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l PHILADELPHIA ELECTRIC COMPANY                               ]
PHILADELPHIA ELECTRIC COMPANY
2301 M ARKET STREET l
]
P.O. BOX 8699 PHILADELPHI A, PA.19101 l
2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 l
JOHN S. MEMPER VICE PRESIDENT
JOHN S. MEMPER VICE PRESIDENT April 4, 198S
    . a m . . .... ..o . ..= a am                                         April 4, 198S Mr. A. Schwencer, Chief                               Docicet No.: 50-352 Licensing Branch No. 2                                               50-353 U. S. Nuclear. Regulatory ConTnission Washington, D.C. 20555                                   FOL No.: NPF-27
. a m........o...= a am Mr. A. Schwencer, Chief Docicet No.:
50-352 Licensing Branch No. 2 50-353 U. S. Nuclear. Regulatory ConTnission Washington, D.C.
20555 FOL No.: NPF-27


==SUBJECT:==
==SUBJECT:==
Line 28: Line 30:


==REFERENCE:==
==REFERENCE:==
: 1)   Letter, D. G. Eisenhut to E. G. Bauer, Jr.
1)
dated October 26, 1984
Letter, D. G. Eisenhut to E. G. Bauer, Jr.
: 2)   Letter, A. Schwencer to E. G. Bauer, Jr.
dated October 26, 1984 2)
dated March 15, 1985
Letter, A. Schwencer to E. G. Bauer, Jr.
: 3)   Letter, J. S. Kemper to A. Schvencer, dated August 16, 1984
dated March 15, 1985 3)
: 4)   Letter, J. S. Kemper to A. Schwencer, dated November 2, 1984
Letter, J. S. Kemper to A. Schvencer, dated August 16, 1984 4)
: 5)   Letter, d. S. Kemper to A. Schwencer, dated March 21, 1985
Letter, J. S. Kemper to A. Schwencer, dated November 2, 1984 5)
: 6)   Letter, d. S. Kemper to A. Schwencer, dated June 26, 1984 FILE:           GOVT 1-1 (NRC)
Letter, d. S. Kemper to A. Schwencer, dated March 21, 1985 6)
Letter, d. S. Kemper to A. Schwencer, dated June 26, 1984 FILE:
GOVT 1-1 (NRC)


==Dear Mr. Schwencer:==
==Dear Mr. Schwencer:==
The purpose of this letter is to advise you of the current status of our efforts to satisfy the three parts of License Condition 2.C.(8Xa), as contained in the reference 1 letter, and to provide Information responsive to the requests for additional information transmitted by your reference 2 letter.
LICENSE CONDITION 2.C.(8Xa) DETAILED CONTROL ROOM DESIGN REVIEll l
Part 1: Task Analysis and Control Rocm inventory l
l As previously conmitted in our reference 3 letter, PEco will complete a task analysis for the Limerick Generating Station and report on it to the NRC by June 30, 1985. This effort is g
currently in progress and on schedule.
g81 hO k$
l 2
F j


The purpose of this letter is to advise you of the current status of our efforts to satisfy the three parts of License Condition 2.C.(8Xa), as contained in the reference 1 letter, and to provide Information responsive to the requests for additional information transmitted by your reference 2 letter.
. Part 2: Control Rocrn Survey i
LICENSE CONDITION 2.C.(8Xa) DETAILED CONTROL ROOM DESIGN REVIEll Part 1: Task Analysis and Control Rocm inventory l
Our reference 4 letter reported the partial' satisfaction of this part of the License Condition and identified the completico of HED SI4-04 (testable lights on the remote shutdown panel) as the only item needed to cormletely satisfy it.
l l                        As previously conmitted in our reference 3 letter, PEco will complete a task analysis for the Limerick Generating Station and report on it to the NRC by June 30, 1985. This effort is            g currently in progress and on schedule.                            g81 l  .,
Correction of HED SI4-04 was recently completed.
hO F
k$      2 j
* l Part 2: Control Rocrn Survey                                               i Our reference 4 letter reported the partial' satisfaction of this part of the License Condition and identified the completico of HED SI4-04 (testable lights on the remote shutdown panel) as the only item needed to cormletely satisfy it. Correction of HED SI4-04 was recently completed.
As stated in response to the first request for additional Information of this letter, safety significance assessment for eight of the seventeen HED's identified by the NRC Audit Team remain to be completed. Preliminary assessment of these HED's have failed to identify any Pricrity 1 (High Safety Significance)
As stated in response to the first request for additional Information of this letter, safety significance assessment for eight of the seventeen HED's identified by the NRC Audit Team remain to be completed. Preliminary assessment of these HED's have failed to identify any Pricrity 1 (High Safety Significance)
HED's. These safety significance assessments will be completed, doctrnented and reported by April 12, 1985. Therefore, following confirmation of these preliminary HED assessments, we consider this part of the Licence Condition to be ccrnpletely satisfied.
HED's.
These safety significance assessments will be completed, doctrnented and reported by April 12, 1985. Therefore, following confirmation of these preliminary HED assessments, we consider this part of the Licence Condition to be ccrnpletely satisfied.
Part 3: Control Rocm Enhancements As we recently advised you in our reference 5 letter, this part of the License Condition has been satisfied.
Part 3: Control Rocm Enhancements As we recently advised you in our reference 5 letter, this part of the License Condition has been satisfied.
REQUEST FOR ADDITIONAL INFORMATION Item 1: Control Room Survey The licensee shall assess and report on the results of the assessment on all of the HED's defined by the NRC Audit Team during the In-Progress Audit.
REQUEST FOR ADDITIONAL INFORMATION Item 1: Control Room Survey The licensee shall assess and report on the results of the assessment on all of the HED's defined by the NRC Audit Team during the In-Progress Audit.


===Response===
===Response===
In Decenter 1983, an NRC Audit Team conducted an audit of the Limerick control room. In their June 1984 Report, the NRC Audit Team identified 17 Htrnan Engineering Discrepancies (HED's).
In Decenter 1983, an NRC Audit Team conducted an audit of the Limerick control room.
These HED's are listed in Attachnents 1 and 2.
In their June 1984 Report, the NRC Audit Team identified 17 Htrnan Engineering Discrepancies (HED's).
Attachment 1 provides a cross reference which lists the 9 NRC Audit Team HED's that have beer. previously Identified and resolved by the Limerick CRDR team along with the HED ntribers used to describe them In the Final and Supplement 91 CRDR Reports (references 6 and 4 respectively).
These HED's are listed in Attachnents 1 and 2. provides a cross reference which lists the 9 NRC Audit Team HED's that have beer. previously Identified and resolved by the Limerick CRDR team along with the HED ntribers used to describe them In the Final and Supplement 91 CRDR Reports (references 6 and 4 respectively).
The 8 remaining NRC Audit Tean HED's have ber     reclassified as Limerick CRDR Team HED's. Attachment 2 provides a cross reference between the two identification systems used by the NRC Audit Team and the Limerick CRDR Team. These HED's will be assessed for safety significance by April 12, 1985.
The 8 remaining NRC Audit Tean HED's have ber reclassified as Limerick CRDR Team HED's. provides a cross reference between the two identification systems used by the NRC Audit Team and the Limerick CRDR Team. These HED's will be assessed for safety significance by April 12, 1985.
Item 2: Assessment of HED's, Resolution of HED SI4-04 The Ilcensee shall report details on the temporary resolution of HED SI4-04 prior to exceeding five percent power.                   ,
Item 2: Assessment of HED's, Resolution of HED SI4-04 The Ilcensee shall report details on the temporary resolution of HED SI4-04 prior to exceeding five percent power.


_3_
_3_
Line 65: Line 75:
===Response===
===Response===
Completion of this HED has been rescheduled from the first refueling outage to prior to exceeding 5 per cent of rated power. This will be done by April 12, 1985.
Completion of this HED has been rescheduled from the first refueling outage to prior to exceeding 5 per cent of rated power. This will be done by April 12, 1985.
Item 4: Verification That Invrovements Will Provide Necessary Corrections And Will Not Introduce New HED's The staff requests the data which verifles the use of a solid red i          background as an enhancement to areas of the workbench and panels and also requests the data vertfles that no new HED is introduced by the correction.
Item 4: Verification That Invrovements Will Provide Necessary Corrections And Will Not Introduce New HED's The staff requests the data which verifles the use of a solid red background as an enhancement to areas of the workbench and panels i
and also requests the data vertfles that no new HED is introduced by the correction.


===Response===
===Response===
            -The CRDR team identified that a red light ilt against a red
-The CRDR team identified that a red light ilt against a red background will be visible. The only time confusion might arise is with an extinguished red light where the unlit bulb could blend in with the red background. This concern has previously been addressed in the final report (reference 6) under HED I4-02.
,            background will be visible. The only time confusion might arise is with an extinguished red light where the unlit bulb could blend in with the red background. This concern has previously been addressed in the final report (reference 6) under HED I4-02.
This HED Identifies failed light bulb conditions. Normally at least one of the lights would be lit (red or green lit at all times, or both red and green ilt with appropriate process feedback). The absence of any lighted bulb Identifies a failed light bulb.
This HED Identifies failed light bulb conditions. Normally at least one of the lights would be lit (red or green lit at all times, or both red and green ilt with appropriate process feedback). The absence of any lighted bulb Identifies a failed light bulb.
i The red background was used during the final validation phase on       )
i The red background was used during the final validation phase on the full scale mock-up of the control room.
the full scale mock-up of the control room. As, documented in the Supplement ill Report, no problems were Identifled with respect to red lights on a red background. In addition, the control room enhancements were completed with this red background in October of 1984 and no problems have been identified during operation since'that date.
As, documented in the Supplement ill Report, no problems were Identifled with respect to red lights on a red background.
In addition, the control room enhancements were completed with this red background in October of 1984 and no problems have been identified during operation since'that date.
Should you require any further information, please do not hesitate to call.
Should you require any further information, please do not hesitate to call.
Sincerely, E M_ !
Sincerely, E M_ !
DFC/dg/04028502 Copy to: (See Attached Service List) i l
DFC/dg/04028502 Copy to: (See Attached Service List)


  . . e 8
e 8
cc: Judge Helen F. Hoyt                 (w/ enclosure)   i Judge derry Harbour             (w/ enclosure)
cc: Judge Helen F. Hoyt (w/ enclosure) i Judge derry Harbour (w/ enclosure)
Judge Richard F. Cole           (w/ enclosure)     l Troy B. Conner, Jr. , Esq.       (w/ enclosure)
Judge Richard F. Cole (w/ enclosure) l Troy B. Conner, Jr., Esq.
                ' Ann P. Hodgdon, Esq.           (w/ enclosure)
(w/ enclosure)
Mr. Frank R. Romano               (w/ enclosure)
' Ann P. Hodgdon, Esq.
Mr. Robert L. Anthony             (w/ enclosure)
(w/ enclosure)
Ms. Phyllis Zitzer               (w/ enclosure)
Mr. Frank R. Romano (w/ enclosure)
Charles W. E111ot, Esq.           (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Zori G. Ferkin, Esq.             (w/ enclosure)
Ms. Phyllis Zitzer (w/ enclosure)
Mr. Thanas Gerusky               (w/ enclosure) e              Director, Penna. Emergency       (w/ enclosure)
Charles W. E111ot, Esq.
Management Agency Angus'R. Love, Esq.               (w/ enclosure)
(w/ enclosure)
David Wersan, Esq.               (w/ enclosure)
Zori G. Ferkin, Esq.
Robert J. Sugarman, Esq g        (w/ enclosure)
(w/ enclosure)
Martha W. Bush, Esq.             (w/ enclosure)
Mr. Thanas Gerusky (w/ enclosure)
Spence W.. Perry, Esq.           (w/ enclosure) 1             ' Jay M.-Gutterrez, Esq.           (w/ enclosure)
Director, Penna. Emergency (w/ enclosure) e Management Agency Angus'R. Love, Esq.
Atomic Safety & Licensing         (w/ enclosure)
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Appeal Board i              Atomic-Safety & Licensing       (w/ enclosure)
David Wersan, Esq.
Board Panel
(w/ enclosure)
              . Docket & Service Section       (w/ enclosure)
Robert J. Sugarman, Esq (w/ enclosure) g Martha W. Bush, Esq.
Mr. James Wiggins               (w/ enclosure)
(w/ enclosure)
Mr. Timothy R. S. Campbell       (w/ enclosure) i w                 -
Spence W.. Perry, Esq.
w ,- - -
(w/ enclosure) 1
' Jay M.-Gutterrez, Esq.
(w/ enclosure)
Atomic Safety & Licensing (w/ enclosure)
Appeal Board Atomic-Safety & Licensing (w/ enclosure) i Board Panel
. Docket & Service Section (w/ enclosure)
Mr. James Wiggins (w/ enclosure)
Mr. Timothy R. S. Campbell (w/ enclosure) i w
w


    ~
~
Attachment 1 4
4 NRC AUDIT TEAM / EXISTING CRDR TEAM HEDS (LIMERICK)
NRC AUDIT TEAM / EXISTING CRDR TEAM HEDS (LIMERICK)
NRC Audit Team HED Existing CRDR Team HED 1.0 CONTROL ROOM WORKSPACE 1.2 B104 - On all vertical Dl Panel Obstruction.
NRC Audit Team HED                         Existing CRDR Team HED 1.0 CONTROL ROOM WORKSPACE 1.2 B104 - On all vertical               Dl Panel Obstruction.
panels, the bottom 1/3 Vertical panels behind is not visible from the benchboards are partially front of the~benchboard, obstructed.
panels, the bottom 1/3               Vertical panels behind is not visible from the               benchboards are partially front of the~benchboard,             obstructed.
1 3.0 ANNUNCIATOR WARNING SYSTEMS 3.2 B109 - Coding of annunciator SD3 Control Layout Consis-controls is inconsistent in tency.
1 3.0 ANNUNCIATOR WARNING SYSTEMS 3.2 B109 - Coding of annunciator           SD3 Control Layout Consis-controls is inconsistent in           tency. Annunciator controls are shape and layout. The color           not consistently laid out, coding of red for central             SD2-04 --- Annunciator Control reset and black for local           Coding. No apparent color coding reset is acceptable,                   of annunciator controls.
Annunciator controls are shape and layout.
5.0 VISUAL DISPLAYS 5.1 B103 - The four-rod display           }lcl Discrepancy - Readings taken-is-too dim to be read in             during the Supplemental Survey normal room light.                     indicate light level to-be within acceptable range.
The color not consistently laid out, coding of red for central SD2-04 --- Annunciator Control reset and black for local Coding.
6.0 LABELS AND LOCATION AIDS 6.1 B107 - Containment boundary           D2 Demarcations on Vertical demarcation does not make             Panels. There is inadequate clear _which side is in     nd       differentiation of groupings on which'is out,                         some vertical boards.
No apparent color coding reset is acceptable, of annunciator controls.
6.2 B108 - On Reactor and Con-           D2 Mimic Flow Path Arrange-tainment Cooling and Isola-           ment. ~ Flow-paths and arrange-tion Panel 601, the mimics           ments are not orderly or are confusing.                       easily recognized.
5.0 VISUAL DISPLAYS 5.1 B103 - The four-rod display
6.3 B102 - On Panel 647-there             D5 Label Nomenclature.
}lcl Discrepancy -
are labels marked " BOP".             Inconsistent use of nomencla-These are redundant displays           ture, acronyms, and abbreviations, or insufficient labels.               DS Hierarchal Labeling.
Readings taken-is-too dim to be read in during the Supplemental Survey normal room light.
                                                        ~
indicate light level to-be within acceptable range.
6.0 LABELS AND LOCATION AIDS 6.1 B107 - Containment boundary D2 Demarcations on Vertical demarcation does not make Panels.
There is inadequate clear _which side is in nd differentiation of groupings on which'is out, some vertical boards.
6.2 B108 - On Reactor and Con-D2 Mimic Flow Path Arrange-tainment Cooling and Isola-ment. ~ Flow-paths and arrange-tion Panel 601, the mimics ments are not orderly or are confusing.
easily recognized.
6.3 B102 - On Panel 647-there D5 Label Nomenclature.
are labels marked " BOP".
Inconsistent use of nomencla-These are redundant displays ture, acronyms, and abbreviations, or insufficient labels.
DS Hierarchal Labeling.
~
Labels are not size coded.
Labels are not size coded.
1 l
1 1
1


4 l
4 l
l NRC Audit Team HED               Existing CRDR Team HED e
l NRC Audit Team HED Existing CRDR Team HED e
6.4 B101 - Abbreviations are in- DS Label Ncmenclature, consistent. Several acronyms Inconsistent use of nomenclature, are used for one word,       acronyms, . and abbreviations.
6.4 B101 - Abbreviations are in-DS Label Ncmenclature, consistent.
7.0 PROCESS COMPUTERS 7.2 B201 - There is excessive     SC3-01 : Process Computer Key-glare on the concave keys     board Glare. Glare makes keys which make the engraving     difficult to read.
Several acronyms Inconsistent use of nomenclature, are used for one word, acronyms,. and abbreviations.
difficult to read, and there SCl-01 ; Proc 4ss Computer Key are many un-needed keys over Arrangement. Functional keys and above the QWERTY board. are difficult to understand.
7.0 PROCESS COMPUTERS 7.2 B201 - There is excessive SC3-01 : Process Computer Key-glare on the concave keys board Glare.
8.0 PANEL LAYOUT 8.2 B112 - On Panel 668, the     SD3 Order of Switches.
Glare makes keys which make the engraving difficult to read.
order of controls is re-     Switches are not in the expected versed numerically.           order (left to right).
difficult to read, and there SCl-01 ; Proc 4ss Computer Key are many un-needed keys over Arrangement.
Functional keys and above the QWERTY board.
are difficult to understand.
8.0 PANEL LAYOUT 8.2 B112 - On Panel 668, the SD3 Order of Switches.
order of controls is re-Switches are not in the expected versed numerically.
order (left to right).


  . . . s b
s b
                                                                                      =
=
Attachment P NRC AUDIT TEAM /NEW CRDR TEAM HEDS (LIMERICK) i NRC Audit Team HED                           New CRDR Team HED 1.0 . CONTROL ROOM WORKSPACE 1.3   B110 - No procedures or             NPl-01 ; Procedure Storage.
Attachment P NRC AUDIT TEAM /NEW CRDR TEAM HEDS (LIMERICK) i NRC Audit Team HED New CRDR Team HED 1.0. CONTROL ROOM WORKSPACE 1.3 B110 - No procedures or NPl-01 ; Procedure Storage.
place to store emergency             No storage space for procedures shutdown procedures is               is provided at the Remote Shut-provided at'the Remote               down Panels.   (El.5)*
place to store emergency No storage space for procedures shutdown procedures is is provided at the Remote Shut-provided at'the Remote down Panels.
(El.5)*
Shutdown Panels.
Shutdown Panels.
          '3.0   ANNUNCIATOR WARNING SYSTEMS 3.1   Bill - The annunciator               NA2 Annunciator Audible
'3.0 ANNUNCIATOR WARNING SYSTEMS 3.1 Bill - The annunciator NA2 Annunciator Audible
                                                                ~
~
audible alarm for two differ-       Alarms. Annunciator audible
audible alarm for two differ-Alarms.
                                ~
Annunciator audible ent sets of annunciators uses alarms are not distinguishable
ent sets of annunciators uses       alarms are not distinguishable the same bell sound. Local-         for alarm location. Different ization is by direction of.         sets of annunciators use the sound,                               same-bell sound.   (F2.1) 7.0   PROCESS COMPUTERS 7.3   B202 - Contrast of engraved         NC5 Process Computer Keyboard printing on keys is not             Lettering. Lettering on keyboard very good, using white on           is not visually distinctive.
~
gray QWERTY keys. This is           (A5.8) due partly to dirt in engraving.
the same bell sound.
7.4     B203 - On the printers, the         NC4 Process Computer Printout guide on the paper drive             Readability. ' Printouts are not covers part of- the printing         easily readable while in printer.
Local-for alarm location.
of approximately 16 lines             (D4.8)
Different ization is by direction of.
sets of annunciators use the
: sound, same-bell sound.
(F2.1) 7.0 PROCESS COMPUTERS 7.3 B202 - Contrast of engraved NC5 Process Computer Keyboard printing on keys is not Lettering.
Lettering on keyboard very good, using white on is not visually distinctive.
gray QWERTY keys.
This is (A5.8) due partly to dirt in engraving.
7.4 B203 - On the printers, the NC4 Process Computer Printout guide on the paper drive Readability. ' Printouts are not covers part of-the printing easily readable while in printer.
of approximately 16 lines (D4.8)
(covers 4 to-5 characters near margin of paper).
(covers 4 to-5 characters near margin of paper).
7.5     B204 - Printouts are subject         NC4 Process Computer Printout to dust cover glare from             Readability. Printouts are not overhead lights on both     .
7.5 B204 - Printouts are subject NC4 Process Computer Printout to dust cover glare from Readability.
easily readable while in printer, front and. top - especially           (D4.8) from a sitting position.
Printouts are not overhead lights on both easily readable while in printer, front and. top - especially (D4.8) from a sitting position.
7.6     B205 - Physical access to           .NC4-03 ; Process-Computer Paper printer copy is difficult           Accessibility. Paper in printer inside the bottom compart-           is not easily accessible.
7.6 B205 - Physical access to
ment in front of the printer.         (D4.7)
.NC4-03 ; Process-Computer Paper printer copy is difficult Accessibility.
Paper in printer inside the bottom compart-is not easily accessible.
ment in front of the printer.
(D4.7)
* BWROG CRS Item Number
* BWROG CRS Item Number


S h
S h
1 NRC Audit Team HED                                                                     New CRDR Team HED i
1 NRC Audit Team HED New CRDR Team HED i
8.0         PANEL LAYOUT 8.1 -B106 - On Panel 648, RCIC                                                         ND3 Control Layout Consis-
8.0 PANEL LAYOUT 8.1 -B106 - On Panel 648, RCIC ND3 Control Layout Consis-
                                                                                                                          ~
~
                            -Division 3 and Division 1                                                   tency.           Components of similar are not in numerical order                                                 functions are not consistently left to right.                                                             ordered from left to right.
-Division 3 and Division 1 tency.
(A3.2)
Components of similar are not in numerical order functions are not consistently left to right.
B105 - On Panel 648, RCIC                                                   ND3 Control Layout Consis-8.3                                                                                                    -
ordered from left to right.
s status lights have differ-                                                 tency.           Components of similar
(A3.2) 8.3 B105 - On Panel 648, RCIC ND3 Control Layout Consis-status lights have differ-tency.
* ent arrangements for                                                       functions are not consistently 1-                                                                                                         ordered from left to right.
Components of similar s
Division 3 and Division 1.
ent arrangements for functions are not consistently 1-Division 3 and Division 1.
ordered from left to right.
(A3.2) l a
(A3.2) l a
J e
J e
____.m_____.__.__.._______._._._____._____________.__________._.___________.___._____._______._._____._____________i._._.__}}
.m
: i...
.}}

Latest revision as of 05:51, 13 December 2024

Advises of Current Status of Efforts to Satisfy License Condition 2.C.(8)(a) Re Detailed Control Room Design Review. Addl Info Re Control Room Survey,Including Encl Listing of Human Error Discrepancies,Provided Per 850315 Request
ML20100G567
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 04/04/1985
From: Kemper J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Schwencer A
Office of Nuclear Reactor Regulation
References
CON-#285-428 OL, NUDOCS 8504080296
Download: ML20100G567 (8)
v • d • e


Text

1 l

PHILADELPHIA ELECTRIC COMPANY

]

2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 l

JOHN S. MEMPER VICE PRESIDENT April 4, 198S

. a m........o...= a am Mr. A. Schwencer, Chief Docicet No.:

50-352 Licensing Branch No. 2 50-353 U. S. Nuclear. Regulatory ConTnission Washington, D.C.

20555 FOL No.: NPF-27

SUBJECT:

Limerick Generating Station, Units 1 and 2 Detailed Control Room Design Review

REFERENCE:

1)

Letter, D. G. Eisenhut to E. G. Bauer, Jr.

dated October 26, 1984 2)

Letter, A. Schwencer to E. G. Bauer, Jr.

dated March 15, 1985 3)

Letter, J. S. Kemper to A. Schvencer, dated August 16, 1984 4)

Letter, J. S. Kemper to A. Schwencer, dated November 2, 1984 5)

Letter, d. S. Kemper to A. Schwencer, dated March 21, 1985 6)

Letter, d. S. Kemper to A. Schwencer, dated June 26, 1984 FILE:

GOVT 1-1 (NRC)

Dear Mr. Schwencer:

The purpose of this letter is to advise you of the current status of our efforts to satisfy the three parts of License Condition 2.C.(8Xa), as contained in the reference 1 letter, and to provide Information responsive to the requests for additional information transmitted by your reference 2 letter.

LICENSE CONDITION 2.C.(8Xa) DETAILED CONTROL ROOM DESIGN REVIEll l

Part 1: Task Analysis and Control Rocm inventory l

l As previously conmitted in our reference 3 letter, PEco will complete a task analysis for the Limerick Generating Station and report on it to the NRC by June 30, 1985. This effort is g

currently in progress and on schedule.

g81 hO k$

l 2

F j

. Part 2: Control Rocrn Survey i

Our reference 4 letter reported the partial' satisfaction of this part of the License Condition and identified the completico of HED SI4-04 (testable lights on the remote shutdown panel) as the only item needed to cormletely satisfy it.

Correction of HED SI4-04 was recently completed.

As stated in response to the first request for additional Information of this letter, safety significance assessment for eight of the seventeen HED's identified by the NRC Audit Team remain to be completed. Preliminary assessment of these HED's have failed to identify any Pricrity 1 (High Safety Significance)

HED's.

These safety significance assessments will be completed, doctrnented and reported by April 12, 1985. Therefore, following confirmation of these preliminary HED assessments, we consider this part of the Licence Condition to be ccrnpletely satisfied.

Part 3: Control Rocm Enhancements As we recently advised you in our reference 5 letter, this part of the License Condition has been satisfied.

REQUEST FOR ADDITIONAL INFORMATION Item 1: Control Room Survey The licensee shall assess and report on the results of the assessment on all of the HED's defined by the NRC Audit Team during the In-Progress Audit.

Response

In Decenter 1983, an NRC Audit Team conducted an audit of the Limerick control room.

In their June 1984 Report, the NRC Audit Team identified 17 Htrnan Engineering Discrepancies (HED's).

These HED's are listed in Attachnents 1 and 2. provides a cross reference which lists the 9 NRC Audit Team HED's that have beer. previously Identified and resolved by the Limerick CRDR team along with the HED ntribers used to describe them In the Final and Supplement 91 CRDR Reports (references 6 and 4 respectively).

The 8 remaining NRC Audit Tean HED's have ber reclassified as Limerick CRDR Team HED's. provides a cross reference between the two identification systems used by the NRC Audit Team and the Limerick CRDR Team. These HED's will be assessed for safety significance by April 12, 1985.

Item 2: Assessment of HED's, Resolution of HED SI4-04 The Ilcensee shall report details on the temporary resolution of HED SI4-04 prior to exceeding five percent power.

_3_

Response

As stated in response to License Condition 2.C.(8Xa) part 2, the permanent resolution to HED SI4-04 is conplete.

Item 3: Assessment of HED's, Reassessment of SPV-07 The licensee shall report results on the reassessment of HED SPV-07.

Response

Completion of this HED has been rescheduled from the first refueling outage to prior to exceeding 5 per cent of rated power. This will be done by April 12, 1985.

Item 4: Verification That Invrovements Will Provide Necessary Corrections And Will Not Introduce New HED's The staff requests the data which verifles the use of a solid red background as an enhancement to areas of the workbench and panels i

and also requests the data vertfles that no new HED is introduced by the correction.

Response

-The CRDR team identified that a red light ilt against a red background will be visible. The only time confusion might arise is with an extinguished red light where the unlit bulb could blend in with the red background. This concern has previously been addressed in the final report (reference 6) under HED I4-02.

This HED Identifies failed light bulb conditions. Normally at least one of the lights would be lit (red or green lit at all times, or both red and green ilt with appropriate process feedback). The absence of any lighted bulb Identifies a failed light bulb.

i The red background was used during the final validation phase on the full scale mock-up of the control room.

As, documented in the Supplement ill Report, no problems were Identifled with respect to red lights on a red background.

In addition, the control room enhancements were completed with this red background in October of 1984 and no problems have been identified during operation since'that date.

Should you require any further information, please do not hesitate to call.

Sincerely, E M_ !

DFC/dg/04028502 Copy to: (See Attached Service List)

e 8

cc: Judge Helen F. Hoyt (w/ enclosure) i Judge derry Harbour (w/ enclosure)

Judge Richard F. Cole (w/ enclosure) l Troy B. Conner, Jr., Esq.

(w/ enclosure)

' Ann P. Hodgdon, Esq.

(w/ enclosure)

Mr. Frank R. Romano (w/ enclosure)

Mr. Robert L. Anthony (w/ enclosure)

Ms. Phyllis Zitzer (w/ enclosure)

Charles W. E111ot, Esq.

(w/ enclosure)

Zori G. Ferkin, Esq.

(w/ enclosure)

Mr. Thanas Gerusky (w/ enclosure)

Director, Penna. Emergency (w/ enclosure) e Management Agency Angus'R. Love, Esq.

(w/ enclosure)

David Wersan, Esq.

(w/ enclosure)

Robert J. Sugarman, Esq (w/ enclosure) g Martha W. Bush, Esq.

(w/ enclosure)

Spence W.. Perry, Esq.

(w/ enclosure) 1

' Jay M.-Gutterrez, Esq.

(w/ enclosure)

Atomic Safety & Licensing (w/ enclosure)

Appeal Board Atomic-Safety & Licensing (w/ enclosure) i Board Panel

. Docket & Service Section (w/ enclosure)

Mr. James Wiggins (w/ enclosure)

Mr. Timothy R. S. Campbell (w/ enclosure) i w

w

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4 NRC AUDIT TEAM / EXISTING CRDR TEAM HEDS (LIMERICK)

NRC Audit Team HED Existing CRDR Team HED 1.0 CONTROL ROOM WORKSPACE 1.2 B104 - On all vertical Dl Panel Obstruction.

panels, the bottom 1/3 Vertical panels behind is not visible from the benchboards are partially front of the~benchboard, obstructed.

1 3.0 ANNUNCIATOR WARNING SYSTEMS 3.2 B109 - Coding of annunciator SD3 Control Layout Consis-controls is inconsistent in tency.

Annunciator controls are shape and layout.

The color not consistently laid out, coding of red for central SD2-04 --- Annunciator Control reset and black for local Coding.

No apparent color coding reset is acceptable, of annunciator controls.

5.0 VISUAL DISPLAYS 5.1 B103 - The four-rod display

}lcl Discrepancy -

Readings taken-is-too dim to be read in during the Supplemental Survey normal room light.

indicate light level to-be within acceptable range.

6.0 LABELS AND LOCATION AIDS 6.1 B107 - Containment boundary D2 Demarcations on Vertical demarcation does not make Panels.

There is inadequate clear _which side is in nd differentiation of groupings on which'is out, some vertical boards.

6.2 B108 - On Reactor and Con-D2 Mimic Flow Path Arrange-tainment Cooling and Isola-ment. ~ Flow-paths and arrange-tion Panel 601, the mimics ments are not orderly or are confusing.

easily recognized.

6.3 B102 - On Panel 647-there D5 Label Nomenclature.

are labels marked " BOP".

Inconsistent use of nomencla-These are redundant displays ture, acronyms, and abbreviations, or insufficient labels.

DS Hierarchal Labeling.

~

Labels are not size coded.

1 1

4 l

l NRC Audit Team HED Existing CRDR Team HED e

6.4 B101 - Abbreviations are in-DS Label Ncmenclature, consistent.

Several acronyms Inconsistent use of nomenclature, are used for one word, acronyms,. and abbreviations.

7.0 PROCESS COMPUTERS 7.2 B201 - There is excessive SC3-01 : Process Computer Key-glare on the concave keys board Glare.

Glare makes keys which make the engraving difficult to read.

difficult to read, and there SCl-01 ; Proc 4ss Computer Key are many un-needed keys over Arrangement.

Functional keys and above the QWERTY board.

are difficult to understand.

8.0 PANEL LAYOUT 8.2 B112 - On Panel 668, the SD3 Order of Switches.

order of controls is re-Switches are not in the expected versed numerically.

order (left to right).

s b

=

Attachment P NRC AUDIT TEAM /NEW CRDR TEAM HEDS (LIMERICK) i NRC Audit Team HED New CRDR Team HED 1.0. CONTROL ROOM WORKSPACE 1.3 B110 - No procedures or NPl-01 ; Procedure Storage.

place to store emergency No storage space for procedures shutdown procedures is is provided at the Remote Shut-provided at'the Remote down Panels.

(El.5)*

Shutdown Panels.

'3.0 ANNUNCIATOR WARNING SYSTEMS 3.1 Bill - The annunciator NA2 Annunciator Audible

~

audible alarm for two differ-Alarms.

Annunciator audible ent sets of annunciators uses alarms are not distinguishable

~

the same bell sound.

Local-for alarm location.

Different ization is by direction of.

sets of annunciators use the

sound, same-bell sound.

(F2.1) 7.0 PROCESS COMPUTERS 7.3 B202 - Contrast of engraved NC5 Process Computer Keyboard printing on keys is not Lettering.

Lettering on keyboard very good, using white on is not visually distinctive.

gray QWERTY keys.

This is (A5.8) due partly to dirt in engraving.

7.4 B203 - On the printers, the NC4 Process Computer Printout guide on the paper drive Readability. ' Printouts are not covers part of-the printing easily readable while in printer.

of approximately 16 lines (D4.8)

(covers 4 to-5 characters near margin of paper).

7.5 B204 - Printouts are subject NC4 Process Computer Printout to dust cover glare from Readability.

Printouts are not overhead lights on both easily readable while in printer, front and. top - especially (D4.8) from a sitting position.

7.6 B205 - Physical access to

.NC4-03 ; Process-Computer Paper printer copy is difficult Accessibility.

Paper in printer inside the bottom compart-is not easily accessible.

ment in front of the printer.

(D4.7)

S h

1 NRC Audit Team HED New CRDR Team HED i

8.0 PANEL LAYOUT 8.1 -B106 - On Panel 648, RCIC ND3 Control Layout Consis-

~

-Division 3 and Division 1 tency.

Components of similar are not in numerical order functions are not consistently left to right.

ordered from left to right.

(A3.2) 8.3 B105 - On Panel 648, RCIC ND3 Control Layout Consis-status lights have differ-tency.

Components of similar s

ent arrangements for functions are not consistently 1-Division 3 and Division 1.

ordered from left to right.

(A3.2) l a

J e

.m

i...

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