE: l.TITLE': OR/Licensing Submittal:
RECIP,NAMEt         RECIPIENT AFFILIATION BENTON',R,           Office. of Nuclear Reactor Regul ationA Director SUBJECT;   Forwards- "CRDR   Fina) Summary Rept" in response to SSER ]E Open Item   ]4<Subpart ].D.]reer rept Suppl 1 to NUREG-0737       8 Reg Guide   1.97.Chronology of util CRDR efforts 8 util*
Suppl 1 to NUREG~0737(Generic Ltr 82"33)NOTES: RECIPIENT ID CODE/NAMFI NRR LB3 BC COPIES LTTR ENCL 7 70 RECIPIENT ID CODE/NAME COPIES LTTR ENCL INTERNAL: ADM/lFMB NRR PAULSONFW NRR/DHFS/PSRB NRR/DL/ORB5 NRR/DSI/ICSB AB HEG F EXTERNAL: 24X NRC PDR 1 1 2 5 1 1]o 1 1o]0 IE/DEPER/EPB NRR/DHFS/HFEB NRR/DL/ORAB NRR/DSI/CPB NRR/DS I/METB NRR/DS I/RSB RGN2 LPDR NSIC 3 5 1 1 1 1 1]0]0 i*1%TOTAL NUMBER OF COPIES REQUIRED: LTTR 36 ENCL Pt  
responses   to requirements of SSER ]<Section 18 also encl+
~n~)<<1tH CKK Carolina Power&LIght Company SEP 1 S f985 SERIAL: NLS-85-325 Mr.Harold R.Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT r UNIT NO.1-DOCKET NO.50-000 RESPONSE TO SER SUPPLEMENT NO.1, OPEN ITEM NO.10, SUBPART I.DI CONTROL ROOM DESIGN REVIEW
DIS TRI BUT ION CODE: A003D     COP IES RECEI VED: L TR   ENCl   SIZE:   l.
TITLE': OR/Licensing     Submittal: Suppl     1 to NUREG~0737(Generic Ltr 82"33)
NOTES:
RECIPIENT           COPIES            RECIPIENT      COPIES ID CODE/NAMFI       LTTR ENCL       ID CODE/NAME     LTTR ENCL NRR  LB3 BC              7      70 INTERNAL: ADM/lFMB                     1            IE/DEPER/EPB        3 NRR PAULSONFW             1            NRR/DHFS/HFEB        5 NRR/DHFS/PSRB            2            NRR/DL/ORAB          1 NRR/DL/ORB5              5            NRR/DSI/CPB          1 NRR/DSI/ICSB              1            NRR/DS I/METB       1 AB            1            NRR/DS I/RSB         1 HEG F                            ]o    RGN2                 1 EXTERNAL: 24X                          1     1o    LPDR                      ]0 NRC  PDR                        ]0   NSIC                      ]0 i
* 1%
TOTAL NUMBER OF COPIES REQUIRED: LTTR               36   ENCL   Pt


==Dear Mr.Denton:==
        ~ n
Carolina Power 4 Light Company (CPRL)hereby submits additional information concerning the Shearon Harris Nuclear Power Plant (SHNPP)Control Room Design Review (CRDR)in response to the SHNPP Safety Evaluation Report (SER), Supplement No.1, Open Item No.10, Subpart I.D.1.Enclosure I provides a background on CPRL's CRDR ef for ts including a chronology of the licensing correspondence concerning the issue.Enclosure 2 presents each requirement of SER Supplement No.1, Section 18, with the corresponding CPRL response.Enclosure 3 is the CRDR Final Summary Report, which includes the relevant information on the SHNPP CRDR needed to complete the Staff's review.With this submittal, CPdcL considers this issue closed.If there are any further questions, please contact Mr.David McCarthy at (919)362-2010 or (919)836-7715.Yours very tru ABC/DCM/rtj (1908CGL)Enclosures A.B.Cutter-Vice Pre ident Nuclear Engineering ttt: Licensing CC: Mr.B.C.Buckley (NRC)Mr.G.F.Maxwell (NRC-SHNPP)
~ ) <<1tH
Dr.3.Nelson Grace (NRC-RII)Mr.Travis Payne (KUDZU)Mr.Daniel F.Read (CHANGE/ELP)
 
Wake County Public Library Mr.Wells Eddleman Mr.R.Ramirez (NRC)Mr.3ohn D.Runkle Dr.Richard D.Wilson Mr.G.O.Bright (ASLB)Dr.3.H.Carpenter (ASLB)Mr.3.L.Kelley (ASLB)(g0[I t..PDR ADOCK 0S000400-.
CKK Carolina Power & LIght Company SEP 1 S  f985 SERIAL: NLS-85-325 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT r      UNIT NO. 1  DOCKET NO. 50-000 RESPONSE TO SER SUPPLEMENT NO. 1, OPEN ITEM NO. 10, SUBPART I.DI CONTROL ROOM DESIGN REVIEW
F PDR"'.-'11 Fa yettevilte Street~P.O.Box 1551~Raleigh, N.C.27602 ENCLOSURE 1 to NLS-85-325
 
~Back round Carolina Power R Light Company (CP&L)conducted a control room human factors design evaluation between April 1980 and 3anuary 1981.By letter dated December 7, 1982, CP&L submitted to the NRC a detailed CRDR Report based on NUREG/CR-1580 criteria.This submittal included evaluations and recommendations concerning the following:
==Dear Mr. Denton:==
human engineering requirements specifications main control board design annunciator review anthropometrics and workspace systems operation analysis emergency procedures review.In the 3anuary 1983 Draft SER, the NRC stated that CP&L should submit a report addressing the points of a program plan (in accordance with NUREG-0700 and NUREG-0737, Supplement No.1)along with a schedule for completing the CRDR and implementing modifications.
 
Furthermore, in a March 25, 1983 meeting, NRC requested CP&L to provide the following:
Carolina Power 4 Light Company (CPRL) hereby submits additional information concerning the Shearon Harris Nuclear Power Plant (SHNPP) Control Room Design Review (CRDR) in response to the SHNPP Safety Evaluation Report (SER),
description of CRDR methods and procedures review staff composition and qualifications resolution of'Summary Report'ecommendations.
Supplement No. 1, Open Item No. 10, Subpart I.D.1.
The Company responded to this request by letter dated 3une 1, 1983.The NRC staff conducted a CRDR audit of the redesigned control room layout and the redesigned main control board on August 15-19, 1983 which resulted in a request for additional documentation (September 9, 1983)to include descriptions of the following:
Enclosure I provides a background on CPRL's CRDR ef for ts including a chronology of the licensing correspondence concerning the issue. Enclosure 2 presents each requirement of SER Supplement No. 1, Section 18, with the corresponding CPRL response. Enclosure 3 is the CRDR Final Summary Report, which includes the relevant information on the SHNPP CRDR needed to complete the Staff's review.
an analysis performed for developing the control board arrangement (Function/Task Analysis);
With this submittal, CPdcL considers this issue closed. If there are any further questions, please contact Mr. David McCarthy at (919) 362-2010 or (919) 836-7715.
an analysis for implementing corrections to Human Engineering Discrepancies (HEDs);and an implementation plan for verifying the Main Control Board design.CP&L responded to this request by letter dated September 27, 1983.The response also included a description of the development, verification, and validation process for Emergency Operating Procedures.
Yours very tru A. B. Cutter - Vice Pre ident Nuclear Engineering ttt: Licensing ABC/DCM/rtj (1908CGL)
Enclosures CC:     Mr. B. C. Buckley (NRC)                                     Mr. R. Ramirez (NRC)
Mr. G. F. Maxwell (NRC-SHNPP)                               Mr. 3ohn D. Runkle Dr. 3. Nelson Grace (NRC-RII)                               Dr. Richard D. Wilson Mr. Travis Payne (KUDZU)                                   Mr. G. O. Bright (ASLB)
( g0 Mr. Daniel F. Read (CHANGE/ELP)                             Dr. 3. H. Carpenter (ASLB)
Wake County Public Library                                  Mr. 3. L. Kelley (ASLB)
Mr. Wells Eddleman
[I 0S000400-.
t.. PDR F
ADOCK PDR "'.-'11 Fa yettevilte Street ~ P. O. Box 1551 ~ Raleigh, N. C. 27602
 
ENCLOSURE       1 to NLS-85-325
                                        ~Back   round Carolina Power R Light Company (CP&L) conducted a control room human factors design evaluation between April 1980 and 3anuary 1981. By letter dated December 7, 1982, CP&L submitted to the NRC a detailed CRDR Report based on NUREG/CR-1580 criteria. This submittal included evaluations and recommendations concerning the following:
human engineering requirements specifications main control board design annunciator review anthropometrics and workspace systems operation analysis emergency procedures review.
In the 3anuary 1983 Draft SER, the NRC stated that CP&L should submit a report addressing the points of a program plan (in accordance with NUREG-0700 and NUREG-0737, Supplement No. 1) along with a schedule for completing the CRDR and implementing modifications. Furthermore, in a March 25, 1983 meeting, NRC requested CP&L to provide the following:
description of CRDR methods and procedures review staff composition and qualifications resolution of 'Summary Report'ecommendations.
The Company responded to this request by letter dated 3une 1, 1983.
The NRC staff conducted a CRDR audit of the redesigned control room layout and the redesigned main control board on August 15-19, 1983 which resulted in a request for additional documentation (September 9, 1983) to include descriptions of the following:
an analysis performed for developing the control board arrangement (Function/Task Analysis);
an analysis for implementing corrections to Human Engineering Discrepancies (HEDs); and an implementation plan   for verifying the Main Control Board design.
CP&L responded to this request by letter dated September 27, 1983. The response also included a description of the development, verification, and validation process for Emergency Operating Procedures.
In the 3anuary 1980 ACRS subcommittee meetings, CP&L discussed the history of the CRDR project, including:
In the 3anuary 1980 ACRS subcommittee meetings, CP&L discussed the history of the CRDR project, including:
redesign of the control room layout redesign of the main control board emergency operating procedures integration of other NUREG-0737, Supplement No.1, requirements (1908CGL/r t j) 0   NLS-85-325 ERFIS SPDS qualifications of human factors reviewers.
redesign of the control room layout redesign of the main control board emergency operating procedures integration of other NUREG-0737, Supplement No. 1, requirements (1908CGL/r t j)
NRC identified areas where the Staff needed additional information to complete its review in its November 1983 SER and 3uly 1980 Supplement No.1 to the SER.Furthermore, shortly after issuing SER Supplement No.1, NRC transmitted requests for additional information (3uly 1983 comments on CPdcL's December 1982 CRDR report, and March 1980 comments on the August 1983 audit).Since these comments were based on much earlier work, CPRL considers the SER Supplement No.1 requirements as encompassing this transmittal.
 
CP&L provided preliminary information in response to the SER by letters dated 3anuary I I and April 9, 1985.The April submittal included a Summary Report.Enclosures 2 and 3 to this submittal complete the response to the SER.The major documentation concerning the SHNPP CRDR is summarized in the following chronology.(l908CGL/rtj
0 Enclosure 1 NLS-85-325 ERFIS SPDS qualifications of human factors reviewers.
)
NRC identified areas where the Staff needed additional information to complete its review in its November 1983 SER and 3uly 1980 Supplement No. 1 to the SER.
Cll   NLS-85-325 CRDR LICENSING CHRONOLOGY 0/80 7/80 11/80 1/28/81 9/81 12/7/82 12/17/82 1/83 3/25/83 0/15/83 6/1/83 8/15-19/83 9/6/83 9/19/83 9/27/83 11/83 I/3-0/80 7/80 CP&L begins evaluating CR design.NRC issues NUREG/CR-1580.
Furthermore, shortly after issuing SER Supplement No. 1, NRC transmitted requests for additional information (3uly 1983 comments on CPdcL's December 1982 CRDR report, and March 1980 comments on the August 1983 audit). Since these comments were based on much earlier work, CPRL considers the SER Supplement No. 1 requirements as encompassing this transmittal.
NRC issues NUREG-0737 CP&L completes Human Factors Design Evaluation (CRDR)(not formally submitted to NRC until 12/7/82).NRC issues NUREG-0700.
CP&L provided preliminary information in response to the SER by letters dated 3anuary I I and April 9, 1985. The April submittal included a Summary Report.
CP&L submits"Human Factors Design Evaluation Report for Shearon Harris Vnit 1 Control Room" to NRC based on NUREG/CR-1580 criteria.t NRC issues NUREG-0737, Supplement No.l.NRC issues DSER-requires CP&L to follow NVREG-0700 criteria for CRDR.CP&L meets with NRC.NRC requests additional information on CRDR.CP&L submits letter on Emergency Response Capability, includes discussion on CRDR.CPRL submits CRDR'program plan,'esponding to 3/25/83 request from NRC.NRC audits CRDR, comparing CP&:L's efforts against NUREG-0700.
Enclosures 2 and 3 to this submittal complete the response to the SER.
CP&L submits information on compliance with Regulatory Guide 1.97.NRC submits summary of audit.CPRL submits additional information as requested at audit.NRC issues SHNPP SER;Open Item 10, Subpart I.D.1, addresses CRDR.ACRS meetings discussed CRDR and integration of CRDR activities with SPDS.NRC issues Supplement No.1 to SER;updating Open Item No.10, Subpart I.D.1, CRDR.(1908CGL/rtj
The major documentation concerning the SHNPP CRDR is summarized in the following chronology.
)
(l908CGL/rtj )
ik   NLS-85-325 8/80 1/11/85 0/9/85 NRC requests additional information, forwarding 7/23/83 comments on 12/7/82 submittal and 3/28/80 comments on 8/83 audit.CPRL submits additional information on CRDR.CPRL submits preliminary CRDR Summary Report.(1908CGL/rtj
 
)
Cll Enclosure 1 NLS-85-325 CRDR LICENSING CHRONOLOGY 0/80               CP&L begins evaluating CR design.
NLS-85-325 ENCLOSURE 2 to NLS-85-325 Res onse to SHNPP SER Su lement No.1, 0 n Item No.10.Sub art I.D.I: Control Room Desi n Review l.Action Re ired b SER Su lement No.1, Section 18.6(1): "Provide a detailed descri ption of the Shearon Harris system function and task-analysis." (SFTA)Furthermore, Section 18.0.1 states: "The staff finds that the applicant must provide a more complete rationale and justification of the method for conducting task analysis for the staff to determine whether the requirements of Supplement No.1 to NUREG-0737 have been satisfied."~kli CPRL described the SHNPP SFTA in its December 7, 1982, April 15, 1983, 3une 1, 1983, September 27, 1983, and April 9, 1985 submittals.
7/80                NRC issues NUREG/CR-1580.
The Company's April 15 and 3une I, 1983 submittals indicated that CPRL used H.B.Robinson Unit 2 (also a Westinghouse PWR Emergency Operating Procedures (EOPs)adapted to the SHNPP design to perform the task analysis.The 3une submittal indicated that these EOPs were used at the simulator to videotape operator activities in abnormal operating and emergency situations.
11/80              NRC issues NUREG-0737 1/28/81            CP&L completes Human Factors Design Evaluation (CRDR) (not formally submitted to NRC until 12/7/82).
In turn, the videotapes were reviewed by senior human factors specialists to analyze task flows for human factors concerns.This letter also stated that operational information was obtained from H.B.Robinson operators cross-trained to SHNPP and through document reviews (such as FSAR and system descriptions).
9/81                NRC issues NUREG-0700.
In the September 1983 letter, CPRL described involvement in the development and use of the Westinghouse Owners'roup (WOG)Emergency Response Guidelines (ERGs), Revision l.CPRL committed to the following:
12/7/82            CP&L submits "Human Factors Design Evaluation Report for Shearon Harris Vnit 1 Control Room" to NRC based on NUREG/CR-1580 criteria.
identifying SHNPP EOPs deviations from the generic EOPs task analyzing those deviations generating plant-specific lists of instruments and controls needed to perform the EOPs in the SHNPP control room comparing the lists to control room design to identify missing or additionally needed components reviewing the Generic Task Analysis along with the ERGs deviations analysis to ensure review of each EOP step and resolving any discrepancies The letter further stated that the functional analysis that CPRL would perform in redesigning the Main Control Board (MCB)would preclude major human engineering discrepancies.
t 12/17/82            NRC issues NUREG-0737, Supplement No.       l.
Sections 6.1.3.3 and 6.0 of the Final Summary Report (Enclosure 3)describe the SFTA in detail including how CPRL used Revision 1 of the WOG ERGs, and the WOG High Pressure (HP)Basic System Review and Task Analysis (SRTA)to develop the plant-speci f ic SFTA.(1908CGL/rtj
1/83                NRC issues DSER - requires CP&L to follow NVREG-0700 criteria for CRDR.
)
3/25/83            CP&L meets with NRC. NRC requests additional information on CRDR.
NLS-85-325 The methodology of the SFTA is outlined below: I.Plant-specific ERGs were prepared based on the WOG ERGs.2.A EOP/ERG Transition Document was prepared which (a)lists differences between the ERG High Pressure (HP)reference plant and SHNPP, (b)explains differences between a WOG and SHNPP step (using step deviation forms), and (c)describes deviations for SHNPP EOP parameters.
0/15/83            CP&L submits letter on Emergency Response Capability, includes discussion on CRDR.
3.Using the SHNPP ERGs, the Transition Document, and other pertinent data, the WOG HP Basic SRTA was converted into a plant-specific SFTA.For each plant-specific ERG, CPkL prepared a plant-specific Task/System Sequence Matrix and Element Table (similar to the WOG tables).The Matrices provided inventories of tasks and sub-tasks; the Element Tables described tasks and include related knowledge, task decision, action, instrumentation, and control requirements.
6/1/83              CPRL submits CRDR 'program plan,'esponding to 3/25/83 request from NRC.
0.A list consisting of plant-specific action and information requirements for each task, was generated using ACTION-INFORMATION REQUIREMENTS DETAIL Forms.This form breaks down each task into behavioral elements.5.After computerizing the system, data were selected and sorted by task to summarize information and action requirements.
8/15-19/83          NRC audits CRDR, comparing CP&:L's efforts against NUREG-0700.
9/6/83              CP&L submits information on compliance with Regulatory Guide 1.97.
9/19/83            NRC submits summary of audit.
9/27/83            CPRL submits additional information as requested at audit.
11/83              NRC issues SHNPP SER; Open Item 10, Subpart I.D.1, addresses CRDR.
I/3-0/80            ACRS meetings discussed CRDR and integration of CRDR activities with SPDS.
7/80                NRC issues Supplement No. 1 to SER; updating Open Item No. 10, Subpart I.D.1, CRDR.
(1908CGL/rtj )
 
ik Enclosure 1 NLS-85-325 8/80   NRC requests additional information, forwarding 7/23/83 comments on 12/7/82 submittal and 3/28/80 comments on 8/83 audit.
1/11/85 CPRL submits additional information on CRDR.
0/9/85  CPRL submits preliminary CRDR Summary Report.
(1908CGL/rtj )
 
Enclosure 2 NLS-85-325 ENCLOSURE 2 to NLS-85-325 Res onse to SHNPP SER Su           lement No. 1, 0 n Item No. 10. Sub art I.D.I:
Control Room Desi n Review
: l. Action Re     ired b SER Su       lement No. 1, Section 18.6(1):
  "Provide a detailed descri ption of the Shearon Harris system function and task-analysis." (SFTA)
Furthermore, Section 18.0.1 states:
          "The staff finds that the applicant must provide a more complete rationale and justification of the method for conducting task analysis for the staff to determine whether the requirements of Supplement No. 1 to NUREG-0737 have been satisfied."
  ~kli CPRL described the SHNPP SFTA in its December 7, 1982, April 15, 1983, 3une 1, 1983, September 27, 1983, and April 9, 1985 submittals.
The Company's April 15 and 3une I, 1983 submittals indicated that CPRL used H. B.
Robinson Unit 2 (also a Westinghouse PWR Emergency Operating Procedures (EOPs) adapted to the SHNPP design to perform the task analysis. The 3une submittal indicated that these EOPs were used at the simulator to videotape operator activities in abnormal operating and emergency situations. In turn, the videotapes were reviewed by senior human factors specialists to analyze task flows for human factors concerns. This letter also stated that operational information was obtained from H. B. Robinson operators cross-trained to SHNPP and through document reviews (such as FSAR and system descriptions).
In the September 1983     letter, CPRL described involvement in the development and use of the Westinghouse Owners'roup (WOG) Emergency Response Guidelines (ERGs), Revision l. CPRL committed to the following:
identifying SHNPP EOPs deviations from the generic EOPs task analyzing those deviations generating plant-specific lists of instruments and controls needed to perform the EOPs in the SHNPP control room comparing the lists to control room design to identify missing or additionally needed components reviewing the Generic Task Analysis along with the ERGs deviations analysis to ensure review of each EOP step and resolving any discrepancies The letter further stated that the functional analysis that CPRL would perform in redesigning the Main Control Board (MCB) would preclude major human engineering discrepancies.
Sections 6.1.3.3 and 6.0 of the Final Summary Report (Enclosure 3) describe the SFTA in detail including how CPRL used Revision 1 of the WOG ERGs, and the WOG High Pressure (HP) Basic System Review and Task Analysis (SRTA) to develop the plant-speci fic SFTA.
(1908CGL/rtj )
 
Enclosure 2 NLS-85-325 The methodology of the SFTA is outlined below:
I. Plant-specific ERGs were prepared based on the WOG ERGs.
: 2. A EOP/ERG Transition Document was prepared which (a) lists differences between the ERG High Pressure (HP) reference plant and SHNPP, (b) explains differences between a WOG and SHNPP step (using step deviation forms), and (c) describes deviations for SHNPP EOP parameters.
: 3. Using the SHNPP ERGs, the Transition Document, and other pertinent data, the WOG HP Basic SRTA was converted into a plant-specific SFTA. For each plant-specific ERG, CPkL prepared a plant-specific Task/System Sequence Matrix and Element Table (similar to the WOG tables). The Matrices provided inventories of tasks and sub-tasks; the Element Tables described tasks and include related knowledge, task decision, action, instrumentation, and control requirements.
: 0. A list consisting of plant-specific action and information requirements for each task, was generated using ACTION-INFORMATIONREQUIREMENTS DETAIL Forms. This form breaks down each task into behavioral elements.
: 5. After computerizing the system, data were selected       and sorted by task to summarize information and action requirements.
The final SFTA product identifies the action and information requirements and performance criteria for tasks that a SHNPP operator would have to complete under emergency conditions.
The final SFTA product identifies the action and information requirements and performance criteria for tasks that a SHNPP operator would have to complete under emergency conditions.
In conclusion, the information provided in the April and 3une l983 and April 1985 submittals and Final Summary Report adequately describes the SHNPP SFTA.Furthermore, recent discussions with the NRC staff indicated that completion of the process described in the April 9, 1985 submittal would adequately satisfy the NUREG-0737, Supplement No.I, requirements.
In conclusion, the information provided in the April and 3une l983 and April 1985 submittals and Final Summary Report adequately describes the SHNPP SFTA.
Therefore, CPRL considers the SER Supplement No.I, Sections I8.0.l and l8.6(I)open items resolved.2.Action Re ired b SER Su lement No.I, Section I8.6(2): "Describe the process used to compare display and control requirements as determined by the function and task analysis, with the control room inventory." In addition, Section IS.0.2 states: "During the in-progress audit, the applicant stated that the Ebasco panel component list had been substituted for a control room inventory[to check existence of controls and displays on the MCB drawings and confirm content vs.need]....Because of the list used and the fact that the WOG generic function and task analysis does not provide a detailed list of control and display requirements, an accurate comparison of control and display requirements with the inventory is not possible." (1908CGL/r t j)
Furthermore, recent discussions with the NRC staff indicated that completion of the process described in the April 9, 1985 submittal would adequately satisfy the NUREG-0737, Supplement No. I, requirements. Therefore, CPRL considers the SER Supplement No. I, Sections I8.0. l and l8.6(I) open items resolved.
NLS-85-325
: 2. Action Re     ired b SER   Su   lement No. I, Section I8.6(2):
~CPR R CPRL described the process used to compare display and control requirements with the control room inventory in its April 9, 1985 submittal.
  "Describe the process used to compare display and control requirements as determined by the function and task analysis, with the control room inventory."
In addition, Sections 6.1.3.0 and 6.5 of the Final Summary Report describe the control room inventory, and Section 6.6 describes how this inventory was used to verify the availability and suitability of control room (CR)components, as identified in the task analysis.Appendix A-26 of the Final Summary Report contains the HEDs generated by this task (as well as their dispositions).
In addition, Section IS.0.2 states:
The methodology of the comparison process is outlined below: l.The CR and relevant information were reviewed to prepare the inventory, which is a database containing information on each CR component including:
        "During the in-progress audit, the applicant stated that the Ebasco panel component list had been substituted for a control room inventory [to check existence of controls and displays on the MCB drawings and confirm content vs. need]....Because of the list used and the fact that the WOG generic function and task analysis does not provide a detailed list of control and display requirements, an accurate comparison of control and display requirements with the inventory is not possible."
type of component location description or nomenclature application/function identification number labels characteristics (scale ranges, etc.).2.The inventory was compared to the operator action and information requirements identified in the SFTA for each component to verify the presence of required instruments and controls for each task sequence analyzed.3.The inventory was also compared to the range, accuracy trend, nomenclature, and control function requirements in the SFTA database to verify the suitability of CR components.
j (1908CGL/r t )
0.Deviations found in Steps 2 and 3 were documented as HEDs (See Appendix'A of the Final Summary Report for HED disposition).
 
In conclusion, the information provided in the April 1985 submittal and in the Final Summary Report adequately describes the process used to compare display and control requirements with the CR inventory.
Enclosure 2 NLS-85-325
Furthermore, recent discussions with the NRC staff indicated that completion of the process described in the April 1985 submittal would adequately satisfy NUREG-0737, Supplement No.1, requirements.
  ~CPR   R CPRL described the process used to compare display and control requirements with the control room inventory in its April 9, 1985 submittal. In addition, Sections 6.1.3.0 and 6.5 of the Final Summary Report describe the control room inventory, and Section 6.6 describes how this inventory was used to verify the availability and suitability of control room (CR) components, as identified in the task analysis. Appendix A-26 of the Final Summary Report contains the HEDs generated by this task (as well as their dispositions).
Therefore, CPRL considers the SER Supplement No.I, Sections 18.0.2 and 18.6(2)open items resolved.3.Action Re ired b SER Su lement No.1, Section 18.6(3): "Describe the process used to verify that the corrective actions achieved the desired improvement without introducing new HEDs into the control room." CPRL Res onse:As a result of the CRDR (conducted from April 1980 through 3anuary 1981), CPRL redesigned the main control board and modified associated CR components using human factors engineering principles.
The methodology of the comparison process is outlined below:
This complete redesign effort produced an optimum human factors design (This effort is described in CPRL's December 7, 1982, 3une I, 1983, and April 9, 1985 submittals to the NRC).(1908CGL/rtj
: l. The CR and relevant information were reviewed to prepare the inventory, which is a database containing information on each CR component including:
)  
type of component location description or nomenclature application/function identification number labels characteristics (scale ranges, etc.).
~I   NLS-85-325 Furthermore, to provide consistent application of human factors principles throughout CR construction, Human Engineering Requirements Specifications (HERS)were developed and applied in designing features that could not be evaluated at the time of the review (such as CR noise levels, unpurchased equipment, etc.).These HERS included the following areas: P annunciator systems color codes for strip chart recorders, pens, and pointers computer systems demarcation and mimic lines labeling rotary selector switches status/monitor light boxes vertical indicators ambient illumination control room furnishings control room temperature, humidity, and ventilation emergency operating procedures noise procedures protective equipment temporary labels voice communications, unaided and telephone.
: 2. The inventory was compared to the operator action and information requirements identified in the SFTA for each component to verify the presence of required instruments and controls for each task sequence analyzed.
The HEDs identified through this application of human factors guidelines are listed in Appendices A and B of the Final Summary Report.The methods CPRL used to resolve HEDs are described in the responses to Nos.0 and 6 of this enclosure.
: 3. The inventory was also compared to the range, accuracy trend, nomenclature, and control function requirements in the SFTA database to verify the suitability of CR components.
These methods followed human factors guidelines.
: 0. Deviations found in Steps 2 and 3 were documented as HEDs (See Appendix'A of the Final Summary Report for HED disposition).
Section 7.3.0 of the Final Summary Report indicates that corrections were verified to be in compliance with NVREG-0700 human engineering guidelines by using mockups, computer-aided design systems and simulator and H.B.Robinson EOPs (where possible).
In conclusion, the information provided in the April 1985 submittal and in the Final Summary Report adequately describes the process used to compare display and control requirements with the CR inventory. Furthermore, recent discussions with the NRC staff indicated that completion of the process described in the April 1985 submittal would adequately satisfy NUREG-0737, Supplement No. 1, requirements.
In conclusion, the information provided in the December 1982, 3une 1983 and April 1985 submittals, and the Final Summary Report adequately describes the process used to verify that the corrective actions achieved the desired improvement without introducing new HEDs into the control room.Therefore, CPRL considers the SER Supplement No.1, Section 18.6(3)open item resolved.0.Action Re ired b SER Su lement No.1, Section 18.6(0)I'first art]: "For each of the HEDs listed in Part A of the in-progress audit report, the applicant.
Therefore, CPRL considers the SER Supplement No. I, Sections 18.0.2 and 18.6(2) open items resolved.
should give the Staf f the status and proposed resolutions, as ivell as a schedule for implementing cor rective action." Furthermore, Section 18.5.1 states: "For those instances in which an HED with safety significance cannot be designed out of the system, and a decision is made by the applicant not to correct the HED or to only partially correct it, the applicant must provide'ustification for the action taken." (1908CGL/r t j)
: 3. Action Re     ired b SER   Su   lement No. 1, Section 18.6(3):
NLS-85-325 n~R CPRL rovides t P he dispositions of the HEDs listed in Part A of the in-progress audit report (Enclosure 2 of NRC's August 1980 transmittal) in Appendix B of the Final Summary Report.In addition, CPRL-identified HEDs and their dispositions are listed in Appendix A.CPRL described the methods used to prioritize and resolve HEDs in Sections 7.2 and 7.3 of the Final Summary Report.This methodology is outlined below: 1.HEDs were assessed for potential for error based on component design factors, task factors, and human factors.Corrective actions for currently identified HEDs have either been completed (as indicated in Appendices A and B of the Final Summary Report)or are currently in the process of being completed.
  "Describe the process used to verify that the corrective actions achieved the desired improvement without introducing new HEDs into the control room."
CPRL expects to complete these prior to fuel load, with the exception of installation of carpeting (HED No.3100-0107; A17-5), which is expected to be completed prior to commercial operation.
CPRL Res onse:
2.Consequences of the error were estimated.
As a result of the CRDR (conducted from April 1980 through 3anuary 1981), CPRL redesigned the main control board and modified associated CR components using human factors engineering principles. This complete redesign effort produced an optimum human factors design (This effort is described in CPRL's December 7, 1982, 3une I, 1983, and April 9, 1985 submittals to the NRC).
The systems and/or functions that would be affected were used to determine impact.3.Four categories of'severity'ere assigned to the HEDs.The highest category was given to HEDs having errors related to safety-related systems and/or functions and those related to Technical Specifications.
(1908CGL/rtj )
0.HEDs that could be corrected by enhancements, training, and/or procedural revisions were identified.
 
5.HEDs initially identified for correction by enhancement were reassessed for their effect on operator performance.
~ I Enclosure 2 NLS-85-325 Furthermore, to provide consistent application of human factors principles throughout CR construction, Human Engineering Requirements Specifications (HERS) were developed and applied in designing features that could not be evaluated at the time of the review (such as CR noise levels, unpurchased equipment, etc.).
6.For the remaining HEDs, design improvement alternatives were chosen after considering:
These HERS included the following areas:
relevant task analysis data potential constraints costs and benefits (where applicable) impact of operator training, plant maintenance, and documentation reduction in probability of operator error.verification that the improvements provide the necessary correction without creating new HEDs Section 7.3.5 describes the method used for scheduling HED solutions.
P annunciator systems color codes for strip chart recorders, pens, and pointers computer systems demarcation and mimic lines labeling rotary selector switches status/monitor light boxes vertical indicators ambient illumination control room furnishings control room temperature, humidity, and ventilation emergency operating procedures noise procedures protective equipment temporary labels voice communications, unaided and telephone.
The schedule was chosen after considering:
The HEDs identified through this application of human factors guidelines are listed in Appendices A and B of the Final Summary Report. The methods CPRL used to resolve HEDs are described in the responses to Nos. 0 and 6 of this enclosure. These methods followed human factors guidelines.
safety consequences of operator errors that could be caused by the HED integration with other NUREG-0737, Supplement No.1, programs plant construction, turnover, and operational constraints operator training/retraining requirements.
Section 7.3.0 of the Final Summary Report indicates that corrections were verified to be in compliance with NVREG-0700 human engineering guidelines by using mockups, computer-aided design systems and simulator and H. B. Robinson EOPs (where possible).
In conclusion, the information provided in the Final Summary Report adequately describes the resolutions for implementing corrections for the HEDs identified in NRC's in-progress audit report.Furthermore, the methodology described above (1908CGL/r t j)   NLS-85-325 assured that proper resolutions and implementation schedules were chosen for HEDs with safety significance.
In conclusion, the information provided in the December 1982, 3une 1983 and April 1985 submittals, and the Final Summary Report adequately describes the process used to verify that the corrective actions achieved the desired improvement without introducing new HEDs into the control room. Therefore, CPRL considers the SER Supplement No. 1, Section 18.6(3) open item resolved.
Recent discussions with the NRC staff indicated that these methods represented a satisfactory process for evaluating the significance of HEDs and developing corrections.
: 0. Action Re     ired b SER   Su   lement No. 1, Section 18.6(0) I'first art]:
Therefore, CPRL considers the SER Supplement No.I, Sections 18.5.1 and 18.6(0)[first part]open items resolved.Action Re ired b SER Su lement No.I, Section I8.6(0)[second art]: "..provide the results of the evaluation of the following items so the staff can determine whether the requirements of Supplement No.1 to NUREG-0737 have been satisfied." l.2.3.Q, 51 6.7.workspace communications remote shutdown panel recorder panel CRTs process computer and periphirals annunciator systems.CPdcL described these evaluations in its December 7, 1983, 3une 1, 1983, and April 9, 1985 submittals.
  "For each of the HEDs listed in Part A of the in-progress audit report, the applicant.
In addition, the Final Summary Report addresses the evaluation processes and results for each of the items in the sections listed below: NRC Item Section of Final Summar Re ort Addressin l.2.30 5.6.7, workspace communications remote shutdown panel recorder panels CRTs process computer and periphirals annunciator systems 3 2)6 I 3 2~6 2 2 0~6 3 1 3.2, 6.1.3.2, 6.2.2.0, 6.3.1 5.0 6.1.3.2, 6.3.3.10 6.1.3.2, 6.3.3.10 6.1.3.2, 6.2.2.0, 6.3.1, 6.3.3.6 Appendix A of the Final Summary Report contains the HEDs generated as a result of these evaluations and their dispositions.
should give the Staf f the status and proposed resolutions, as ivell as a schedule for implementing cor rective action."
The communications survey has not yet been completed; however, it will be completed prior to fuel load and any related corrections will be dispositioned.
Furthermore, Section 18.5.1 states:
In conclusion, the information provided in previous submittals and in the Final Summary Report adequately addresses the seven items listed above.Therefore, CPkL considers SER Supplement No.1, Section 18.6(0)[second part]open item resolved.Action Re uired b SER Su lement No.I, Section 18.5.2: "Applicant must submit for staff evaluation information concerning any HEDs identified during the verification process, their resolution, and an acceptable time schedule for implementing corrective actions." (1908CGL/r t jNLS-85-325
          "For those instances in which an HED with safety significance cannot be designed out of the system, and a decision is made by the applicant not to correct the HED or to only partially correct it, the applicant must provide
~PR R CPRL describes the verification process in Section 6.6 of the Final Summary Report.(The response to No.0 of this enclosure summarizes the methods used to resolve and schedule HEDs.)This report indicates that HEDs were prepared for any action or information requirement where an appropriate display, control, or other device was missing or where components deviated from selected NUREG-0700 criteria.Appendix A-26 of the Final Summary Report provides a summary description and disposition for HEDs identified in the verification process.Corrective actions for currently identified HEDs have either been completed (as indicated in Appendices A and 8 of the Final Summary Report)or are currently in the process of being completed.
        'ustification for the action taken."
CPdcL expects to complete these prior to fuel load, with the exception of installation of carpeting (HED No.3100-0107; A17-5), which is expected to be completed prior to commercial operation.
(1908CGL/r t j)
In conclusion, the Final Summary Report provides adequate information on the HEDs identified during the verification process, including their resolution and implementation schedule.Therefore, CPRL considers the SER Supplement No.I, Section 18.5.2 open item resolved.Action Re ired b SER Su lement No.1, Section 18.5.3"The applicant did not provide information on coordinating the CRDR activity with the SPDS, Regulatory Guide 1.97, and the emergency response facilities." C~PR R Safet Parameter Dis la S stem (SPDS)CPRL described the coordination of CRDR activities with the SPDS in its April 15, 1983 and April 9, 1985 submittals, as well as in the 3anuary 3, 1980 Advisory Committee on Reactor Safeguards (ACRS)Subcommittee meeting.In the April 1983 submittal, CPRL stated that it would perform the control room design improvement verification and validation activities after the SPDS was installed and functional; in the ACRS meeting, CPRL explained that as a result of the CRDR, the SPDS would be added as two board-mounted CRTs nearest the dedicated ESF controls.Sections 1.3, 6.1.3.2, 6.1.3.7, 6.0.3.10, and 6.3.3.10 of the Final Summary Report (Enclosure 3)also discuss the coordination of CRDR activities with SPDS.Section 1.3 states that the placement of the primary and redundant SPDS CRTs ensure maximum readability of the displays.Re ulator Guide 1.97 CPRL described the coordination of CRDR activities with Regulatory Guide 1.97 requirements in its September 6, 1983 and April 15, 1983 submittals and in the 3anuary 1980 ACRS Subcommittee meeting.In its April 1983 submittal, CPRL indicated that it was developing final Regulatory Guide 1.97 compliance plans following the ERC NUTAC Draft Guidelines for (1908CGL/rtj
 
)
Enclosure 2 NLS-85-325 n
'   NLS-85-325 I Integrated Implementation Plan, and that it would perform the design improvement verification and validation activities after the Regulatory Guide 1.97 instrumentation is installed and functional.
  ~R CPRL P rovides t he dispositions of the HEDs listed in Part A of the in-progress audit report (Enclosure 2 of NRC's August 1980 transmittal) in Appendix B of the Final Summary Report. In addition, CPRL-identified HEDs and their dispositions are listed in Appendix A.
Corrective actions for currently identified HEDs have either been completed (as indicated in Appendices A and B of the Final Summary Report) or are currently in the process of being completed. CPRL expects to complete these prior to fuel load, with the exception of installation of carpeting (HED No. 3100-0107; A17-5), which is expected to be completed prior to commercial operation.
CPRL described the methods used to prioritize and resolve HEDs in Sections 7.2 and 7.3 of the Final Summary Report. This methodology is outlined below:
: 1. HEDs were assessed for potential for error based on component design factors, task factors, and human factors.
: 2. Consequences of the error were estimated. The systems and/or functions that would be affected were used to determine impact.
: 3. Four categories of 'severity'ere assigned to the HEDs. The highest category was given to HEDs having errors related to safety-related systems and/or functions and those related to Technical Specifications.
: 0. HEDs that could be corrected by enhancements,     training, and/or procedural revisions were identified.
: 5. HEDs initially identified for correction by enhancement were reassessed for their effect on operator performance.
: 6. For the remaining HEDs, design improvement alternatives were chosen after considering:
relevant task analysis data potential constraints costs and benefits (where applicable) impact of operator training, plant maintenance, and documentation reduction in probability of operator error.
verification that the improvements provide the necessary correction without creating new HEDs Section 7.3.5 describes the method used for scheduling HED solutions. The schedule was chosen after considering:
safety consequences of operator errors that could be caused by the HED integration with other NUREG-0737, Supplement No. 1, programs plant construction, turnover, and operational constraints operator training/retraining requirements.
In conclusion, the information provided in the Final Summary Report adequately describes the resolutions for implementing corrections for the HEDs identified in NRC's in-progress audit report. Furthermore, the methodology described above (1908CGL/r tj )
 
Enclosure 2 NLS-85-325 assured that proper resolutions and implementation schedules were chosen for HEDs with safety significance. Recent discussions with the NRC staff indicated that these methods represented a satisfactory process for evaluating the significance of HEDs and developing corrections. Therefore, CPRL considers the SER Supplement No. I, Sections 18.5.1 and 18.6(0) [first part] open items resolved.
Action Re     ired b SER Su   lement No. I, Section I8.6(0) [second       art]:
"..provide the results of the evaluation of the following items so the staff can determine whether the requirements of Supplement No. 1 to NUREG-0737 have been satisfied."
: l. workspace
: 2. communications
: 3. remote shutdown panel Q,    recorder panel 51    CRTs
: 6. process computer and periphirals
: 7. annunciator systems.
CPdcL described these evaluations in its December 7, 1983, 3une 1, 1983, and April 9, 1985 submittals. In addition, the Final Summary Report addresses the evaluation processes and results for each of the items in the sections listed below:
Section of Final NRC Item                                  Summar Re ort Addressin
: l. workspace                          3 2) 6  I 3 2~ 6 2 2 0~ 6 3 1
: 2. communications                      3.2, 6.1.3.2, 6.2.2.0, 6.3.1 30    remote shutdown panel              5.0 recorder panels
: 5. CRTs                                6.1.3.2, 6.3.3.10
: 6. process computer and periphirals                        6.1.3.2, 6.3.3.10 7,    annunciator systems                6.1.3.2, 6.2.2.0, 6.3.1, 6.3.3.6 Appendix A of the Final Summary Report contains the HEDs generated as a result of these evaluations and their dispositions. The communications survey has not yet been completed; however, it will be completed prior to fuel load and any related corrections will be dispositioned.
In conclusion, the information provided in previous submittals and in the Final Summary Report adequately addresses the seven items listed above. Therefore, CPkL considers SER Supplement No. 1, Section 18.6(0) [second part] open item resolved.
Action Re uired b SER     Su lement No. I, Section   18.5.2:
"Applicant must submit for staff evaluation information concerning any HEDs identified during the verification process, their resolution, and an acceptable time schedule for implementing corrective actions."
(1908CGL/r t )
j
 
Enclosure 2 NLS-85-325
~PR     R CPRL describes the verification process in Section 6.6 of the Final Summary Report. (The response to No. 0 of this enclosure summarizes the methods used to resolve and schedule HEDs.) This report indicates that HEDs were prepared for any action or information requirement where an appropriate display, control, or other device was missing or where components deviated from selected NUREG-0700 criteria.
Appendix A-26 of the Final Summary Report provides a summary description and disposition for HEDs identified in the verification process. Corrective actions for currently identified HEDs have either been completed (as indicated in Appendices A and 8 of the Final Summary Report) or are currently in the process of being completed. CPdcL expects to complete these prior to fuel load, with the exception of installation of carpeting (HED No. 3100-0107; A17-5), which is expected to be completed prior to commercial operation.
In conclusion, the Final Summary Report provides adequate       information on the HEDs identified during the verification process, including their resolution and implementation schedule. Therefore, CPRL considers the SER Supplement No. I, Section 18.5.2 open item resolved.
Action Re     ired b SER   Su   lement No. 1, Section 18.5.3 "The applicant did not provide information on coordinating the CRDR activity with the SPDS, Regulatory Guide 1.97, and the emergency response facilities."
C~PR   R Safet   Parameter Dis la     S stem (SPDS)
CPRL described the coordination of CRDR activities with the SPDS in its April 15, 1983 and April 9, 1985 submittals, as well as in the 3anuary 3, 1980 Advisory Committee on Reactor Safeguards (ACRS) Subcommittee meeting.
In the April 1983 submittal, CPRL stated that it would perform the control room design improvement verification and validation activities after the SPDS was installed and functional; in the ACRS meeting, CPRL explained that as a result of the CRDR, the SPDS would be added as two board-mounted CRTs nearest the dedicated ESF controls.
Sections 1.3, 6.1.3.2, 6.1.3.7, 6.0.3.10, and 6.3.3.10 of the Final Summary Report (Enclosure 3) also discuss the coordination of CRDR activities with SPDS.
Section 1.3 states that the placement of the primary and redundant SPDS CRTs ensure maximum readability of the displays.
Re ulator   Guide 1.97 CPRL described the coordination of CRDR activities with Regulatory Guide 1.97 requirements in its September 6, 1983 and April 15, 1983 submittals and in the 3anuary 1980 ACRS Subcommittee meeting.
In its April 1983 submittal, CPRL indicated that it was developing final Regulatory Guide 1.97 compliance plans following the ERC NUTAC Draft Guidelines for (1908CGL/rtj )
 
'
Enclosure 2 NLS-85-325 I
Integrated Implementation Plan, and that it would perform the design improvement verification and validation activities after the Regulatory Guide 1.97 instrumentation is installed and functional.
In the January 1980 ACRS meeting, CPRL described the integration of the ERFIS computer system with Regulatory Guide 1.97 requirements.
In the January 1980 ACRS meeting, CPRL described the integration of the ERFIS computer system with Regulatory Guide 1.97 requirements.
Section 1.3 of the Final Summary Report (Enclosure 3)states that CPRL incorporated the Regulatory Guide 1.97 instrumentation into the MCB layout using the same human factors guidelines used in the MCB re-design effort.The Final Summary Report also states that the verification and validation activities have assured that these modifications did not introduce HEDs.Emer enc Res onse Facilities (ERFs)In the January 1980 ACRS meeting, the April 9, 1985 submittal, and Section 1.3 of the Final Summary Report, CPRL states that the same integrated plant computer system (ERFIS)drives the CRTs in the MCB and ERFs.The Final Summary Report further states that the communications systems between the control room and ERFs conform to 10CFR50, Appendix E, requirements.
Section 1.3 of the Final Summary Report (Enclosure 3) states that CPRL incorporated the Regulatory Guide 1.97 instrumentation into the MCB layout using the same human factors guidelines used in the MCB re-design effort.
These documents adequately describe coordinating the CRDR activities with the ERFs.Conclusion:
The Final Summary Report also states that the verification and validation   activities have assured that these modifications did not introduce HEDs.
The information provided in previous submittals and in the Final Summary Report adequately describes the coordinating of the CRDR activities with the SPDS, Regulatory Guide 1.97, and the emergency response facilities.
Emer enc     Res onse Facilities (ERFs)
Therefore, CPdcL considers the SER Supplement No.1, Section 18.5.3 open item resolved.(1908CGL/rtj
In the January 1980 ACRS meeting, the     April 9, 1985 submittal, and Section 1.3 of the Final Summary Report, CPRL states that the same integrated plant computer system (ERFIS) drives the CRTs in the MCB and ERFs. The Final Summary Report further states that the communications systems between the control room and ERFs conform to 10CFR50, Appendix E, requirements. These documents adequately describe coordinating the CRDR activities with the ERFs.
)}}
 
== Conclusion:==
 
The information provided in previous submittals and in the Final Summary Report adequately describes the coordinating of the CRDR activities with the SPDS, Regulatory Guide 1.97, and the emergency response facilities. Therefore, CPdcL considers the SER Supplement No. 1, Section 18.5.3 open item resolved.
(1908CGL/rtj )}}

Revision as of 04:10, 22 October 2019

Forwards Crdr Final Summary Rept in Response to Sser 1, Open Item 14,Subpart 1.D.1,per Suppl 1 to NUREG-0737 & Reg Guide 1.97.Chronology of Util Crdr Efforts & Util Responses to Requirements of Sser 1,Section 18 Also Encl
ML18019A378
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 09/13/1985
From: Cutter A
CAROLINA POWER & LIGHT CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML18019A379 List:
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 NLS-85-325, NUDOCS 8509180073
Download: ML18019A378 (25)


Text

REGULA'lOY INFORMATION DISTRIBUTIOTOTEM (RIDS)

ACCESSION NBR:8509180073 DOC ~ DATE: 85/09/13 NOTARIZED: NO DOCKET" 0 FACIL:50-400 Shearon Harris Nuclear Power Planta Unit ]< Carolina 05000400 AUTH'AME AUTHOR AFFILIATION CUTTERFA,BE Carolina Power 8 Light Co.

RECIP,NAMEt RECIPIENT AFFILIATION BENTON',R, Office. of Nuclear Reactor Regul ationA Director SUBJECT; Forwards- "CRDR Fina) Summary Rept" in response to SSER ]E Open Item ]4<Subpart ].D.]reer rept Suppl 1 to NUREG-0737 8 Reg Guide 1.97.Chronology of util CRDR efforts 8 util*

responses to requirements of SSER ]<Section 18 also encl+

DIS TRI BUT ION CODE: A003D COP IES RECEI VED: L TR ENCl SIZE: l.

TITLE': OR/Licensing Submittal: Suppl 1 to NUREG~0737(Generic Ltr 82"33)

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAMFI LTTR ENCL ID CODE/NAME LTTR ENCL NRR LB3 BC 7 70 INTERNAL: ADM/lFMB 1 IE/DEPER/EPB 3 NRR PAULSONFW 1 NRR/DHFS/HFEB 5 NRR/DHFS/PSRB 2 NRR/DL/ORAB 1 NRR/DL/ORB5 5 NRR/DSI/CPB 1 NRR/DSI/ICSB 1 NRR/DS I/METB 1 AB 1 NRR/DS I/RSB 1 HEG F ]o RGN2 1 EXTERNAL: 24X 1 1o LPDR ]0 NRC PDR ]0 NSIC ]0 i

  • 1%

TOTAL NUMBER OF COPIES REQUIRED: LTTR 36 ENCL Pt

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CKK Carolina Power & LIght Company SEP 1 S f985 SERIAL: NLS-85-325 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT r UNIT NO. 1 DOCKET NO.50-000 RESPONSE TO SER SUPPLEMENT NO. 1, OPEN ITEM NO. 10, SUBPART I.DI CONTROL ROOM DESIGN REVIEW

Dear Mr. Denton:

Carolina Power 4 Light Company (CPRL) hereby submits additional information concerning the Shearon Harris Nuclear Power Plant (SHNPP) Control Room Design Review (CRDR) in response to the SHNPP Safety Evaluation Report (SER),

Supplement No. 1, Open Item No. 10, Subpart I.D.1.

Enclosure I provides a background on CPRL's CRDR ef for ts including a chronology of the licensing correspondence concerning the issue. Enclosure 2 presents each requirement of SER Supplement No. 1, Section 18, with the corresponding CPRL response. Enclosure 3 is the CRDR Final Summary Report, which includes the relevant information on the SHNPP CRDR needed to complete the Staff's review.

With this submittal, CPdcL considers this issue closed. If there are any further questions, please contact Mr. David McCarthy at (919) 362-2010 or (919) 836-7715.

Yours very tru A. B. Cutter - Vice Pre ident Nuclear Engineering ttt: Licensing ABC/DCM/rtj (1908CGL)

Enclosures CC: Mr. B. C. Buckley (NRC) Mr. R. Ramirez (NRC)

Mr. G. F. Maxwell (NRC-SHNPP) Mr. 3ohn D. Runkle Dr. 3. Nelson Grace (NRC-RII) Dr. Richard D. Wilson Mr. Travis Payne (KUDZU) Mr. G. O. Bright (ASLB)

( g0 Mr. Daniel F. Read (CHANGE/ELP) Dr. 3. H. Carpenter (ASLB)

Wake County Public Library Mr. 3. L. Kelley (ASLB)

Mr. Wells Eddleman

[I 0S000400-.

t.. PDR F

ADOCK PDR "'.-'11 Fa yettevilte Street ~ P. O. Box 1551 ~ Raleigh, N. C. 27602

ENCLOSURE 1 to NLS-85-325

~Back round Carolina Power R Light Company (CP&L) conducted a control room human factors design evaluation between April 1980 and 3anuary 1981. By letter dated December 7, 1982, CP&L submitted to the NRC a detailed CRDR Report based on NUREG/CR-1580 criteria. This submittal included evaluations and recommendations concerning the following:

human engineering requirements specifications main control board design annunciator review anthropometrics and workspace systems operation analysis emergency procedures review.

In the 3anuary 1983 Draft SER, the NRC stated that CP&L should submit a report addressing the points of a program plan (in accordance with NUREG-0700 and NUREG-0737, Supplement No. 1) along with a schedule for completing the CRDR and implementing modifications. Furthermore, in a March 25, 1983 meeting, NRC requested CP&L to provide the following:

description of CRDR methods and procedures review staff composition and qualifications resolution of 'Summary Report'ecommendations.

The Company responded to this request by letter dated 3une 1, 1983.

The NRC staff conducted a CRDR audit of the redesigned control room layout and the redesigned main control board on August 15-19, 1983 which resulted in a request for additional documentation (September 9, 1983) to include descriptions of the following:

an analysis performed for developing the control board arrangement (Function/Task Analysis);

an analysis for implementing corrections to Human Engineering Discrepancies (HEDs); and an implementation plan for verifying the Main Control Board design.

CP&L responded to this request by letter dated September 27, 1983. The response also included a description of the development, verification, and validation process for Emergency Operating Procedures.

In the 3anuary 1980 ACRS subcommittee meetings, CP&L discussed the history of the CRDR project, including:

redesign of the control room layout redesign of the main control board emergency operating procedures integration of other NUREG-0737, Supplement No. 1, requirements (1908CGL/r t j)

0 Enclosure 1 NLS-85-325 ERFIS SPDS qualifications of human factors reviewers.

NRC identified areas where the Staff needed additional information to complete its review in its November 1983 SER and 3uly 1980 Supplement No. 1 to the SER.

Furthermore, shortly after issuing SER Supplement No. 1, NRC transmitted requests for additional information (3uly 1983 comments on CPdcL's December 1982 CRDR report, and March 1980 comments on the August 1983 audit). Since these comments were based on much earlier work, CPRL considers the SER Supplement No. 1 requirements as encompassing this transmittal.

CP&L provided preliminary information in response to the SER by letters dated 3anuary I I and April 9, 1985. The April submittal included a Summary Report.

Enclosures 2 and 3 to this submittal complete the response to the SER.

The major documentation concerning the SHNPP CRDR is summarized in the following chronology.

(l908CGL/rtj )

Cll Enclosure 1 NLS-85-325 CRDR LICENSING CHRONOLOGY 0/80 CP&L begins evaluating CR design.

7/80 NRC issues NUREG/CR-1580.

11/80 NRC issues NUREG-0737 1/28/81 CP&L completes Human Factors Design Evaluation (CRDR) (not formally submitted to NRC until 12/7/82).

9/81 NRC issues NUREG-0700.

12/7/82 CP&L submits "Human Factors Design Evaluation Report for Shearon Harris Vnit 1 Control Room" to NRC based on NUREG/CR-1580 criteria.

t 12/17/82 NRC issues NUREG-0737, Supplement No. l.

1/83 NRC issues DSER - requires CP&L to follow NVREG-0700 criteria for CRDR.

3/25/83 CP&L meets with NRC. NRC requests additional information on CRDR.

0/15/83 CP&L submits letter on Emergency Response Capability, includes discussion on CRDR.

6/1/83 CPRL submits CRDR 'program plan,'esponding to 3/25/83 request from NRC.

8/15-19/83 NRC audits CRDR, comparing CP&:L's efforts against NUREG-0700.

9/6/83 CP&L submits information on compliance with Regulatory Guide 1.97.

9/19/83 NRC submits summary of audit.

9/27/83 CPRL submits additional information as requested at audit.

11/83 NRC issues SHNPP SER; Open Item 10, Subpart I.D.1, addresses CRDR.

I/3-0/80 ACRS meetings discussed CRDR and integration of CRDR activities with SPDS.

7/80 NRC issues Supplement No. 1 to SER; updating Open Item No. 10, Subpart I.D.1, CRDR.

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ik Enclosure 1 NLS-85-325 8/80 NRC requests additional information, forwarding 7/23/83 comments on 12/7/82 submittal and 3/28/80 comments on 8/83 audit.

1/11/85 CPRL submits additional information on CRDR.

0/9/85 CPRL submits preliminary CRDR Summary Report.

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Enclosure 2 NLS-85-325 ENCLOSURE 2 to NLS-85-325 Res onse to SHNPP SER Su lement No. 1, 0 n Item No. 10. Sub art I.D.I:

Control Room Desi n Review

l. Action Re ired b SER Su lement No. 1, Section 18.6(1):

"Provide a detailed descri ption of the Shearon Harris system function and task-analysis." (SFTA)

Furthermore, Section 18.0.1 states:

"The staff finds that the applicant must provide a more complete rationale and justification of the method for conducting task analysis for the staff to determine whether the requirements of Supplement No. 1 to NUREG-0737 have been satisfied."

~kli CPRL described the SHNPP SFTA in its December 7, 1982, April 15, 1983, 3une 1, 1983, September 27, 1983, and April 9, 1985 submittals.

The Company's April 15 and 3une I, 1983 submittals indicated that CPRL used H. B.

Robinson Unit 2 (also a Westinghouse PWR Emergency Operating Procedures (EOPs) adapted to the SHNPP design to perform the task analysis. The 3une submittal indicated that these EOPs were used at the simulator to videotape operator activities in abnormal operating and emergency situations. In turn, the videotapes were reviewed by senior human factors specialists to analyze task flows for human factors concerns. This letter also stated that operational information was obtained from H. B. Robinson operators cross-trained to SHNPP and through document reviews (such as FSAR and system descriptions).

In the September 1983 letter, CPRL described involvement in the development and use of the Westinghouse Owners'roup (WOG) Emergency Response Guidelines (ERGs), Revision l. CPRL committed to the following:

identifying SHNPP EOPs deviations from the generic EOPs task analyzing those deviations generating plant-specific lists of instruments and controls needed to perform the EOPs in the SHNPP control room comparing the lists to control room design to identify missing or additionally needed components reviewing the Generic Task Analysis along with the ERGs deviations analysis to ensure review of each EOP step and resolving any discrepancies The letter further stated that the functional analysis that CPRL would perform in redesigning the Main Control Board (MCB) would preclude major human engineering discrepancies.

Sections 6.1.3.3 and 6.0 of the Final Summary Report (Enclosure 3) describe the SFTA in detail including how CPRL used Revision 1 of the WOG ERGs, and the WOG High Pressure (HP) Basic System Review and Task Analysis (SRTA) to develop the plant-speci fic SFTA.

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Enclosure 2 NLS-85-325 The methodology of the SFTA is outlined below:

I. Plant-specific ERGs were prepared based on the WOG ERGs.

2. A EOP/ERG Transition Document was prepared which (a) lists differences between the ERG High Pressure (HP) reference plant and SHNPP, (b) explains differences between a WOG and SHNPP step (using step deviation forms), and (c) describes deviations for SHNPP EOP parameters.
3. Using the SHNPP ERGs, the Transition Document, and other pertinent data, the WOG HP Basic SRTA was converted into a plant-specific SFTA. For each plant-specific ERG, CPkL prepared a plant-specific Task/System Sequence Matrix and Element Table (similar to the WOG tables). The Matrices provided inventories of tasks and sub-tasks; the Element Tables described tasks and include related knowledge, task decision, action, instrumentation, and control requirements.
0. A list consisting of plant-specific action and information requirements for each task, was generated using ACTION-INFORMATIONREQUIREMENTS DETAIL Forms. This form breaks down each task into behavioral elements.
5. After computerizing the system, data were selected and sorted by task to summarize information and action requirements.

The final SFTA product identifies the action and information requirements and performance criteria for tasks that a SHNPP operator would have to complete under emergency conditions.

In conclusion, the information provided in the April and 3une l983 and April 1985 submittals and Final Summary Report adequately describes the SHNPP SFTA.

Furthermore, recent discussions with the NRC staff indicated that completion of the process described in the April 9, 1985 submittal would adequately satisfy the NUREG-0737, Supplement No. I, requirements. Therefore, CPRL considers the SER Supplement No. I, Sections I8.0. l and l8.6(I) open items resolved.

2. Action Re ired b SER Su lement No. I, Section I8.6(2):

"Describe the process used to compare display and control requirements as determined by the function and task analysis, with the control room inventory."

In addition, Section IS.0.2 states:

"During the in-progress audit, the applicant stated that the Ebasco panel component list had been substituted for a control room inventory [to check existence of controls and displays on the MCB drawings and confirm content vs. need]....Because of the list used and the fact that the WOG generic function and task analysis does not provide a detailed list of control and display requirements, an accurate comparison of control and display requirements with the inventory is not possible."

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Enclosure 2 NLS-85-325

~CPR R CPRL described the process used to compare display and control requirements with the control room inventory in its April 9, 1985 submittal. In addition, Sections 6.1.3.0 and 6.5 of the Final Summary Report describe the control room inventory, and Section 6.6 describes how this inventory was used to verify the availability and suitability of control room (CR) components, as identified in the task analysis. Appendix A-26 of the Final Summary Report contains the HEDs generated by this task (as well as their dispositions).

The methodology of the comparison process is outlined below:

l. The CR and relevant information were reviewed to prepare the inventory, which is a database containing information on each CR component including:

type of component location description or nomenclature application/function identification number labels characteristics (scale ranges, etc.).

2. The inventory was compared to the operator action and information requirements identified in the SFTA for each component to verify the presence of required instruments and controls for each task sequence analyzed.
3. The inventory was also compared to the range, accuracy trend, nomenclature, and control function requirements in the SFTA database to verify the suitability of CR components.
0. Deviations found in Steps 2 and 3 were documented as HEDs (See Appendix'A of the Final Summary Report for HED disposition).

In conclusion, the information provided in the April 1985 submittal and in the Final Summary Report adequately describes the process used to compare display and control requirements with the CR inventory. Furthermore, recent discussions with the NRC staff indicated that completion of the process described in the April 1985 submittal would adequately satisfy NUREG-0737, Supplement No. 1, requirements.

Therefore, CPRL considers the SER Supplement No. I, Sections 18.0.2 and 18.6(2) open items resolved.

3. Action Re ired b SER Su lement No. 1, Section 18.6(3):

"Describe the process used to verify that the corrective actions achieved the desired improvement without introducing new HEDs into the control room."

CPRL Res onse:

As a result of the CRDR (conducted from April 1980 through 3anuary 1981), CPRL redesigned the main control board and modified associated CR components using human factors engineering principles. This complete redesign effort produced an optimum human factors design (This effort is described in CPRL's December 7, 1982, 3une I, 1983, and April 9, 1985 submittals to the NRC).

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~ I Enclosure 2 NLS-85-325 Furthermore, to provide consistent application of human factors principles throughout CR construction, Human Engineering Requirements Specifications (HERS) were developed and applied in designing features that could not be evaluated at the time of the review (such as CR noise levels, unpurchased equipment, etc.).

These HERS included the following areas:

P annunciator systems color codes for strip chart recorders, pens, and pointers computer systems demarcation and mimic lines labeling rotary selector switches status/monitor light boxes vertical indicators ambient illumination control room furnishings control room temperature, humidity, and ventilation emergency operating procedures noise procedures protective equipment temporary labels voice communications, unaided and telephone.

The HEDs identified through this application of human factors guidelines are listed in Appendices A and B of the Final Summary Report. The methods CPRL used to resolve HEDs are described in the responses to Nos. 0 and 6 of this enclosure. These methods followed human factors guidelines.

Section 7.3.0 of the Final Summary Report indicates that corrections were verified to be in compliance with NVREG-0700 human engineering guidelines by using mockups, computer-aided design systems and simulator and H. B. Robinson EOPs (where possible).

In conclusion, the information provided in the December 1982, 3une 1983 and April 1985 submittals, and the Final Summary Report adequately describes the process used to verify that the corrective actions achieved the desired improvement without introducing new HEDs into the control room. Therefore, CPRL considers the SER Supplement No. 1, Section 18.6(3) open item resolved.

0. Action Re ired b SER Su lement No. 1, Section 18.6(0) I'first art]:

"For each of the HEDs listed in Part A of the in-progress audit report, the applicant.

should give the Staf f the status and proposed resolutions, as ivell as a schedule for implementing cor rective action."

Furthermore, Section 18.5.1 states:

"For those instances in which an HED with safety significance cannot be designed out of the system, and a decision is made by the applicant not to correct the HED or to only partially correct it, the applicant must provide

'ustification for the action taken."

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Enclosure 2 NLS-85-325 n

~R CPRL P rovides t he dispositions of the HEDs listed in Part A of the in-progress audit report (Enclosure 2 of NRC's August 1980 transmittal) in Appendix B of the Final Summary Report. In addition, CPRL-identified HEDs and their dispositions are listed in Appendix A.

Corrective actions for currently identified HEDs have either been completed (as indicated in Appendices A and B of the Final Summary Report) or are currently in the process of being completed. CPRL expects to complete these prior to fuel load, with the exception of installation of carpeting (HED No. 3100-0107; A17-5), which is expected to be completed prior to commercial operation.

CPRL described the methods used to prioritize and resolve HEDs in Sections 7.2 and 7.3 of the Final Summary Report. This methodology is outlined below:

1. HEDs were assessed for potential for error based on component design factors, task factors, and human factors.
2. Consequences of the error were estimated. The systems and/or functions that would be affected were used to determine impact.
3. Four categories of 'severity'ere assigned to the HEDs. The highest category was given to HEDs having errors related to safety-related systems and/or functions and those related to Technical Specifications.
0. HEDs that could be corrected by enhancements, training, and/or procedural revisions were identified.
5. HEDs initially identified for correction by enhancement were reassessed for their effect on operator performance.
6. For the remaining HEDs, design improvement alternatives were chosen after considering:

relevant task analysis data potential constraints costs and benefits (where applicable) impact of operator training, plant maintenance, and documentation reduction in probability of operator error.

verification that the improvements provide the necessary correction without creating new HEDs Section 7.3.5 describes the method used for scheduling HED solutions. The schedule was chosen after considering:

safety consequences of operator errors that could be caused by the HED integration with other NUREG-0737, Supplement No. 1, programs plant construction, turnover, and operational constraints operator training/retraining requirements.

In conclusion, the information provided in the Final Summary Report adequately describes the resolutions for implementing corrections for the HEDs identified in NRC's in-progress audit report. Furthermore, the methodology described above (1908CGL/r tj )

Enclosure 2 NLS-85-325 assured that proper resolutions and implementation schedules were chosen for HEDs with safety significance. Recent discussions with the NRC staff indicated that these methods represented a satisfactory process for evaluating the significance of HEDs and developing corrections. Therefore, CPRL considers the SER Supplement No. I, Sections 18.5.1 and 18.6(0) [first part] open items resolved.

Action Re ired b SER Su lement No. I, Section I8.6(0) [second art]:

"..provide the results of the evaluation of the following items so the staff can determine whether the requirements of Supplement No. 1 to NUREG-0737 have been satisfied."

l. workspace
2. communications
3. remote shutdown panel Q, recorder panel 51 CRTs
6. process computer and periphirals
7. annunciator systems.

CPdcL described these evaluations in its December 7, 1983, 3une 1, 1983, and April 9, 1985 submittals. In addition, the Final Summary Report addresses the evaluation processes and results for each of the items in the sections listed below:

Section of Final NRC Item Summar Re ort Addressin

l. workspace 3 2) 6 I 3 2~ 6 2 2 0~ 6 3 1
2. communications 3.2, 6.1.3.2, 6.2.2.0, 6.3.1 30 remote shutdown panel 5.0 recorder panels
5. CRTs 6.1.3.2, 6.3.3.10
6. process computer and periphirals 6.1.3.2, 6.3.3.10 7, annunciator systems 6.1.3.2, 6.2.2.0, 6.3.1, 6.3.3.6 Appendix A of the Final Summary Report contains the HEDs generated as a result of these evaluations and their dispositions. The communications survey has not yet been completed; however, it will be completed prior to fuel load and any related corrections will be dispositioned.

In conclusion, the information provided in previous submittals and in the Final Summary Report adequately addresses the seven items listed above. Therefore, CPkL considers SER Supplement No. 1, Section 18.6(0) [second part] open item resolved.

Action Re uired b SER Su lement No. I, Section 18.5.2:

"Applicant must submit for staff evaluation information concerning any HEDs identified during the verification process, their resolution, and an acceptable time schedule for implementing corrective actions."

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Enclosure 2 NLS-85-325

~PR R CPRL describes the verification process in Section 6.6 of the Final Summary Report. (The response to No. 0 of this enclosure summarizes the methods used to resolve and schedule HEDs.) This report indicates that HEDs were prepared for any action or information requirement where an appropriate display, control, or other device was missing or where components deviated from selected NUREG-0700 criteria.

Appendix A-26 of the Final Summary Report provides a summary description and disposition for HEDs identified in the verification process. Corrective actions for currently identified HEDs have either been completed (as indicated in Appendices A and 8 of the Final Summary Report) or are currently in the process of being completed. CPdcL expects to complete these prior to fuel load, with the exception of installation of carpeting (HED No. 3100-0107; A17-5), which is expected to be completed prior to commercial operation.

In conclusion, the Final Summary Report provides adequate information on the HEDs identified during the verification process, including their resolution and implementation schedule. Therefore, CPRL considers the SER Supplement No. I, Section 18.5.2 open item resolved.

Action Re ired b SER Su lement No. 1, Section 18.5.3 "The applicant did not provide information on coordinating the CRDR activity with the SPDS, Regulatory Guide 1.97, and the emergency response facilities."

C~PR R Safet Parameter Dis la S stem (SPDS)

CPRL described the coordination of CRDR activities with the SPDS in its April 15, 1983 and April 9, 1985 submittals, as well as in the 3anuary 3, 1980 Advisory Committee on Reactor Safeguards (ACRS) Subcommittee meeting.

In the April 1983 submittal, CPRL stated that it would perform the control room design improvement verification and validation activities after the SPDS was installed and functional; in the ACRS meeting, CPRL explained that as a result of the CRDR, the SPDS would be added as two board-mounted CRTs nearest the dedicated ESF controls.

Sections 1.3, 6.1.3.2, 6.1.3.7, 6.0.3.10, and 6.3.3.10 of the Final Summary Report (Enclosure 3) also discuss the coordination of CRDR activities with SPDS.

Section 1.3 states that the placement of the primary and redundant SPDS CRTs ensure maximum readability of the displays.

Re ulator Guide 1.97 CPRL described the coordination of CRDR activities with Regulatory Guide 1.97 requirements in its September 6, 1983 and April 15, 1983 submittals and in the 3anuary 1980 ACRS Subcommittee meeting.

In its April 1983 submittal, CPRL indicated that it was developing final Regulatory Guide 1.97 compliance plans following the ERC NUTAC Draft Guidelines for (1908CGL/rtj )

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Enclosure 2 NLS-85-325 I

Integrated Implementation Plan, and that it would perform the design improvement verification and validation activities after the Regulatory Guide 1.97 instrumentation is installed and functional.

In the January 1980 ACRS meeting, CPRL described the integration of the ERFIS computer system with Regulatory Guide 1.97 requirements.

Section 1.3 of the Final Summary Report (Enclosure 3) states that CPRL incorporated the Regulatory Guide 1.97 instrumentation into the MCB layout using the same human factors guidelines used in the MCB re-design effort.

The Final Summary Report also states that the verification and validation activities have assured that these modifications did not introduce HEDs.

Emer enc Res onse Facilities (ERFs)

In the January 1980 ACRS meeting, the April 9, 1985 submittal, and Section 1.3 of the Final Summary Report, CPRL states that the same integrated plant computer system (ERFIS) drives the CRTs in the MCB and ERFs. The Final Summary Report further states that the communications systems between the control room and ERFs conform to 10CFR50, Appendix E, requirements. These documents adequately describe coordinating the CRDR activities with the ERFs.

Conclusion:

The information provided in previous submittals and in the Final Summary Report adequately describes the coordinating of the CRDR activities with the SPDS, Regulatory Guide 1.97, and the emergency response facilities. Therefore, CPdcL considers the SER Supplement No. 1, Section 18.5.3 open item resolved.

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