ML20082J138

Forwards Licensee Supplemental Summary Rept for Plant Dcrdr, Including Open Issues,As Requested in NRC SER

ML20082J138
Person / Time
Site:	Browns Ferry
Issue date:	08/22/1991
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-56104, TAC-56105, TAC-56106, NUDOCS 9108270185
Download: ML20082J138 (6)

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k Tennr$e Ver+y A.B Pod DMu Bm Wn Deue Ad-r% Wm AUG 2 2 1991-0 J w Zenngue va newm aws een, opewes U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - SUPPLEMENTAL RESPONSE TO NRC SAFETY EVALUATION FOR TNE BFN DETAILED CONTROL ROOM DESIGN REVIEW (DCRDR) -

TACS 56104, 56105, 56106

References:

1. NRC Letter dated August 15, 1990, " Safety Evaluation for Browns Ferry Plant - Detailed Control Room Design Review Program"

2. NRC Letter dated August 9, 1988, " Safety Evaluation for the Detailed Control Room Design, Browns Ferry Nuclear Plant, Units 1, 2 and 3"

3. TVA letter dated November 9, 1988, " Response to NRC Safety Evaluation for BFH Detailed Control Room Design Review (DCRDR)"

4. TVA Letter dated December 28, 1989, " Browns Ferry Nuclear Performance Plan, Attachment IV-4, Response to Request for Additional Information"

5. TVA letter dated July 10, 1991, " Regulatory Framework for the Restart bf Units 1 and 3" This letter provides TVA's supplemental summary report for the BFN DCRDR as requested by NRC safety evaluation report (SER). The SER (Reference 1) requested TVA provide a response 90 days after Unit 2 restart to address the remaining open issues with the BFN DCRDR program.

9108270185 910822 PDR ADOCK 05000259  : k-P PDR }

. 2 Nuclear Regulatory Cohaission E'j3 2 2 f$l The BFN DCRDR audit was conducted by NRC during February 1988. The Staff's SER (Reference 2) identified that TVA had only partially met the requirements of NUREG-0737, Supplement 1, Item I.D.1. TVA's response (Reference 3) addressed those issues required for Unit 2 restart and committed to address the remaining three issues within 90 days after restart. NRC issued a subsequent SER (Reference 1) which documented the completion of the restart issues and acknowledged TVA's 90-day post-restart commitment for the remaining open issues.

Enclosure 1 to this letter provides a summary of each of the open issues. TVA considers that the information requested by NRC has been provided and requests the issuance of a revised SER.

A summary list of commitments contained in this letter is provided in Enclosure 2. If you have any questions concerning this matter please telephone Patrick P. Carier at (205) 729-3566.

Very truly youro, TENNESSEE VALLEY AUTHORITY

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Enclosures cc (Enclosures):

NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commiosion One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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. , . l ENCLOSURE 1 i

Detailed Control Room Design Review (DCRDR)

Open Issues Symmary of Ite.m The control room survey was identified as an open item because generic human engineering discrepancies (HEDs) were written for departures from human engineering criteria for labeling, color coding, switch handle conventions and meter banding. The individual instances of those discrepancies were not identified during-the survey process.

Status of Item .

TVA has completad the control room survey as sequested. The survey lists generic human engineering concerns (HECs) which were used to develop generic HEDs in the. areas of labeling, color coding, switch handle conventions and ,

meter banding. The HECs were used to perform the survey and document specific instrument / component discrepancies. BFN's completed control toom survey for Units 1, 2'and 3 is available on site for staff review.  ;

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Symmary of Item: ,

The safety evaluation report (SER) (Reference 1) determined that TVA conducted '

an appropriate program for selection of design improvements to resolve the HEDs identified in the DCRDR. However, NRC identified the need for a revised ,

-implementation schedule, to ensure that safety significant HEDs (Category 1 '

and 2) will be corrected before the completion of the second refueling outage after restart.  !

Slatus of Item:

For Unit 2, Reference 4 states that TVA will complete safety significant HEDs (Categories 1 and 2) prior to restart from the next refueling outage (Cycle 6). Non-safety signif2 cant HEDs (Categories 3 and 4) will be implemented +

prior to restart from the second refueling outage (Cycle 7), only if they are determined to have a positive cost / benefit ratio.

i For Unita 1 and 3, Reference 5. states that TVA will complete safety i significant HEDs (Category 1 and 2) and those HEDs required for Unit 2 restart ;

privr to the restart of Units 1 and 3. Additionally, non-safety significant HEDs (Categories 3 and 4) will be implemented prior to restart only if they  ;

are determined to have a positive cost / benefit ratio.

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• Page 2 of 3 ENCLOSURE 1 (Cont'd)

Eummary_qLItem:

The SER (Reference 1) stated that TVA did not demonstrate adequate coordination between DCRDR control room improvements and programs for the Safety Parameter Display System (SPDS) and Regulatory Guide 1.97 instruments.

S1ALUa_allitmi SEDS The SPDS is in the design phase of development as a function of the Integrated Computer System (ICS). Coordination between DCRDR and the SPDS program has been accomplished by formal and informal memorandums and use of the same personnel (e.g., engineering, operations, training) to perform direct and indirect support of both efforts. Present coordination and agreements consist of the following.

1. ICS and DCRDR personnel have evaluated IIEDs which could be corrected by use of the ICS.

2. DCRDR will locate and/or install all ICS equipment in the control room.

3. DCRDR will provide annunciator and primary containment isolation. data interfaces with the ICS as noted by the ICS data base input list.

4. DCRDR personnel (engineering) will support lluman Factor development and review of system man-machine interface and design prepared to implement the above.

5. Iluman Factors review (per TVA procedure PI 89-06) of ICS design packages.

Based on the above documented coordination and the activities and programs in place to perform and implement integration, the requirement to coordinate these two programs is considered complete.

Rentlatary_GuMc_idl The lack of coardination between the DCRDR and Regulatory Guide (RG) 1.97 instruments, was due to inadequate design procedures. The DCRDR review, which consisted of task analysis, inventory of instruments used (including RG 1.97) and the checklist surveys of control room instruments, was based on the as-constructed plant. The reactor vessel instrument in question was designed but not installed at the time of the DCRDR review.

The reactor vessel level instrument identified by the NRC has been revised for Unit 2 restart to close NUREG 0737, Item II.K.3.27 (common reference for reactor vessel level). Emergency operating instructions (E01a) upgrades for Uni 2 addressed this and other control room instrument usability during procedure verification and validation.

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• Page 3 of 3 ENCLOSURE 1 (Cont'd)

TVA procedures now require a lluman Factors review of designs which could impact the control room operator. Design Procedure (PI 89-06) requires a iluman Factors review of designs which impact the operator. Site Director's Standard Practice 8.10 require Operations and Training department coordination during each phase of design package development. Also, Site Standard Practice 12.16 for writing and approving emergency procedures, describes use of Iluman Factors trained individuals to support procedure verification and validation and addresses consistency of procedures and instrumentation and labeling.

Based on the information presented above, TVA has in place procedures and programs to prevent and correct deficiencies in instrument design.

PLLIC207/3/10 i

ENCLOSURE 2

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Supplemental Response, BFN DCRDR Safety Evaluation Summary of Commitments Non-safety significant ilEDs (Category 3 and 4) vill be implemented a rior to restart for Unita 1 and 3, only if they are determined to have a positive cost / benefit ratio,

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