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{{#Wiki_filter:~~I Enc1osure 8 AUDIT REPORT HUMAN FACTORS ENGINEERING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON<<HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY HATEM ELAYAT JACK W.SAVAGE Lawrence Livermore National Laboratory March 28, 1984 0009R  
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I Enc1osure 8 AUDIT REPORT HUMAN FACTORS ENGINEERING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON<<HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY HATEM ELAYAT JACK W. SAVAGE Lawrence Livermore National Laboratory March 28, 1984 0009R
-.DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY 1.Background 2.Discussion 2.1 Audit Team Activities CONTENTS Pacae 2.2 DCRDR Planning 2.2.1 Review Team Selection 2.2.2 Management Responsibility 2.2.3 Data Management 2.2.4 Equipment and Workspace 2.2.5 Scheduling 5 5 6 7 2.3 Detailed Control Room Design Rhview 2.3.1 Review of Operating Experience 2.3.2 Systems Function and Task Analysis 2.3.3 Control Room Inventory 2.3.4 Control Room Survey 2.3.5 Verification of Task Performance Capabili 2.3.6 Validation of Control Room Functions~~ties 7 7 7 9 9 10 ll 2.4 Assessment and Implementation 2.4.1 Assessment of HEDs 2.4.2 Selection of Design Improvements 2.4.3 Implementation 2.4.4 Verification of Design Improvements
 
.2.4.5 Verification No New HEDs Created.2.4.6 Coordination of Control Room Improvements with Other-Programs 2.5 Reporting 3.Conclusions 4.Ref erences.5.Appendix Part A: HEDs Identified During the In-Progress Audit Part 8: Photo Summary.ll ll 12 12 13 13 13 14 15 16 18 21 26 1.BACKGROUND Item IO-l, Control Room Design Reviews," of Task ID,"Control Room Design," of the Nuclear Regulatory Commission (NRC)action plan developed as a result of the TMI-2 Accident (NUREG-0660), states that operating licensees and applicants for operating licenses will be required to perform a Detailed Control-Room Design Review (DCRDR)to identify and correct design discrepancies.
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The objective, as stated in NUREG-0660, is to improve the ability of nuclear power plant control room operators to prevent or cope with accidents if they occur by improving the information provided to them.Supplement 1 to NUREG-0737 confirmed and clarified the OCROR requirement in NUREG-0660.
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As a result'of Supplement 1 to NUREG-0737, each applicant or licensee is required to conduct their OCROR on a schedule negotiated with NRC.NUREG-0700 describes four phases of the OCROR'o be performed by the applicant and licensee.The phases ar e: 1.Planning 2.Review 3.Assessment and Implementation 4.Reporting NUREG-0801,"Evaluation Criteria for Oe&iled Control Room Design Review," provides the necessary criteria for evaluating each phase.As a requirement of Supplement 1 to NUREG-0737, the applicant and licensee is required to submit a program plan that describes how.the following elements of the OCROR will be accomplished:
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1.Establishment of a qualified multidisciplinary review team.2.Function and task analyses to identify control room operator tasks and information and control requirements during emergency operations.
 
3.A comparison of display and control requirements with a control room inventory..
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4.A control room survey to identify deviations from accepted human factors principles.
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5.Assessment of human engineering discrepancies (HEDs)to determine which HEDs are significant and should be corrected.
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6.Selection of design improvements.
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7.Verification that seIected design improvements will provide the necessary correction.
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8.Verification that improvements will not introduce new HEDs.-1 4~)9.I Coordination of control room improvements with changes from other programs such as SPOS, operator training, Reg.Guide 1.97 instrumentation and upgraded emergency operating procedures
I'UDIT
.The NRC requires each applicant and licensee to submit a summary report at the end of the OCRDR., The report should describe the proposed control room changes, and implementation schedules, and provide justification for leaving safety significant HEDs uncorrected or partially corrected.
            'o  I REPORT HUMAN FACTORS ENGINEERING -.
The NRC will evaluate the organization, process, and results of each OCROR.The evaluation of the applicant OCRDR efforts will consist of the following, as described in NUREG-0801:
DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY CONTENTS Pacae
l.An evaluation of the program plan report submitted by the licensee/applicant.
: 1. Background
2.A visit to some of the plant sites to audit the progr ess of the OCROR programs.3.An evaluation of the licensee/applicant OCROR summary report.4.A possible pre-implementation audit.5.The preparation of a Safety Evaluation Report (SER)that will present the results of the NRC evaluation.
: 2. Discussion 2.1     Audit   Team Activities 2.2     DCRDR   Planning 2.2.1     Review Team Selection 2.2.2     Management Responsibility                         5 2.2.3     Data Management                                   5 2.2.4     Equipment and Workspace                           6 2.2.5     Scheduling                                         7 2.3     Detailed Control Room Design Rhview                         7 2.3.1     Review of Operating Experience                   7 2.3.2     Systems Function and Task Analysis               7 2.3.3     Control Room Inventory                           9 2.3.4     Control Room Survey                         ~  ~  9 2.3.5     Verification of Task Performance Capabili ties  10 2.3.6     Validation of Control Room Functions             ll 2.4     Assessment and Implementation                             ll 2.4.1     Assessment of HEDs                               ll 2.4.2     Selection of Design Improvements                 12 2.4.3     Implementation                                 12 2.4.4     Verification of Design Improvements .           13 2.4.5     Verification No New HEDs Created .               13 2.4.6     Coordination of Control Room Improvements with Other- Programs                         13 2.5     Reporting                                                 14
4~~j 2 D IS CUSS ION I The Shearon-Harris Nuclear Power Plant, Unit 1: (SNNPP-1)operated by Carolina Power and Light Company (CP5L), is an applicant for an operating license.As required by Supplement 1 to NUREG-0737, completion of a DCRDR is required prior to licensing.
: 3. Conclusions                                                       15
A human factors engineering in-progress audit of the Shearon-Harris Nuclear Power Plant Control Room design review was performed at the site on August 15 through August 18, 1983.The audit was carried out by a team from the Human Factors Engineering Branch (HFEB), Division of Human Factors Safety, assisted by consultants from Lawrence Livermore National Laboratory, Livermore, Cal i f orni a.2.1 AUDIT TEAM ACTIVITIES CPKL provided a number of documents to support the NRC in-progress audit prior to, during, and following the audit.These documents are listed below: l.Documents submitted prior to the audit: o Human Factors Design Evaluation Report for the Shearon-Harris Unit 1 Control Room, January 23, 1981, revised September 16, 1981.o Errata sheets of April 14, 1983, for the above report.o Supplementary information attached to CP5L letter LAP-83-156, June 1, 1983.2.Documents made available during and subsequent to the site audit: o Sample HED sheets.o Sample HED status information report.o Sample HED listing.o Shearon-Harris Nuclear Power Plant Unit 1 control room design evaluation records file index.o Representative set of interim MCB panel drawings.0 Additional information requested by NRC audit.team, CPEL letter LAP-83-426, September 27, 1983.Available at the audit site were: a)Shearon-Harris Control Board Simulator, which is significantly different from the main control boar d;and b)Shearon-Harris Main Control Board (MCB), which is still under construction.
: 4. Ref erences   .                                                   16
If CPEL operating and engineering personnel, as well as the human factors consultant from Essex Corporation involved in the DCRDR, were available on a daily basis dur ing the audit.The in-progress audit by the NRC audit.team consisted of briefings, discussions, document r eviews, and a brief review of the Shearon-Harris Simulator and the incomplete Shearon-Harris MCB.The emphasis was on evaluating the organization and processes of the applicant DCRDR.The in-progress audit findings are summarized below.2.2 DCRDR PLANNING 2.2.1 Review Team Selection Supplement 1 to NUREG-0737 requires the establishment of a qualified multidisciplinary review team.Guidelines in team selection are found in NUREG-0700 and NUREG-0801.
: 5. Appendix                                                           18 Part A:     HEDs Identified During the In-Progress Audit         21 Part 8:     Photo Summary   .                                     26
CP&L established a multidisciplinary review team for the DCRDR of the Shearon-Harris Nuclear Plant.The team consisted of CPEL and Essex Corporation personnel, repr esenting a cross-section of.the required disciplines.
: 1. BACKGROUND Item IO-l, Control Room Design Reviews," of Task ID, "Control Room Design,"
The qualifications of the review team members are contained in Appendix A of the CPLL report, and a description of the review team composition was stated in the CPEL letter of June 1, 1983.The review team was divided into the following three groups'.o'uman Factors Evaluation Group.o Human Factors/Operations Support Group..o Project Management/Nuclear Operations/Plant Engineering and Design Group.The Human Factors Evaluation Group was composed of six intermediate and junior level human factors specialists from the Essex Corporation field office located in Raleigh, North Carolina.The group's responsibility was stated to be to conduct data collection, data reduction, and preliminary data analysis;however, the extent of each group member's participation is not clear, with the exception of the group supervisor.
of the Nuclear Regulatory Commission (NRC) action plan developed as a result of the TMI-2 Accident (NUREG-0660), states that operating licensees and applicants for operating licenses will be required to perform a Detailed Control-Room Design Review (DCRDR) to identify and correct design discrepancies. The objective, as stated in NUREG-0660, is to improve the ability of nuclear power plant control room operators to prevent or cope with accidents   if they occur by improving the information provided to them.
The group supervisor's responsibility was to coordinate the evaluation activities, interface with CPEL project manager, and represent the human factors position at HED review meetings.The Human Factors/Operations Support Group was composed of Essex Corpor ation home office personnel located in Alexandria, Virginia.This group consisted of five senior human factors specialists, a nuclear engineer, two reactor operators, three junior human factors specialists, a procedure specialist, and a photographer.
Supplement 1 to NUREG-0737 confirmed and clarified the OCROR requirement in NUREG-0660. As a result'of Supplement   1 to NUREG-0737, each applicant or licensee is required to conduct their     OCROR on a schedule negotiated with NRC.
The overall responsibility of this group was stated to be review, in-depth analysis, discrepancy definition and discrepancy resolution recommendations, data collection support, and operational and engineering analysis.The group leader was not identified for this group, and the extent of each member's participation is not clear.
NUREG-0700   describes four phases of the OCROR'o     be performed by the applicant and licensee. The phases ar e:
The Project Management/Nuclear Operations/Plant Engineering and Design Group was composed of CPKL personnel from various disciplines, representing the Nuclear Plant Engineering Department, System Planning and Coordination Department, Nuclear Operations Department, Nuclear Operations Department'raining.
: 1. Planning
The group leader for this group coordinated the activities of Essex, CPEL, EBASCO (AEE)and the NSSS (Westinghouse), and reviewed the overall progress of the DCROR.This group was supported by EBASCO and Westinghouse representatives to provide any required review and comments on design philosophies, discrepancy analysis, etc.The NRC audit team concluded that the CP&L review team, as described above will satisfy the requirement of Supplement 1 to NUREG-0737 to establish a multidisciplinary review team to conduct a OCROR.2.2.2 Mana ement Res onsibilit NUREG-0700 recommends that applicant management support is needed to ensure'to the OCROR team the availability of information, equipment, and all categor ies of manpower needed to conduct the review.Although not stated in the CPLL report, it was evident during the NRC audit that management fully supported the OCROR process as intended by the guidance in NUREG-0700.
: 2. Review
Some examples of management support stated to the NRC audit team are: o Descriptions of management participation, follow-up, and review of the OCROR and the control room redesign process.o A statement describing how management stopped control board fabrication for several months to allow the review and.redesign modifications to be resolved, thus avoiding wasted construction effort and retrofit expense.o Personnel from other plants were made available to contribute their appropriate expertise and experience.
: 3. Assessment   and Implementation
2.2.3 Data Management NUREG-0700 guidelines recommend that methods of data management should be established prior to the OCRDR.This involves: 1.Providing the review team members with reference material (panel layout drawings, control room floor plans, etc.)2.The selection of standard forms to be used for recording the results of the CR review., 3.The setting up of a system for the management of these standard forms and the data obtained during the DCRDR.During the in-progress audit of Shearon-Harris.Nuclear Power Plant Unit 1, the NRC audit team did not observe an elaborate mechanized data management system being used.However, reference material was provided to the review team, and the forms used to record OCROR data were informally retained in filing cabinets, mostly in their raw form, after being completed by the review team members.The review forms and sheets used in the OCROR are described below: o The Human Engineering discrepancy forms were used to record the discrepancy items and their location on the MCB, a problem description and guidelines violated, the description of the specific operator error(s)resulting from the HED, the list of procedures or operations that use the discrepancy items that induced operator errors, the list of consequences of operator error during all modes of operation, and suggestions for potential backfits.These forms were filled out by survey team members and later checked and validated by the HF consultant.
: 4. Reporting NUREG-0801,   "Evaluation Criteria for Oe&iled Control Room Design Review,"
A panel area layout sheet, which contained a drawing for a specific panel area.HEOs were identified and recorded on these sheets by the team members and subsequently reviewed by the HF consultant and the CP&L project manager.o A computerized HED status information report was used to record all HEDs.The report listed all HEOs by IO number, HED description, and status (i.e., whether resolved, deleted or other status).A coded numbering scheme was used to describe HEDs as follows: o Plant location.o Generating unit location.o Physical location.o Component type or design feature;o HED sequence number.The NRC audit team concluded that the applicant's data management meets the intent of NUREG-0700 guidelines.
provides the necessary criteria for evaluating each phase.
2.2.4 Equipment and Workspace The applicant's plans do not specifically describe plans for the OCROR review team workspace and equipment requirements as recommended in NUREG-0700.
As a requirement of Supplement 1 to NUREG-0737, the applicant and licensee is required to submit a program plan that describes how. the following elements of the OCROR will be accomplished:
However, the NRC audit team understands that adequate meeting spaces in the main control room building and simulator building were made available to the CPEL OCROR team, HF consultant, and operating personnel during the survey and redesign processes.
: 1. Establishment of   a qualified multidisciplinary review   team.
Equipment needs wer e minimal-since the survey and redesign work utilized paper mock-ups and mark-ups of simulator and control room panel drawings, which were supplied by design and drafting room personnel as appropriate.
: 2. Function and task analyses to identify control room operator tasks and information and control requirements during emergency operations.
It is assumed that equipment needed for the remaining CPLL OCROR tasks (e.g., illumination and sound'evel meters, HVAC evaluation equipment, etc.)will be made available to the review team when needed.It was evident to the NRC audit team that adequate clerical, reproduction and other peripheral support services are available whenever needed.
: 3. A comparison of display and control requirements with     a control room inventory..
2.2.5~E NUREG-0700 recommends that the planning of the control room review include the development of a detailed schedule of review tasks.The CP&L report did not describe any schedules for the OCROR processes.
: 4. A control room survey to identify deviations from accepted       human factors principles.
No formal milestone charts,.task schedules, or personnel assignments were observed.As described to the NRC audit team, scheduling was done on a verbal, informal day-to-day basis in a manner to accomplish the required tasks within a predetermined time period.Attendance at the review meetings of individual team members and other personnel was understood to be determined by the needs of the agenda of each particular meeting.Specific personnel attendance was understood to be determined by the CP5L project manager and the Essex human factors engineer, both of whom were always present.Oespite the absence of a formal documented scheduling method, the NRC audit team concluded that the review tasks were adequately staffed and were executed in an acceptable way.Attachment 3 to CPQ letter of September 27, 1983, describes a schedule for development, verification, arid validation of SHNPP-1 EOPs using the simulator initially, and the SHNPP-1 Control Room finally, after the CR is functional.
: 5. Assessment of human engineering discrepancies (HEDs) to determine which HEDs are significant and should be corrected.
2.3 OETAILEO CONTROL ROON OESIGN REVIEM 2.3.1 Review of 0 eratin Ex erience Two steps are recommended by NUREG-0700 guidelines for reviewing operating experience.
: 6. Selection of design improvements.
These include the examination of available documents and the-survey of control room operating personnel.
: 7. Verification that seIected design improvements will provide the necessary correction.
There was no mention in the CPEL report of a formal review or examination of operating experience documents.
: 8. Verification that improvements will not introduce new HEDs.
The NRC audit team is not aware of the details of any formal operator questionnaires or CR operating personnel interview processes.
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However, as described to the NRC audit team, the Har ris operating experience information was collected from operators whose experience was obtained from other plants, including H.B.Robinson, Unit 2.It was stated that operator input was used in the determination of HEO corrective actions and verification that the final designs are user-oriented, as CPEL desires.The NRC audit team concluded that operating experience was factored into the review process directly instead of via a formal interview/reporting process.2.3.2 S stems Function and Task Anal sis Supplement 1 to NUREG-0737 requires the applicant to perform systems function and task analyses to establish the input and output requirements of control room operator tasks to serve as a basis for defining the requirements for control room instrumentation, controls, and other equipment, which will ensure the safe operation of the plant under emergency conditions.
 
This can be accomplished by carrying out the following systems functions and task analysis
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:~steps identified in the NUREG-0700 guidelines.
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l.Identification of Systems and Subsystems.
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2.Identification of Operating Events for Analysis.3.Function Identification.
: 9. Coordination of control room improvements with changes from other programs such as SPOS, operator training, Reg. Guide 1.97 instrumentation and upgraded emergency operating procedures .
4.Operator Task Identification and Analysis.The task analysis performed by CPLL, using NUREG-1580 guidelines, differs from the above NUREG-0700 guidelines because NUREG-0700 was published while the CPKL analysis was still in progress.The task analysis guidelines in NUREG-1580 are based on analyzing rocedures to provide documentation of operator actions, information requirements, an controls and displays used in executing the chosen procedures.
The NRC requires each applicant and licensee to submit a summary report at the end of the OCRDR., The report should describe the proposed control room changes, and implementation schedules, and provide justification for leaving safety significant HEDs uncorrected or partially corrected.
NUREG-0700 task analysis guidelines, on the other hand, are based on a systematic top-down function/task analysis to determine information and Nih b'1 d<<h actual instrumentation and controls which are available in the control room.The NRC audit team observes that there may not be uniformity between CPKL and NUREG-0700 in the meaning of the terms"function" and"functional analysis." In response'to an NRC audit team request, CPEL stated in their letter of September 27, 1983, that a generic top-down task analysis, based on the identification of event sequences, plant systems, and operator functions and tasks (e.g.,'s recommended in NUREG-0700), was performed on the High Pressure (HP)Basic Version of the Westinghouse Owners Group (WOG)Emergency Response Guidelines (ERGs).NRC staff review of the WOG guidelines indicate that they are a satisfactory start in identifying and describing tasks;but that they are generic, not plant specific.They do not identify required information and control capability characteristics sufficiently to compar e to a control room instrumentation and control inventory.
The NRC will evaluate the organization, process, and results of each OCROR.
There is no substantiating documentation describing the details or completeness of the methodology used in the task analysis.It is also not clear to the NRC audit team whether CPEL or the WOG Committee performed the task analysis.It is stated that the primary outputs of the WOG task analysis are tables listing all instruments and controls utilized in performing the ERGs.jt is stated that CP&L plans to use the WOG generic analysis to do the following:
The evaluation of the applicant OCRDR efforts will consist of the following, as described in NUREG-0801:
o Identify SHNPP-Unit 1 deviations from the Generic ERGs.o Task analyze the differences and generate SHNPP-Unit 1 plant-specific lists of instruments and controls required to perform the Harris EOPs in the SHNPP-Unit 1 Control Room.
: l. An evaluation of the program plan report submitted by the licensee/applicant.
o Compare the plant specific equipment lists with the Control Room inventory (see 2.3.3;below)to identify missing components or needed components not included in the design.o Review each step of the SHNPP-Unit 1 EOPs by reviewing the generic task analyses and the ERG deviation analyses., o Resolve and correct applicable identified HEDs.It appears to the NRC audit team that CP5L is contending that the above steps will follow the NUREG-0700 recommendation to define instrumentation and control requirements by a top-down function/task analysis approach.It is the NRC audit team's position that the CPKL process described above may not result in defining operator information and control requirements independently from consideration of equipment that is already installed in the control room.This process may not ensure that the man/machine interface is complete or that an optimal design for safe operation will result.The NRC audit team concluded that a more complete rationale and justification for CPEL's approach to conducting their task analyses will be needed to determine whether the requirements of Supplement 1 to NUREG-0737 have been s ati sf i ed.2.3.3 Control Room Inventor Supplement 1 to NUREG-0737 requires the~pplicant.to make a control room inventory and to compare the operator display and control requirements determined from the task analyses with the control room inventory to determine missing controls and displays.Ouring the in-progress audit it was stated that the EBASCO panel component list was substituted for a control room inventory.
: 2. A visit to some of the plant sites to audit the progr ess of the OCROR programs.
This list was used to check the existence of controls and displays on the MCB panel drawings, to confirm the expected panel content vs.need.The needs, as expressed in the EBASCO component list, were determined by EBASCO and CPEL operating experience.
: 3. An evaluation of the licensee/applicant OCROR summary report.
The NRC audit team's position is that Supplement 1 to NUREG-0737 is not fully satisfied because the WOG generic function and task analysis, as described previously in Section 2.3.2, does not specify control and display characteristic requirements in sufficient detail to permit comparison with the inventory characteristics.
: 4. A possible pre-implementation audit.
2.3.4 Control Room Surve Supplement 1 to NUREG-0737 requires that a control room survey be conducted to identify deviations from accepted human factors principles.
: 5. The preparation of a Safety Evaluation Report (SER) that will present the results of the   NRC evaluation.
NUREG-0700 provides guidelines and criteria for conducting a control room survey.The objective of the control room survey is to identify, for assessment and possible correction, characteristics of displays, controls, equipment, layout, and ambient conditions that do not conform to good human engineering practices.
 
The Harris control room survey was carried out through reviews of plant design documents, reviews of vendor documentation, and reviews of layout drawings.The Shearon-Harris Simulator was used where applicable.
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A to-scale Part 8\-Shearon-Harris Photo Summary'F1ndin Carousel Location 88 89 Photo IDf 17 18 Photo Description Remote Shut-down panel Remote Shut-down panel 90 91 92 93 94 19S ZOS 21S 22S 23S Simulator Panel Simulator Panel Simulator Panel Simulator Panel Simulator Panel 95 96 97 24S 25S 26S Simul ator radi ation monitors Simulator.
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Instrumentation Simulator radiation monitor computer 98 ZTS Simulator remote instructor console 99 Simulator-General view 100 101 29S 30S Simulator-General view Simulator-General view 102 31S CPEL paste-ups:
D IS CUSS
left-original panels;right-new design panels 0009R-31'-
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t II paper mock-up was also used as a basis for identifying HEOs and as a starting point from which to relocate controls and displays.During the course of the in-progress audit, the NRC audit team observed that the simulator room and its environmental aspects do not duplicate those of the main control room, although it continues to be used for training and procedure walk/talk throughs.The CR survey process initiated by CP&L consisted of the following steps: l.Essex Corporation personnel generated initial HEOs by examining panel layout drawings.HEDs were identified by writing a description of the problem on the drawing.Often, several HEOs were identified in this manner.The panel layout drawing literally became a scratch pad upon which the observations of the reviewer were written.These observations later became the basis for determining HED resolutions
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.2.The Essex Corporation field project manager then reviewed and provided the initial verification of these HEDs.3.Next, the CP&L project manager and his assistant reviewed the HEDs for accuracy and completeness and concurred with the potential operational problems the HEOs indicated.
The Shearon-Harris Nuclear Power Plant, Unit 1: (SNNPP-1) operated                 by Carolina Power and Light Company (CP5L), is an applicant for an operating                 license. As required by Supplement 1 to NUREG-0737, completion of a DCRDR is                 required prior to licensing.
4.At this point, the Essex Corporation management reviewed and approved the HEDs in preparation for the following step.5.HEDs were then presented to a group of people at the site for review and resolution.
A human   factors engineering in-progress audit of the Shearon-Harris Nuclear Power   Plant Control Room design review was performed at the site on August 15 through August 18, 1983. The audit was carried out by a team from the Human Factors Engineering Branch (HFEB), Division of Human Factors Safety, assisted by consultants from Lawrence Livermore National Laboratory, Livermore, Cal i forni a.
These people nnsisted of Essex Corporation, EBASCO, Westinghouse, and CP&L training, engineering, construction, and operations personnel as appropriate.
2.1     AUDIT TEAM ACTIVITIES CPKL   provided a number   of documents to support the NRC in-progress audit prior to, during,   and   following the audit. These documents are listed below:
The human factors consultant stated during the in-progress audit that the HEDs will be"designed out" of the board in the course of the review and redesign work by following a policy of correcting the HEDs as many times as necessary to eliminate, them before they determine that the redesign is complete.As a result of the control room audit, it is the NRC audit team's position that the applicant's CR survey meets the intent of NUREG-0700 guidelines and that the applicant intends to satisfy the requirements of Supplement 1 to NUREG-0737.
: l. Documents submitted     prior to the audit:
2.3.5 Verification of Task Performance Ca abilities The objective of"verification of task performance capabilities"'as described in NUREG-0700 guidelines is to assur e that the CR contains sufficient controls and instruments so that operator tasks can be performed in the existing CR with minimum potential for human error.Verification can be accomplished by comparing the instrument and equipment requirement derived from the task analysis to the inventory of existing instrumentation, controls, and other equipment.
o     Human   Factors Design Evaluation Report for the Shearon-Harris Unit 1 Control Room, January 23, 1981, revised September 16, 1981.
This verification step was not carried out at Shearon-Harris since instrument and equipment requirements wer e not derived from the function and task analysis described in NUREG-0700; rather, the task analysis and review process was primarily based on NUREG 1580.It appeared to the NRC audit team that CP&L's version of the verification that was accomplished during the redesign effort was done by using selected-10-'
o   Errata sheets of April 14, 1983, for the above report.
e procedures as a basis to identify operational functions, operator tasks, and to identify the controls and instruments needed to execute the procedures.
o     Supplementary information attached to           CP5L letter LAP-83-156, June 1, 1983.
Plans for future verification of SHNPP-1 EOPs are described in Attachment 3 to CP&L letter of September 27, 1983.The results of this verification should be reported to NRC for review on a schedule acceptable to NRC.2.3e6 Validation of Control Room Functions The objectives of the validation process as outlined in NUREG-0700 is the determination of whether functions allocated to CR operating personnel can be accomplished within the structure of defined operating and emergency procedures and the existing design of the CR.This validation step was not accomplished at Shearon-Harris, nor addressed in the CP&L report.However, Attachment 3 to CP&Ls letter of September 27, 1983, describes their plans to validate the SHNPP.-1 EOPs.The results of this validation should be reported to NRC for review on a schedule acceptable to NRC.2.4 ASSESSMENT AND IMPLEMENTATION 2.4.1 Assessment of HEDs Supplement 1 to NUREG-0737 requires that HEDs be assessed to determine which HEDs are significant and should be corrected.
: 2. Documents made     available during     and subsequent   to the site audit:
NUREG-0700 and NUREG-0801 contain guidelines for the assessment process.A formal documented assessment of HEDs,~s intended by the NUREG-0700 guidelines, was not done by the CP&L review team.Instead, the assessment function was accomplished as one of several parallel iterative processes executed during what CPKL called the~redesi n of the Harris Main Control Boards (MCB).It was stated that the initial HED identification process was completed on each panel before moving to the next.The candidate HEDs were screened by the on-site human factors consultant in conjunction with the CP&L review project manager.Those that survived to be corrected were then discussed (assessed) in batches in meetings attended by the review team membership, which included the human factor s consultant, the CP&L review project manager, CP&L operating and engineering personnel, and EBASCO (A&E)and Westinghouse personnel as appropriate.
o     Sample   HED sheets.
The CP&l project manager and the Essex human factors consultant were always present at all meetings, with additional members present when their expertise was needed.There were many redesign review meetings during which the Harris control room was repeatedly and iteratively laid out.As stated to the NRC audit team, this process included discussion of many alternate resolutions prior to the selection of the final resolution to each HED.The stated CP&l policy was to correct every HED by designing it out of the system, with the objective of achieving an HED-free board.The execution of this philosophy obviates the necessity to follow the NUREG-0700 recommendations of formally assessinq each HED for importance, potential safety consequences, the cumulative impact of minor HEDs, determination of priorities, setting implementation schedules, etc.
o     Sample   HED status information report.
The NRC audit team concludee that the applicant's method will satisfy the requirements of Supplement 1 to NUREG-0737.
o     Sample   HED listing.
2.4.2 Selection of Desi n Im rovements Supplement 1 to NUREG-0737 requires selection of control room design improvements that will correct significant HEDs.It also states that improvements that can be accomplished with an enhancement program should be done promptly.As stated in Section 2.4.1.of this report, alternate design improvements for each HEO wer e considered during the CP5L redesign review process, and this function was another iterative parallel process executed dur ing the redesign of the Harris MCB.NUREG-1580 criteria, along with the Essex developed Human Engineering Requirements Specifications (HERS)are understood to have been used to support the review team choice of resolutions for each HED.As described in the Harris Report, the conduct of the redesign effort appear s to have been similar to the determination of a new design.Some examples f ol low.The Harris Report, Section 4, Annunciator Review, and their letter, LAP-83-426, of September 27, 1983, states that the annunciator need, location, and grouping considerations resulted in removing about 250 tiles from the MCB.Also, it was stated to the NRC audit team that the MCB redesign rdview resulted in the removal of about 200 cotttrols and the relocation of a significant number of unnecessary items from front to rear panels.EBASCO and Westinghouse concurrence was obtained for CP5L proposed component removals.Appendix 0 of the Harris report;"Reconmended Control Room Equipment Arrangement," describes how the recommended panel arrangements were determined by consider ing such factors as equipment location desirability, the readability of displays and labels from various MCB locations, visual angles, adverse effect on short-term operators'emory because of movement distances between equipment, discrimination problems due to viewing distances, etc.In addition, a quarter scale mock-up was used to study and confirm rearrangement of the boards.The mock-up was also used to verify and confirm labeling, demarcation, and annunciator arrangement.
o     Shearon-Harris     Nuclear Power Plant Unit       1 control room design evaluation records       file index.
It was stated that part of the redesign effort included ongoing discussions with operators to verify that the MCB redesign details and HED corrective actions were compatible with operational needs, and left no discrepancies uncorrected.
o     Representative     set of interim     MCB panel drawings.
This included verification that any equipment found missing was, or would be, installed before the redesign was considered complete.The NRC audit team concluded that the applicant will satisfy requirements of Supplement 1 to NUREG-0737 if the SHNPP OCRDR summary report completely documents the methodology and results of design improvement selection so that the NRC can confirm that the requirements have been satisfied.
0     Additional information requested by           NRC audit. team,   CPEL letter LAP-83-426, September       27, 1983.
NUREG-0700 describes guidelines for determining the implementation schedule for des i gn improvements.
Available at the audit site were: a) Shearon-Harris Control Board Simulator, which is significantly different from the main control boar d; and b)
The Harris Report does not include a section on implementation because their 0 policy of correcting all HEDs during the.execution of the redesign process pr ior to operation obviates it.The CPSL letter, LAP-83-156, of June 3, 1983, expresses confidence that the verification and validation following the availability of the WOG task analysis and generic guidelines, and the completion of SHNPP EOPs verification and validation will reveal few,'if any, MCB human factors concerns.If any HEDs should be identified the NRC audit team concluded that a continuation of the CPEL redesign corrective action policy will result in their correction.
Shearon-Harris Main Control Board (MCB), which is still under construction.
 
If CPEL   operating and engineering personnel, as well         as the human factors consultant from Essex Corporation involved in the           DCRDR, were available on a daily basis dur ing the audit.
The in-progress audit by the NRC audit .team consisted of briefings, discussions, document r eviews, and a brief review of the Shearon-Harris Simulator and the incomplete Shearon-Harris MCB. The emphasis was on evaluating the organization and processes of the applicant DCRDR. The in-progress audit findings are summarized below.
2.2     DCRDR PLANNING 2.2.1     Review Team Selection Supplement   1 to NUREG-0737   requires the establishment of a qualified multidisciplinary review       team. Guidelines in team selection are found in NUREG-0700 and NUREG-0801.
CP&L   established a multidisciplinary review team for the DCRDR of the Shearon-Harris Nuclear Plant. The team consisted of CPEL and Essex Corporation personnel, repr esenting a cross-section of. the required disciplines.
The qualifications of the review team members are contained in Appendix A of the CPLL report, and a description of the review team composition was stated in the CPEL letter of June 1, 1983.
The review team was     divided into the following three groups'.
o'uman         Factors Evaluation Group.
o     Human   Factors/Operations   Support Group..
o     Project Management/Nuclear Operations/Plant Engineering         and Design Group.
The Human Factors     Evaluation Group   was composed   of six intermediate and junior level   human   factors specialists from the     Essex Corporation   field office located in Raleigh, North Carolina. The group's responsibility was stated to be to conduct data collection, data reduction, and preliminary data analysis; however, the extent of each group member's participation is not clear, with the exception of the group supervisor. The group supervisor's responsibility was to coordinate the evaluation activities, interface with CPEL project manager, and represent the human factors position at HED review meetings.
The Human   Factors/Operations     Support Group was composed of Essex Corpor ation home   office personnel located in Alexandria, Virginia. This group consisted of five senior human factors specialists, a nuclear engineer, two reactor operators, three junior human factors specialists, a procedure specialist, and a photographer.       The overall responsibility of this group was stated to be review, in-depth analysis, discrepancy definition and discrepancy resolution recommendations, data collection support, and operational and engineering analysis. The group leader was not identified for this group, and the extent of each member's participation is not clear.
 
The   Project Management/Nuclear Operations/Plant Engineering and Design Group was composed of CPKL personnel from various disciplines, representing the Nuclear Plant Engineering Department, System Planning and Coordination Department, Nuclear Operations Department, Nuclear Operations The group leader for this group coordinated the activities of Department'raining.
Essex, CPEL, EBASCO (AEE) and the NSSS (Westinghouse), and reviewed the overall progress of the DCROR. This group was supported by EBASCO and Westinghouse representatives to provide any required review and comments on design philosophies, discrepancy analysis, etc.
The   NRC audit team concluded that the CP&L review team, as described above will   satisfy the requirement of Supplement 1 to NUREG-0737 to establish a multidisciplinary review team to conduct a OCROR.
2.2.2     Mana ement Res       onsibilit NUREG-0700 recommends         that applicant management support is   needed to ensure'to the OCROR team the availability of information, equipment,           and all categor ies of manpower needed to conduct the review.
Although not stated in the CPLL report,         it was evident during the NRC audit that management fully supported the OCROR process as intended by the guidance in NUREG-0700.
Some examples     of management   support stated to the   NRC audit team are:
o     Descriptions of management participation, follow-up,           and                 review of the OCROR and the control room redesign process.
o     A statement describing how management stopped control board fabrication for several       months to allow the review and. redesign modifications to be resolved, thus avoiding wasted construction effort   and retrofit   expense.
o     Personnel     from other plants were made available to contribute                       their appropriate expertise and experience.
2 .2.3   Data Management NUREG-0700 guidelines recommend that methods of data management should                             be established prior to the OCRDR. This involves:
: 1. Providing the review team members with reference material (panel layout drawings, control room floor plans, etc.)
: 2. The selection of standard forms to       be used for recording the results of the CR review.,
: 3. The setting     up of a system for the management of these standard forms and the   data   obtained during the DCRDR.
During the in-progress audit of Shearon-Harris .Nuclear Power Plant Unit 1, the NRC audit team did not observe an elaborate mechanized data management system being used. However, reference material was provided to the review team, and
 
the forms used to record OCROR data were informally retained in filing cabinets, mostly in their raw form, after being completed by the review team members. The review forms and sheets used in the OCROR are described below:
o     The Human   Engineering discrepancy forms were used to record the discrepancy items and their location on the MCB, a problem description and guidelines violated, the description of the specific operator error(s) resulting from the HED, the list of procedures or operations that use the discrepancy items that induced operator errors, the list of consequences of operator error during all modes of operation, and suggestions for potential backfits. These forms were filled out by survey team members and later checked and validated by the HF consultant.
A panel area layout sheet, which contained a drawing for a specific panel area. HEOs were identified and recorded on these sheets by the team members and subsequently reviewed by the HF consultant and the CP&L project manager.
o   A computerized     HED status information report was used to record all HEDs. The   report listed all HEOs by IO number, HED description, and status (i.e., whether resolved, deleted or other status).
A coded numbering scheme was used to describe     HEDs as follows:
o     Plant location.
o   Generating unit location .
o     Physical location.
o   Component   type or design feature; o     HED sequence   number.
The NRC audit team concluded that the applicant's data       management meets the intent of   NUREG-0700 guidelines.
2.2.4   Equipment and Workspace The applicant's plans do not specifically describe plans for the OCROR review team workspace and equipment requirements as recommended in NUREG-0700.
However, the NRC audit team understands that adequate meeting spaces in the main control room building and simulator building were made available to the CPEL OCROR team, HF consultant, and operating personnel during the survey and redesign processes.       Equipment needs wer e minimal-since the survey and redesign work utilized paper mock-ups and mark-ups of simulator and control room panel drawings, which were supplied by design and drafting room personnel as appropriate.     It is assumed that equipment needed for the remaining CPLL OCROR tasks (e.g., illumination and sound'evel       meters, HVAC evaluation equipment, etc.) will be made available to the review team when needed.
It was evident to the NRC audit team that adequate clerical, reproduction and other peripheral support services are available whenever needed.
 
2.2.5     ~E NUREG-0700 recommends           that the planning of the control     room review   include the development       of a detailed schedule of review tasks.
The CP&L     report did not describe any schedules for the OCROR processes. No formal milestone charts,. task schedules, or personnel assignments were observed. As described to the NRC audit team, scheduling was done on a verbal, informal day-to-day basis in a manner to accomplish the required tasks within a predetermined time period. Attendance at the review meetings of individual team members and other personnel was understood to be determined by the needs of the agenda of each particular meeting. Specific personnel attendance was understood to be determined by the CP5L project manager and the Essex human factors engineer, both of whom were always present.                 Oespite the absence of a formal documented scheduling method, the NRC audit               team   concluded that the review tasks were adequately staffed and were               executed in an acceptable way. to CPQ letter of September 27, 1983, describes a schedule for development, verification, arid validation of SHNPP-1 EOPs using the simulator initially, and       the   SHNPP-1   Control   Room finally, after the CR is functional.
2.3     OETAILEO CONTROL ROON OESIGN REVIEM 2.3.1     Review     of 0 eratin   Ex erience Two steps are recommended by NUREG-0700 guidelines for reviewing operating experience. These include the examination of available documents and the-survey of control room operating personnel. There was no mention in the CPEL report of a formal review or examination of operating experience documents.
The NRC audit team is not aware of the details of any formal operator questionnaires or CR operating personnel interview processes.                 However, as described to the NRC audit team, the Har ris operating experience information was collected from operators whose experience was obtained from other plants, including H. B. Robinson, Unit 2.
It was stated that operator input was used in the determination of HEO corrective actions and verification that the final designs are user-oriented, as CPEL desires.         The NRC audit team concluded that operating experience was factored into the review process directly instead of via a formal interview/reporting process.
2.3.2     S stems Function and Task Anal           sis Supplement     1 to   NUREG-0737   requires the applicant to perform systems function and task analyses         to establish   the input and output requirements of control room operator       tasks   to serve as a basis for defining the requirements for control room instrumentation, controls, and other equipment, which will ensure the safe operation of the plant under emergency conditions. This can be accomplished by carrying out the following systems functions and task analysis
:~
steps   identified in the     NUREG-0700   guidelines.
: l. Identification of     Systems and Subsystems.
: 2. Identification of Operating Events for Analysis .
: 3. Function   Identification.
: 4. Operator Task     Identification   and Analysis.
The task analysis performed by CPLL, using NUREG-1580 guidelines, differs from the above NUREG-0700 guidelines because NUREG-0700 was published while the CPKL analysis was still in progress.
The task   analysis guidelines in NUREG-1580 are based on analyzing rocedures to provide documentation of operator actions, information requirements, an controls and displays used in executing the chosen procedures.
NUREG-0700   task analysis guidelines, on the other hand, are based on a systematic top-down function/task analysis to determine information and Nih           b'     1           d<<h actual instrumentation       and controls which are available in the control room.
The NRC audit team observes that there may not be uniformity between CPKL and NUREG-0700 in the meaning of the terms "function" and "functional analysis."
In response 'to an NRC audit team request, CPEL stated in their letter of September 27, 1983, that a generic top-down task analysis, based on the identification of event       sequences,   plant systems, and operator functions and tasks   (e.g.,'s     recommended   in NUREG-0700), was performed on the High Pressure (HP) Basic Version of the         Westinghouse Owners Group (WOG) Emergency Response Guidelines (ERGs). NRC staff review of the WOG guidelines indicate that they are a satisfactory start in identifying and describing tasks; but that they are generic, not plant specific. They do not identify required information and control capability characteristics sufficiently to           compar e to a control room instrumentation and control inventory.
There is no substantiating documentation describing the details or completeness of the methodology used in the task analysis.             It is also not clear to the NRC audit team whether CPEL or the WOG Committee performed the task analysis.
It is   stated that the primary outputs of the WOG task analysis are tables listing all     instruments and controls utilized in performing the ERGs.
jt is   stated that     CP&L plans to use the   WOG generic analysis to do the following:
o     Identify   SHNPP-Unit   1 deviations from the Generic   ERGs.
o     Task analyze   the differences and generate SHNPP-Unit 1 plant-specific lists of instruments       and controls required to perform the Harris   EOPs in the SHNPP-Unit 1 Control Room.
 
o     Compare   the plant specific equipment lists with the Control Room inventory (see 2.3.3; below) to identify missing components or needed components not included in the design.
o     Review each step   of the SHNPP-Unit 1 EOPs by reviewing the generic task analyses and the   ERG deviation analyses. ,
o     Resolve and correct applicable     identified HEDs.
It appears     to the NRC audit team that CP5L is contending that the above     steps will follow the     NUREG-0700 recommendation to define instrumentation and control     requirements by a top-down function/task analysis approach.
It is the NRC audit team's position that the CPKL process described above may not result in defining operator information and control requirements independently from consideration of equipment that is already installed in the control room. This process may not ensure that the man/machine interface is complete or that an optimal design for safe operation will result.
The   NRC   audit team concluded that a more complete rationale and justification for CPEL's approach to conducting their task analyses will be needed to determine whether the requirements of Supplement 1 to NUREG-0737 have been s ati sf i ed.
2.3.3       Control Room Inventor Supplement     1 to NUREG-0737 requires the~pplicant .to make a control room inventory and to compare the operator display and control requirements determined from the task analyses with the control room inventory to determine missing controls and displays.
Ouring the in-progress audit       it was stated that the EBASCO panel component list was     substituted for a control room inventory. This list was used to check the existence of controls and displays on the MCB panel drawings, to confirm the expected panel content vs. need. The needs, as expressed in the EBASCO     component   list, were determined by   EBASCO and CPEL operating experience.
The   NRC   audit team's position is that Supplement 1 to NUREG-0737 is not fully satisfied because the WOG generic function and task analysis, as described previously in Section 2.3.2, does not specify control and display characteristic requirements in sufficient detail to permit comparison with the inventory characteristics.
2.3.4       Control Room Surve Supplement     1 to NUREG-0737 requires that a control room survey be conducted to identify deviations from accepted human factors principles. NUREG-0700 provides guidelines and criteria for conducting a control room survey.
The   objective of the control room survey is to identify, for assessment and possible correction, characteristics of displays, controls, equipment, layout, and ambient conditions that do not conform to good human engineering practices. The Harris control room survey was carried out through reviews of plant design documents, reviews of vendor documentation, and reviews of layout drawings. The Shearon-Harris Simulator was used where applicable. A to-scale
 
                                                \
Part 8 - Shearon-Harris   Photo Summary Carousel         Photo Location           IDf         Photo Description
                                                        'F1ndin 88                17        Remote Shut-down panel 89                18        Remote Shut-down panel 90             19S         Simulator Panel 91              ZOS          Simulator Panel 92            21S          Simulator Panel 93              22S          Simulator Panel 94              23S          Simulator Panel 95             24S           Simul ator radi ation monitors 96              25S          Simulator. Instrumentation 97              26S          Simulator radiation monitor computer 98             ZTS         Simulator remote instructor console 99                           Simulator   - General view 100             29S         Simulator - General view 101              30S          Simulator - General view 102             31S         CPEL paste-ups:
left - original     panels; right -   new design panels 0009R
                            - 31'-
 
t II
 
paper mock-up was also used as a basis for identifying HEOs and as a starting point from which to relocate controls and displays. During the course of the in-progress audit, the NRC audit team observed that the simulator room and its environmental aspects do not duplicate those of the main control room, although   it continues to be used for training and procedure walk/talk throughs.
The CR survey process   initiated   by CP&L consisted of the following steps:
: l. Essex Corporation personnel generated initial HEOs by examining panel layout drawings. HEDs were identified by writing a description of the problem on the drawing. Often, several HEOs were identified in this manner. The panel layout drawing literally became a scratch pad upon which the observations of the reviewer were written. These observations later became the basis for determining HED resolutions .
: 2. The Essex   Corporation field project manager then reviewed and provided the initial verification of these HEDs.
: 3. Next, the   CP&L project   manager and his assistant reviewed the HEDs for accuracy   and completeness     and concurred with the potential operational problems the       HEOs indicated.
: 4. At this point, the Essex Corporation management reviewed and approved the HEDs in preparation for the following step.
: 5. HEDs were then presented to a group of people at the site for review and resolution. These people nnsisted of Essex Corporation, EBASCO, Westinghouse, and CP&L training, engineering, construction, and operations personnel     as appropriate.
The human factors     consultant stated during the in-progress audit that the HEDs will be "designed     out" of the board in the course of the review and redesign work by following a policy of correcting the HEDs as many times as necessary to eliminate, them before they determine that the redesign is complete.
As a result of the control room audit, it is the NRC audit team's position that the applicant's CR survey meets the intent of NUREG-0700 guidelines and that the applicant intends to satisfy the requirements of Supplement           1 to NUREG-0737.
2.3.5     Verification of   Task Performance     Ca abilities The objective of "verification of task performance capabilities" 'as described in NUREG-0700 guidelines is to assur e that the CR contains sufficient controls and instruments so that operator tasks can be performed in the existing CR with minimum potential for human error. Verification can be accomplished by comparing the instrument and equipment requirement derived from the task analysis to the inventory of existing instrumentation, controls, and other equipment. This verification step was not carried out at Shearon-Harris since instrument and equipment requirements wer e not derived from the function and task analysis described in NUREG-0700; rather, the task analysis and review process was   primarily based on   NUREG   1580.
It appeared   to the NRC audit team that CP&L's version of the verification that was accomplished     during the redesign effort was done by using selected
                                            '
 
e procedures   as a basis to identify operational functions, operator tasks,   and to identify the controls and instruments needed to execute the procedures.
Plans for future verification of SHNPP-1 EOPs are described in Attachment 3 to CP&L letter of September 27, 1983.       The results of this verification should be reported to NRC for review on a schedule acceptable to NRC.
2.3e6     Validation of Control Room Functions The   objectives of the validation process as outlined in NUREG-0700 is the determination of whether functions allocated to CR operating personnel can be accomplished within the structure of defined operating and emergency procedures and the existing design of the CR. This validation step was not accomplished at Shearon-Harris, nor addressed in the CP&L report. However, to CP&Ls letter of September 27, 1983, describes their plans to validate the SHNPP.-1 EOPs. The results of this validation should be reported to NRC for review on a schedule acceptable to NRC.
2.4     ASSESSMENT AND IMPLEMENTATION 2.4.1     Assessment of HEDs Supplement   1 to NUREG-0737 requires that HEDs be assessed to determine which HEDs   are significant and should be   corrected. NUREG-0700 and NUREG-0801 contain guidelines for the assessment     process.
A formal documented assessment   of HEDs,~s intended by the     NUREG-0700 guidelines, was not done by the CP&L review team. Instead, the assessment function was accomplished as one of several parallel iterative processes executed during what CPKL called the ~redesi n of the Harris Main Control Boards (MCB).
It was   stated that the initial HED identification process was completed on each panel   before moving to the next. The candidate HEDs were screened by the on-site human factors consultant in conjunction with the CP&L review project manager. Those that survived to be corrected were then discussed (assessed) in batches in meetings attended by the review team membership, which included the human factor s consultant, the CP&L review project manager, CP&L operating and engineering personnel, and EBASCO (A&E) and Westinghouse personnel as appropriate. The CP&l project manager and the Essex human factors consultant were always present at all meetings, with additional members present when their expertise was needed.
There were many redesign review meetings during which the Harris control room was repeatedly and iteratively laid out. As stated to the NRC audit team, this process included discussion of many alternate resolutions prior to the selection of the final resolution to     each HED.
The stated CP&l policy was to correct every HED by designing it out of the system, with the objective of achieving an HED-free board. The execution of this philosophy obviates the necessity to follow the NUREG-0700 recommendations of formally assessinq each HED for importance, potential safety consequences, the cumulative impact of minor HEDs, determination of priorities, setting implementation schedules, etc.
 
The NRC   audit team concludee that the applicant's     method will satisfy the requirements of Supplement 1 to NUREG-0737.
2.4.2     Selection of Desi n Im rovements Supplement 1 to NUREG-0737 requires selection of control room design improvements that will correct significant HEDs.       It also states that improvements that can be accomplished with an enhancement program should be done promptly.
As stated in Section 2.4.1. of this report, alternate design improvements for each HEO wer e considered during the CP5L redesign review process, and this function was another iterative parallel process executed dur ing the redesign of the Harris MCB. NUREG-1580 criteria, along with the Essex developed Human Engineering Requirements Specifications (HERS) are understood to have been used to support the review team choice of resolutions for each HED.
As described   in the Harris Report, the conduct of the redesign effort appear       s to have been   similar to the determination of     a new design. Some examples fol low.
The Harris Report, Section 4, Annunciator Review, and their letter, LAP-83-426,   of September 27, 1983, states that the annunciator need, location, and grouping considerations resulted in removing about 250 tiles from the MCB.
Also,   it was stated to the NRC audit team that the MCB redesign rdview resulted in the removal of about 200 cotttrols and the relocation of a significant number of unnecessary items from front to rear panels. EBASCO and Westinghouse concurrence was obtained for CP5L proposed component removals.
Appendix 0 of the Harris report; "Reconmended Control Room Equipment Arrangement," describes how the recommended panel arrangements were determined by consider ing such factors as equipment location desirability, the readability of displays and labels from various MCB locations, visual angles, adverse effect on short-term operators'emory because of movement distances between equipment, discrimination problems due to viewing distances, etc. In addition, a quarter scale mock-up was used to study and confirm rearrangement of the boards. The mock-up was also used to verify and confirm labeling, demarcation, and annunciator arrangement.         It was stated that part of the redesign effort included ongoing discussions with operators to verify that the MCB redesign details and HED corrective actions were compatible with operational needs, and left no discrepancies uncorrected. This included verification that any equipment found missing was, or would be, installed before the redesign was considered complete.
The NRC audit team concluded that the applicant will satisfy requirements         of Supplement 1 to NUREG-0737     if the SHNPP OCRDR summary report completely documents the methodology and results of design improvement selection so         that the NRC can confirm that the requirements have been satisfied.
NUREG-0700 describes guidelines     for determining the implementation schedule for des i gn improvements.
The Harris Report does not include     a section on implementation because their
 
0 policy of correcting all       HEDs   during the. execution of the redesign process pr ior to operation obviates       it.
The CPSL   letter,   LAP-83-156, of June 3, 1983, expresses confidence that the verification   and   validation following the availability of the WOG task analysis and generic guidelines, and the completion of SHNPP EOPs verification and validation will reveal few, 'if any, MCB human factors concerns.             If any HEDs should be identified the NRC audit team concluded that a continuation of the CPEL redesign corrective action policy will result in their correction.
Such identification of future HEDs, their resolution, and an acceptable time schedule for implementing the corrective action should be reported to NRC for evaluation.
Such identification of future HEDs, their resolution, and an acceptable time schedule for implementing the corrective action should be reported to NRC for evaluation.
2.4.4 Verification of Desi n Improvements Supplement 1 to NUREG-0737 requires verification that selected design improvements will provide the necessary corrections of HEDs.As stated in Sections 2.4.1 and 2.4.2, the execution of the CPAL MCB redesign process to design HEDs out of the system incorporates HED assessment',,the consideration of alternate designs in the selection and implementation of design improvements, and the use of the mock-up to study and confirm MCB rearrangements.
2.4.4     Verification of     Desi n Improvements Supplement 1   to NUREG-0737     requires verification that selected design improvements   will   provide the necessary corrections of HEDs.
As explained to the NRC audit team, it is inherent in this process that HED corrective actions will be verified to provide the necessary corrections of HEDs.The NRC audit team expects that CPEL wiR satisfy this requirement of Supplement 1 to NUREG-0737.
As   stated in Sections 2.4.1 and 2.4.2, the execution of the CPAL MCB redesign process to design     HEDs out of the system incorporates HED assessment',,the consideration of alternate designs in the selection and implementation of design improvements, and the use of the mock-up to study and confirm MCB rearrangements.       As explained to the NRC audit team,       it is inherent in this process that HED corrective actions will be verified to provide the necessary corrections of HEDs.
2.4.5 Verification No New HEDs Created Supplement 1'to NUREG-0737 requires verification that control room design improvements will not introduce new HEDs into the control room.The NRC audit team observed that the CPEL redesign process inherently verifies that the HED corrective actions will not introduce new HEDs into the control room.The NRC audit, team therefore expects that CP&L will satisfy this requirement of Supplement 1 to NUREG-0737.
The   NRC audit team expects that       CPEL wiR satisfy this requirement of Supplement   1 to NUREG-0737.
2.4.4 Coordination of Control Room Im rovements with Other Pro rams Supplement 1 to NUREG-0737 requires that control room improvements be coordinated with changes from other programs;e.g., safety parameter display system (SPDS), operator training, Regulatory Guide 1.97 (R.G.1.97), and emergency operating procedures (EOPs).Harris EOPs are still being developed using modfied Robinson procedures and the Harris simulator.
2 .4.5   Verification   No New HEDs   Created Supplement 1 'to NUREG-0737 requires         verification that control   room design improvements will not introduce new           HEDs   into the control room.
The EOP development will include consideration of Westinghouse Owners Group Emergency Response Guidelines, and it was stated that the EOPs wi 11 be task analyzed prior to implementation.
The   NRC audit team observed that the CPEL redesign process inherently verifies that the   HED corrective actions will not introduce new HEDs into the control room. The NRC audit, team therefore expects that CP&L will satisfy this requirement of Supplement       1 to NUREG-0737.
The results of the task analysis will be fed back to the EOPs and the DCRDR.CPEL plans to complete the systems operation and task analysis and verify and validate the EOPs after they are implemented and the MCB is fully functional.
2.4.4     Coordination of Control       Room Im   rovements with Other Pro rams Supplement   1 to NUREG-0737     requires that control room improvements     be coordinated with changes from other programs; e.g., safety parameter display system (SPDS), operator training, Regulatory Guide 1.97 (R.G. 1.97), and emergency operating procedures (EOPs).
It was stated that subsequent MCB modifications will follow the same processes as the MCB redesign.The status of the SPOS was explained in a special meeting w'ith the NRC audit team.The SPOS design is not yet complete, but will include human factors considerations.
Harris EOPs are still being developed using modfied Robinson procedures and the Harris simulator. The EOP development will include consideration of Westinghouse Owners Group Emergency Response Guidelines, and             it was stated that the EOPs   wi 11 be task   analyzed prior     to implementation. The results of the task analysis will be fed back to the EOPs and the DCRDR. CPEL plans to complete the systems operation and task analysis and verify and validate the EOPs after they are implemented and the MCB is fully functional.
CPKL is buying an SAI computer which will feed six CRTs, and will do all of the data processing to meet NUREG-0696 requirements.
 
-EOF and TSC consoles will also have access to the SPOS displays.A written color code standard does not exist, but it is intended to limit the displays to no more than four colors.Two hours of events will be contained in memory, and will be frozen if a safety-related event occurs.Selected out-of-tolerance data will be recorded with a 10-minute compressed time span.The computer will be locked, will run a card control access system, and operators will not be able to change the programming.
It was   stated that subsequent     MCB modifications will follow the same   processes as the   MCB   redesign.
The NRC audit team expects that the SPOS as described will meet the intent of the requirements.
The   status of the   SPOS was explained in a special meeting w'ith the NRC audit team. The SPOS design is not yet complete, but will include human factors considerations. CPKL is buying an SAI computer which will feed six CRTs, and will do all of the data processing to meet NUREG-0696 requirements. EOF and   -
The final design should be reported to NRC for review and implemented on a schedule approved by NRC.Based on discussions with CP5L concerning coordination, the NRC audit team concluded that the applicant intends to meet the requirements of Supplement 1 to NUREG-0737 to coordinate the DCROR with other control room improvement programs.2.5 REPORTING A program plan report of January 23, 1981, with revisions of September 16, 1981, and supplemental information dated April 14,, 1983, was submitted on June 1, 1983.The NRC staff notified CPKL by telephone in July 1983 that the program plan was incomplete, and that additional information would be required before NRC can determine its acceptability.
TSC consoles will also have access to the SPOS displays.         A written color code standard does not exist, but it is intended to limit the displays to no more than four colors. Two hours of events will be contained in memory, and will be frozen     if a safety-related event occurs.     Selected out-of- tolerance data will be recorded with a 10-minute compressed time span. The computer will be locked, will run a card control access system, and operators will not be able to change the programming.
A letter of September 27, 1983, submitted additional information requested by the staff during the on-site in-progress audit of August'5 through 18, 1983.Since there are several areas in which the OCROR is incomplete, these topics must be addressed by CPEL in their OCRDR summary report to fully satisfy the requirements of Supplement 1 to NUREG-0737.
The   NRC audit team expects that the     SPOS as described will meet the intent of the requirements.       The final   design should be reported to NRC for review and implemented on a     schedule approved by NRC.
3.CONCLUSIONS CPSL is currently continuing its OCROR and making improvements to the redesigned MCB.NRC audit team and staff reviews of the Shearon-Harris reports and the results of the in-progress on-site audit determined that CPKL is conducting a OCROR that will substantially meet the guidelines of NUREG-0700 and the requirements of Supplement 1 to NUREG-0737, except for the fo1 1 owing: o The system function and task analysis was not conducted by CPEL as recorrmended in NUREG-0700.
Based on   discussions with CP5L concerning coordination, the NRC audit team concluded     that the applicant intends to meet the requirements of Supplement         1 to NUREG-0737 to coordinate the DCROR with other control room improvement programs.
o The comparison of display and control requirements determined by a function and task analysis with a control room inventory was not fully performed by CPEL as recommended in NUREG-0700.
2.5     REPORTING A program plan report of January 23, 1981, with revisions of September 16, 1981, and supplemental information dated April 14,, 1983, was submitted on June 1, 1983. The NRC staff notified CPKL by telephone in July 1983 that the program plan was incomplete, and that additional information would be required before NRC can determine its acceptability. A letter of September 27, 1983, submitted additional information requested by the staff during the on-site in-progress audit of August'5 through 18, 1983.
o Verification and validation of SHNPP-1 EOPs will be completed after the control room is functional, as defined in Attachment 3 to CP5L letter of September 27, 1983.o Some items were not included in the CPEl report because they were not ready for review.These items are described in the Appendix to this report.Any needed corrective actions or changes resulting from the above should be implemented prior to licensing or on a schedule acceptable to the NRC.0009R 4.REFERENCES 1.Human Factors Design Evaluation Report for Shearon-Harris Unit 1 Control Room, January 23, 1981, revised September 16, 1981, and April 14, 1983.2.Supplement 1 to NUREG-0737,"Requirements for Emergency Response Capability" (Generic Letter No.82-33), December 17, 1982.3.NUREG-0700,"Guidelines for Control Room Design Reviews," September 1981.4.NUREG-0801,"Evaluation Criteria for Detailed Control Room Design Reviews," Draft for Comment, October 1981.5.CP&L letter LAP-83-156 to H.R.Oenton, supplemental information to the OCRDR summary report entitled,"Human Factors Design Evaluation Report for the Shearon-Harris Unit 1," June 1, 1983.6.CP5L letter LAP-83-426 to H.R.Oenton, information requested by the NRC audit team, September 27, 1983.7.NUREG-1580,"Human Engineering Guide to Control Room Evaluation," July 1980.0009R APPENDIX OISPOSITION ANO STATUS OF HEOS 5.APPENDIX This Appendix discusses the disposition of human engineering discrepancies (HEDs)documented during the CP&L OCROR process, and reviewed by the NRC audit team during the in-progress audit of August 15-18, 1983.It also includes HEDs identified by the NRC audit team.Table 3-1 of Attachment 1 of the CP&L letter of June 1, 1983, tabulates and categorizes the 134 HED reports generated and resolved during the CP&L OCROR.It was stated to the NRC audit team that CP&L will resolve additional HEDs that may be identified in the future by the same OCROR processes described in the main body of this report.The following descriptions of the resolved HEDs are transcribed from Table 3-1 of the CP&L letter: HED reports generated during the OCROR have been reviewed by CP&L and resolved.The CP&L resolutions of the 134 HED reports are: o.49 HEDs were resolved by rearrangement of the control board.o ll HEDs were resolved by a hardware change on the main control board.o 8 HEOs were resolved by a label or meter scale change.o 3 HEDs were resolved by an administrative or maintenance procedure change.o 33 HEDs were withdrawn because they were unique to the simulator and not applicable for the SHNPP-1 Control Room.o 4 HEDs were withdrawn because each HEO was defined as not applicable by peer review.o 2 HEDs had corrective action taken but the action did not totally resolve the HED.Justification was provided and approved by CP&L management on a case-by-case basis.o 24 HEOs had no corrective action taken.Justification was provided and approved by CP&L management on a case-by-case basis.None of these HEDs were considered by CP&L to have safety significance.
Since there are several areas in which the         OCROR is incomplete, these topics must be addressed     by CPEL in   their OCRDR summary report to fully satisfy the requirements of     Supplement 1   to NUREG-0737.
The NRC audit team reviewed in detail with CP&L and the human factors consultant all 24 of the HEDs for which no corrective action was taken and foundthis determination to be acceptable.
: 3. CONCLUSIONS CPSL     is currently continuing its     OCROR and making improvements to the redesigned     MCB. NRC audit team and staff reviews of the Shearon-Harris reports and the results of the in-progress on-site audit determined that CPKL is conducting a OCROR that will substantially meet the guidelines of NUREG-0700 and the requirements of Supplement 1 to NUREG-0737, except for the fo1 1 owing:
A representative sampling of individual HEDs and resolutions from the other categories was reviewed and were found to be acceptable.
o     The system     function and task analysis   was not conducted by CPEL as recorrmended   in NUREG-0700.
The NRC audit team on-site review process was typically as follows: o The original documents identifying and describing the problems were inspected and discussed.
o     The comparison of     display and control requirements determined by     a function   and task analysis with a control room inventory was not fully performed by CPEL as recommended in NUREG-0700.
o The documents examined consisted of marked-up and annotated panel drawings, handwritten and typed preprinted HED forms, and photographs
o     Verification     and validation of SHNPP-1 EOPs will be completed after the control room is functional, as defined in Attachment       3 to CP5L letter of September 27, 1983.
.
o     Some   items were not included in the CPEl report because they were not ready   for review. These items are described in the Appendix to this report.
0 o The HED descriptions discussed included the following:
Any needed     corrective actions or   changes resulting from the above should be implemented       prior to licensing or   on a schedule acceptable to the NRC.
-A description of the equipment and its location.-A description of the problem.-Identification of the guidelines violated.-Identification of specific operator errors resulting from the HED.-A list of procedures or operations affected.-Consequence of operator error.-Suggested backfits.-The HED resolutions selected.The NRC audit team observations are as follows: o All of the HEDs discussed were written up on the paper mock-ups of the original MCB panels-none on the incomplete MCB panels.o The execution of the resolutions was carried out on a continuing iterative basis until the final design and layout was achieved.o The final design was then drafted up and used for construction of the MCB.o Future HEOs.will follow the same process.o CPSL stated policy is to fix all HEDs and end up with an HEO-free MCB.The NRC audit team also reviewed the pa&ially completed MCB and independently identified the HEDs contained in Part A of this Appendix.It was stated that'most of the HEDs listed in Part A of the Appendix duplicated HEDs previously identified by the CPEL OCRDR.However;a one-to-one identification between the CPEL HEOs and the NRC audit team HEDs was not made.For each of the HEDs listed in Part A of this Appendix, CP5L should report to the NRC the status and proposed resolutions, and an implementation schedule for corrective action must be submitted to the NRC'20 days prior to loading fuel (PTLF).Discrepancies must be corrected PTLF or on a schedule approved by the NRC.Items listed below.were not included in the CP5l report because they were not ready for review.CP&L must complete the OCRDR and supply additional information about these items to enable the NRC to determine the acceptability of the OCRDR.Numbers in parentheses are the corresponding sections of Chapter 6 of NUREG-0700:
0009R
1.Workspace (6.1)2.Communications (6.2)3.Remote Shutdown Panel (all)4.Recorder Panel (all)5.CRTs (6.7)6.Process Computer and Peripherals (6.7) 7.Annunciator Items o Set Points (6.3.1.2a) o General Alarms (6.3.1.2b)o Multi-Channel or Shared Alarms (6.3.1.2c(l), c(2))o Multi-unit Alarms (6.3.1.2d) o Signal Detection (6.3.2.1 a through f)o Coding (6.3.2.2)o Visual Annunciator Panel Labeling (6.3.3.lb(2))
: 4. REFERENCES
: 1. Human Factors Design Evaluation Report for Shearon-Harris Unit 1 Control Room, January 23, 1981, revised September 16, 1981, and April 14, 1983.
: 2. Supplement 1 to NUREG-0737, "Requirements for Emergency Response Capability" (Generic Letter No. 82-33), December 17, 1982.
: 3. NUREG-0700,   "Guidelines for Control Room Design Reviews," September 1981.
: 4. NUREG-0801,   "Evaluation Criteria for Detailed Control Room Design Reviews," Draft for Comment, October 1981.
: 5. CP&L letter LAP-83-156 to H. R. Oenton, supplemental information to the OCRDR summary report entitled, "Human Factors Design Evaluation Report for the Shearon-Harris Unit 1," June 1, 1983.
: 6. CP5L letter LAP-83-426 to H. R. Oenton, information requested by the   NRC audit team, September 27, 1983.
: 7. NUREG-1580,   "Human Engineering Guide to Control Room Evaluation," July 1980.
0009R
 
APPENDIX OISPOSITION ANO STATUS OF HEOS
: 5. APPENDIX This Appendix discusses the disposition of human engineering discrepancies (HEDs) documented during the CP&L OCROR process, and reviewed by the NRC audit team during the in-progress audit of August 15-18, 1983. It also includes HEDs identified by the NRC audit team.           Table 3-1 of Attachment 1 of the CP&L letter of June 1, 1983, tabulates and categorizes the 134 HED reports generated and resolved during the CP&L OCROR. It was stated to the NRC audit team that CP&L will resolve additional HEDs that may be identified in the future by the same OCROR processes described in the main body of this report.
The   following descriptions of the resolved           HEDs are transcribed from Table 3-1 of the CP&L letter:
HED reports generated during the OCROR have been reviewed by               CP&L and resolved. The CP&L resolutions of the 134 HED reports are:
o   . 49 HEDs were   resolved by rearrangement of the control board.
o     ll HEDs   were resolved by     a hardware change on the main control board.
o     8 HEOs were   resolved by   a   label or meter scale change.
o     3 HEDs were resolved by an       administrative or maintenance procedure change.
o     33 HEDs were withdrawn because they were unique to the simulator and not applicable for the SHNPP-1 Control Room.
o     4 HEDs were   withdrawn because each       HEO was defined as not applicable by peer review.
o     2 HEDs had   corrective action taken but the action did not totally resolve the   HED. Justification     was   provided and approved by   CP&L management   on a case-by-case     basis.
o     24 HEOs had no corrective action taken.           Justification was provided and approved by CP&L management on a case-by-case basis.             None of these HEDs were considered by CP&L       to have safety significance.
The NRC audit team reviewed in detail with CP&L and the human factors consultant all 24 of the HEDs for which no corrective action was taken and foundthis determination to be acceptable. A representative sampling of individual HEDs and resolutions from the other categories was reviewed and were found to be acceptable.
The NRC audit team on-site review process         was   typically as follows:
o     The original documents   identifying     and describing the problems were inspected and discussed.
o     The documents examined consisted of marked-up and annotated panel drawings, handwritten and typed preprinted HED forms, and photographs .
 
0 o     The HED descriptions discussed included the following:
            - A description of the equipment and its location.
            - A description of the problem.
            - Identification of the guidelines violated.
            - Identification of specific operator errors resulting from the     HED.
            - A list of procedures or operations affected.
            - Consequence of operator error.
            - Suggested   backfits.
            - The HED   resolutions selected.
The NRC audit team observations are     as   follows:
o     All of the HEDs discussed were written up on the paper mock-ups of the original MCB panels   none on the incomplete MCB panels.
o     The execution of the resolutions was carried out on a continuing iterative basis until the final design and layout was achieved.
o     The final design was then drafted up and used     for construction of the MCB.
o     Future   HEOs. will follow the   same process.
o     CPSL stated policy is to   fix all   HEDs and end up with an HEO-free MCB .
The NRC audit team also reviewed the pa&ially completed MCB and independently identified the     HEDs contained in Part A of this Appendix.     It was stated that
'most of the HEDs listed in Part A of the Appendix duplicated HEDs previously identified by the CPEL OCRDR. However; a one-to-one identification between the CPEL HEOs and the NRC audit team HEDs was not made. For each of the HEDs listed in Part A of this Appendix, CP5L should report to the NRC the status and proposed resolutions, and an implementation schedule for corrective action must be submitted to the NRC'20 days prior to loading fuel (PTLF).
Discrepancies must be corrected PTLF or on a schedule approved by the NRC.
Items listed below. were not included in the CP5l report because they were not ready for review. CP&L must complete the OCRDR and supply additional information about these items to enable the NRC to determine the acceptability of the OCRDR. Numbers in parentheses are the corresponding sections of Chapter   6 of NUREG-0700:
: 1. Workspace   (6.1)
: 2. Communications   (6.2)
: 3. Remote Shutdown Panel   (all)
: 4. Recorder Panel   (all)
: 5. CRTs (6.7)
: 6. Process   Computer and Peripherals     (6.7)
                                            -  19-
: 7. Annunciator Items o     Set Points (6.3.1.2a) o     General Alarms (6.3.1.2b )
o     Multi-Channel or Shared Alarms     (6.3.1.2c(l), c(2))
o     Multi-unit Alarms (6.3.1.2d) o     Signal Detection (6.3.2.1   a through f) o     Coding (6.3.2.2) o     Visual Annunciator Panel Labeling (6.3.3.lb(2))
Visual Annunciator Panel Lamp Replacement (6.3.3.lc(3))
Visual Annunciator Panel Lamp Replacement (6.3.3.lc(3))
o Alarm Recognition and Identification (6.3.3.2 c through f)o Arrangement of Tiles, Labeling of Axes (6.3.3.3c(3))
o     Alarm Recognition and Identification (6.3.3.2 c through     f) o   Arrangement of Tiles, Labeling of Axes (6.3.3.3c(3))
Arrangement of Tiles, Blank Tiles (6.3.3.3f) o Tile Legends, Controls, Silence (6.3.4.1a(2))
Arrangement of Tiles, Blank Tiles (6.3.3.3f) o     Tile Legends, Controls, Silence (6.3.4.1a(2))
Tile Legends, Controls, Acknowledge (6.3.4.lb(2))
Tile Legends, Controls, Acknowledge (6.3.4.lb(2))
Tile Legends, Controls, Reset (6.3.4.1c(3))
Tile Legends, Controls, Reset (6.3.4.1c(3))
Tile Legends, Controls, Test (6.3.4.1d(2))
Tile Legends, Controls, Test (6.3.4.1d(2))
o Annunciator Response Procedures Availability (6.3.4.3a) e 8.SPDS Missing information should be reported to NRC for review.Any needed corrective actions or changes shall be implemented prior to licensing or on a schedule acceptable to the NRC.Part 8 of this Appendix is a list of photos taken by the NRC audit team during their independent review of the MCB.  
o     Annunciator Response Procedures Availability (6.3.4.3a) e
: 8. SPDS Missing information should be reported to NRC for review. Any needed corrective actions or changes shall be implemented prior to licensing or         on a schedule acceptable to the NRC.
Part 8 of this Appendix is a   list of photos taken by the   NRC audit team during their   independent review of the   MCB.
 
\'.
\'.
p~~~AUDIT REPORT APPENDIX-PART A HUMAN FACTORS ENGINEERING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY Part A-This part contains Human Engineering Oiscrepancies (HEOs)identified by the NRC audit team during the in-progress audit.The number in parentheses (8-xxx)is the HED ID number assigned by the team.These must be reviewed by the applicant and a resolution and implementation schedule submitted 120 days PTLF.Discrepancies must be corrected PTLF or on a schedule approved by the NRC.PHOTO PINGING 1.0 CONTROL ROOM WORKSPACE HED 1.1 Since the control room at SHNPP is not completed, the arrangement could not be evaluated according to Section 1.0 of NUREG-0700.
p   ~
G8 1.2 On all panels, the pash buttons for the lamp tests of the status lights are mounted above optimum height;i.e., not within reach.of 5th percentile female.(8202)2.0 COMMUN I CAT IONS 2.1 Since the control room at SHNPP is not completed, the communications system could not'e evaluated according to Section 2.0 of NUREG-0700.
  ~~
3.0 ANNUNCIATOR WARNING SYSTEMS 3.1 3.2 3.3 3,4 On the reactor and tur bine first.-out panels, there is no prioritization scheme for alarms other than red/white.
AUDIT REPORT APPENDIX   - PART A HUMAN FACTORS ENGINEERING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY Part A - This part contains Human Engineering Oiscrepancies (HEOs) identified by the NRC audit team during the in-progress audit. The number in parentheses (8-xxx) is the HED ID number assigned by the team. These must be reviewed by the applicant and a resolution and implementation schedule submitted 120 days PTLF. Discrepancies must be corrected PTLF or on a schedule approved by the NRC.
(8453)On all panels, large matrixes of annunciator lights and status lights have no coordinate axis labels.(8458)On the-annunciator visual alarm subsystem, cues for out-of-service alarms are not planned for.(8471).On the annunciator operator response subsystem, there is no coding of controls for easy recognition.
PHOTO   PINGING                                   HED 1.0   CONTROL ROOM WORKSPACE 1.1       Since the control room at SHNPP is not completed, the arrangement could not be evaluated according to Section 1.0 of NUREG-0700.
(8463)-21 PHOTO FINDING 4.0 CONTROLS AUDIT REPORT APPENDIX PART A HED G16 G29 G38 4.1 4.2 4.3 4.4 Since the lamps on the MCP were not powered, they could not be reviewed for legibility and other features of Section 6.4 of NUREG-0700.
G8       1.2       On all panels, the pash buttons for the lamp tests of the status lights are mounted above optimum height; i.e., not within reach. of 5th percentile female. (8202)
On Panel 1A1, valves (Lo Head Sl Train 8 to Cold Leg 8888)open to the left and close to the right, which is inconsistent with other panels.(8212)On Panel 181, a valve switch (AUX FW Turbine Stm Line Drain: ISO MS-817 SAB)has a J-handle instead of a T-handle like other valve switches.(8225)On Panel 101 several key switches for the generator breakers are"off"'o the left, instead of the standard vertical position.(8234)5.0 VISUAL DISPLAYS G9 L3 G24 G19 G37 5.1 5.2 5.3 5.4 5.5 On all MCB panels and'on the auxiliary equipment Panel fl,"Hagan" brand process controllers have scales too small to read.(8204)On all MCB panels and on recorder panel, top scale of recorders is.hidden by the cover and unreadable from a normal position.(8220)On many panels, scales on meters had more than the r ecommended maximum graduations between numeral s.(8215)On Panel 181 and other MCB panels, panel division lines are not distinguished from flow lines, header lines, or other functional representations.
: 2. 0         I COMMUN CAT IONS 2 .1       Since the control room at SHNPP is not completed, the communications system could not'e evaluated according     to Section 2.0 of NUREG-0700.
(8233)For all lamps for displays, the testing procedure is to remove the lamp and replace it with a new one.(8203)22  
3.0   ANNUNCIATOR WARNING SYSTEMS 3.1       On the reactor and tur bine first.-out panels, there is no prioritization   scheme for alarms other than red/white.
~~:0 PHOTO FINDING 6.0 LABELS ANO LOCATION AIOS AUOIT REPORT APPENOIX PART A GB 6.1 G26 6.2 On the MCB, there are no labels on status lights.(8209)On Panel 181, there is an unlabeled push button unit.(8222)G28 G33 6.3 6.4 On Panel 181, recorders with pointers have unlabeled scales;e.g., water flow recorder MR-AF-2050.
(8453) 3.2        On all panels, large matrixes of annunciator lights and status lights have no coordinate axis labels. (8458) 3.3        On the- annunciator visual alarm subsystem,   cues for out-of-service alarms are not planned for. (8471) 3,4      . On the annunciator operator response subsystem, there is no coding of controls for easy recognition. (8463)
(8224)On Panel 182, there is no label on a push button in a turbine control unit.(8229)G43-6.6 G48 All MCB panel switches outlined in red, signifying that they are safety related,, have no labels for easy identification.
                                                - 21
(8245)L8 R23 A27 R25 R26 L2 L7 G10 G7 R28 R22 6.7 6.8 6.9 6.10 6.11 6.12 6.13 6.14 6.15 6.16 On the recorder panel, there are no summary labels.(8252)On Panel 1AA, accumulators are identified as 1, 2, and 3 on instrumentation (e.g-., PI921, 23, 25, 27, 29, 31)and as A, 8, and C on controls on sloping panel.(8470)On Panel lA1', on pump meters, instrument numbers are missing..(8254)On Panel 1Al, labels read Pump 1 and 2 on meters and Pump A and B on switches on sloping panel.(8253)On the auxiliary equipment Panel tl, the labels are smaller than those on MCB.(8247)On the recorder panel, the labels are smaller than those on the MCB;they are also below the recorders and therefore in shadows.(8251)On several MCB panels,"10" and"1000" and other scale mul tipliers are written vertically.
 
(8205)On Panels 1A1, lA2, and 1C, the annunciator switches have labels written vertically on buttons.(8201)On Panel 1A2 and 181 there are labels crossed out;e.g., TK-381A, TK-38181, TK-386, FK-275.(8255)On Panel lAl, there are pencil markings on high-low indicators.
AUDIT REPORT APPENDIX PART A PHOTO    FINDING                                    HED 4.0  CONTROLS 4.1      Since the lamps on the MCP were not powered, they could not be reviewed for legibility and other features of Section 6.4 of NUREG-0700.
The markings cover bezels for four sets of two indicators.
G16      4.2      On   Panel 1A1, valves (Lo Head Sl Train 8 to Cold Leg 8888) open   to the left and close to the right, which is inconsistent with other panels. (8212)
(8469)
G29      4.3      On   Panel 181, a valve switch (AUX FW Turbine Stm Line Drain: ISO MS-817 SAB) has a J-handle instead of a T-handle like other valve switches. (8225)
AUOIT REPORT APPENOIX PART A e PHOTO FINDING HEO R32 6.17 On Panels 101 and 102, there are four Lo's that should be Hi, and vice versa, for the speed on the fan cooler.(8257)G12 G13 G40 Ll R33 G25 G31 Gl 1 G22 G30 G32 G39 6.18 6.19 6.20 6.21 6.22 6.23 6.24 6.25 6.26 6.27 6.28 6.29 6.30 On Panel 1AA, CNMT spray chemical block CT-V88 SB, the label"block" is outlined in pencil.The meaning of this is not clear.(8207)On Panel 1AA, there is a 1 abel ing problem: r eads"Accumulator A (8875A)and 8 (88758)N2 Supply and Vent" and"ACC 1C N2 Supply and Vent ISO VA" (SI-Y534SN).
G38      4.4      On  Panel 101 several key switches for the generator breakers are     "off"'o the left, instead of the standard vertical position.       (8234) 5.0   VISUAL DISPLAYS G9       5.1     On   all MCB panels and'on the   auxiliary equipment Panel fl, L3                "Hagan" brand process     controllers have scales too small to read. (8204)
(8465)On Panel 101, on fan cooler switches AH-2, A-SA and others,"STOP" is to the right.(8236)On the auxiliary equipment Panel$1, the abbreviation CNTMT;e.g., on SP-V314SASP3155A, is inconsistent with summary label and MCB labels.(8246)On Panel 101, for the diesel generator switch, standard labeling is not followed for STOP location.(8258)On Panel 1C and other panels,"percent" is used on some scales and"X" on others.(8221)On Panel 182, on the main turbine meters (EH Oil and Turbine Oil)some scales are in powers of 10 (e.g.,"40 x 103")and adjacent scales are written out (e.g.,"1500").(8227)On Panel lAA, labels now read: CNMT SUMP CNMT SUMP TEMP Consistent labels would read: CNMT SUMP LVL CNMT SUMP TEMP (8206)On Panel 1C, intermediate range meter 1R N35 AMPS has no minus sign for negative scale readings.(8218)Safety system panels are not identified by summary label.(8240)On Panel 182 and the auxiliary equipment panels, light indicator labels are not visible;also too crowded.(8226)On Panel 182, labels on push buttons for turbine control alarms have four lines of text, not easily readable.(8228)On Panel 101, the label on light indicator is not visible on several switches.(8235)
G24      5.2      On all MCB panels and on recorder panel, top scale of recorders is. hidden by the cover and unreadable from a normal   position.   (8220)
PHOTO FINDING AUDIT REPORT APPENDIX PART A HED G41 6.31 On the MCB, on the annunciator panels, up to four lines of text are not easily readable.(8243)G15 G17 6.32 On the MCB, all panels, process controller labels are obstructed by projecting plastic buttons.(8211)6.33.On Panel 1A2, rotary wheel controls (e.g., BTRS.fan selector)obstruct 1 abel s.(8213)G34 6.34 On Panel 188, pointers on rotary wheels (e.g., HClCT-3205) are not easily distinguished; color coding would help.(8230)G14 6.35 On Pan'el 1AT and others, flow lines are needed in some parts.(8210)7.0 PROCESS COMPUTERS 7.1 Since the SHNPP control room does not have computers in place, the control room could not be evaluated according to Section 7.0 of NUREG=D700.
G19      5.3      On many panels, scales on meters had more than     the r ecommended   maximum graduations between numeral s. (8215)
8.0 PANEL LAYOUT R19 G42 8.1 8.2 8.3 The simulator is significantly different from the actual CR.(8242)On Panel 1Al, for the containment spray actuators, pairs are not labeled"Train A" and"Train 8".(Operator must actuate two controls for Train A and two for Train 8).(8466)On the MCB, on all panels, coordinate axes on large matrixes of push buttons are not labeled.(8244)9.0 CONTROL-DISPLAY INTEGRATION
G37      5.4      On Panel 181 and other MCB panels, panel division lines are not distinguished from flow lines, header lines, or other functional representations.       (8233) 5.5      For all lamps for displays, the testing procedure is to remove the lamp and replace       it with a new one. (8203) 22
.R30 9.1 The CNMT spray pump test is in Panel 101 while the CNMT spray system is in Panel.1AA.(8256)  
 
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AUOIT REPORT APPENOIX PART A PHOTO   FINDING 6.0   LABELS ANO LOCATION AIOS GB       6.1     On the   MCB, there are   no labels   on status lights.   (8209)
G26      6.2      On  Panel 181, there is an unlabeled push button           unit.
(8222)
G28       6.3     On Panel   181, recorders with pointers have unlabeled scales;   e.g., water flow recorder MR-AF-2050. (8224)
G33      6.4      On Panel 182, there     is no label   on a push button in a turbine control unit.         (8229)
G43-     6. 6     All MCB panel switches outlined in red, signifying that G48                they are safety related,, have no labels for easy identification. (8245)
L8       6.7     On  the recorder panel, there are no summary labels.             (8252)
R23      6.8      On  Panel  1AA, accumulators     are identified as 1, 2, and 3 on instrumentation (e.g-., PI921, 23, 25, 27, 29, 31)           and as A, 8, and C on controls on sloping panel. (8470)
A27      6.9      On Panel lA1', on pump meters,       instrument numbers are missing..     (8254)
R25      6. 10    On Panel   1Al, labels read Pump 1 and 2 on meters         and Pump A R26                and B on switches on sloping panel. (8253)
L2        6.11    On the auxiliary equipment Panel         tl, the labels are smaller than those on MCB. (8247)
L7        6.12    On the recorder panel, the labels are smaller than those on the MCB; they are also below the recorders and therefore in shadows.     (8251)
G10      6.13    On several   MCB   panels, "10"   and "1000" and   other scale mul tipliers   are written     vertically.     (8205)
G7        6.14    On Panels 1A1, lA2, and 1C, the annunciator switches have labels written vertically on buttons. (8201)
R28      6.15    On Panel 1A2 and 181 there are labels crossed             out; e.g.,
TK-381A, TK-38181, TK-386, FK-275. (8255)
R22      6.16    On   Panel   lAl, there   are pencil markings on high-low indicators.     The markings cover     bezels for four sets of two indicators.     (8469 )
 
e AUOIT REPORT APPENOIX PART A PHOTO FINDING                               HEO R32   6.17 On Panels 101 and 102, there are four Lo's       that should be Hi, and   vice versa, for the speed on the fan     cooler.   (8257)
G12   6.18  On  Panel 1AA, CNMT spray chemical block CT-V88 SB, the label "block" is outlined in pencil. The meaning of this is not clear. (8207)
G13    6.19  On  Panel 1AA, there is a 1 abel ing problem: r eads "Accumulator    A (8875A) and 8 (88758) N2 Supply and Vent" and "ACC 1C N2 Supply and Vent ISO VA" (SI-Y534SN). (8465)
G40    6.20  On Panel 101, on fan cooler switches AH-2, A-SA and        others, "STOP"   is to the right. (8236)
Ll    6.21  On the auxiliary equipment Panel     $ 1, the abbreviation CNTMT;  e.g.,  on SP-V314SASP3155A, is    inconsistent with summary label and MCB labels.      (8246)
R33    6.22  On Panel 101,   for the diesel generator switch, standard labeling is not followed for STOP location. (8258)
G25    6.23  On Panel  1C and other panels, "percent" is used      on some scales and "X" on others.     (8221)
G31    6.24  On Panel   182, on the main turbine meters (EH Oil and Turbine Oil) some scales are in powers of 10 (e.g., "40 x 103") and adjacent scales are written out (e.g.,
              "1500"). (8227)
Gl 1  6.25  On  Panel lAA,   labels now read:   CNMT SUMP CNMT SUMP TEMP Consistent labels would read:       CNMT SUMP LVL CNMT SUMP TEMP     (8206)
G22    6.26  On Panel 1C, intermediate range meter 1R N35 AMPS has no minus sign for negative scale readings.         (8218) 6.27  Safety system panels are not identified by summary label.
(8240)
G30    6.28  On Panel 182 and the auxiliary equipment panels, light indicator labels are not visible; also too crowded. (8226)
G32    6.29  On Panel 182, labels on push buttons       for turbine control alarms have four lines of text, not       easily readable. (8228)
G39    6.30  On Panel 101, the label on   light indicator is not visible on several switches. (8235)
 
AUDIT REPORT APPENDIX PART A PHOTO    FINDING                                          HED G41       6.31       On the MCB, on the annunciator panels, up to four lines of text are not easily readable. (8243)
G15       6.32       On the MCB, all panels, process controller labels are obstructed by projecting plastic buttons. (8211)
G17      6.33   . On Panel   1A2,   rotary   wheel   controls (e.g.,   BTRS. fan selector) obstruct       1 abel s.   (8213)
G34       6.34       On Panel 188, pointers on rotary wheels (e.g., HClCT-3205) are not easily distinguished; color coding would help.
(8230 )
G14       6.35       On Pan'el 1AT and   others, flow lines are     needed   in some parts.     (8210) 7.0   PROCESS   COMPUTERS 7.1       Since the SHNPP control room does not have computers in place, the control room could not be evaluated according to Section 7.0 of NUREG=D700.
8.0   PANEL LAYOUT 8.1       The simulator is significantly different from the actual CR.   (8242)
R19      8.2        On Panel 1Al, for the containment spray actuators, pairs are not labeled "Train A" and "Train 8". (Operator must actuate two controls for Train A and two for Train 8).
(8466)
G42      8.3        On the MCB, on all panels, coordinate axes on large matrixes of push buttons are not labeled. (8244) 9.0   CONTROL-DISPLAY INTEGRATION       .
R30       9. 1       The CNMT   spray   pump   test is in   Panel 101 while the   CNMT spray system is in       Panel. 1AA.   (8256)
 
AUDIT REPORT APPENDIX  - PART 8 HUMAN FACTORS ENGINEER ING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY Part  8  - Shearon-Harris  Photo Summary Carousel
~Find1n  Location            IDS          Photo Descri    tion 6.14                        G7            Annunciator reset/test switch (8201) 1.1, 6.1                    G8            Generic    - Reaching for push button for  a lamp  test (8202) 5.1                          G9            Generic - Process controller      for small to read scale (8204) 6.13                        Gl 0          Scales  - "10" written 0 (8205)
                                                    - Inconsistent labels 6.25 12'hoto          Gll          Meters containment (8206 )
sump  level  and temp 6.18                        G12          Valve label - "Block" meaning unclear (8207) 6.19                        G13          Valve label    - Abbreviations inconsistent (8208) 5.4, 6.35                    G14          Valves  -  Need  flow lines (8210) 6.32                        G15          Process controller - Labels obstructed (8211) 4.2        10              G16          Valves  -  Open  to  left  (8212) 6.33                        G17          Rotary wheel - Labels obstructed (8213) 6.33                        G18          Rotary wheel - Labels obstructed (8214)
 
e Part 8 - Shearon-Harris  Photo Summary Carousel        Photo
~Findin Location        IO&#xb9;          Photo Oescri        tion 5.3      13            G19          Scale - More than          9 gradations (8215) 14            G20          Scale    -  Roman    numerals  for  IO (8216 )
G21          Temp  Meter    -  Label unclear (8217) 6.26      16            G22          Scale    -  Needs    - sign  (8218)
G23          Log  scale (8219) 5.2                      G24          Scale    -  Top  scale  illigible (8220) 6.23      19            G25          ScaIe    - Inconsistent label (8221) 6.2      20            G26          Push buttom        unit unlabeled    (8222 )
21            G27          Scale No label (8223) 6.3      22            G28          Scale    -  No  label (8224) 4.3      23            G29          Valve switch        - Inconsistent shape-J  instead of      T (8225) 6.28                    G30          Valve switch        -  Label on  light indicator not visible; too            crowded (8226) 6.24      25            G31          Scales      - I'nconsistent labeling (8227) 6.29      26            G32          Push  buttons - Label too crowded (8228) 6.4      27            G33          Push  button -        No label (8229    )
6.34      28            G34          Rotary knobs - Could use color to identify arrow (8230) 29            G35          Key  switch - "Off" position not vertical (8231) 30            G36          Scale for voltage incorrect (8232) 5.4      31            G37          Panel    color coding for lines (8233)
 
t Part 8  - Shearon-Harris  Photo Summary Carousel      . Photo
~Findin    Location          ID&#xb9;          Photo Oescri  tion 4~4          32              G38          Key switches  "off" positions not vertical  (8234) 6.30        33              G39          Light indicators not visible (8235) 6.20        34              G40          Fan  cooler switch "stop" to the right  (8236) 6.31        35                            Annunciator panel has too many lines of text (8243) 8.3, 3.2    36              G42          Push  button matrix -  No labels  on coord. axes (8244) 6.6          37              G43          Switches outlined in red have no 38              G44          clear labels 6.21, 6.28  39              Ll            Valves inconsistent abbreviation and too crowded (8246) 6.11        40              L2            Meter labels on auxiliary equipment panel smaller than MCB (8247) 5.1                          L3            Process  controller'Hagan)  on auxiliary equipment Panel    &#xb9;1 (8204) 42              L4            Alarm panel missing    CNR (8248) 43                            Rod  position indicators (8249) 44              L6            Status indi cator panel missing (8250) 6.12        45              L7            Recorder panel recorder labels too small and in shadows (8251) 6.7          46              LS            No summary  of labels  on recorder panel (8252)
L9            Recorder panel, no units or label on meter scale (8223) 8.2          48              R19          Train A, Train 8, not clearly indicated (8466)


AUDIT REPORT APPENDIX-PART 8 HUMAN FACTORS ENGINEER ING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY Part 8-Shearon-Harris Photo Summary~Find1n 6.14 1.1, 6.1 5.1 6.13 6.25 6.18 6.19 5.4, 6.35 6.32 4.2 6.33 6.33 Carousel Location 10 12'hoto IDS G7 G8 G9 Gl 0 Gll G12 G13 G14 G15 G16 G17 G18 Photo Descri tion Annunciator reset/test switch (8201)Generic-Reaching for push button for a lamp test (8202)Generic-Process controller for small to read scale (8204)Scales-"10" written 0 (8205)Meters-Inconsistent labels containment sump level and temp (8206)Valve label-"Block" meaning unclear (8207)Valve label-Abbreviations inconsistent (8208)Valves-Need flow lines (8210)Process controller
Part B - Shearon-Harris   Photo Summary Carousel         Photo
-Labels obstructed (8211)Valves-Open to left (8212)Rotary wheel-Labels obstructed (8213)Rotary wheel-Labels obstructed (8214) e Part 8-Shearon-Harris Photo Summary~Findin 5.3 Carousel Location 13 Photo IO&#xb9;G19 Photo Oescri tion Scale-More than 9 gradations (8215)6.26 5.2 6.23 6.2 14 16 19 20 G20 Scale-Roman numerals for IO (8216)G21 Temp Meter-Label unclear (8217)G22 Scale-Needs-sign (8218)G23 Log scale (8219)G24 Scale-Top scale illigible (8220)G25 ScaIe-Inconsistent label (8221)G26 Push buttom unit unlabeled (8222)21 G27 Scale-No label (8223)6.3 22 G28 Scale-No label (8224)4.3 6.28 6.24 6.29 6.4 6.34 5.4 23 25 26 27 28 29 30 31 G29 G30 G31 G32 G33 G34 G35 G36 G37 Valve switch-Inconsistent shape-J instead of T (8225)Valve switch-Label on light indicator not visible;too crowded (8226)Scales-I'nconsistent labeling (8227)Push buttons-Label too crowded (8228)Push button-No label (8229)Rotary knobs-Could use color to identify arrow (8230)Key switch-"Off" position not vertical (8231)Scale for voltage incorrect (8232)Panel color coding for lines (8233) t Part 8-Shearon-Harris Photo Summary~Findin Carousel.Photo Location ID&#xb9;Photo Oescri tion 4~4 6.30 6.20 6.31 8.3, 3.2 6.6 6.21, 6.28 6.11 5.1 6.12 6.7 8.2 32 33 34 35 36 37 38 39 40 42 43 44 45 46 48 G38 G39 G40 G42 G43 G44 Ll L2 L3 L4 L6 L7 LS L9 R19 Key switches"off" positions not vertical (8234)Light indicators not visible (8235)Fan cooler switch"stop" to the right (8236)Annunciator panel has too many lines of text (8243)Push button matrix-No labels on coord.axes (8244)Switches outlined in red have no clear labels Valves inconsistent abbreviation and too crowded (8246)Meter labels on auxiliary equipment panel smaller than MCB (8247)Process controller'Hagan) on auxiliary equipment Panel&#xb9;1 (8204)Alarm panel missing CNR (8248)Rod position indicators (8249)Status indi cator panel missing (8250)Recorder panel recorder labels too small and in shadows (8251)No summary of labels on recorder panel (8252)Recorder panel, no units or label on meter scale (8223)Train A, Train 8, not clearly indicated (8466)  
~Findin Location         IOf          Photo Oescri   tion R20          Order not  logical by system    (8467 )
50            R21          Order not  logical by system (B468) 6.16      51            R22          Pencil markings on switch 6.8       52            R23          Accumulators'identified      as 1, 2, 3 on  instruments    and A, B, C on auxiliary  equipment Panel Pl (B470) 6.10      53            R25          Inconsistent labels      on meters and 54            R26          scales  "1 and  2" is "A and B" (B253) 6.9                      R27          No IO  numbers on instrument (B254) 6.15      56            R28          Meters have labels crossed out (B255) 57            R29          1B2, J handle    instead of  T (401) 9.1      58            R30          CNMT pump  test switch far from 59            R31          system (B256) 6.17      60            R32          Labels incorrect on speed of fan cooler; high and low reversed (B257) 6.22      61            R33          Oiesel generator B, convention not followed (B258) 62              22          Mosaic  - Panel  lAA 63              23          Mosaic  - Panel  lAl 64              24          Mosaic.  - Panel  1Al 65              25          Mosaic  - Panel  1A1 66              26          Mosaic  - Panel  lA2 67              27          Mosaic  - Panel  lA2 68              28          Mosaic  - Panel  1Cl


Part B-Shearon-Harris Photo Summary~Findin 6.16 6.8 Carousel Location 50 51 52 Photo IOf Photo Oescri tion R20 Order not logical by system (8467)R21 Order not logical by system (B468)R22 Pencil markings on switch R23 Accumulators'identified as 1, 2, 3 on instruments and A, B, C on auxiliary equipment Panel Pl (B470)6.10 6.9 6.15 53 54 56 R25 R26 R27 R28 Inconsistent labels on meters and scales"1 and 2" is"A and B" (B253)No IO numbers on instrument (B254)Meters have labels crossed out (B255)9.1 57 58 59 R29 1B2, J handle instead of T (401)R30 CNMT pump test switch far from R31 system (B256)6.17 6.22 60 61 62 63 64 65 R32 R33 22 23 24 25 Labels incorrect on speed of fan cooler;high and low reversed (B257)Oiesel generator B, convention not followed (B258)Mosaic-Panel lAA Mosaic-Panel lAl Mosaic.-Panel 1Al Mosaic-Panel 1A1 66 67 26 27 Mosaic-Panel lA2 Mosaic-Panel lA2 68 28 Mosaic-Panel 1Cl t
t Part B - Shearon-Harris   Photo Summary Carousel         Photo
Part B-Shearon-Harris Photo Summary~Findin Carousel Location 69 Photo?OP 29 Photo Oescri tion Mosaic-Panel 1C1 70 71 72 30 31 Mosaic-Panel lB1 Mosaic-Panel 1Bl Mosaic-Panel 181 73 74 75 76 33 34 35 36 Mosaic-Panel 1B2 Mosaic-Panel 182 Mosaic-Panel 182 Mosaic-Panel 1BB 77 37 Mosaic-Panel 1D1 78 79 2 Mosaic-Panel 101 Mosaic-Panel 1Dl 80 81 82 83 7 Mosaic-Panel 102 Mosaic-Panel 102 Mosaic-Panel 102 Mosaic-Panel 102 84 Recorder panel 85 Auxiliary equipment Panel 8'1 86 87 15 16 Remote Shut-down panel Remote Shut-down panel-30-}}
~Findin Location         ?OP           Photo Oescri   tion 69              29          Mosaic - Panel   1C1 70             30           Mosaic - Panel lB1 71              31          Mosaic - Panel 1Bl 72                          Mosaic - Panel   181 73             33           Mosaic - Panel 1B2 74              34          Mosaic - Panel 182 75              35          Mosaic - Panel 182 76              36          Mosaic - Panel 1BB 77             37           Mosaic - Panel   1D1 78               2           Mosaic - Panel   101 79                          Mosaic - Panel   1Dl 80                           Mosaic - Panel   102 81                          Mosaic - Panel 102 82                          Mosaic - Panel   102 83              7          Mosaic - Panel   102 84                           Recorder panel 85                           Auxiliary equipment   Panel 8'1 86             15           Remote Shut-down panel 87              16          Remote Shut-down panel
                              }}

Revision as of 04:22, 22 October 2019

Audit Rept, Human Factors Engineering Detailed Control Room Design Review In-Progress Audit.
ML18018B632
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 03/28/1984
From: Elayat H
LAWRENCE LIVERMORE NATIONAL LABORATORY
To:
Shared Package
ML18018B633 List:
References
0009R, 9R, NUDOCS 8404230171
Download: ML18018B632 (42)


Text

~ ~

I Enc1osure 8 AUDIT REPORT HUMAN FACTORS ENGINEERING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON<<HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY HATEM ELAYAT JACK W. SAVAGE Lawrence Livermore National Laboratory March 28, 1984 0009R

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DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY CONTENTS Pacae

1. Background
2. Discussion 2.1 Audit Team Activities 2.2 DCRDR Planning 2.2.1 Review Team Selection 2.2.2 Management Responsibility 5 2.2.3 Data Management 5 2.2.4 Equipment and Workspace 6 2.2.5 Scheduling 7 2.3 Detailed Control Room Design Rhview 7 2.3.1 Review of Operating Experience 7 2.3.2 Systems Function and Task Analysis 7 2.3.3 Control Room Inventory 9 2.3.4 Control Room Survey ~ ~ 9 2.3.5 Verification of Task Performance Capabili ties 10 2.3.6 Validation of Control Room Functions ll 2.4 Assessment and Implementation ll 2.4.1 Assessment of HEDs ll 2.4.2 Selection of Design Improvements 12 2.4.3 Implementation 12 2.4.4 Verification of Design Improvements . 13 2.4.5 Verification No New HEDs Created . 13 2.4.6 Coordination of Control Room Improvements with Other- Programs 13 2.5 Reporting 14
3. Conclusions 15
4. Ref erences . 16
5. Appendix 18 Part A: HEDs Identified During the In-Progress Audit 21 Part 8: Photo Summary . 26
1. BACKGROUND Item IO-l, Control Room Design Reviews," of Task ID, "Control Room Design,"

of the Nuclear Regulatory Commission (NRC) action plan developed as a result of the TMI-2 Accident (NUREG-0660), states that operating licensees and applicants for operating licenses will be required to perform a Detailed Control-Room Design Review (DCRDR) to identify and correct design discrepancies. The objective, as stated in NUREG-0660, is to improve the ability of nuclear power plant control room operators to prevent or cope with accidents if they occur by improving the information provided to them.

Supplement 1 to NUREG-0737 confirmed and clarified the OCROR requirement in NUREG-0660. As a result'of Supplement 1 to NUREG-0737, each applicant or licensee is required to conduct their OCROR on a schedule negotiated with NRC.

NUREG-0700 describes four phases of the OCROR'o be performed by the applicant and licensee. The phases ar e:

1. Planning
2. Review
3. Assessment and Implementation
4. Reporting NUREG-0801, "Evaluation Criteria for Oe&iled Control Room Design Review,"

provides the necessary criteria for evaluating each phase.

As a requirement of Supplement 1 to NUREG-0737, the applicant and licensee is required to submit a program plan that describes how. the following elements of the OCROR will be accomplished:

1. Establishment of a qualified multidisciplinary review team.
2. Function and task analyses to identify control room operator tasks and information and control requirements during emergency operations.
3. A comparison of display and control requirements with a control room inventory..
4. A control room survey to identify deviations from accepted human factors principles.
5. Assessment of human engineering discrepancies (HEDs) to determine which HEDs are significant and should be corrected.
6. Selection of design improvements.
7. Verification that seIected design improvements will provide the necessary correction.
8. Verification that improvements will not introduce new HEDs.

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9. Coordination of control room improvements with changes from other programs such as SPOS, operator training, Reg. Guide 1.97 instrumentation and upgraded emergency operating procedures .

The NRC requires each applicant and licensee to submit a summary report at the end of the OCRDR., The report should describe the proposed control room changes, and implementation schedules, and provide justification for leaving safety significant HEDs uncorrected or partially corrected.

The NRC will evaluate the organization, process, and results of each OCROR.

The evaluation of the applicant OCRDR efforts will consist of the following, as described in NUREG-0801:

l. An evaluation of the program plan report submitted by the licensee/applicant.
2. A visit to some of the plant sites to audit the progr ess of the OCROR programs.
3. An evaluation of the licensee/applicant OCROR summary report.
4. A possible pre-implementation audit.
5. The preparation of a Safety Evaluation Report (SER) that will present the results of the NRC evaluation.

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The Shearon-Harris Nuclear Power Plant, Unit 1: (SNNPP-1) operated by Carolina Power and Light Company (CP5L), is an applicant for an operating license. As required by Supplement 1 to NUREG-0737, completion of a DCRDR is required prior to licensing.

A human factors engineering in-progress audit of the Shearon-Harris Nuclear Power Plant Control Room design review was performed at the site on August 15 through August 18, 1983. The audit was carried out by a team from the Human Factors Engineering Branch (HFEB), Division of Human Factors Safety, assisted by consultants from Lawrence Livermore National Laboratory, Livermore, Cal i forni a.

2.1 AUDIT TEAM ACTIVITIES CPKL provided a number of documents to support the NRC in-progress audit prior to, during, and following the audit. These documents are listed below:

l. Documents submitted prior to the audit:

o Human Factors Design Evaluation Report for the Shearon-Harris Unit 1 Control Room, January 23, 1981, revised September 16, 1981.

o Errata sheets of April 14, 1983, for the above report.

o Supplementary information attached to CP5L letter LAP-83-156, June 1, 1983.

2. Documents made available during and subsequent to the site audit:

o Sample HED sheets.

o Sample HED status information report.

o Sample HED listing.

o Shearon-Harris Nuclear Power Plant Unit 1 control room design evaluation records file index.

o Representative set of interim MCB panel drawings.

0 Additional information requested by NRC audit. team, CPEL letter LAP-83-426, September 27, 1983.

Available at the audit site were: a) Shearon-Harris Control Board Simulator, which is significantly different from the main control boar d; and b)

Shearon-Harris Main Control Board (MCB), which is still under construction.

If CPEL operating and engineering personnel, as well as the human factors consultant from Essex Corporation involved in the DCRDR, were available on a daily basis dur ing the audit.

The in-progress audit by the NRC audit .team consisted of briefings, discussions, document r eviews, and a brief review of the Shearon-Harris Simulator and the incomplete Shearon-Harris MCB. The emphasis was on evaluating the organization and processes of the applicant DCRDR. The in-progress audit findings are summarized below.

2.2 DCRDR PLANNING 2.2.1 Review Team Selection Supplement 1 to NUREG-0737 requires the establishment of a qualified multidisciplinary review team. Guidelines in team selection are found in NUREG-0700 and NUREG-0801.

CP&L established a multidisciplinary review team for the DCRDR of the Shearon-Harris Nuclear Plant. The team consisted of CPEL and Essex Corporation personnel, repr esenting a cross-section of. the required disciplines.

The qualifications of the review team members are contained in Appendix A of the CPLL report, and a description of the review team composition was stated in the CPEL letter of June 1, 1983.

The review team was divided into the following three groups'.

o'uman Factors Evaluation Group.

o Human Factors/Operations Support Group..

o Project Management/Nuclear Operations/Plant Engineering and Design Group.

The Human Factors Evaluation Group was composed of six intermediate and junior level human factors specialists from the Essex Corporation field office located in Raleigh, North Carolina. The group's responsibility was stated to be to conduct data collection, data reduction, and preliminary data analysis; however, the extent of each group member's participation is not clear, with the exception of the group supervisor. The group supervisor's responsibility was to coordinate the evaluation activities, interface with CPEL project manager, and represent the human factors position at HED review meetings.

The Human Factors/Operations Support Group was composed of Essex Corpor ation home office personnel located in Alexandria, Virginia. This group consisted of five senior human factors specialists, a nuclear engineer, two reactor operators, three junior human factors specialists, a procedure specialist, and a photographer. The overall responsibility of this group was stated to be review, in-depth analysis, discrepancy definition and discrepancy resolution recommendations, data collection support, and operational and engineering analysis. The group leader was not identified for this group, and the extent of each member's participation is not clear.

The Project Management/Nuclear Operations/Plant Engineering and Design Group was composed of CPKL personnel from various disciplines, representing the Nuclear Plant Engineering Department, System Planning and Coordination Department, Nuclear Operations Department, Nuclear Operations The group leader for this group coordinated the activities of Department'raining.

Essex, CPEL, EBASCO (AEE) and the NSSS (Westinghouse), and reviewed the overall progress of the DCROR. This group was supported by EBASCO and Westinghouse representatives to provide any required review and comments on design philosophies, discrepancy analysis, etc.

The NRC audit team concluded that the CP&L review team, as described above will satisfy the requirement of Supplement 1 to NUREG-0737 to establish a multidisciplinary review team to conduct a OCROR.

2.2.2 Mana ement Res onsibilit NUREG-0700 recommends that applicant management support is needed to ensure'to the OCROR team the availability of information, equipment, and all categor ies of manpower needed to conduct the review.

Although not stated in the CPLL report, it was evident during the NRC audit that management fully supported the OCROR process as intended by the guidance in NUREG-0700.

Some examples of management support stated to the NRC audit team are:

o Descriptions of management participation, follow-up, and review of the OCROR and the control room redesign process.

o A statement describing how management stopped control board fabrication for several months to allow the review and. redesign modifications to be resolved, thus avoiding wasted construction effort and retrofit expense.

o Personnel from other plants were made available to contribute their appropriate expertise and experience.

2 .2.3 Data Management NUREG-0700 guidelines recommend that methods of data management should be established prior to the OCRDR. This involves:

1. Providing the review team members with reference material (panel layout drawings, control room floor plans, etc.)
2. The selection of standard forms to be used for recording the results of the CR review.,
3. The setting up of a system for the management of these standard forms and the data obtained during the DCRDR.

During the in-progress audit of Shearon-Harris .Nuclear Power Plant Unit 1, the NRC audit team did not observe an elaborate mechanized data management system being used. However, reference material was provided to the review team, and

the forms used to record OCROR data were informally retained in filing cabinets, mostly in their raw form, after being completed by the review team members. The review forms and sheets used in the OCROR are described below:

o The Human Engineering discrepancy forms were used to record the discrepancy items and their location on the MCB, a problem description and guidelines violated, the description of the specific operator error(s) resulting from the HED, the list of procedures or operations that use the discrepancy items that induced operator errors, the list of consequences of operator error during all modes of operation, and suggestions for potential backfits. These forms were filled out by survey team members and later checked and validated by the HF consultant.

A panel area layout sheet, which contained a drawing for a specific panel area. HEOs were identified and recorded on these sheets by the team members and subsequently reviewed by the HF consultant and the CP&L project manager.

o A computerized HED status information report was used to record all HEDs. The report listed all HEOs by IO number, HED description, and status (i.e., whether resolved, deleted or other status).

A coded numbering scheme was used to describe HEDs as follows:

o Plant location.

o Generating unit location .

o Physical location.

o Component type or design feature; o HED sequence number.

The NRC audit team concluded that the applicant's data management meets the intent of NUREG-0700 guidelines.

2.2.4 Equipment and Workspace The applicant's plans do not specifically describe plans for the OCROR review team workspace and equipment requirements as recommended in NUREG-0700.

However, the NRC audit team understands that adequate meeting spaces in the main control room building and simulator building were made available to the CPEL OCROR team, HF consultant, and operating personnel during the survey and redesign processes. Equipment needs wer e minimal-since the survey and redesign work utilized paper mock-ups and mark-ups of simulator and control room panel drawings, which were supplied by design and drafting room personnel as appropriate. It is assumed that equipment needed for the remaining CPLL OCROR tasks (e.g., illumination and sound'evel meters, HVAC evaluation equipment, etc.) will be made available to the review team when needed.

It was evident to the NRC audit team that adequate clerical, reproduction and other peripheral support services are available whenever needed.

2.2.5 ~E NUREG-0700 recommends that the planning of the control room review include the development of a detailed schedule of review tasks.

The CP&L report did not describe any schedules for the OCROR processes. No formal milestone charts,. task schedules, or personnel assignments were observed. As described to the NRC audit team, scheduling was done on a verbal, informal day-to-day basis in a manner to accomplish the required tasks within a predetermined time period. Attendance at the review meetings of individual team members and other personnel was understood to be determined by the needs of the agenda of each particular meeting. Specific personnel attendance was understood to be determined by the CP5L project manager and the Essex human factors engineer, both of whom were always present. Oespite the absence of a formal documented scheduling method, the NRC audit team concluded that the review tasks were adequately staffed and were executed in an acceptable way. to CPQ letter of September 27, 1983, describes a schedule for development, verification, arid validation of SHNPP-1 EOPs using the simulator initially, and the SHNPP-1 Control Room finally, after the CR is functional.

2.3 OETAILEO CONTROL ROON OESIGN REVIEM 2.3.1 Review of 0 eratin Ex erience Two steps are recommended by NUREG-0700 guidelines for reviewing operating experience. These include the examination of available documents and the-survey of control room operating personnel. There was no mention in the CPEL report of a formal review or examination of operating experience documents.

The NRC audit team is not aware of the details of any formal operator questionnaires or CR operating personnel interview processes. However, as described to the NRC audit team, the Har ris operating experience information was collected from operators whose experience was obtained from other plants, including H. B. Robinson, Unit 2.

It was stated that operator input was used in the determination of HEO corrective actions and verification that the final designs are user-oriented, as CPEL desires. The NRC audit team concluded that operating experience was factored into the review process directly instead of via a formal interview/reporting process.

2.3.2 S stems Function and Task Anal sis Supplement 1 to NUREG-0737 requires the applicant to perform systems function and task analyses to establish the input and output requirements of control room operator tasks to serve as a basis for defining the requirements for control room instrumentation, controls, and other equipment, which will ensure the safe operation of the plant under emergency conditions. This can be accomplished by carrying out the following systems functions and task analysis

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steps identified in the NUREG-0700 guidelines.

l. Identification of Systems and Subsystems.
2. Identification of Operating Events for Analysis .
3. Function Identification.
4. Operator Task Identification and Analysis.

The task analysis performed by CPLL, using NUREG-1580 guidelines, differs from the above NUREG-0700 guidelines because NUREG-0700 was published while the CPKL analysis was still in progress.

The task analysis guidelines in NUREG-1580 are based on analyzing rocedures to provide documentation of operator actions, information requirements, an controls and displays used in executing the chosen procedures.

NUREG-0700 task analysis guidelines, on the other hand, are based on a systematic top-down function/task analysis to determine information and Nih b' 1 d<<h actual instrumentation and controls which are available in the control room.

The NRC audit team observes that there may not be uniformity between CPKL and NUREG-0700 in the meaning of the terms "function" and "functional analysis."

In response 'to an NRC audit team request, CPEL stated in their letter of September 27, 1983, that a generic top-down task analysis, based on the identification of event sequences, plant systems, and operator functions and tasks (e.g.,'s recommended in NUREG-0700), was performed on the High Pressure (HP) Basic Version of the Westinghouse Owners Group (WOG) Emergency Response Guidelines (ERGs). NRC staff review of the WOG guidelines indicate that they are a satisfactory start in identifying and describing tasks; but that they are generic, not plant specific. They do not identify required information and control capability characteristics sufficiently to compar e to a control room instrumentation and control inventory.

There is no substantiating documentation describing the details or completeness of the methodology used in the task analysis. It is also not clear to the NRC audit team whether CPEL or the WOG Committee performed the task analysis.

It is stated that the primary outputs of the WOG task analysis are tables listing all instruments and controls utilized in performing the ERGs.

jt is stated that CP&L plans to use the WOG generic analysis to do the following:

o Identify SHNPP-Unit 1 deviations from the Generic ERGs.

o Task analyze the differences and generate SHNPP-Unit 1 plant-specific lists of instruments and controls required to perform the Harris EOPs in the SHNPP-Unit 1 Control Room.

o Compare the plant specific equipment lists with the Control Room inventory (see 2.3.3; below) to identify missing components or needed components not included in the design.

o Review each step of the SHNPP-Unit 1 EOPs by reviewing the generic task analyses and the ERG deviation analyses. ,

o Resolve and correct applicable identified HEDs.

It appears to the NRC audit team that CP5L is contending that the above steps will follow the NUREG-0700 recommendation to define instrumentation and control requirements by a top-down function/task analysis approach.

It is the NRC audit team's position that the CPKL process described above may not result in defining operator information and control requirements independently from consideration of equipment that is already installed in the control room. This process may not ensure that the man/machine interface is complete or that an optimal design for safe operation will result.

The NRC audit team concluded that a more complete rationale and justification for CPEL's approach to conducting their task analyses will be needed to determine whether the requirements of Supplement 1 to NUREG-0737 have been s ati sf i ed.

2.3.3 Control Room Inventor Supplement 1 to NUREG-0737 requires the~pplicant .to make a control room inventory and to compare the operator display and control requirements determined from the task analyses with the control room inventory to determine missing controls and displays.

Ouring the in-progress audit it was stated that the EBASCO panel component list was substituted for a control room inventory. This list was used to check the existence of controls and displays on the MCB panel drawings, to confirm the expected panel content vs. need. The needs, as expressed in the EBASCO component list, were determined by EBASCO and CPEL operating experience.

The NRC audit team's position is that Supplement 1 to NUREG-0737 is not fully satisfied because the WOG generic function and task analysis, as described previously in Section 2.3.2, does not specify control and display characteristic requirements in sufficient detail to permit comparison with the inventory characteristics.

2.3.4 Control Room Surve Supplement 1 to NUREG-0737 requires that a control room survey be conducted to identify deviations from accepted human factors principles. NUREG-0700 provides guidelines and criteria for conducting a control room survey.

The objective of the control room survey is to identify, for assessment and possible correction, characteristics of displays, controls, equipment, layout, and ambient conditions that do not conform to good human engineering practices. The Harris control room survey was carried out through reviews of plant design documents, reviews of vendor documentation, and reviews of layout drawings. The Shearon-Harris Simulator was used where applicable. A to-scale

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Part 8 - Shearon-Harris Photo Summary Carousel Photo Location IDf Photo Description

'F1ndin 88 17 Remote Shut-down panel 89 18 Remote Shut-down panel 90 19S Simulator Panel 91 ZOS Simulator Panel 92 21S Simulator Panel 93 22S Simulator Panel 94 23S Simulator Panel 95 24S Simul ator radi ation monitors 96 25S Simulator. Instrumentation 97 26S Simulator radiation monitor computer 98 ZTS Simulator remote instructor console 99 Simulator - General view 100 29S Simulator - General view 101 30S Simulator - General view 102 31S CPEL paste-ups:

left - original panels; right - new design panels 0009R

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paper mock-up was also used as a basis for identifying HEOs and as a starting point from which to relocate controls and displays. During the course of the in-progress audit, the NRC audit team observed that the simulator room and its environmental aspects do not duplicate those of the main control room, although it continues to be used for training and procedure walk/talk throughs.

The CR survey process initiated by CP&L consisted of the following steps:

l. Essex Corporation personnel generated initial HEOs by examining panel layout drawings. HEDs were identified by writing a description of the problem on the drawing. Often, several HEOs were identified in this manner. The panel layout drawing literally became a scratch pad upon which the observations of the reviewer were written. These observations later became the basis for determining HED resolutions .
2. The Essex Corporation field project manager then reviewed and provided the initial verification of these HEDs.
3. Next, the CP&L project manager and his assistant reviewed the HEDs for accuracy and completeness and concurred with the potential operational problems the HEOs indicated.
4. At this point, the Essex Corporation management reviewed and approved the HEDs in preparation for the following step.
5. HEDs were then presented to a group of people at the site for review and resolution. These people nnsisted of Essex Corporation, EBASCO, Westinghouse, and CP&L training, engineering, construction, and operations personnel as appropriate.

The human factors consultant stated during the in-progress audit that the HEDs will be "designed out" of the board in the course of the review and redesign work by following a policy of correcting the HEDs as many times as necessary to eliminate, them before they determine that the redesign is complete.

As a result of the control room audit, it is the NRC audit team's position that the applicant's CR survey meets the intent of NUREG-0700 guidelines and that the applicant intends to satisfy the requirements of Supplement 1 to NUREG-0737.

2.3.5 Verification of Task Performance Ca abilities The objective of "verification of task performance capabilities" 'as described in NUREG-0700 guidelines is to assur e that the CR contains sufficient controls and instruments so that operator tasks can be performed in the existing CR with minimum potential for human error. Verification can be accomplished by comparing the instrument and equipment requirement derived from the task analysis to the inventory of existing instrumentation, controls, and other equipment. This verification step was not carried out at Shearon-Harris since instrument and equipment requirements wer e not derived from the function and task analysis described in NUREG-0700; rather, the task analysis and review process was primarily based on NUREG 1580.

It appeared to the NRC audit team that CP&L's version of the verification that was accomplished during the redesign effort was done by using selected

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e procedures as a basis to identify operational functions, operator tasks, and to identify the controls and instruments needed to execute the procedures.

Plans for future verification of SHNPP-1 EOPs are described in Attachment 3 to CP&L letter of September 27, 1983. The results of this verification should be reported to NRC for review on a schedule acceptable to NRC.

2.3e6 Validation of Control Room Functions The objectives of the validation process as outlined in NUREG-0700 is the determination of whether functions allocated to CR operating personnel can be accomplished within the structure of defined operating and emergency procedures and the existing design of the CR. This validation step was not accomplished at Shearon-Harris, nor addressed in the CP&L report. However, to CP&Ls letter of September 27, 1983, describes their plans to validate the SHNPP.-1 EOPs. The results of this validation should be reported to NRC for review on a schedule acceptable to NRC.

2.4 ASSESSMENT AND IMPLEMENTATION 2.4.1 Assessment of HEDs Supplement 1 to NUREG-0737 requires that HEDs be assessed to determine which HEDs are significant and should be corrected. NUREG-0700 and NUREG-0801 contain guidelines for the assessment process.

A formal documented assessment of HEDs,~s intended by the NUREG-0700 guidelines, was not done by the CP&L review team. Instead, the assessment function was accomplished as one of several parallel iterative processes executed during what CPKL called the ~redesi n of the Harris Main Control Boards (MCB).

It was stated that the initial HED identification process was completed on each panel before moving to the next. The candidate HEDs were screened by the on-site human factors consultant in conjunction with the CP&L review project manager. Those that survived to be corrected were then discussed (assessed) in batches in meetings attended by the review team membership, which included the human factor s consultant, the CP&L review project manager, CP&L operating and engineering personnel, and EBASCO (A&E) and Westinghouse personnel as appropriate. The CP&l project manager and the Essex human factors consultant were always present at all meetings, with additional members present when their expertise was needed.

There were many redesign review meetings during which the Harris control room was repeatedly and iteratively laid out. As stated to the NRC audit team, this process included discussion of many alternate resolutions prior to the selection of the final resolution to each HED.

The stated CP&l policy was to correct every HED by designing it out of the system, with the objective of achieving an HED-free board. The execution of this philosophy obviates the necessity to follow the NUREG-0700 recommendations of formally assessinq each HED for importance, potential safety consequences, the cumulative impact of minor HEDs, determination of priorities, setting implementation schedules, etc.

The NRC audit team concludee that the applicant's method will satisfy the requirements of Supplement 1 to NUREG-0737.

2.4.2 Selection of Desi n Im rovements Supplement 1 to NUREG-0737 requires selection of control room design improvements that will correct significant HEDs. It also states that improvements that can be accomplished with an enhancement program should be done promptly.

As stated in Section 2.4.1. of this report, alternate design improvements for each HEO wer e considered during the CP5L redesign review process, and this function was another iterative parallel process executed dur ing the redesign of the Harris MCB. NUREG-1580 criteria, along with the Essex developed Human Engineering Requirements Specifications (HERS) are understood to have been used to support the review team choice of resolutions for each HED.

As described in the Harris Report, the conduct of the redesign effort appear s to have been similar to the determination of a new design. Some examples fol low.

The Harris Report, Section 4, Annunciator Review, and their letter, LAP-83-426, of September 27, 1983, states that the annunciator need, location, and grouping considerations resulted in removing about 250 tiles from the MCB.

Also, it was stated to the NRC audit team that the MCB redesign rdview resulted in the removal of about 200 cotttrols and the relocation of a significant number of unnecessary items from front to rear panels. EBASCO and Westinghouse concurrence was obtained for CP5L proposed component removals.

Appendix 0 of the Harris report; "Reconmended Control Room Equipment Arrangement," describes how the recommended panel arrangements were determined by consider ing such factors as equipment location desirability, the readability of displays and labels from various MCB locations, visual angles, adverse effect on short-term operators'emory because of movement distances between equipment, discrimination problems due to viewing distances, etc. In addition, a quarter scale mock-up was used to study and confirm rearrangement of the boards. The mock-up was also used to verify and confirm labeling, demarcation, and annunciator arrangement. It was stated that part of the redesign effort included ongoing discussions with operators to verify that the MCB redesign details and HED corrective actions were compatible with operational needs, and left no discrepancies uncorrected. This included verification that any equipment found missing was, or would be, installed before the redesign was considered complete.

The NRC audit team concluded that the applicant will satisfy requirements of Supplement 1 to NUREG-0737 if the SHNPP OCRDR summary report completely documents the methodology and results of design improvement selection so that the NRC can confirm that the requirements have been satisfied.

NUREG-0700 describes guidelines for determining the implementation schedule for des i gn improvements.

The Harris Report does not include a section on implementation because their

0 policy of correcting all HEDs during the. execution of the redesign process pr ior to operation obviates it.

The CPSL letter, LAP-83-156, of June 3, 1983, expresses confidence that the verification and validation following the availability of the WOG task analysis and generic guidelines, and the completion of SHNPP EOPs verification and validation will reveal few, 'if any, MCB human factors concerns. If any HEDs should be identified the NRC audit team concluded that a continuation of the CPEL redesign corrective action policy will result in their correction.

Such identification of future HEDs, their resolution, and an acceptable time schedule for implementing the corrective action should be reported to NRC for evaluation.

2.4.4 Verification of Desi n Improvements Supplement 1 to NUREG-0737 requires verification that selected design improvements will provide the necessary corrections of HEDs.

As stated in Sections 2.4.1 and 2.4.2, the execution of the CPAL MCB redesign process to design HEDs out of the system incorporates HED assessment',,the consideration of alternate designs in the selection and implementation of design improvements, and the use of the mock-up to study and confirm MCB rearrangements. As explained to the NRC audit team, it is inherent in this process that HED corrective actions will be verified to provide the necessary corrections of HEDs.

The NRC audit team expects that CPEL wiR satisfy this requirement of Supplement 1 to NUREG-0737.

2 .4.5 Verification No New HEDs Created Supplement 1 'to NUREG-0737 requires verification that control room design improvements will not introduce new HEDs into the control room.

The NRC audit team observed that the CPEL redesign process inherently verifies that the HED corrective actions will not introduce new HEDs into the control room. The NRC audit, team therefore expects that CP&L will satisfy this requirement of Supplement 1 to NUREG-0737.

2.4.4 Coordination of Control Room Im rovements with Other Pro rams Supplement 1 to NUREG-0737 requires that control room improvements be coordinated with changes from other programs; e.g., safety parameter display system (SPDS), operator training, Regulatory Guide 1.97 (R.G. 1.97), and emergency operating procedures (EOPs).

Harris EOPs are still being developed using modfied Robinson procedures and the Harris simulator. The EOP development will include consideration of Westinghouse Owners Group Emergency Response Guidelines, and it was stated that the EOPs wi 11 be task analyzed prior to implementation. The results of the task analysis will be fed back to the EOPs and the DCRDR. CPEL plans to complete the systems operation and task analysis and verify and validate the EOPs after they are implemented and the MCB is fully functional.

It was stated that subsequent MCB modifications will follow the same processes as the MCB redesign.

The status of the SPOS was explained in a special meeting w'ith the NRC audit team. The SPOS design is not yet complete, but will include human factors considerations. CPKL is buying an SAI computer which will feed six CRTs, and will do all of the data processing to meet NUREG-0696 requirements. EOF and -

TSC consoles will also have access to the SPOS displays. A written color code standard does not exist, but it is intended to limit the displays to no more than four colors. Two hours of events will be contained in memory, and will be frozen if a safety-related event occurs. Selected out-of- tolerance data will be recorded with a 10-minute compressed time span. The computer will be locked, will run a card control access system, and operators will not be able to change the programming.

The NRC audit team expects that the SPOS as described will meet the intent of the requirements. The final design should be reported to NRC for review and implemented on a schedule approved by NRC.

Based on discussions with CP5L concerning coordination, the NRC audit team concluded that the applicant intends to meet the requirements of Supplement 1 to NUREG-0737 to coordinate the DCROR with other control room improvement programs.

2.5 REPORTING A program plan report of January 23, 1981, with revisions of September 16, 1981, and supplemental information dated April 14,, 1983, was submitted on June 1, 1983. The NRC staff notified CPKL by telephone in July 1983 that the program plan was incomplete, and that additional information would be required before NRC can determine its acceptability. A letter of September 27, 1983, submitted additional information requested by the staff during the on-site in-progress audit of August'5 through 18, 1983.

Since there are several areas in which the OCROR is incomplete, these topics must be addressed by CPEL in their OCRDR summary report to fully satisfy the requirements of Supplement 1 to NUREG-0737.

3. CONCLUSIONS CPSL is currently continuing its OCROR and making improvements to the redesigned MCB. NRC audit team and staff reviews of the Shearon-Harris reports and the results of the in-progress on-site audit determined that CPKL is conducting a OCROR that will substantially meet the guidelines of NUREG-0700 and the requirements of Supplement 1 to NUREG-0737, except for the fo1 1 owing:

o The system function and task analysis was not conducted by CPEL as recorrmended in NUREG-0700.

o The comparison of display and control requirements determined by a function and task analysis with a control room inventory was not fully performed by CPEL as recommended in NUREG-0700.

o Verification and validation of SHNPP-1 EOPs will be completed after the control room is functional, as defined in Attachment 3 to CP5L letter of September 27, 1983.

o Some items were not included in the CPEl report because they were not ready for review. These items are described in the Appendix to this report.

Any needed corrective actions or changes resulting from the above should be implemented prior to licensing or on a schedule acceptable to the NRC.

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4. REFERENCES
1. Human Factors Design Evaluation Report for Shearon-Harris Unit 1 Control Room, January 23, 1981, revised September 16, 1981, and April 14, 1983.
2. Supplement 1 to NUREG-0737, "Requirements for Emergency Response Capability" (Generic Letter No. 82-33), December 17, 1982.
3. NUREG-0700, "Guidelines for Control Room Design Reviews," September 1981.
4. NUREG-0801, "Evaluation Criteria for Detailed Control Room Design Reviews," Draft for Comment, October 1981.
5. CP&L letter LAP-83-156 to H. R. Oenton, supplemental information to the OCRDR summary report entitled, "Human Factors Design Evaluation Report for the Shearon-Harris Unit 1," June 1, 1983.
6. CP5L letter LAP-83-426 to H. R. Oenton, information requested by the NRC audit team, September 27, 1983.
7. NUREG-1580, "Human Engineering Guide to Control Room Evaluation," July 1980.

0009R

APPENDIX OISPOSITION ANO STATUS OF HEOS

5. APPENDIX This Appendix discusses the disposition of human engineering discrepancies (HEDs) documented during the CP&L OCROR process, and reviewed by the NRC audit team during the in-progress audit of August 15-18, 1983. It also includes HEDs identified by the NRC audit team. Table 3-1 of Attachment 1 of the CP&L letter of June 1, 1983, tabulates and categorizes the 134 HED reports generated and resolved during the CP&L OCROR. It was stated to the NRC audit team that CP&L will resolve additional HEDs that may be identified in the future by the same OCROR processes described in the main body of this report.

The following descriptions of the resolved HEDs are transcribed from Table 3-1 of the CP&L letter:

HED reports generated during the OCROR have been reviewed by CP&L and resolved. The CP&L resolutions of the 134 HED reports are:

o . 49 HEDs were resolved by rearrangement of the control board.

o ll HEDs were resolved by a hardware change on the main control board.

o 8 HEOs were resolved by a label or meter scale change.

o 3 HEDs were resolved by an administrative or maintenance procedure change.

o 33 HEDs were withdrawn because they were unique to the simulator and not applicable for the SHNPP-1 Control Room.

o 4 HEDs were withdrawn because each HEO was defined as not applicable by peer review.

o 2 HEDs had corrective action taken but the action did not totally resolve the HED. Justification was provided and approved by CP&L management on a case-by-case basis.

o 24 HEOs had no corrective action taken. Justification was provided and approved by CP&L management on a case-by-case basis. None of these HEDs were considered by CP&L to have safety significance.

The NRC audit team reviewed in detail with CP&L and the human factors consultant all 24 of the HEDs for which no corrective action was taken and foundthis determination to be acceptable. A representative sampling of individual HEDs and resolutions from the other categories was reviewed and were found to be acceptable.

The NRC audit team on-site review process was typically as follows:

o The original documents identifying and describing the problems were inspected and discussed.

o The documents examined consisted of marked-up and annotated panel drawings, handwritten and typed preprinted HED forms, and photographs .

0 o The HED descriptions discussed included the following:

- A description of the equipment and its location.

- A description of the problem.

- Identification of the guidelines violated.

- Identification of specific operator errors resulting from the HED.

- A list of procedures or operations affected.

- Consequence of operator error.

- Suggested backfits.

- The HED resolutions selected.

The NRC audit team observations are as follows:

o All of the HEDs discussed were written up on the paper mock-ups of the original MCB panels none on the incomplete MCB panels.

o The execution of the resolutions was carried out on a continuing iterative basis until the final design and layout was achieved.

o The final design was then drafted up and used for construction of the MCB.

o Future HEOs. will follow the same process.

o CPSL stated policy is to fix all HEDs and end up with an HEO-free MCB .

The NRC audit team also reviewed the pa&ially completed MCB and independently identified the HEDs contained in Part A of this Appendix. It was stated that

'most of the HEDs listed in Part A of the Appendix duplicated HEDs previously identified by the CPEL OCRDR. However; a one-to-one identification between the CPEL HEOs and the NRC audit team HEDs was not made. For each of the HEDs listed in Part A of this Appendix, CP5L should report to the NRC the status and proposed resolutions, and an implementation schedule for corrective action must be submitted to the NRC'20 days prior to loading fuel (PTLF).

Discrepancies must be corrected PTLF or on a schedule approved by the NRC.

Items listed below. were not included in the CP5l report because they were not ready for review. CP&L must complete the OCRDR and supply additional information about these items to enable the NRC to determine the acceptability of the OCRDR. Numbers in parentheses are the corresponding sections of Chapter 6 of NUREG-0700:

1. Workspace (6.1)
2. Communications (6.2)
3. Remote Shutdown Panel (all)
4. Recorder Panel (all)
5. CRTs (6.7)
6. Process Computer and Peripherals (6.7)

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7. Annunciator Items o Set Points (6.3.1.2a) o General Alarms (6.3.1.2b )

o Multi-Channel or Shared Alarms (6.3.1.2c(l), c(2))

o Multi-unit Alarms (6.3.1.2d) o Signal Detection (6.3.2.1 a through f) o Coding (6.3.2.2) o Visual Annunciator Panel Labeling (6.3.3.lb(2))

Visual Annunciator Panel Lamp Replacement (6.3.3.lc(3))

o Alarm Recognition and Identification (6.3.3.2 c through f) o Arrangement of Tiles, Labeling of Axes (6.3.3.3c(3))

Arrangement of Tiles, Blank Tiles (6.3.3.3f) o Tile Legends, Controls, Silence (6.3.4.1a(2))

Tile Legends, Controls, Acknowledge (6.3.4.lb(2))

Tile Legends, Controls, Reset (6.3.4.1c(3))

Tile Legends, Controls, Test (6.3.4.1d(2))

o Annunciator Response Procedures Availability (6.3.4.3a) e

8. SPDS Missing information should be reported to NRC for review. Any needed corrective actions or changes shall be implemented prior to licensing or on a schedule acceptable to the NRC.

Part 8 of this Appendix is a list of photos taken by the NRC audit team during their independent review of the MCB.

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AUDIT REPORT APPENDIX - PART A HUMAN FACTORS ENGINEERING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY Part A - This part contains Human Engineering Oiscrepancies (HEOs) identified by the NRC audit team during the in-progress audit. The number in parentheses (8-xxx) is the HED ID number assigned by the team. These must be reviewed by the applicant and a resolution and implementation schedule submitted 120 days PTLF. Discrepancies must be corrected PTLF or on a schedule approved by the NRC.

PHOTO PINGING HED 1.0 CONTROL ROOM WORKSPACE 1.1 Since the control room at SHNPP is not completed, the arrangement could not be evaluated according to Section 1.0 of NUREG-0700.

G8 1.2 On all panels, the pash buttons for the lamp tests of the status lights are mounted above optimum height; i.e., not within reach. of 5th percentile female. (8202)

2. 0 I COMMUN CAT IONS 2 .1 Since the control room at SHNPP is not completed, the communications system could not'e evaluated according to Section 2.0 of NUREG-0700.

3.0 ANNUNCIATOR WARNING SYSTEMS 3.1 On the reactor and tur bine first.-out panels, there is no prioritization scheme for alarms other than red/white.

(8453) 3.2 On all panels, large matrixes of annunciator lights and status lights have no coordinate axis labels. (8458) 3.3 On the- annunciator visual alarm subsystem, cues for out-of-service alarms are not planned for. (8471) 3,4 . On the annunciator operator response subsystem, there is no coding of controls for easy recognition. (8463)

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AUDIT REPORT APPENDIX PART A PHOTO FINDING HED 4.0 CONTROLS 4.1 Since the lamps on the MCP were not powered, they could not be reviewed for legibility and other features of Section 6.4 of NUREG-0700.

G16 4.2 On Panel 1A1, valves (Lo Head Sl Train 8 to Cold Leg 8888) open to the left and close to the right, which is inconsistent with other panels. (8212)

G29 4.3 On Panel 181, a valve switch (AUX FW Turbine Stm Line Drain: ISO MS-817 SAB) has a J-handle instead of a T-handle like other valve switches. (8225)

G38 4.4 On Panel 101 several key switches for the generator breakers are "off"'o the left, instead of the standard vertical position. (8234) 5.0 VISUAL DISPLAYS G9 5.1 On all MCB panels and'on the auxiliary equipment Panel fl, L3 "Hagan" brand process controllers have scales too small to read. (8204)

G24 5.2 On all MCB panels and on recorder panel, top scale of recorders is. hidden by the cover and unreadable from a normal position. (8220)

G19 5.3 On many panels, scales on meters had more than the r ecommended maximum graduations between numeral s. (8215)

G37 5.4 On Panel 181 and other MCB panels, panel division lines are not distinguished from flow lines, header lines, or other functional representations. (8233) 5.5 For all lamps for displays, the testing procedure is to remove the lamp and replace it with a new one. (8203) 22

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AUOIT REPORT APPENOIX PART A PHOTO FINDING 6.0 LABELS ANO LOCATION AIOS GB 6.1 On the MCB, there are no labels on status lights. (8209)

G26 6.2 On Panel 181, there is an unlabeled push button unit.

(8222)

G28 6.3 On Panel 181, recorders with pointers have unlabeled scales; e.g., water flow recorder MR-AF-2050. (8224)

G33 6.4 On Panel 182, there is no label on a push button in a turbine control unit. (8229)

G43- 6. 6 All MCB panel switches outlined in red, signifying that G48 they are safety related,, have no labels for easy identification. (8245)

L8 6.7 On the recorder panel, there are no summary labels. (8252)

R23 6.8 On Panel 1AA, accumulators are identified as 1, 2, and 3 on instrumentation (e.g-., PI921, 23, 25, 27, 29, 31) and as A, 8, and C on controls on sloping panel. (8470)

A27 6.9 On Panel lA1', on pump meters, instrument numbers are missing.. (8254)

R25 6. 10 On Panel 1Al, labels read Pump 1 and 2 on meters and Pump A R26 and B on switches on sloping panel. (8253)

L2 6.11 On the auxiliary equipment Panel tl, the labels are smaller than those on MCB. (8247)

L7 6.12 On the recorder panel, the labels are smaller than those on the MCB; they are also below the recorders and therefore in shadows. (8251)

G10 6.13 On several MCB panels, "10" and "1000" and other scale mul tipliers are written vertically. (8205)

G7 6.14 On Panels 1A1, lA2, and 1C, the annunciator switches have labels written vertically on buttons. (8201)

R28 6.15 On Panel 1A2 and 181 there are labels crossed out; e.g.,

TK-381A, TK-38181, TK-386, FK-275. (8255)

R22 6.16 On Panel lAl, there are pencil markings on high-low indicators. The markings cover bezels for four sets of two indicators. (8469 )

e AUOIT REPORT APPENOIX PART A PHOTO FINDING HEO R32 6.17 On Panels 101 and 102, there are four Lo's that should be Hi, and vice versa, for the speed on the fan cooler. (8257)

G12 6.18 On Panel 1AA, CNMT spray chemical block CT-V88 SB, the label "block" is outlined in pencil. The meaning of this is not clear. (8207)

G13 6.19 On Panel 1AA, there is a 1 abel ing problem: r eads "Accumulator A (8875A) and 8 (88758) N2 Supply and Vent" and "ACC 1C N2 Supply and Vent ISO VA" (SI-Y534SN). (8465)

G40 6.20 On Panel 101, on fan cooler switches AH-2, A-SA and others, "STOP" is to the right. (8236)

Ll 6.21 On the auxiliary equipment Panel $ 1, the abbreviation CNTMT; e.g., on SP-V314SASP3155A, is inconsistent with summary label and MCB labels. (8246)

R33 6.22 On Panel 101, for the diesel generator switch, standard labeling is not followed for STOP location. (8258)

G25 6.23 On Panel 1C and other panels, "percent" is used on some scales and "X" on others. (8221)

G31 6.24 On Panel 182, on the main turbine meters (EH Oil and Turbine Oil) some scales are in powers of 10 (e.g., "40 x 103") and adjacent scales are written out (e.g.,

"1500"). (8227)

Gl 1 6.25 On Panel lAA, labels now read: CNMT SUMP CNMT SUMP TEMP Consistent labels would read: CNMT SUMP LVL CNMT SUMP TEMP (8206)

G22 6.26 On Panel 1C, intermediate range meter 1R N35 AMPS has no minus sign for negative scale readings. (8218) 6.27 Safety system panels are not identified by summary label.

(8240)

G30 6.28 On Panel 182 and the auxiliary equipment panels, light indicator labels are not visible; also too crowded. (8226)

G32 6.29 On Panel 182, labels on push buttons for turbine control alarms have four lines of text, not easily readable. (8228)

G39 6.30 On Panel 101, the label on light indicator is not visible on several switches. (8235)

AUDIT REPORT APPENDIX PART A PHOTO FINDING HED G41 6.31 On the MCB, on the annunciator panels, up to four lines of text are not easily readable. (8243)

G15 6.32 On the MCB, all panels, process controller labels are obstructed by projecting plastic buttons. (8211)

G17 6.33 . On Panel 1A2, rotary wheel controls (e.g., BTRS. fan selector) obstruct 1 abel s. (8213)

G34 6.34 On Panel 188, pointers on rotary wheels (e.g., HClCT-3205) are not easily distinguished; color coding would help.

(8230 )

G14 6.35 On Pan'el 1AT and others, flow lines are needed in some parts. (8210) 7.0 PROCESS COMPUTERS 7.1 Since the SHNPP control room does not have computers in place, the control room could not be evaluated according to Section 7.0 of NUREG=D700.

8.0 PANEL LAYOUT 8.1 The simulator is significantly different from the actual CR. (8242)

R19 8.2 On Panel 1Al, for the containment spray actuators, pairs are not labeled "Train A" and "Train 8". (Operator must actuate two controls for Train A and two for Train 8).

(8466)

G42 8.3 On the MCB, on all panels, coordinate axes on large matrixes of push buttons are not labeled. (8244) 9.0 CONTROL-DISPLAY INTEGRATION .

R30 9. 1 The CNMT spray pump test is in Panel 101 while the CNMT spray system is in Panel. 1AA. (8256)

AUDIT REPORT APPENDIX - PART 8 HUMAN FACTORS ENGINEER ING DETAILED CONTROL ROOM DESIGN REVIEW IN-PROGRESS AUDIT SHEARON-HARRIS NUCLEAR POWER PLANT CAROLINA POWER AND LIGHT COMPANY Part 8 - Shearon-Harris Photo Summary Carousel

~Find1n Location IDS Photo Descri tion 6.14 G7 Annunciator reset/test switch (8201) 1.1, 6.1 G8 Generic - Reaching for push button for a lamp test (8202) 5.1 G9 Generic - Process controller for small to read scale (8204) 6.13 Gl 0 Scales - "10" written 0 (8205)

- Inconsistent labels 6.25 12'hoto Gll Meters containment (8206 )

sump level and temp 6.18 G12 Valve label - "Block" meaning unclear (8207) 6.19 G13 Valve label - Abbreviations inconsistent (8208) 5.4, 6.35 G14 Valves - Need flow lines (8210) 6.32 G15 Process controller - Labels obstructed (8211) 4.2 10 G16 Valves - Open to left (8212) 6.33 G17 Rotary wheel - Labels obstructed (8213) 6.33 G18 Rotary wheel - Labels obstructed (8214)

e Part 8 - Shearon-Harris Photo Summary Carousel Photo

~Findin Location IO¹ Photo Oescri tion 5.3 13 G19 Scale - More than 9 gradations (8215) 14 G20 Scale - Roman numerals for IO (8216 )

G21 Temp Meter - Label unclear (8217) 6.26 16 G22 Scale - Needs - sign (8218)

G23 Log scale (8219) 5.2 G24 Scale - Top scale illigible (8220) 6.23 19 G25 ScaIe - Inconsistent label (8221) 6.2 20 G26 Push buttom unit unlabeled (8222 )

21 G27 Scale No label (8223) 6.3 22 G28 Scale - No label (8224) 4.3 23 G29 Valve switch - Inconsistent shape-J instead of T (8225) 6.28 G30 Valve switch - Label on light indicator not visible; too crowded (8226) 6.24 25 G31 Scales - I'nconsistent labeling (8227) 6.29 26 G32 Push buttons - Label too crowded (8228) 6.4 27 G33 Push button - No label (8229 )

6.34 28 G34 Rotary knobs - Could use color to identify arrow (8230) 29 G35 Key switch - "Off" position not vertical (8231) 30 G36 Scale for voltage incorrect (8232) 5.4 31 G37 Panel color coding for lines (8233)

t Part 8 - Shearon-Harris Photo Summary Carousel . Photo

~Findin Location ID¹ Photo Oescri tion 4~4 32 G38 Key switches "off" positions not vertical (8234) 6.30 33 G39 Light indicators not visible (8235) 6.20 34 G40 Fan cooler switch "stop" to the right (8236) 6.31 35 Annunciator panel has too many lines of text (8243) 8.3, 3.2 36 G42 Push button matrix - No labels on coord. axes (8244) 6.6 37 G43 Switches outlined in red have no 38 G44 clear labels 6.21, 6.28 39 Ll Valves inconsistent abbreviation and too crowded (8246) 6.11 40 L2 Meter labels on auxiliary equipment panel smaller than MCB (8247) 5.1 L3 Process controller'Hagan) on auxiliary equipment Panel ¹1 (8204) 42 L4 Alarm panel missing CNR (8248) 43 Rod position indicators (8249) 44 L6 Status indi cator panel missing (8250) 6.12 45 L7 Recorder panel recorder labels too small and in shadows (8251) 6.7 46 LS No summary of labels on recorder panel (8252)

L9 Recorder panel, no units or label on meter scale (8223) 8.2 48 R19 Train A, Train 8, not clearly indicated (8466)

Part B - Shearon-Harris Photo Summary Carousel Photo

~Findin Location IOf Photo Oescri tion R20 Order not logical by system (8467 )

50 R21 Order not logical by system (B468) 6.16 51 R22 Pencil markings on switch 6.8 52 R23 Accumulators'identified as 1, 2, 3 on instruments and A, B, C on auxiliary equipment Panel Pl (B470) 6.10 53 R25 Inconsistent labels on meters and 54 R26 scales "1 and 2" is "A and B" (B253) 6.9 R27 No IO numbers on instrument (B254) 6.15 56 R28 Meters have labels crossed out (B255) 57 R29 1B2, J handle instead of T (401) 9.1 58 R30 CNMT pump test switch far from 59 R31 system (B256) 6.17 60 R32 Labels incorrect on speed of fan cooler; high and low reversed (B257) 6.22 61 R33 Oiesel generator B, convention not followed (B258) 62 22 Mosaic - Panel lAA 63 23 Mosaic - Panel lAl 64 24 Mosaic. - Panel 1Al 65 25 Mosaic - Panel 1A1 66 26 Mosaic - Panel lA2 67 27 Mosaic - Panel lA2 68 28 Mosaic - Panel 1Cl

t Part B - Shearon-Harris Photo Summary Carousel Photo

~Findin Location ?OP Photo Oescri tion 69 29 Mosaic - Panel 1C1 70 30 Mosaic - Panel lB1 71 31 Mosaic - Panel 1Bl 72 Mosaic - Panel 181 73 33 Mosaic - Panel 1B2 74 34 Mosaic - Panel 182 75 35 Mosaic - Panel 182 76 36 Mosaic - Panel 1BB 77 37 Mosaic - Panel 1D1 78 2 Mosaic - Panel 101 79 Mosaic - Panel 1Dl 80 Mosaic - Panel 102 81 Mosaic - Panel 102 82 Mosaic - Panel 102 83 7 Mosaic - Panel 102 84 Recorder panel 85 Auxiliary equipment Panel 8'1 86 15 Remote Shut-down panel 87 16 Remote Shut-down panel