ML20042E458

Responds to Inconsistencies in Terminology & Labelling Identified During NRC 890118 & 19 Audit of Facility Dcrdr. Util Believes Control Room Inventory Requirement of Suppl 1 to NUREG-0737,satisfied

ML20042E458
Person / Time
Site:	Comanche Peak
Issue date:	04/12/1990
From:	William Cahill, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, TXX-90137, NUDOCS 9004230073
Download: ML20042E458 (3)

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- EE F ===l Log # TXX-90137

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= 907 1UELECTRIC g,g,yQ;t,,,,o,1 William J. Cahill, Jr. April 12, 1990 hecutive Vkr besLJent U. S. Nuclear Regulatory Commission Attn: Document Control Desk '

Washington, D. C. 20555 ,

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-445 COMPARISON OF DISPLAY'AND CONTROL REQUIREMENTS WITH A CONTROL ROOM INVENTORY-REF: 1) U. S. Nuclear Regulatory Commission, " Safety Evaluation Report'-

related to the operation of Comanche Peak Steam Electric Station,_

Units 1 and 2", NUREG 0797, Supplement-22, dated January, 1990 .,

2) D. G. Eisenhut (NRC), " Supplement I-to NUREG-0737 Requirements-for Emergency Response Capability " Generic Letter 82 33, dated-December 17, 1982

3) William J. Cahill, Jr. " Docketing of Miscellaneous Commitments."

TU Electric letter (TXX-90005) dated January 4. 1990 Gentlemen:

As indicated in reference 1 during the NRC staff's January 18 and 19.,1989, audit of the CPSES Detailed Control Room Design . Review _(DC_RDR), a number. of -

inconsistencies in terminology and: labelling were identified along with several inconsistencies between the parameter values documented in the emergency operating procedures (EOPs) and-the values which.can_be read on the control displays. In the same reference, in item I.D.1. " Control Room Design ,

Review," of Section 22.2. " Discussion of [THI-2]' Requirements." it was stated-that, in order to complete the OCRDR requirement of reference 2, a supplemental, detailed comparison of display and control requirements to the-control room inventory should be performed for the additional task analysis of symptoms and entry conditions, and further,-- that- this supplemental comparison should include verification in the control room. It'was also stated that the-previous comparison of required display characteristics for all- E0P' tasks-should be checked in the control room to ensure that the: parameter values and ranges specified in the procedures can in fact be. read on the existing-displays, and that the labels and terminology are consistent.- AsLindicated in j reference 3. TV Electric committed to complete this activity and submit a i report prior to exceeding 5% power for Unit 1. This letter constitutes that j report.

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a TXX-90137 Page 2 of 3 Before describing this task, it should be indicated that, when the DCRDR audit was conducted in January, 1989, the E0Ps in effect were Revision 2 and the procedure governing E0P changes, i.e., ODA-204, " Preparation of Emergency Response Guidelines," was Revision 5. Since that time, the E0Ps have

rogressed through several improvements, as has ODA-204. The E0Ps are-currently Revision 5 and the ODA is Revision 8. Further -at the time of the NRC's team inspection of Emergency Response Guidelines-(ERGS) in August,-1989, j the E0Ps used by the team were Revision 4 and the then current ODA-204 was' '

Revision 7. In preparation for the August, 1989, team inspection of ERGS, all 43 of the E0Ps underwent a complete plant walkdown, including the symptoms.and entry conditions and attachments, as well as a series of independent audits.

The walkdown included checks to assure'that labels and terminology are  ;

consistent, as well as a determination of the adequacy of indicator ranges and '

their readability. As a result of these audits and walkdowns, changes were made to the Rev 4 E0Ps, including a number of corrections to E0P 0.0 and its symptoms and entry conditions.

The work performed in completing the commitment made in reference 3 was separated into two tasks and is summarized below:

Task 1- A supplemental, detailed comparison of . display and control re-quirements to the control room inventory should be performed for the ad-ditional task analysis of symptoms and entry conditions:1this should in-  !

ciude verification in the control room (see reference 1, pg. 22-3). j Task 1 response- This supplemental,- detailed comparison, including verification in the control room, was performed in-January of this-year.

The results of the additional task analysis, which was performed on the j symptoms and entry conditions for all 43 E0Ps, identified a number of; deficiencies with regard to the instrumentation to be used in carrying out the steps of the symptoms and entry conditions. The specific instrumentation involved was recorded on Indicator Worksheets prepared for the ERG Guideline Task Analysis. These_ deficiencies resulted from the fact that the task analysis which was performed,'as-required by ODA-204, when the E0Ps changed from Rev. 3 to Rev. 4, did not contain a requirement to include the symptoms and entry conditions. Since then, ODA-204 has' 4 been revised to require that the symptoms and entry conditions be included in the function and task analysis which is to be performed when E0Ps are '

revised. This new requirement was effective when the E0Ps were changed from Rev. 4 to Rev. 5 in March of this year, at which time the'Rev. 5 symptoms and entry conditions underwent a task analysis.

It is to be noted that the current set of Rev. 5 E0Ps has had these  !

deficiencies corrected. '

Task 2- The previous comparison of required display characteristics for all E0P tasks should be checked in the control room to ensure that para- >

meter values and ranges specified in the procedures can in fact be read on  ;

the existing displays, and that the labels and terminology are consis- '

tent (see reference 1, pg. 22-3).

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1 o s TXX 90137 Page 3 of 3 '

Task 2 response- This task was performed in January of this year by. ,

actually walking through each of the draft ~Rev. 5 E0Ps in the control room using the function and task analysis for the Rev. 4 E0Ps to check-the display instrumentation for readability, range adequacy and consistency in labelling and terminology. This review identified one inadequacy which -

resulted in a change to the steam generator pressure setpt,;.it in order to improve readability.

4 Both of these tasks were performed by a SRO licensed supervisor. and a R0 licensed operator. The Indicater Worksheets used during performance of the l function and task analysis in Task I were prepared by an operations engineer who is currently enrolled in the shift technical advisor program. These work sheets were reviewed by the Operations Support Manager who is SR0 licensed -

and were approved by a SRO licensed supervisor. i Based on the above information. TU. Electric believes that the' control room inventory requirement of Supplement I to NUREG 0737 (2) has been satisfied.

If you have any questions or require additional.information, please contact either Ralph Flores or Ray Ashley of the TV Electric staff; they can he '

reached by phone at (817) 897-5590 and (214) 812-8415, respectively. -l 1 1 Sincerely, i I

WAy.eJJf,A j

! William J. Cahill, Jr. 4 By:

Roger-D. Walker

$4 1

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j Manager of Nuclear Licensing .l l

RLA/vid  :

I c Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 1 i

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