ML20127N284

Requests Required Due Dates for Submittal of Control Room Design Review & Rev 2 to Reg Guide 1.97 Be Changed to 850930 & 861130,respectively,in Full Power OL Due to Current Startup Schedule

ML20127N284
Person / Time
Site:	Fermi
Issue date:	05/21/1985
From:	Jens W DETROIT EDISON CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-REGGD-01.097 NE-85-0705, NUDOCS 8505230485
Download: ML20127N284 (3)

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ra$ ions May 21, 1985 NE-85-0705 Director.of Nuclear Reactor Regulation Attention: Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

(1) ?ermi 2 NRC License No. NPF-33 NRC Docket No. 50-341 (2)-Detroit Edison to NRC Letter, " Response to Supplement 1 of NUREG-0737, Requirements for Emergency Response Capability (Generic' Letter 82-33) December 17, 1982", EF2-62262, dated April 15, 1983 (3) Confirmation of Schedule in Edison " Response to Supplement 1 of NUREG-0737, (Generic Letter 82-33)", NE-85-0191, dated April 15, 1985

Subject:

Edison Schedule for Response to Items in Sunclement 1 to NUREG-0737 Attachment 2 to Licence No. NPF-33 documented Edison's proposed schedule for submittal of the Control Room Design Review Summary Report. (CRDR) and report on Regulatory Guide 1.97, Revision 2. Attachment 2 to NPF-33 was based on Reference (2). Reference (3) was submitted as required by a commitment in Reference (2) to confirm the intended schedule by April 15,

-1985. Subsequent discussions with your staff regarding the pace of activities leading to. full power licensing and power' ascension testing, plus.the desirable sequence of events for a CRDR resulted in a more critical evaluation of this intended schedule. Accordingly, we request that the full power license reflect dates for the Regulatory Guide 1.97 and CRDR reports of September 30, 1985 and November 30, 1986, respectively..

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Mr. B. J. Youngblood May 21, 1985 ,

NE-85-0705 Page 2 The proposed schedule, documented in the License as a License Condition, was provided in April, 1983. It was assumed at that time to be sufficiently past plant.startup so as to. minimize other' activities duringLthat very busy period. In addition, it would have-permitted experience to be gained with plant systems and the Control Room;in the operational mode. Unfortunately, the plant construction schedule slipped and that. intended schedule is,now impacting the startup program.

Relevant to the Regulatory Guide 1.97 report, the Instrumen-

-tation and Control Engineers' involved are crucial to the startup testing program and resolution of problems therein. A

" DRAFT". report showing how the guidance of the Regulatory Guide is met-has been developed. Nevertheless, significant work by +

these individuals would be required to finalize-the-information, receive and resolve comments, and submit the report to the NRC. Revising the submittal date to September 30 allows this activity to be integrated into the work plans of these key engineers, assuring satisfactory completion of all crucial tasks during the startup period.

Relevant to the CRDR summary report, key personnel are similarly involved in high priority activities. The original September 30th date was predicated on an earlier fuel-load schedule and would have allowed significant operational experience to be-gained in_the Control Room to provide 3 meaningful input to finalizing the human factors decisions being addressed by the report.. With-the; current plant startup schedule,~the plantzwill be in the midst of startup and power ascension testing while this developmental work is proceeding.

Extending the report due date to November 30, 1986 allows the control Room experience to be utilized in the report development. .

In addition, the earlier September 30, 1985 schedule for completion of the CRDR summary report was predicated on using the existing plant Emergency Operating Procedures (EOP's) based on Revision 3 of the BWR Owners Group (BWROG) Emergency Procedure Guidelines (EPG's). The EOP's.were developed in 1981 based on the EPG's without a documented task analysis being H performed. They were revised thereafter as improvements from the EPG's became known. As discussed in a May 4, 1984 meeting between the BWROG.and the NRC's Human Factors Engineering Branch,-EPG's provide an acceptable function analysis that identifies, on a high level, generic information and control needs. -However, the EPG's do not explicitly identify the plant

' specific information and control needs for preparing EOP's and determining the adequacy of existing instrumentation and controls as part of the Control Room Design Review. Plant specific analysis is required to translate the EPG's to plant

, specific technical guidelines which then can be used to identify the control and information needs via a task analysis of these technical guidelines.

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B. J. Youngblood May/21, 1985 -

, - NE-85-0705

- Page'3 As stated earlier,-due to the vintage of their development 1 (1981),Jthe current ~ Fermi;2 EOP's were not developed with a1 complete formally documented technical analysis as is currently

- the desired method. It had been thought that the EOP's themselves would provide-.the basis for the CRDR summary report. The extended schedule will allow the preferred methodology-using a task analysis.to be followed. Duplication '

of work will also be minimized since the task analysis which will be developed to support the. Procedures Generation Package *'

for the next revision of the EOP's-will be used to support the CRDR.- This will also allow the upgraded Revision 4 of the BWROG EPG's to be the basis forfthe work. As discussed with your staff in.a meeting on May.17, 1985, since' Detroit Edison' already has had an acceptable preliminary review of its 1

Control Room design and EOP's by NRC for full power operation,

- this more deliberate extended review including a task analysis is considered to be more desirable and productive.

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Accordingly, it is requested that the required due dates for the above reports be changed as indicated in the full power-operating. license. If you should have any questions, please call O. K. Earle at (313) 586-4211.

Sincerely, f

cc: Mr. P. M. Byron Mr. J. L. Mauch Ms. A. M. Ramey-Smith USNRC Document. Control Desk Washington, D.C. 20555 t

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• Due July 31, 1986 - License condition 3(a) in Attachment 2 to

- the Fermi 2 Operating License NPF-33.

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