ML20198C506

Supplemental Program Plan for Dcrdr

ML20198C506
Person / Time
Site:	Calvert Cliffs
Issue date:	11/01/1985
From:	BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20198C470	List: ML20198C468 ML20198C506
References
PROC-851101, NUDOCS 8511120105
Download: ML20198C506 (37)

Text

_-

SUPPLEMENTAL PROGRAM PLAN FOR THE DETAILED CONTROL ROOM DESIGN REVIEW CALVERT CLIFFS NUCLEAR POWER PLANT November 1, 1985 8511120\OF

(

t _-

Table of Contents Page 1.0 Introduction 1-1 1.1 Background 1-1 1.2 Review Phases 1-1 1.2.1 Generic Task Analysis 1-1 1.2.2 Planning 1-2 1.2.3 Plant-Specific Task Analysis 1-2 1.2.4 Control Room Survey 1-2 1.2.5 Validation of Control Room Functions 1-2 1.2.6 Verification of Task Performance Capabilites 1-3 1.2.7 Assessment and Implementaion 1-3 1.2.8 Coordination 1-4 1.2.9 Validation of HED Corrections 1-4 1.3 Schedule 1-4 2.0 Management and Staffing 2-1 2.1 Introduction 2-1 2.2 Review Team 2-1 2.3 Oversight Committee 2-1 2.4 Human Factors Contractor 2-1 3.0 Documentation and Document Control 3-1 3.1 Introduction 3-1 3.2 Task Listings 3-1 3.3 Information and Control Requirements 3-1 3.4 Survey Checklists 3-1 3.5 Supplement to the Final Summary Report 3-1 4.0 Review Procedures 4-1 4.1 Generic Task Analysis 4-1 4.1.1 Multidisciplinary Team 4-1 4.1.2 Development of Task Statements, Task 4-1 Listings and the Task Inventory 4.1.3 Development of Task Element I&C 4-3 Requirements and Characteristics 4.1.4 Consolidation of I&C Requirements 4-3 and Characteristics 4.2 Plant-Specific Task Analysis 4-4 4.2.1 Overall Conversion Process 4-4 4.2.2 Plant-Specific ICCR Scope 4-5 4.2.3 Plant-Specific Task Analysis 4-6 4.2.4 Data Base Management System Modification 4-6 4.2.5 Developing Plant-Specific Task Listing 4-6 and Inventory 4.2.6 Task Analysis For Plant-Specific ICCR 4-7 4.2.7 Plant-Specific Consolidation of 4-8 Information and Control Requirements and Characteristics 4.3 Control Room Survey 4-8 4.4 Validation of Control Room Functions 4-9

4.4.1 Walk-through Talk-through Procedure 4-9 t 4.4.2 Real Time Run-through Procedure 4-15 4.5 Verification of Task Performance Capabilities 4-16 i

Tablo of Contents (Continued)

, Page

, 5.0 Assessment, Implementation and Validation 5-1 5.1 Introduction 5-1 5.2 Assessment 5-1 5.2.1 HED Categories 5-1 1

5.2.2 Corrective Actions 5-2 5.2.3 Scheduling Priority of Corrective Actions 5-2 5.3 Implemention 5-6 5.4 Validation 5-6 6.0 Coordination 6-1 I

1 i

i i

i_ _ _ _ _ _ _ . - - _, , -. , . - , . - - - - - - - - - - - ~ - --~, ~ - - ~ ' - ~ - - ~ ~ ~ ~ ' " " ' ' ~ ' " ~ '

_ - . - -- - _ _ . . - _ --. . -. - -. .. . . . .=.

1 i

1.0 Introduction ,

1.1 Background

In response to NUREG-0737, Supplement 1, BG&E sub-mitted a Program Plan on September 1, 1983 for conducting a Detailed Control Room Design Review (DCRDR) at Calvert Cliffs.

In a letter dated December 30, 1983 and during an in-progress audit conducted from November 27-30, 1984, the NRC staff sug- ,

gested certain changes to the Program Plan to assure that the program would adequately identify and correct any major Human Engineering Deficiencies (HEDs) in the control room.

These suggestions have led to the decision to per-form additional tasks under the DCRDR. These additional taska will consist of nine phases which, in conjunction with the ohiginal work will fully satisfy the requirements of NUREG-0700. The major phases of the review will be a systems func-1 tion review and task analysis and a new control room survey to the NUREG-0700 Section 6 guidelines.

4 1.2 Review Phases The supplemental review will be conducted in nine phases, as follow:

. Phase I -

Generic Task Analysis

)

. Phase II -

Planning i . Phase III - Plant-Specific Task Analysis

. Phase IV - Control Room Survey

. Phase V -

Validation of Control Room Functions

. Phase VI -

Verification of Task Performance Cap-abilities ,

. Phase VII - Assessment and Implemention  !

. Phase VIII- Coordination

. Phase IX -

Validation of HED Corrections Figure 1-1 shows the phases and task flow for the f supplemental review. Boxes with bold lines are completed phases; all other phases will be completed as shown in the schedule contained in Section 1.3 of this document. Detailed descriptions of the phases are contained in Section 5 Review Procedures of this document. A summary of the activities of i ,

each phase is contained-in the following.

6 1.2.1 Generic Task Analysis A generic systems functions review and task analysis was performed by Combustion Engineering and documented in CEN-307 " Generic Information and Control Requirements Review."

CEN-307 describes the methodology and results of a task analy-sis conducted on the Combustion Engineering Emergency Proca-

dures Guidelines (CEN-152, Rev.H02) in order to identify the operator information and control requirements needed to sup-port operations in accordance with the Emergency Procedures Guidelines for a generic reference plant.

1-1

____'-_ ,o -- - - - - _ , . . - . .- .. .~,

j Thic rsport will ba ussd to dsvalop a Calvart Cliffs plant-specific information and controls requirements document.

i 1.2.2 Planning

A project plan has been developed including a sche-i dule and a review team has been selected. The project plan-

,! ning phase consisted of the following task:

1. Select review team I 2. Identify scope of supplemental review

! 3. Prepare schedule i I 4. Establish procedures, methods and document I

control

5. Write supplemental program plan l 1.2.3 Plant-Specific Task Analysis ,

j A Clavert Cliffs plant-specific task analysis will

be developed using the guidelines presented in the generic i

task analysis. The conversion process will consist of the following tasks:

1. Modify task analysis for differences between j Calvert Cliffs and the reference plant

2. Modify task analysis for differences between i j the Emergenc2 Procedures Guidelines and the L Emergency Operating Procedures t

! 3. Revise information and control requirements

] to reflect modified task analysis

1.2.4 Control Room Survey Surveys will be conducted on the control room using

.the NUREG-0700 Section 6 guidelines and all checklists will be l reexamined. Checklists will be developed to ensure that all

! ' criteria are examined. Photographs and the plant simulator

! will be used for the surveys in addition to the control room

to enhance the data collection process. Human Engineering Discrepancy (HED) reports will be written to address devia-tions from the guidelines and entered into the existing HED tracking system.

l i

1.2.5 Validation of Control Room Function i The purpose of this phase is to consider control

! room adequacy from the perspective of integrated functional requirements. The process will involve examination of the interaction and dependencies of operators and control room i equipment. Specific concerns include:

. Spatial relationship required in task sequence

._ Equipment response time vis-a-vis procedural requirements 1-2 e

_ _ - _ ~ . - - . . - - , _ . ....-..,m - , . , . . - - - . . _ . , , , _ _ . . - - _ . . . , , . . _ _ - , . . _ _ - , . _ _ , ,_-

. Work load and division of responsibilitics among operators

. Operator communications

. Instrumentation adequacy vis-a-vis the EOPs Validation will be accomplished in two phases-both phases employing the Calvert Cliffs simulator. First, the simulator will be used as a static control room mock-up to de-termine if the displays and controls called for in the Emer-gency Operating Procedures (EOPs) are adequate and spatially located so they can be used with the number of individuals on shift. Secondly, design basis events that require operators to use the EOPs will be identified and run on the Calvert Cliffs simulator.

It should be noted that the validation of control room functions will be fully integrated with the validation of the Calvert Cliffs upgraded EOPs. The decision to integrate the DCRDR and the EOP activities is based upon consideration of manpower savings and availability of operators and simula-tor time. However, it is anticipated that many more benefits will result from this approach. Both the validation of con-trol room functions effort and the EOP validation effort will be enhanced by having the many diciplines that are re-presented in both efforts working together as a team. Also this coordination of the two activities will add to the con-sistency of information produced.

1.2.6 Verification of Task Performance Capabilities The plant-specific information and controls require-ments generated in the plant-specific task analysis phase will be compared with the existing control room inventory and HEDs generated to address inconsistencies. These HEDs will also be entered into the existing tracking system.

1.2.7 Assessmant and Implemention All HEDs will be assessed according to the evalu-ation criteria established during the original DCRDR. These criteria are, in order of importance, as follows:

1. Potential for Error

2. Safety Significance

3. Potential Consequences The goal is to have HEDs requiring corrections cor-rected in the order determined by the evaluation within the timeframe of the tenth refueling outage for Unit 1 and the eighth refueling outage for Unit 2. Modifications not re-quiring an outage will be scheduled prior to the outages.

1-3

1.2.8 Coordination The plant-specific information and controls require-ments will be compared to the SPDS database, the R.G. 1.97 list of variables and the Emergency Operating Procedures to verify that they are complete and in agreement. Revisions will be made to these documents as necessary to have them conform with each other.

1.2.9 Validation of HED Corrections After all of the modifications have been made to correct HEDs a walkdown will be performed to validate the modifications. This validation will review the modifications to ensure that the HEDs were actually corrected and that no new HEDs were created by the modifications.

1.3 Schedule A schedule has been prepared detailing the timeframe and completion date for each of the review phases. Figure 1-2 shows this schedule which will be integrated into the overall DCRDR schedule.

1-4 i

l \

l \

l

FIGURE 1-1 EPGS CEN-152 ORIGINAL

)

REVIEW  ;

l i.

. GENERIC l TASK ANALYSIS y II .

4 PLANNING  ;

III.

11/85 SPECIFIC TASK ANALYSIS 5/86 SUPPLEMENTAL

~

PLAN TO NRC u

VERIFICATION 1/85 IV. _

0F TASK ONTROL PERFORMANCE 00M =

CAPA8ILITIES SURVEY 1/87 5/86 o

VII VALIDATION ggg 0F CONTROL ~ ~ "

AND ROOM FUNCTIONS 5/86 IMPLEMENTATION 6/87 VIII . SUPPLEMENTAL

=

COORDINATION = REPORT TO THE y NRC NA 12/87 IX. 6/87 ON 0F HED CORRECTIONS 12/88 eg ammame- .

m ammer-

! E 3 11/85 5/86 1/87 6/87' 12f87 12 88 III. PLANT SPECIFIC '

TASK ANALYSIS i IV. SURVEY i

l V. VALIDATION OF CONTROL ROOM -

FUNCTIONS 1

]

'N 4

VI. VERIFICATION OF w TASK PERFORMANCE - ,

'g CAPABILITIES

'e H

LL.

I VII. ASSESSMENT AND IMPLEMENTATION mm

! VIII. COORDINATION i

i

{ IX. VALIDATION OF

) HEDs

}

i

)

i

. I l

2.0 Management and Staffing l l

j 2.1 Introduction l The Detailed Control Room Design Review team will report to an oversight committee. This committee will in turn report directly to BG&E management allowing the review team su"ficient authority to perform a thorough review.

2.2 Review Team I The project leader will be responsible for overall '

coordination of the DCRDR. Assisting the project leader will be a multidisciplined team consisting of the following indivi-1 duals:

, . Procedures Engineer j . Senior Reactor Operator

. Instrumentation and Controls Engineer

. Training Specialist

. Human Factors Specialist In addition, each of these review team members will be able to draw on the resources of other subject matter ex-l perts (SME) in their areas of expertise.

2.3 Oversight Committee The oversight committee members will represent the four areas in the BG&E Nuclear Energy Division that will in-terface with the DCRDR. The committee will consist of the following members

. General Supervisor, Design Engineering

. General Supervisor, Operations

. General Supervisor, Electrical and Controls Maintenance

. General Supervisor, Nuclear Training The committee will have periodic meetings with the review team and will report on progress to the Department Man-agers within the Division.

2.4 Human Factors Contractor ARD Corporation has been contracted to provide Human

' Engineering services to BG&E to support the DCRDR because BG&E does not have in-house human factors expertise. ARD will pro-vide the human factors specialist on the review team and other ARD employees will be utilized as necessary for surveying the control room and compiling data.

2-1

3.0 Documentation and Document Control 3.1 Introduction In addition to the documentation used and developed during the orignal review a computer database of the task listing and information and control requirements will be developed. Also survey checklists based on the guidelines contained in NUREG-0700 will be developed. Any new HEDs indentified during the supplemental review will be controlled within the existing HED documentation and trac? ting system.

3.2 Task Listings Task listings for all tasks required to be performed to accomplish the Emergency Procedures were generated during the generic task analysis phase. These task listings are con-tained in a computer database which will be modified during the plant-specific task analysis phase to create plant speci-fic task listings. This database will be retained as a living document and updated as modifications are made to the plant.

3.3 Information and Control Requirements During the generic task analysis phane an Informa-tion and Controls Requirements database was also created ca-taloging the characteristic requirements for all information and controls. The characterisics derived for each requirement were type of display / control, mode, range, units, response time and availability. Characteristics may be added or de-leted as necessary during the plant-specific task analysis phase. This database will be updated during the plant-speci-fic task analysis phase to conform with the plant-specific tash listings. This database will also be incorporated into plant documentation and updated as necessary.

3.4 Survey Checklists The checklists generated during the survey phase will be retained for traceability of corrected HEDs to the violated guideline criteria.

3.5 Supplement to the Final Summary Report 3' A supplement to the Final Summary Report will be prepared at the conclusion of the supplemental review. The report will consist of the following sections:

1.0 Methodology 1.1 Review Plan 1.2 Management and Staffing 1.3 Documentation 1.4 Review Procedures 3-1

, -- , - - , - - . , , ,, e,,

i -

1.4.1 Generic Task Analysis 1.4.2 Plant-Specific Task Analysis 1.4.3 Survey 1.4.4 Validation of Control Room Functions 1.4.5 Verification of Task Performance Capabilities 2.0 Review Findings 2.1 Task Analysis Findings 2.2 Survey Findings 2.3 Verification of Task Performance Capabilities Findings 2.4 Validation of Control Room Functions Findings 3.0 Implementation 3.1 Assessment of HEDs 3.2 Implementation Schedule 3-2

4.0 Review Procedures 4.1 Generic Task Analysis The generic task analysis was performed by Combus-tion Engineering at the request of the Combustion Engineering Owners Group. This section describes the analysis which is further described in CEN-307.

4.1.1 Multidisciplinary Team 4

The analysis was conducted as a team effort. With the exception of the senior reactor operators (SROs), all team members participated in each phase of the analysis described below. The SRos functioned strictly as subject matter experts (SMEs). In addition to the actual conduct of the work, bi-weekly technical review meetings were held. All team members participated in the meetings and reviewed the work which had been completed in the prior two weeks. These meetings pro-vided an additional opportunity for a cross-discipline review of the work as it was developed.

1 4.1.2 Development of Task Statements, Task Listings and The Task Inventory l '

The first level of analysis in the study was the division of CEN-152 into safety function steps within each Emergency Procedure Guideline (EPG) section. Each EPG step

or section was summarized by noting the safety functions be-ing addressed. With this departure from the wording of CEN-152, the same numbering of steps was preserved in the analysis i for reference purposes.

I The next level of the analysis involved the develop-ment of a unique set of tasks which could be related to the steps of the EPGs. Team members analyzed a particular guide-

, line or guideline section to develop the tasks which would be required to maintain or restore the safety functions of a particular EPG step. Tasks were identified as a set of opera-tor actions which constitute a unit of work that is indepen-dent of the particular task sequence (i.e, the same regard-less of the preceding or subsequent task). Tasks were identi-fled at approximately the same general level of abstraction.

Some tasks overlapped with other tasks. That is, " Determine pressurizer level" is an appropriate task and appeared as a task element of a number of other tasks of somewhat greater complexity. Next, a commonality analysis was conducted across all of the event scenarios. The goal of this analysis was to identify the minimum number of unique task statements which would encompass all of the task requirements for all EPG steps. The purpose is to minimize the task analysis effort and to assure consistency of analysis and results across all

, EPGS.- The result was a set of approximately 150 task state-

ments.

4-1 1

...-,..r ..,..m. -,----+-y---,,w.-,w---wery--,.-,e- . y ,. v-,-m- - , . . , . . . --

Then, task listings were developed for each EPG.

These list the tasks in their order of occurrence in the EPG.

A particular EPG step may contain one or more tasks from the complete list of unique task statements. Task listings com-prise tasks for all of the EPG steps, supplementary informa-tion items, safety function status checks, and the functional recovery guideline resource assessment trees. Where appro-priate, task listings summarize each EPG step by noting the relevant safety functions addressed in that step. Each task is numbered sequentially starting from task 1 through the num-ber of tasks which appear in the EPG. This number is referred to as the task sequence number.

Simultaneously, a task inventory was developed to identify the location of each unique task statement from the task listings throughout the system. The task inventory iden-tifies, for each task, the relevant plant system, the task statement, EPG title, EPG section, and EPG task sequence num-ber.

Each task was broken down into elements of human action, referred to as task elements. Task elements begin with one of the well defined verbs from a predetermined verb list. Task elements define the elementary human actions which are required to execute a particular task (in their order of anticipated occurrence). The header verb for each task ele-ment indicates whether the human action is in the sensory-cognitive arena or in the behavioral arena. These two regimes correspond, respectively, to information and control require-ments. Thus, each element has an associate.d information or control function.

Elements were developed using a system of general matrices which identify, at the component level, a list of po-tential instruments or controls versus a list of potential task element header verbs. These matrices provided a struc-tured approach to developing task elements as well as ensuring consideration of all possible information and control func-tions for a particular component.

The reference plant description and consultation with SMEs provided information regarding the components which required monitoring or operation under a given task. When determining task elements, the conditions under which the task was performed were considered, as were the purpose of the task, initiating cues, and affected safety function. This en-sured a context in which to judge the task and to discern the operator actions necessary to complete it. Thus, each task is a sequence of human actions (defined in the task elements) needed to accomplish a particular safety function using par-ticular plant systems, subsystems and components. The analy-sis of each task was conducted in the task inventory. In 4-2

addition to SME input regarding the operating sequences, a variety of plant simulation analyses were consulted to define the task context.

A task breakdown for each task statement location in the EPG systems was then developed. Each task breakdown con-tains the task statement, the purpose of the task, the initi-ating cues for that task (in the context of an EPG), the safe-ty functions which the task is intended to affect, the INPO task number which cross-references the task statement to the INPO Job Task Analysis, the task elements associated with that task, and the plant system which is affected by each task ele-ment. Since a task is defined as a unit of operator activity which is independent of the scenario in which it is implement-ed, the elements contained under each task are adequate to support the execution of that task in each EPG location in which the task appears.

4.1.3 Development of Task Element I&C Requirements and Characteristics Once the task elements were identified, the minimum functione.1 characteristics of the implied information and con-trol requirement were determined and a rationale for each of these characteristics documented. Since each task has the potential for appearing in a large number of plant transient scenarios, the characteristics for the information and control requirements were developed to encompass all of the scenarios in which that task appears. A gross determination of these scenarios was obtained by observing in which EPG (e.g., steam generator tube rupture, excess steam demand, loss of coolant accident, etc.) the task appeared. Expansion and refinement of these scenarios is obtained by reviewing plant thermohy-draulic analyses as well as discussion with SMEs. Human fac-tors principles as well as additional engineering documenta-tion provided further rationale for the development of I&C characteristics. The rationale are summarized and documented in the I&C characteristic bases. The I&C characteristics themselves are documented in-total in the Information and Con-trol Characteristics report (CEN-307).

4.1.4 Consolidation of I&C Requirements and Characteristics The analysis data to this point was coded for input to the computerized Database Management System (DBMS) on co-ding sheets. " Add data" screens from the main menu for task breakdown and I&C bases are used for this input.

Once all of the task were analyzed and input to the DBMS, all of the information and control requirements and their minimum functional characteristics were sorted out of the data base according to affected plant system and component within that system. This sorting of data was accomplished au-tomatically. This consolidation sort provides a listing of information and control minimum functional characteristics by 4-3

FIGURE L}-]

GENERIC TO PLANT SPECIFIC ICCR CONVERSION PROCESS DEFINE PLANT DEFINE ANALYSIS REVISE DATA BASE SPECIFIC SCOPE MODEL MANAGEMENT SYSTEM PL,H, PRO PL,H,IC PL. PRO,H-4 U v I

REVISE TASK STATEMENTS, TASK LISTINGS, TASK INVENTORY PL,H,SRO, PRO W

DATA ENTRY T

1f ,

DEVELOP NEW TASK ELEMENTS AND I & C CHARACTERISTICS PL,H,SRO,IC, PRO 7

DATA ENTRY a

d SORT NEW I & C REQUIREMENTS BY COMPONENT IEGEND OF TEAM PARTICIPANTS T 4

w@

PL - PROJECT LEADER DEVELOP NEW CONSOLIDATED

"~

SP C AL T LIST OF I & C REQUIREMENTS SR0 - SENIOR REACTOR PL,H,SRO OPERATOR y ,

IC - I & C ENGINEER DATA ENTRY PRO -PROCEDURES ENGINEER T T - TECHNICIAN 7

DATA OUTPUT p __

T -7 PLANT SPECIFIC"I & C REQUIREMENT

~

component and parmits inspection of those characteristics, i The purpose of conducting such a sort is that a particular information or control function may have had characteristics developed under a number of task statement headings. These characteristics were developed for each task given the plant transient scenarios in which that task was embedded. Thus, a variety of characteristics may have been developed for each information or control requirement depending on the number of tasks and, therefore, scenarios, in which that require-ment appears. The consolidation provides the basis for in-specting the characteristics developed for each requirement.

A single list of characteristics can then be identified for each requirement which.will encompass all of the characteris- ~

tics developed for all tasks throughout all EPG scenarios.

For example, the pressurizer level information functiona!

i' range (percent of level) may have been developed in a num-ber of tasks. If the level range developed for one task was 20 to 80% and the range developed for another task was 30 to

90%, then the consolidated list would provide an encompassing

range of 20 to 90% to ensure coverage of all tasks in which

! the pressurizer level was required. The consolidated list was i then re-input to the DBMS. These entries develop a new data.

j base file of information and control' requirements organized by

affected components within affected characteristics for each requirement and are identified in this data base file. Each i requirement is uniquely identifed in the consolidated data base file. This is the file of information and control re-quirements and their characteristics required to support emergency operations in accordance with the Combustion Engi-neering Emergency Procedure Guidelines.

I 4.2 Plant-Specific Task Analysis I

The DCRDR team will perform the conversion of the 3

generic task analysis to a Calvert Cliffs plant-specific task l analysis. The conversion will in turn lead to the development l of an information and controls requirements list for Calvert -

Cliffs as the final product. Unit 1 will be analyzed and dif-ferences between Unit 1 and Unit 2 noted for inclusion in the i

inf'rmation o and control requirements.

4.2.1 Overall Conversion Process i

Figure 4-1 indicates the major activities that will i occur while conducting the. conversion and the critical person-(

nel for each activity. The first three activities, develop-ment of the analysis model, definition of plant specific scope, and modification of the data base management system, may occur in parallel. Definition of the model is important i

to insuring consistency and technical adequacy of the product.

Definition of scope is important to define the boun-daries of the work and to delineate the applecability of the procedures. The data base management system (DBMS) will be modified as necessary to conform to the analytical model and scope. The next activity will be the revision of the EOP task 4-4 i

l listings, the task statement list, and the task inventory.

Taken together, these three activities develop the framework

~

for the balance of the analysis. Review of elements developed under the generic ICCR will be the next major activity. This activity also includes development of revised I&C characteris-tics to correspond to the plant specific design. The final i

activity in the conversion will be the development of a new i

consolidated information and controls list. The DBMS is structured to facilitate data manipulation and input required to generate this list.

4.2.2 Plant-Specific ICCR Scope The scope of the plant-specific ICOR will consist of

! the actions and systems required by the revised Emergency Ope-rating Procedures.

The central purpose of the ICCR is to conduct an analysis to determine, independent of the existing design (to the extent practical), what kinds of controls and infor-mation displays are needed by the operator in the control room i

to conduct emergency operations. Emergency operations are de-fined in NUREG-0899 as any plant transient which is initiated i

i by or results in a reactor trip or an engineered safeguard feature actuation. The Combustion Engineering Emergency Pro-cedure Guidelines (CEN-152, Rev. 02) provide the technical basis for developing plant specific emergency operating pro-cedures for dealing with the kinds of events referred to in l NUREG-0899, and thus only these operations will be analyzed.

The plant systems which may be used during an emer-gency and which must be monitored and controlled from the con-trol room will be defined at the beginning of the analytical effort. As part of the conversion effort it will be decided I

where plant specific design differences from the reference

' plant exist and determined which additional, if any, plant systems will be incorporated in the analysis. Design diffe-rences between Calvert Cliffs and the reference plant may con-sist of different component sizing, different numbers of com-ponents, different types of components, different arrangements i

of components, or equivalent or alternative systems to those defined in the reference plant. Plant-specific FSARs, systems I

descriptions, engineering documentation, component specifica-tions, thermohydraulic and nuclear analyses, and training ma-terial will be used in determining differences between Calvert Cliffs and reference plant designs. Plant systems not covered in the generic reference plant description may be referred to 4

or operated in plant specific emergency operating procedures.

l 4-5

These systems will also be included in the scope of the plant-specific conversion effort. Only those systems which are spe-cifically called on for operation or monitoring in plant-spe-cific procedures will be added. In some instances, only parts l

, of systems, subsystems, or components from subsystems will be l l '

added to complete the picture. Plant-specific subject matter  ;

experts (reactor operators and senior reactor operators) will assist in making these determinations.

The result of this activity will be a brief descrip-tion of the systems to be included within the analyses, speci-fic loci of design differences between the generic reference ~

plant and Calvert Cliffs, a list of the emergency operating procedures, and a discussion of any activities outside the control room which are to be within the scope of the analysis.

4.2.3 Plant-Specific Task Analysis A review will be made in consultation with the human factors specialist of the generic task analysis model. The generic ICCR analysis model uses certain definitions, assump-tions, and structure. These will be reviewed for applicabi-lility to the plant-specific conversion. For example, certain characteristics are defined and were analyzed for the informa-tion and controls identified in the generic analysis. Addi-tional characteristics for the information and controls may be

! defined if necessary. For example, definitions may be altered

} '

and/or verbs added to the verb list for plant-specific pur-posed.

4.2.4 Data Base Management System Modification i

The data base management system (DBMS) provided with the generic ICCR may require modification for the plant-speci-fic conversion. Modification will derive directly from and provide support for changes to either the scope of the analy-sis or changes in the task analysis model as discussed in Sec-tions 4.2.2 and 4.2.3 above. For the most part, changes to j the DBMS may take four forms:

i

1. Changes to the contents of existing data base files.

4

2. Additional data base files.

3. Additional input capabilities to be stored

! either in existing data base files or new data base files.

i 4. New data base sorting and report features.

4.2.5 Developing Plant-Specific Task Listings and Inventory i

conversion of the generic ICCR to the plant-specific ICCR may require revision of the task statements, task list-ings, and, therefore, the task inventory. This activity is an 4-6 l . -- . -- - .. -- --- .. - - - -

7 important part of the conversion effort since the task list-ings provide the basic structure for conducting the task anal-ysis.

Using the plant-specific systems,and SME input, the plant-specific task statement list will be developed. The i

generic list which was generated for the generic ICCR will be i

marked up to (1) delete inapplicable tasks and (2) to add tasks which are needed to address plant-specific design diffe-

, rences and scope differences. In addition to requiring the i addition and deletion of tasks, this may also require changing 5

the order of the tasks as they appear in the task listings. A number of tasks are grouped under the system referred to as '

" miscellaneous" and are simply bracketed statements which say 4

(plant-specific). The task inventory provides the location of these tasks throughout the guideline system. Task which de-scribe the operator activities for these plant-specific ac-l tions will be developed and added to the task statement list i

and task listings. The guidelines used in the generic effort for writing tasks will be used to maintain consistency.

As the task listings are modified to reflect plant-specific operating sequences and equipment, the task inventory

~

will also be revised. The task inventory provides a location for each task throughout the emergency operating procedure system by procedure, procedure step, and task sequence number inside that procedure. The revised task statement list, EOP ,

, task listing, and task inventory, will then be entered into 4

the data base.

4.2.6 Task Analysis For Plant-Specific ICCR Task statements which were developed in the generic ICCR but which were deleted for the plant-specific ICCR as de-scribed in Section 4.2.5 above will now be deleted from the

! data base.

l Task statements which were added to the list provid-ed with the generic ICCR will be entered into the data base.

Task elements will be developed to describe *:he units of human activity which describe each task. Subject

' matter experts (SMEs) will be consulted for the development of task elements. Structured component verb matrices will

be used for developing task elements. Plant-specific proce- '

l dures will also be used in developing task elements.

The operations SMEs will also review all of the ele-ments contained under all the tasks which were not modified from the generic ICCR. Their review may result in the addi-l tion, deletion or modification of certain elements contained

under the unchanged. tasks.

l 4-7 L__________.__.-_..__-- . _ _ , _ _ _ _ _ _ _ . . . _ _ _ _ _ . _ _ _ . . _

Next, new characteristics for all of the information and controls associated with all revised elements and elements affected by differences in the design between the reference plant and Calvert Cliffs will be generated. Development of revised I&C characteristics will require considerable input from operations SMEs, human factors specialists, and engineer-ing specialists.

4.2.7 Plant-Specific Consolidation of Information and Control Characteristics Requirements Once all of the tasks, task elements, and I&C char-acteristics have been revised as appropriate for the plant-specific effort, a consolidation of these requirements will be accomplished. The DBMS will be used to sort out of the data base all of the I&C requirements associated with each component contained in each of the affected systems addressed in the plant-specific ICCR. The characteristics will then be combined under information and control names in a way which insures that the range of each characteristic encompasses all the requirements developed in the task analysis. This data will then be re-entered to the DBMS. Once the consolidation has been accomplished and the data re-entered to the DBMS, a

' revised consolidated plant-specific list of I&C requirements and characteristics will be provided.

4.3 Control Room Survey The human factors engineering survey will follow the guidelines illustrated in Section 6 of NUREG-0700. This survey will consider the extent to which human performance characteristics are considered within the control room.

• A comparison of instrument and control features to the human engineering guidelines will be conducted using the data yielded from the task analysis and visual examination.

Human Factors Specialists, in concert with expe-ri'enced BG&E personnel knowledgeable of plant systems and control room instruments and equipment, and operations per-sonnel, will observe and measure control room features.

The Human Factors Engineering guidelines will be addressed for the nine topic areas below:

1. Control Room Workspace

2. Communications

3. Annunciator Warning Systems

4. Controls

5. Visual Display

6. Labels and Loccations Aids

7. Process Computers

8. Panel Layout

9. Control-display Integration l

l 4-8 l

l~

l

j i

BG&E recognizes the differences in the orientation of guideline topics and will use the checklist approach.

Discrepancies will be noted for each non-compliant item and a 4

photographic log will be developed for reference. .

4.4 Validation of Control Room Functions I

The objective of the validation review is to deter-mine if the functions allocated to the control room operation crew can be accomplished effectively within the structure of the emergency operating precedures (EOPs) and the existing

control room. The scope of this task will be limited to the '

scenerios covered by the EOPs because the analysis that pro-

'. duced the Emergency Procedures Guidelines encompassed all de-sign basis events. These scenerios will be run both as a i

walk-through talk-through and as a real time run-through on ,

j the plant sinulator.

4.4.1 Walk-Through Talk-Through Procedure The walk-throughs will be performed according to the follow-ing procedural steps:

A) The project leader will select an event for valida- L tion from the list and obtain the appropriate proce-1 dure (s).

B) The human factors specialist, with the assistance of the project leader, will develop a floor diagram of the unit work space and identify workstations.

i C) A trained operating crew will review the proca-dure (s). Different crews will walk through diffe-

! rent selected events.

D) The project leader will brief the participating con-trol room operation crew.

4 5

' E) The control room crew will then walk through what

' they would do while following the appropriate pro-i cedure(s). During the walk-through, the opera-tor (s) will describe what they are doing. '

! F) The operator (s) will be accompanied by the human factors specialist during the walk-through of each l event. The human factors specialist will take ab-l servational notes on a procedural, step-by-step basis, attending to the relation between operator l

performance and centrol board / control room design.

! In particular, the-human factors specialist will evaluate and critique the walk-through on the i

evaluation criteria checklist Figure 4-2.

?fN

-. - =- . _ - - - .

G) An additional team member will observe the walk-through to record workstation-work flow informa-tion, using the unit floor diagram developed in step B above as a guide. The information recorded will include:

. Direction of movement

. Sequence of movement

. Frequency of the movement

. Estimated time criticality of the movement

. Real-time estimate of the time that the operator (s) spends at each work-station d

e 4-10 y - - . - - ._-- ,

__ m___ _.__. ._ m _ _-- , y + , ,, - - ,-w --

.7-----

Figure 4-2 EVALUATION CRITERIA YES NO/HED I. USEABILITY A. Level of Detail

/ 1. Is there sufficient information to perform the specified actions at each step?

/ 2. Are the alternatives adequately described at each decision point?

/ 3. Are the labeling, abbreviations, and location information as pro-vided in the EOP sufficient to enable the operator to find the needed equipment?

/ 4. Is the EOP missing information needed to manage the emergency condition?

/ 5. Are the contingency actions suf-ficient to address the symptoms?

/ 6. Are the titles and numbers suf-ficiently descriptive to enable the operator to find referenced and branched procedures?

B. Understandability t

/ 1. Is the EOP easy to read?

/ 2. Are the figures and tables easy to read with accuracy?

/ 3. Can the values on figures and charts be easily determined?

/ 4. Are caution and note statements readily understandable?

/ 5. Are the EOP steps readily under-standable?

II. OPERATIONAL CORRECTNESS A. Plant Compatibility

/ 1. Can the actions specified in the procedure be performed in the designated sequence?

4-11

Figura 4-2 Con't.

/ 2. Are there alternate success paths that are not included in the EOPs?

/ 3. Can the information from the plant instrumentation be ob-tained, as specified by the EOP?

/ 4. Are the plant symptoms speci-fled by the EOP entry conditions adequate to enable the operator to select the applicable EOP?

1

/ 5. Are the EOP entry conditions appropriate for the plant sym-toms displayed to the operator?

/ 6. Is information or equipment not specified in the EOP required to accomplish the task?

/ 7. Do the plant responses agree with the EOP basis?

/ 8. Are the instrument readings and tolerances started in the EOP consistent with the instrument values displayed on the instru-ments?

/ 9. Is the EOP physically compati-ble with the work situation (too bulky to hold, binding would not allow them to lay flat in work space, no place to lay the EOPs down to use)?

/ 10. Are the instrument readings and tolerances specified by the EOP for remotely located instru-ments accurate?

B. Operator Compatibility

/ 1. If time intervals are speci-fled, can the procedure action steps be performed on the plant within or at the designated time intervals?

/ 2. Can the procedure action steps be performed by the operating shift?

4-12 l

l

i Figuro 4-2 Con't.

/ 3. If specific actions are assign-ed to individual shift person-nel, does the EOP adequately aid in the coordination of ac-tions among shift personnel where necessary?

+

/ 4. Can the operating shift follow the dsignated action step sequences?

/ 5. Can the particular steps or sets of steps be readily locat-ed when required?

/ 6. Can procedure exit point be re-turned to without omitting steps when required?

/ 7. Can procedure branches be en-tered at the correct point?

/ 8. Are EOP exit points specified adequately?

III. Human Factors A. Availability of Controls and Displays

/ 1. Is the required control or dis-play available on the control board?

/ 2. Is the required control or dis-play in the logical and expect-ed area of the control board for the function and sequence being performed?

l B. Suitability of Controls and Dis-P lay

/ 1. Is the range of the control or display sufficient for the ex-pected process values?

! / 2. Are the units and scales appro-priate?

/ 3. Is the required display feed-back available to verify that l

1 the control step was success-fully performed?

4-13

{

Figure 4-2" Con't.

/ 4. Is the resolution of the con-trol or display sufficient to perform the required function?

/ 5. Are the spatial relationships of the controls and displays proper for the sequence being performed?

/ 6. Are the controls and displays -

labeled consistent with the procedure and is the labeling understandable?

/ 7. Is the sensitivity of the con-trol or display appropriate for the process?

h-lh l

4.4.2 Rcal Tims Run-Through Precedure Real-time simulations will be performed according to the fol-lowing procedural steps:

A) The project leader will select an event for valida-tion, from the list, and obtain the appropriate procedure (s).

B) The human factors specialist with assistance as needed from the project learder will develop a floor diagram of the unit work space and identify unit workstatiena.

C) A trained operating crew will review the proce-dure (s). Different crews will run through dif-ferent events for videotaping.

D) The project leader will assemble and brief the par-ticipating control room personnel. Any assumptions about the operating situation will be specified to the operator (s) during the briefing.

E) A microphone will be attached to the operators and they will be asked during the event simulation to describe what they are doing.

F) The videotape will be started when the event is initiated.

G) The event simulation run-through will begin.

i H) During the event simulation, a voice-over narration by a subject matter expert may be performed on the j videotape.

I) During the event simulation, another team member will observe the event to record workstation-work flow information, using the floor diagram of the unit work space prepared earlier. The information recorded should include:

. Direction of movement

! . Sequence of movement

. Frequency of the movement 4

. Estimated time criticality of the movement A real-time estimate of the time that the opera-tor (s) spent at the workstations can be obtained from the videotapes.

l J) At a cue from the operating crew performing the

! event simulation, the project leader will termi-

! nate the event and video-taping.

4-15 l

- +-,+r w v - - + --- >--+: . . - - --,o-- - . -i% -w - ;-y,- --

K) The videotape operator, at that point, will remove the tape from the recorder and log in: A) the event taped, B) the date of taping, C) the time of <

taping, D) any unusual circumstances surrounding the taping, E) the names of the operating personnel l taped, F) the name of the event narrator (if appli-cable) and G) the counter reading from the video-tape recorder.

4.5 Verification of Task Performance Capabilities The revised consolidated plant-specific I&C re-quirements list developed in the plant-specific task analy-sis phase will be compared to the inventory of control room instruments and controls, and differences and discrepancies noted. The inventory will be developed to a level of detail and with the same characteristics as the ICCR.

All of the characteristics specified in the I&C requirements list will be verfied to insure that they are encompassed by the existing plant instruments and controls.

HEDs will then be initiated to document areas where existing equipment is inadequate. The HEDs will be coded appropri-ately to indicate that they were identified during the task performance capabilities verification phase, and then en-tered into the HED system for assessment and implementation.

The DBMS will be used to document the verification process by adding plant data in new columns alongside the I&C requirements. After all of the data is input, the com-parisions will be made and the HEDs generated. All discre-pant ite=s will be flagged for ease of identification and compilation.

4-16 l

)

• I 5.0 Assessment, Implementation and Validation 5.1 Introduction All HEDs generated during the supplemental review will be assessed on the same criteria as used during the orig-inal DCRDR. Those HEDs evaluated as requiring control room modification will be scheduled for implementation via the appropriate method. After these new corrections have been

implemented, all HEDs initiated during the original and sup-plemental DCRDRs will be validated during a control room walk-

, down. -

t 5.2 Assessment A set of criteria (listed in Table 1) will be appli-ed in a structured manner (see figure 5-1) to classify HEDs in terms of their significance and associated scheduling priori-ty. All HEDs will be subjected to this process to ensure con-sistent categorization and prioritization. Only those HEDs

assessed as requiring correction will be implemented.

Categories were established on the basis of the likelihood that an HED would degrade operator performance, the safety significance of the systems pontentially involved, and the potential consequences. The probability of an operating j crew error and the severity fo the potential consequence of that error will be evaluated by appropriately qualifed mem-

! bers of th3 DCRDR Review Team. Each HED will be assumed to potentiate the most severe associated operator error iden-

, tified, avoiding the need to assess multiple modes of per-l formance degradation.

j i

If a safety-related (SR) system is involved and vio-lation of a technical specification or other unsafe condition could be potentiated by the HED, it will be assigned the high-est category of importance and the highest scheduling priori-ty. .

For all other HEDs, the potential for error will as-sumed to be high unless the Human Factors Specialist explicit-ty evaluates the potential to be low on the basis of the per-l formance shaping factors in Table 2. If the most severe ope-1 rator error associated with a low-potential HED would not lead

to a technical specification violation or to an unsafe condi-tion, the HED will not be considered to be significant. These NEDs will assigned to the lowest category of importance. If a reasonable method of correction is identified, they will be

scheduled for implementation. Until and unless such HEDs are corrected, they will be tracked to ensure that their cumula-tive impact remains acceptably small.

5.2.1 HED Categories j Category I HEDs for which there are documented errors or

reported potential for errors with safety-

.i 5-1

.- - - - . = - - . . _. . - - _- - -. -

related equipment or systems capable of crea-ting unsafe plant conditions-and/or violation of the Technical Specifications. These are assigned "A" scheduling priority.

Category II HEDs which potentiate errors with equipment or systems designated as safey-related; or which create or contribute to effects which could cause unsafe operations, plant conditions, and/or violations of the operating License's Technical Specifications. These are assigned a scheduling priority based upon evaluated significance.

Category III HEDs which potentiate errors with equipment or systems which are NOT safety-related, would not contribute to unsafe operations or plant conditions, and would not contribute to a vio-lation of the Technical Specifications.

5.2.2 Corrective Actions In evaluating proposed design modifications, the DCRDR Team will consider the following:

1. Does the modification conform to the appli-cable precepts of human engineering prac-tice?

j 2. Does the modification introduce new HEDs?

3. Will the information and control require-ment be met after the modification; and will other requirements'for effective task performance (e.g., proximity and consis-l tency of controls and displays used in the task) be met after the modification?

) 4. For each function affected, will the modi-fication enhance (or at least, not detract from) integrated performance of the task sequences involved in accomplishing the function?

l In addition, as indicated above, the modifi- '

cations will be checked for consistency and compatibility with established control room conventions, features that will not be modified, and other proposed modifications.

Evaluation of proposed modifications will be facilitated through the use of photographs and control room-walkdowns as necessary.

! 5.2.3 Scheduling Priority of Corrective Actions i

The categorization of discrepancies resulting from the application of criteria and methods described in 5-2 l

l l

l

- - . - ,_ - - - - . ,, . , _ - - , _s-- . , , __ _-.,-.m. . , _ . - - _ . . . _ . - . , - - . . . _ _ _ . _ _

the previous section will be used as the basis for deter-mining the urgency of corrective actions. All Categories I and II HEDs will be evaluated and scheduled for cor-rective action or determined to be acceptable without correction.

For the purpose of scheduling corrective ac-tions, the following priorities will be assigned.

Priority A -

Prompt - By the end of the next re-fueling outage for each unit, subject to the availability of materials and i engineering.

Priority B -

Near Term - By the end of the second refueling outage for each unit, sub-ject to the availability of materials and engineering.

Priority C -

Long Term - By the end of the third outage for each unit.

In all cases, actions on a shorter schedule than that indicated will be considered as schedules of other plant modifications change. Non-outage work will not be deferred to outage periods without justification.

)

i 5 '

TABLE 1 PRIORITY ASSIGNMENT GUIDANCE NOTES Responsible Question Guidance Team Member How was the a) Was it assessed through de- Project Leader potential for sign surveys, guide document human error sign surveys, guide document

, identified? comparisons, procedural task analysis / function analysis or other design document reviews?

(This group represents potential errors with no prior reports of operational occurrence)

(

b) All error occurrences reported in team meetings are to be treated as documented errors.

Is the error Has the HED been determined to have Human potential sig- more than a minimal potential for Factors nificant? degrading human performance capa- Specia-bilities? (See Table 2 for list performance shaping factors.)

Is the equip-

Reference:

Calvert Cliffs Q-List Instrumen-i ment safety- and its attachments. tation and related? Controls Engineer Does the ef- Could the induced error have Reactor

. fect of the direct safety impact or does it Operator error have increase the potential of an event or I&C high safety sequence leading to any unsafe Engineer significance? occurrence significantly?

Could the er- a) Resources: Technical Specifi- Reactor ror induce a cations, Final Safety Analy- Operator or Technical Spe- Eis Report, team knowledge I&C Engi-cification or of systems / equipment inter- neer lead to unsafe actions, design diversity operations er and redundancy; various plant plant condi- specific and NSSS tions? Generic Transient Analyses.

b) Determinations of potential Tech-nical Specification violations should include the citation if readily identifiable.

5-4 l

TABLE 2 ERROR POTENTIAL ASSESSMENT The following will be evaluated in assessing error potential:

Whether overall operator performance is degraded by the HED's impact on body physiology.

Whether the HED degrades sensory performance.

Whether information processing capability is exceeded because of the HED.

Whether the HED induces direct error due to principles of learning.

Whether task difficulty and reliability are affected by the HED.

The following performance shaping factors were considered:

Body physiology

- fatigue / physical stress

- discomfort

- injury

- anthropometry Sensory / perceptual performance

- vision

- audition

- proprioception

- touch Information processing

- overload

- confusion

- recall

- pattern matching / recognition

- data manipulation (comparing, extrapolating, etc.)

Learning

- inhibition

- habituation

- response predominance

- transfer

- response competition

- response latency Task demands

- frequency

- duration

- competition

- sequence 4

- speed

- communication

- precision

- information

5-5

HUMAN ENGINEERING DISCREPANCY s.

CLASSIFICATION 5 h.

5si o m o.

( START )

o TECH SPEC POT IAL YES YES DOCUMENTED - '

S AF ETY VIOLATION OR I A ERR RELATED OPE A ASSESSED NO NO o

POTENTIAL HIGH HIGH TECH SPEC SAFETY YES YES YES FOR RELATED SAFETY VIOLATION OR ~- H A ERROR SIGNIFICANCE p LOW NO NO NO TECH SPEC YES SA E OPERATION NO TECH SPEC VIRA OR YES e OPERA '" M NO

~

TECH SPEC *M Vl%A OR YES ,

o OPERATION NO Y

= g~ &

FIGURE 5-1 M M.

5.3 Implementation i Changes to the design of licensed nuclear power plants are permitted under 10CFR 50.59 without prior approval provided the changes do not require a change in Technical Specificaions and do not constitute or create an unreviewed safety question.

Maintenace Requests (MRs) are initiated at Calvert Cliffs; control of these MRs is administered through the pro-cedures contained in the Calcert Cliffs Instructions (CCIs).

Human Engineering Discrepancy (HED) modifications which do not constitute formal design changes, such as enhancement addi-tions or label changes are controlled by initiation of an MR.

The operations (SRO) member of the DCRDR Team will be respon-sible for initiating MRs to resolve outstanding issues in this area. Field Change Requests (FCRs) are initiated at Calvert Cliffs to control design changes or additions. The design process itself is controlled by the Responsible Design Or-ganization, Electric Engineering Department. The Electric Engineering Department members of the DCRDR Team will be re-sponsible for assuring that FCRs to resolve outstanding issues are implemented in accordance with approved recom-mendations.

5.4 Validation In order to insure that HED corrective actions are accomplished as intended, an administrative procedure will be put in place that requires the utilization of a human factors manual during control room modifications. When a modification is initiated via a Facility Change Request (FCR) it will be reviewed for compliance with human factors criteria, and signed-off as appropriate. This administrative procedure will not only insure that all HEDs are properly corrected, but it will also force a human factors review of modifications initiated from sources other than the DCRDR. It is the inten-tion of BG&E to not only address items of history but also to maintain sound engineering practices once the detailed control room design review has been completed.

1 5-6 i

6.0 Coordination I- Tasks, elements of te.sks and the information and control characteristics associated with the elements found in the analysis of operator actions are the products of the site-specific task analysis effort. This analysis of operator actions performed during plant transient scenarios as defined in CEN 152, will be utilized as a key component of coordina-tion of NUREG-0737 activities. Task analysis generated lists of instrumentation will be provided to project personnel as-e sociated with Reg Guide 1.97 issues to insure that instrumen-tion operability requirements are individually reviewed in an -

operator / event content. SPDS personnel will be provided simi-lar lists of needed instrumentation and the characteristics

, associated with them in order to insure consistency between i

software and hard wired control room displays. In addition I&C constructs on a micro level from the task analysis (e.g.

valve status, pump status and flow indication) can be reviewed on a macro level (e.g. system status) to insure that the i SPDS offers the higher level construct information necessary to operations personnel in emergency settings. Emergency operating Procedures will be reviewed in conjuction with the task analysis to insure their accuracy and comprehensiveness.

Where appropriate, highly specific renditions of operator actions from the task analysis will be reviewed by operators j in training to insure that the EOPs can be performed with the 4

degree of skill necessary for safe and effective plant opera-I tion. Where other initiatives are impacted by the DCRDR, e.g.

upgraded Emergency Support Facilities, they will be integrated

either on an informal or special meeting basis as is deemed appropriate by BG&E engineering and operations personnel in

conjuntion with the DCRDR team.

E 1

l 6-3 l

l

._-._-__.-_.._._..,_,..,-,,..,...-..,,,.._..m.___,,_ -

. . . - , , ,