ML20116N584

Discusses Schedule for Completion of Detailed Control Room Design Review Audit Rept in Response to NUREG-0737,Suppl 1. Probable Action Plan Addressing NRC Recommendations Re Summary Rept Submitted on 850204 Encl

ML20116N584
Person / Time
Site:	Cooper
Issue date:	04/30/1985
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Vassallo D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 NSL8500077, TAC-56114, NUDOCS 8505070269
Download: ML20116N584 (8)

Text

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h Nebraska Public Power District NSL8500077

""""Nddk*bieO'***" S April 30,1985 '66-298 Director, Nuclear Reactor Regulation Attention: Mr. Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Detailed Control Room Design Review (DCRDR) -

In-Progress Audit Report Response

Reference:

1) Letter from J. M. Pilant to D. B. Vassallo, dated February 4, 1985, "NUREG-0737, Supplement 1 -

Detailed Control Room Design Review Summary Report" Your letter of March 20, if65, requested that the District provide our NRC Project Manager with a schedule for addressing various recommendations not already resolved in our DCRDR Summary Report of Reference 1. It is anticipated that the Supplement to our Summary Report will be submitted approximately February,1986. The District must implement an action plan with considerable scope in order to address the staff's recommendations. The most probable action plan is outlined in Attachr.ient 1, including the estimated completion date for each of the various phases. The scheduled dates for completion provided herein are coasidered estimated dates in accordance with our April 15, 1983, response to NUREG-0737, Supplement 1. As defined in Attachment 8 to that document, our NRC Project Manager will be kept informed of all substantive changes in the implementation schedule.

It should be noted that the District will not directly impleraent some of the staff's recommendations. For example, the staff recommends that Regulatory Guide 1.97 instrumentation be available prior to EOP implementation; however, the District is under Order to implement the EOP's prior. to September,1985, before the Regulatory Guide 1.97 efforts are complete. If the staff wishes to discuss-any of the enclosed information in further detail prior to submittal . of our Supplement to the Summary l

Report, the District would welcome an additional meeting with the i staff or a conference call. l goS t i j

P"P%tiH%% PDR- l J

I '.- 'Mr. Domenic 'B.' Vesxllo.

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April 30,1985 It must also -be -recognized that the schedules submitted in Reference' l for accomplishing modifications to the Control Room are . subject to change due to the additional effort required in implementing the staff's recommendations.

-If you have any questions, please call.

Sincerely, Jay. M.- Pilant Manager, Technical Staff Nuclerr-Power Group JMP::?s30/1 2

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'Attrchment 1-RESPONSE TO NRC MARCH 20, 1985 DETAILED CONTROL ROOM DESIGN REVIEW IN PROGRESS AUDIT REPORT.

NRC RECOMMENDATION / SUGGESTION NPPD PROBABLE RESOLUTION / ACTION ESTIMATED COMPLETION DATE I. Task Analysis - Recommendations

a. Task analysis. definition of inferma- Characteristics of information and _

September ~30,,19851

-tion and control characteristics for controls required to perform the E0Ps

.the E0Ps should; define requirements will'be expanded in order to define for operability under accident con- requirements for operability:under dition (e.g., power quality and accident conditions. This informa-

. qualification of portions of the tion will be contained in the task-instrument and control loops lo- analysis sheets.

cated in harsh environments).

b.. Task analysis definition of informa- For tasks that require the operator. September 30, 1985 tion and control characteristics for to determine the magnitude of a the E0Ps should;. identify require- parameter, the required indicator ments.on indicator resolution for accuracy will be noted in the task

' tasks that require the operator to analysis sheets.

' determine the value of a parameter or compare the value of a parameter

.against a action, control or caution point.

c. . Task analysis definition of informa- The task analysis sheets will be re- September 30, 1985 tion and control characteristics'for viewed and where details are lacking, the E0Ps should; maintain a.consis- additional details will be provided, tent level of detail throughout the Information regarding information^and analysis. control requirements for operability.

under accident conditions and indi-cator accuracy will' provide _such addi-tional detail.

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NRC RECOMMENDATION /SUCCESTION HPPD PROBABLE RESOLUTION / ACTION ESTIMATED COMPLETION.DATE~

d. Function and Task Analysis'should be A' Verification and Valida' tion process' lN/Av

,. carried through:to; Normal Proce- -was used to verify;the adequacy.of

'dures implicitly referenced.in E0Ps the E0Ps. A Function and. Task Analy-

'that are required to support perfor- sis is felt to be. unnecessary for mance of,EOPs.. Norma 1' Procedures. implicitly refe .

renced;in the E0Ps. _The station pro-cedural' initiation, approval process, and on going review process of,these.

Normal Procedures are judged to be adequate measures to ensure.that such procedures.can sufficiently support the.EOPs as' required.

e. Function and Task Analysis should be A Verification and Validation-process N/A carried through to; existing Emer- was used to verify the adequacy of-

.gency Procedures to the extent they the EOPs. A Function and Task Analy-wil1~still:be in use after implemen- sis is felt to be unnecessary'for the tation-of the E0PS. existing Emergency Procedures which will still be in use after.implemen-tation of the EOPs. The station pro-cedural initiation, approval process, and ongoing review of.these proce-

'dures ensures.adaquacy and workabil-ity of these procedures.

'f.. Function and Task Analysis should be The Verification and Validation pro- N/A

. carried through to; revised E0Ps, if cess used on the E0Ps are judged to significant revisions are required. be adequate by~NPPD, and. additional prior to implementation. Function and Task ~ Analysis is con-sidered unnecessary for the E0Ps.

If significant revisions are required

.to the E0Ps prior to implementation, a Verification and Validation-process will be conducted on the revisions.

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tr NRC RECOMMENDATION / SUGGESTION NPPD PROBABLE' RESOLUTION / ACTION ESTIMATED COMPLETION DATE'

' g. ' Function and Task An'alysis should be The need:for a Function and-Task . February, 1986 carried through to; SPDS'and PMIS '

= Analysis for the SPDS and PMIS. Pro .

. Procedures _ required to support per ' cedures will be, assessed upon develop-formance of:EOFa. ment of the procedures.. The.SPDS will be operable February,1986.

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II. Control Room Survey.- Recommendations

a. .The apparentfoversights noted.in the 1A Control-Room Survey will be per- November 30,;1985 Control. Room Survey'nhould.be re- formed guided by NUREG 0700 and dis- ,

viewed to determine'if.they are indi- crepancies will be identified-and catfie of a systematic problem with assessed for safety importance.

'the survey process, and appropriate action should be taken.

- b. The control lnuma environment and A Control Room environment and commu- February, 1986 communications survey should be re- nications survey will be conducted by

• peated after completion of planned a Human Factors consultant following modifications that will affect the Control Room modifications, environment (e.g., PMIS, SPDS,'and a new communications system)~. -This resurvey should consider the ability of operators to communicate while wearing self-contained. breathing apparatus and. respirators.

c. Human Factors principles, conven- SPDS/PMIS Human Factor principles, July 1, 1985 a

tions 'nd' plant nomenclature consis- conventions, and nomenclature will be tent with that used in the' Control- -compared against that used in the

. Room should be implemented in the- . Control Room and discrepancies noted.

design of the SPDS and FMIS..

d. .The safety significance'of'the lack .The lack of lamp test capability will November 30, 1985 of lamp test capability should be be reassessed for safety importance Completion of reassessed. and the results of the-assessment- Reassessment.

will be reported in the Supplement to

~the Summary Report submitted approxi-

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mately February, 1986.

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NRC RECOMMENDATION / SUGGESTION NPPD PROBABLE RESOLUTION / ACTION - ESTIMATED COMPLETION DATE-4

.e. .The specifics of each:HE0' identified .As the Con' trol Room Survey-is con- ' September 30,"1985.

by the Control. Room Survey should be ducted guided by NUREG.0700, HEOs. ,

documented and justification pro-! will be additionally detailed and'

, vided for any HEOs.that are not

' assessed;per NUREG 0700. Justi ! '

corrected. fication for HEOs not corrected will be provided.

f. It'should'be verified.that Regula- The District is under NRC order to N/A tory Guide 1.97 instruments required implement the E0P's by September,

for performance of E0Ps will be 1985, without necessarily having; alls

l. available" prior tc.EOP implementa .

Regulatory Guide 1.97f,instrumenta-tion andLthat relabeling of Control tions available. Most of the Regula-

Boards and procedure" changes'are tory. Guide.l.97. instrumentation is

~ happening in a manner that ensures

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available. The EOPs remain func-

. consistent nomenclature between the

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tional and' beneficial without the procedures.and boards.

remaining Regulatory Guide 1.97

. instrumentation. installed. Consis .

tency will be maintained between control board changes and related procedures.

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- III. Other Items - Recommendations-

a. Modifications planned to resolve. The Supplement to the Summary Report February 1986 HEDs should be described and comple- will provide additional detail:of

, tion schedule commitments provided. proposed modifications needed to re-

~A supplement to the Summary Report solve HEDs. The Supplement will also will be needed to provide descrip- contain an updated schedule for tions and schedules for modification design modifications already identi-plans resulting from feasibility. fied and those that might be deve-studies. loped due to the results of feasibi-lity studies.

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NRC RECOMMENDATION / SUGGESTION NPPD PROBABLE RESOLUTION / ACTION ~ ESTIMATED' COMPLETION DATE'-

b. The details of NPPD's verification' A verification documentation process" June 30 1985;-

Jprocess for HED correctionsishould .will be developed and followed to en- . Development.of a be included.. 'sure that HEDs corrected by_ design. . verification. '

. modification are resolved, andithat' ' documentation, -

3 no,new HEDs areJcreated by.implemen . process.:

-u tation of the. design mo'difications..

cThis process >will be. described in the-Supplement to the Summary Report.

c.- An updated ~ schedule for NUREG-0737 The Supplement'to the Summary Report ' February. 1986L Supplement 1, activities should be will provide an updated. schedule for

. included. .This update shows inter- ' NUREG-0737 activities showing the relationships among these tasks. integration' effort for these activi-ties. -. ,.

IV. NRC Suggestions

.<- a. , Copies of survey checklists, task' A DCRDR working-file will be created June 30,'1985:

.ana'ysis worksheets, and other.DCRDR- and kept at Cooper Nuclear Station.

documentation should be obtained

, from General Electric and organized < i into.a working' file for.use by NPPD-team members and individuals and~

' organization. responsible for HED- [

correction modifications and other i ~ related efforts. .

b.- HED records s'ould h be upgraded so The format and content used to docu- June 30, 1985 the written documentation alone is ment the HEDs will be reviewed and adequate to provide non-DCRDR team recommendations made, members a clear understanding of

. . 'each HED.

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NRC RECOMMENDATILN/ SUGGESTION NPPD PROBABLE RESOLUTION / ACTION ESTIMATED COMPLETION DATE

- c. Any portions of 'the Control Room As previously stated..NUREG-0700 will. N/A JSurvey that are repeated' or updated be used as a guideline in conducting.

should make use of the NUREG-0700 another control room survey. Further checklists. . control room surveys or updates will use NUREG 0700 as a guideline,

d. 'Further coordination of SPDS..PMIS, A functional plan for total integra- _ July 30, 1985 DCRDR, Reg. Guide 1.97, and EOPs.at tion of these various activities will-the working level should be con- be developed and reviewed.

sidered.

e.. The operating experience review .The operating experience review from July'30, 1985 should be extended to include expe- the Summary Reports of other'similar rience at other BWRs similar to BWR-4s will be reviewed and Cooper. evaluated.

f. = Human factors' engineering principles Human factor engineering principles 1986 Refueling should be applied to the design of. will be incorporated into the' design Outage.- Planned

'the CNS remote shutdown capability,. of the remote shutdown panel. installation of the including the remote shutdown remote shutdown panels. capability.

. g. Design conventions and nomenclature Design conventions and nomenclature 1986 Refueling applied to remote shutdown equipment applied to remote shutdown equipment Outage - Planned should be consistent with those used will be consistent with those used installation of the in the control room. in the control room, remote shutdown capability.

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