ML19332D159
| ML19332D159 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/22/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1727, TAC-56116, TAC-65225, NUDOCS 8911300099 | |
| Download: ML19332D159 (5) | |
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DONALD C. SHELTON
- w. % w a -vu w Docket' Number 50-346' l
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- License Number'NPF-3
. Serial Number 1727 m
November 22, 1989
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' United States Nuclear Regulatory Commission Document Control Desk
'Vashington, D. C. 20555
Subject:
Human Engineering Discrepancy (HED). Resolution Schedule Gentlemen The purpose of'this letter.is to provide clarification to Toledo Edison's (TE)
June 29,:1988 submittal-(Serial' Number 1537) that provided TE's schedule for corrective actions-to resolve the 378 HED items, identified as part of the Detailed Control Room Design Reviev (DCRDR) Program.
TE's April.9,-1987, submittal (Serial Number 1350) provided a plan (v perform
. eleven Special Studies to determine resolution for the 378 HEDs.
In order to complate the task, TE formed Special Study Teams to evaluate each HED and identify'the corrective actions necessary to resolve the specific concerns of the HED.
On July 25,.1988 the disposition of all.HED's was compiled in-the 1988 HED Summary Report. This report met the NUREG 1177 requirement that all HED's were to be disposition by~the end of the fifth refueling outage (SRF0).
In the June 29, 1988 submittal (Serial Number 1537), corrective actions identified by the Study' Teams were categorlzed into three categories:
1.
Those deemed necessary to resolve the 29 safety-significant HEDs.
2.
Those deemed necessary to r~ solve operational concerns.
3.
Those deemed necessary to provide operational enhancements.
.Those corrective actions deemed.necessary to resolve the 29 safety-significant HEDs and the operational concerns were completed at the end of SRF0, with'the exception of two corrective actions for HED No. 3.1.037.
The letter of June L
29, 1988 (Serial Number 1537) provided justification for completing these remaining corrective actions for HED No. 3.1.037, in the sixth refueling I'
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. outage (6RFO). TE stated in Serial Number 1537 that ve_would promptly notify the NRC of any other unavoidable delays to the schedule.
The following provides clarification to TE's schedule for corrective actions for the remaining HED items._
1.
Corrective actions for 227 HED items have been implemented.
2.
Corrective actions for 140 HED items are scheduled during the 6RF0.
3.
After additional review, TE has determined that modifications for portions of two HED items (3.1.009 and 5.1.004) are not needed.
See attachment 1 for justification.
4._
The corrective action for a portion of one HED item (4.1.020) vill not be completed until after the 6RFO.
See attachment 1 for justification for completing the corrective action after the 6RFO.
5.
The corrective action for a portion of one HED item (9.2.027) is being evaluated to determine if any modification is needed.
See attachment 1 for justification.
6.
TE's Special Study Team identified seven (HED items: 5.1.010, 5.1.016, 5.1.017, 5.1.020, 5.1.025, 5.1.027 and 5.1.033) operational enhancement items needed for certain control recorders and meters (Bailey). These deficiencies were identified as: poor contrast between pointers and scales; poor visibility of data on recorders; poor quality pens that clog and smudge the paper; recorders that mechanically or electrically hang up; inadequate height of graduation marks; more than nine graduations between numerals on recorder scale; and pointers being too narrov. With the additional prevent 1ve maintenance that has been performed, TE has determined that no additional corrective actions are required until the equipment (Bailey Recorders ~and Meters) fails and spare parts can no longer be obtained. As the equipment performs its intended design function and no significant operator burden is created by not replacing the equipment, TE considers the equipment adequate and longer term replacement acceptable.
Toledo Edison vill provide the following to the NRC for changes to this schedule, if any, before restart from the 6RFO:
1.
Justification for HEDs not corrected or partially corrected.
2.
An implementation schedule for each HED correction, including the rationale for schedule delays beyond the sixth refueling outage.
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License Number NPF-3 l
Serial Number 1727
- Page'3 If you.have any questions concerning this matter, please contact.
e Mr.- R. V. Schrauder, Nuclear Licensing Manager, at (419) 249-2366.
+ Very tru
- yours, f
RTH/ eld-Attachment cc: P. M. Byron, DB-1-NRC Senior Resident. Inspector
- A. B. Davis, Regional Administrator, NRC-Region III T..V. Vambach, NRC/NRR DB-1 Senior Project Manager
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'N t Serial Nu2ber 1727-Attachment Page 1 ATTACHMENT 1 JUSTIFICATION FOR NOT INCLUDING HED ITEMS IN THE SIXTH REFUELING OUTAGE HED Number 3.1.009 The Fire Protection Panel (C5796) alarm bell is too loud as confirmed by measurement [14 DB above ambient] and subjective evaluation.
However, the alarm bell is required to meet Fire Protection Code standards. The amount the alarm noise level could be reduced and still satisfy the Fire Code Standard, was so minimal that the implementation of the modification could not be justified.
'HED Number 5.1.004 The range of the condenser pressure recorder (PR 5330/531) is too narrow-(0 to 10 inches of Hg) and should be expanded to greater than 17 inches of Hg to cover alarms and turbine trip limits.
MOD 88-0119 was written to implement this change.
After additional review TE determined that the change is not necessary based on the following:
- 1. If the recorder scale is changed from 0-10 inches to 0-20 inches Hg, some loss of resolution at the lov end (<5 inches) would occur. This change is not desired since the current scale of 0-10 inches is the normal operating band with the unit on line.
- 2. HED 5.1.004 identified a concern that without a scale range covering automatic actior.s the operators may take actions that vep1d cause unnecessary plant transients. (i. e.,-if the Control Room (CTRM) indication pegs out at 10 inches Hg, the operator may trip the MFPTs).
As the MFFTs have redundant lov vacuum trips and their is little chance of having a transient stabilize vacuum between 10 inches and 12.5 inches Hg this is not considered a valid concern.
.HED Number 4.1.020 Modification 89-0096 was written in order to establish a convention that motor operated throttle valves are provided with dual light indication when in mid-stroke position. This convention vill provide the operators with a positive feedback indication for those valves that may be in mid-stroke positions for extended periods of time.
The current design is to have both red and green lights out during the valves mid-stroke transit.
MOD 88-0214 is scheduled to be implemented during the 6RF0 and vill provide dual light indication for the throttle valves while in mid-stroke position.
o Dockat Nu bar 50-346
' J ' ?' - Lic;nsa Nurb2r NPF-3' Serial ~ Number 1727 4
Attachment
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Page 2-9 In the course of the review of MOD 88-0214 design package, it was discovered that five throttle valves in the Auxiliary Steam & Gland Seal Systems were inadvertently omitted from the MOD. A new modification, MOD 89-0096 was written to provide dual light indication for these valves.
Due to the design schedule for modification design preparation and the impact on the outage vorkload, it was determined by Toledo Edison that MOD 89-0096 would not be scheduled for implementation during the 6RFO. The basis for this decision, is that this modification to these five valves is considered to be an operational enhancements, not critical to plant operation and they can be scheduled to be implemented with the unit on line.
MOD 89-0096 is scheduled for cycle 7 (during operations following startup from the 6RFO). As an interim measure during 6RF0, the five valves vill be labeled and included in operator-training to identify them as operating differently until MOD 89-0096 is implemented.
HED Number 9.2.027 A portion of HED item 9.2.027, cites inadequacy in the SFAS Cabinet Data Lights.
MOD 87-1330 has been vr!tten to correct the inadequacy in HED item 9.2.027.
The SFAS Cabinet Data Light problem is related to the SFAS Cabinet indication ar.d does not refer to the control room indications. These lights are not normally used or viewed by the operators during emergency operations. The problem with the ambiguous SFAS data lights is primarily a concern during surveillance testing and shift checks of the cabinets. The main concern is that misinterpretation of the lights could result in an unwanted actuation of SFAS equipment during surveillance testing, or an equipment problem could go undetected, when a half channel' trip is present, during normal operations.
MOD 87-1330 is being evaluated by Toledo Edison to determine the need for the modification and a schedule should corrective actions be required.
The following is the basis for this decision:
- 1. The SFAS Cabinet Data lights are not normally used or viewed by the operators during emergency operations and the problem with the ambiguous SFAS data lights is primarily a concern during surveillance testing and shift checks of the cabinets.
- 2. To decrease.the probability of unwanted component actuation, additional procedure guidance has been provided and operators have been trained on these changes.
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