ML20151L345
| ML20151L345 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/06/1985 |
| From: | SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY |
| To: | NRC |
| Shared Package | |
| ML20151L350 | List: |
| References | |
| CON-NRC-03-82-096, CON-NRC-3-82-96, RTR-NUREG-0737, RTR-NUREG-737 TAC-51154, NUDOCS 8512110183 | |
| Download: ML20151L345 (19) | |
Text
{{#Wiki_filter:. s SUPPLEMENT TO THE s' TECHNICAL EVALUATION REPORT
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1 ,. 0F THE DETAILED CONTROL ROOM DES'GN REVIEW (, FOR THE DAVIS-BESSE NUCLEAR POWER STATION December 6,1985 Prepared by: - I Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102 s Under Contract to : U.S. Nuclear Regulatory Commission e
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s' l L 1 TABLE OF CONTENTS .
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Section Pa1e. 1
- 1. Qualifications and Structure of the DCRDR Team . . . . . . .
2 i 2. Function and Task Analysis . . . . . . . . . . . . . . . . .
- 3. Comparison of Display and Control Requirements With a Control Room Inventory . . . . . . . . . . . . . . . . . . . 3 L
- 4. Control Room Survey .................... 4
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- 5. . As sessment of HEDs . . . . . . . . . . . . . . . . . . . . . 4 r 6
- 6. Selection of Design Improvements . . . . . . . . . . . . . .
4
- 7. Verification That Improvements Will Provide the Necessary Corrections Without Introducing New HEDs . . . . . . . . . . 10
, 8. Coordination of the DCRDR With Other Improvement -
j Programs . . . . . . . . . . . . . . . . . . . . . . . . . . 11 i
. . ..................... 12 l,
SUMMARY
AND CONCLUSIONS RE FE RE N CE S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
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I. - 'l S l-8 'l SUPPLEMENT TO THE TECHNICAL EVALUATION REPORT l i 0F THE - DETAILED CONTROL ROOM DESIGN REVIEW
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! FOR THE 1 :
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, DAVIS-8 ESSE NUCLEAR POWER STATION
, ! This report documents the findings from e review of Toledo Edison (TED) Company's Appendix C.S.1 to Revision 4 of the Davis-Besse Course of Action
; (C0A). Appendix C.5.1 documents TED's COA related to deficiencies in its i Detailed Control Room Design Review (DCRDR) being conducted at its Davis-Besse Nuclear Power Station (Reference _1). Based upon the findings of a pre , implementation audit conducted the week of April 29, 1985, the NRC staff l concluded that it was unable to close out any of the nine requirements
- associated with conducting a DCRDR in accordance with Supplement 1 to NUREG-0737 and that an NRC/TED management meeting be held in Bethesda to discuss
! the status of the Davis-Besse DCRDR (Reference 2). The NRC met with TED on Detober 9,1985, to discuss the DCRDR; the minutes of this meeting were I ' documented and transmitted to TED (Reference 3). TED submitted its COA attached to a letter dated November 16, 1985. The findings from a review of Appendix C.5.1 of the C0A are described below as they. pertain to each of the i DCRDR requirements of Supplement 1 to NUREG-0737. These findings reflect the conclusions of the NRC and SAIC. f
- 1. Qualifications and Structure of the DCRDR Team The NRC audit team found during the pre-implementation audit that TED's plans for performing the activities remaining to be completed did not include an adequate level of involvement of human factors specialists. The 6 1 remaining DCRDR activities were the development and conduct of the special I studies, and the development and verification of HED corrections. In the meeting. TED and its human factors consultant, Essex Corporation, stated that human factors specialists for these and other activities will be involved as follows: '
s A dedicated project leader from Essex Corporation has 5Heen estab-
; 11shed.
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i i e A human factors specialist will be dedicated to each special study. ! e Human factors specialists wfil be involved in the development and verification of HED corrections. e Human factors specialists will be involved in the upgrading of the System Function and Task Analysis, the survey of components added
; to the control room since the survey was last performed, the reassessment of HEDs, the production of control room design stan-dards and conventions, and the upgrading of DCRDR data collection j- and HED forms.
ll .Throughout the C0A, TED reaffirmed its commitment to this level of involvement of human factors specialists in the DCRDR. In addition. TED has l committed to the involvement of human factors specialists in its current I Systems Review and Test Program and in the Facility Change Request (FCR) {
, process during and after completion of the DCRDR. TED's commitment to the human factors participation in the DCRDR satisfies the concerns of the NRC "
, and will meet this requirement of Supplement I to NUREG-D737. Also, TED's
; commitment to human factors involvener.t 4fter the DCRDR is completed is i commendable.
- i
- 2. Function and Task Analysis During the pre-implementation audit, the NRC audit team found TED's L System Function and Task Analysis (SFTA) to be incomplete. The NRC audit team concluded that the following activities should be performed in order to meet the Function and Task Analysis requirement:
- 1. Analyze operator tasks, information and control requirements, and required characteristics of instruments and controls necessary to monitor and assess the various challenges and failure modes of the Radioactivity Release critical safety function.
- 2. Comprehensively analyze information and control requirements and requjred characteristics of instruments and controls for Steam Generator Tube Rupture.
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. 3. In addition to items 1 and 2, analyze required characteristics of [; instruments and controls for all emergency operator tasks.
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In the meeting, TED stated that it will upgrade the SFTA. In the COA, TED reaffirmed its commitment. The SFTA upgrade activitites will include - the following:
- 1. An analysis of operator tasks, information and control require-ments, and required characteristics of instruments and controls necessary to monitor and assess the various challenges and failure modes of the Radioactivity Release critical safety function.
- 2. A reanalysis of operator actions for steam generator tube rupture 4 to ensure comprehensive identification of information and control requirements.
- 3. An analysis of required characteristics of instruments and controls ,
i for all emergency operator tasks. In summary. TED's SFTA upgrade will satisfy the NRC's previous concerns. However, the SFTA performed to satisfy DCRDR requirements should be an extension of the NRC-approved SFTA performed to develop the upgraded plant-specific E0Ps. The NRC will conclude on the adequacy of the SFTA performed to satisfy DCRDR requirements after TED receives NRC approval of the SFTA performed to develop the plant-specific E0Ps.
- I
- 3. Comparison of Display and Control Requirements With a Control Room Inventory The NRC audit team concluded that due to the incompleteness of the SFTA, the comparison or verification of the information and control require-ments and required characteristics of instruments and controls with the control room mock-up could not be considered incomplete. The NRG, audit team
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concluded that in order to close out this element of the DCRDR requirements, TED aust perform a verification of equipment availability and human engi-neering suitability for the requirements that are developed from'the activi-ties necessary to upgrade the SFTA to completion. In the meeting and in its 3
-1 }. h i proposed SFTA upgrade approach. TED indicated that this will be done. TED j reaffirmed this commitment in the COA. TED's intended verification approach will satisfy the NRC's previous concerns. However, the adequatrof this verification process will be dependent on the adequacy of the SFTA relative -l to upgraded plant-specific E0Ps. 1 4. Control Room Survey The NRC audit team found that the control room survey conducted up to l the time of the pre-implementation audit was satisfactory. However, the I
, following aspects of the control room were not evaluated:
I 'e ' The new conponents added to the control room since the survey was performed. e The annunciator system flash patterns.
, TED stated in the meeting that the new or added components in the -
i control room will undergo a human factors evaluation. In addition, the j annunciator system flash patterns have undergone a review by Essex and will be handled as an HED in the annunciator study. TED reaffirmed this commit- ';' ment in its COA. These activities will satisfy the NRC's concerns regarding the control room survey, and the requirements of Supplement I to NUREG-0737 I for a control room survey will have been met. TED should provide to the NRC l documentation of the assessment and resolution of any HEDs identified from L the review of new components added to the control room and the HED associated with annunciator system flash patterns. 4
- 5. Assessment of HEDs The NRC audit team concluded during the pre-implementation audit that TED's assessment of HEDs was not acceptable due to deficiencies in the following areas:
e The consideration of cumulative and interactive effects of individual HEDs. l e The reprioritization of 29 safety-related HEDs. 4
[ The NRC audit team found that there was no systematic review of indi-vidual HEDs to determine the presence of cumulative and interactive effects upon the assessment of HEDs. In the meeting, the NRC learned that through d the use of HED database possessed by Essex. TED will conside'r t'hehmulative and interactive effects of individual HEDs upon the HED assessments. A review of the capabilities of the computerized HED database found that the l approach proposed shcu,1d be effective in identifying cumulative and inter- i t active effects. The nroposed approach is to use various HED database fields (e.g., problem type er NUREG-0700 guideline discrepancy, component title or type) to enable the identification of component or problem interactions. TED stated that in instances where interrelated HEDs with varying categori-zations are found, lower categorized HEDs will be upgraded. TED's intent in the reprioritization of the 29 safety-significant HEDs f associated with the special studies was to establish scheduling priorities 1 in the completion of the ten special studies. A result of this reprioriti-zation was the downgrading of the safety significance of all 29 HEDs as it relates to the implementation of HED corrections. The reprioritization , assigned later implementation dates to the corrections of these 29 safety-significant HEDs. In addition to this delay in the implementation schedule of corrections to safety-significant HEDs, the NRC audit team found the reprioritization to be unsatisfactory due to the absence of human factors input. Overall, the NRC found the reprioritization of the 29 safety-significant HEDs to be unacceptable since (1) the safety significance of each of these 29 HEDs was downgraded from its original assessment; (2) the reprioritization did not include human factors input whereas the original ' assessment did; (3) the justification for reprioritizing these 29 safety-significant HEDs was not satisfactory. , In the meeting, TED stated that it and Essex will reassess the 29 safety-significant HEDs. TED stated that while some of the HED corrections will be performed prior to the rest, all corrections to the 29 HEDs will get priority attention. In the COA, TED stated that these 29 safety-significant HEDs have 1.2en reviewed with human factors personnel involvement.4n conjunc-tion with the work of the Systems Review Group. TED states, "The. outcome is that action will be taken on a minunum of 12 of the 29 safety-significant HEDs during, the current outage" (Appendix C.5.1,p.13). This statement indicates that the assessment of some of the 29 safety- significant HEDs i 5
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q relative to the correction implementation schedule has been revised from j that given in the January 31, 1985, submittal (Reference 4). However, it' is not clear which of the 29 safety-significant HEDs are affected. -{though it 3 can be assumed that those MEDs associated with the SFRCS an'd }the June 9 J 1985, event are among those revised TED should identify by HED number. which HEDs are to be corrected in the current outage. l l
- In summary. TED's plans for the reassessment of HEDs for cumulative and interactive effects and its review of the assessment of the 29 safety- ; significant HEDs relative to the implementation of UED corrections appear to ,' be acceptable. In order to close out this requirement. TED needs to .
identify by HED number which HEDs are to be corrected in the current outage. l 6. Selection of Design Improvements l Based on the findings of the pre-implementation audit, the NRC audit j team concluded that the following activities were necessary in order for TED , j to meet this DCRDR requirement: , f I l s Carry out and document a systematic process of selecting design ! improvements. j i ; a i e Ensure cumulative and interactive effects of individual HEDs that i will be corrected, not corrected, or partially corrected upon the l whole integrated control room improvement package are considered. e Improve HED documentation for completeness, clarity, accuracy, and auditability. e Develop solutions to HEDs and implementation schedules that are i acceptable to the NRC. At the time of the pre-implementation audit. TED had made little progress toward the identification and resolution of HED correcitions since the submittal ten months prior to the' Summary Report. No systematic, rigorous process for identifying and selecting among alternative corrections L to HEDs had been developed or employed. TED had developed corrective actions or justifications for not taking corrective actions for only 50% of 6 ?
- . _ . - - . _ = _- -.
I . : iI-i 't the HEDs listed in the Summary Report. In the meeting. TED had discussed ! but not documented its process for selecting HED corrections. In the C0A, TED states that it plans to develop and. select design improvempts in the special studies. TED'provided the work plan for the SFRCS pa(el special study as a sample of the process for developing and selecting design im- l provements. Although the SFRCS panel work plan appears to be satisfactory in and of itself, the various special studies TED will be performing are sufficiently unique so that a conclusion on the adequacy of the sample work plan cannot be generalized to the others. In order to progress towards the resolution of the NRC's concern regarding the process for selecting design improvements TED should provide work plans for the other special studies.
-The'NRC audit team found no integrated approach to the development of HED carrections. The approach taken by TED appeared to promote a piecemeal method of selecting and implementing HED corrections without adequate con-l sideration of cumulative and interactive effects of HEDs. In the meeting, i and in the COA, TED responded to this concern by stating that the HED l database will enable cumulative and interactive effects of HEDs to be con- .
sidered. The HEDs considered will include all HEDs, not just those associ-i sted with the special studies. As mentioned in the Assessment of HEDs section of this report, the HED database appears to be suitable for performing this function. TED stated in the meeting and in the COA that it upgraded and completed the HED documentation found during the pre-implementation audit to be incomplete, ambiguous, and inaccurate. TED stated that all components involved with each HED have been recorded for traceability through the HED j correction process. To close out this particular NRC concern TED should l I provide several HED samples which demonstrate the upgrading of HED documen- -l tation (e.g., examples of "before and after"). A review of the Summary Report found many instances where the responses I to HEDs were not finalized, and were ambiguous, uninformative, or otherwise i unacceptable to the NRC. The NRC audit team stated in the pretimplemen-tation audit report that in order to meet the requirements of Supplement 1 to NUREG-D732. TED should develop solutions to HEDs and implementation schedules that are approved by the NRC. TED stated in the meeting that it intends to d'o so. TED reiterated this intention in the C0A by stating that 7 3
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[I through the use of such aids as the. on-line HED database, the design !' improvements selected will be agreeable to the NRC. 1 . In response to the NRC's concerns rejarding the schedule 'fo'r*Taplemen-tation of HED corrections. TED stated the following in the C0A*(Appendix !
- ! C.5.1, p.8)
! " Toledo Edison has revised the schedule. Under the new l schedule, all 29 HEDs identified as safety significant in the Summary Report and further classified as either jj of high or medium safety significance in the January
" 1985 supplementary letter will be corrected during the current outage or the first following refueling outage (referred to as the 5th Refueling Gutage) currently 1
expected in 1986/87. All other HED corrections, i including those categorized as low or non-safety sig- - I nificant, will be made during the second planned (sixth) refueling outage (currently expected in 1988) or will be ~ defined in Facility Change Request (FCR) packages for ] i implementation according to the Integrated Living Schedul e." The portion of the statement in which TED says, "... or will be defined in Facility Change Request (FCR) packages for implementation acording to the Integrated Living Schedule." raises a concern for the timeliness in which corrections are to be made to HEDs categorized as low safety significance in the January 1985 supplementary letter or as nonsafety significant. In the schedule for implementing HED corrections, the NRC requires that the cor-rections of safety-significant HEDs associated with the Steam Feedwater I' Rupture Control System (SFRCS), Feedwater (FW) System, and Post Accident Monitoring (PAM) System be implemented prior to restart. All other safety-significant HED corrections, including those for HEDs categorized as low in the January 1985 supplementary letter, should be implemented by the end of the fifth refueling outage. All other HED corrections should be, implemented 3 i- by the end of the sixth refueling outage. The following statement ii. *e COA indicates TED'4 intentions to comply with this implementation schedu . but cites the probability that HED corrections will be implemented after the l. sixth refueling outage (see Appendix C.5.1, p.29): l t. 8
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; "It is expected that all DCRDR programs will be closed g
out by the end of the second planned (6th) refueling
! outage following restart (tentatively scheduled ).
1988). At that time, all HEDs will have been resolve:d, and those designated for backfit or design change will ' have had the appropriate FCRs developed. It is antici-pated that some of thesa FCRs may not be implemented [ , during the sixth refueling outage. The decisions j concerning those HEDs to be delayed beyond the sixth refueling outage will be documented. This documentation I will be available for staff review. Other HEDs which have been designated as not requiring design modifi-cation will also have appropriate justification for that : designation."
) ; TED indicates in this statement that documentation of decisions concerning l
those HEDs delayed beyond the sixth refueling outage will be available for NRC review. In order to progress towards the resolution of the NRC's concern . regarding the schedule for implementation of HED corrections. TED should i provide after completion of the special studies an implementation schedule I for each HED correction including the rationale for schedule delays beyond the sixth refueling outage. l In summary, the concerns of the NRC regarding TED's performance of activities in the area of selecting design improvements have not been resolved to the point of being able to close out this requirement of Supple-
- l. ment I to NUREG-D737. TED has satisfactorily demonstrated the capability for considering the cumulative and interactive effects of individual HEDs that ,
l will be corrected, not corrected, or partially corrected. The other concerns ! of the NRC associated with th1 selection of design improvements that have not been resolved are the following areas:
; e The process of selecting design improvements The upgrade of HED documentation s
e The development of solutions to 'HEDs and implementation schedules e k 9 y *
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L l In order to progress towards the resolution of these areas of concern and to
.l close out this requirement of Supplement 1 to NUREG-0737, the following i documentation should be provided by TED: ,
e The work plans for the special studies (except for the SFRCS panel). i e Several sample HEDs which demonstrate the upgrading of HED documen-j
' tation (e.g., examples of "before and after").
'i All the prdposed corrections to.HEDs, including those to be per-
; e formed during the current outage and afterwards.
; -e- -Justifications to all those HEDs not corrected or partially
! corrected.
g e An implementation schedule for each HED correction, including the
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rationale for schedule delays beyond the sixth refueling outage. l The HED documentation should be detailed enough to provide a clear descrip-tion of the HED, the systems and/or components involved, and the proposed HED
- corrections or justifications for not correcting, or partially correcting ,
- HEDs. Particular attention to detail should be given to the proposed HED l
corrections and justifications for not correcting or partially correcting r HEDs. Proposed HED corrections should be described in sufficient length and l l , detail to provide the NRC with an unambiguous picture of the backfit that has been or will be implemented. Justifications for not correcting or partially { correcting HEDs should be in similar detail and should address behavioral or
, operational factors involved in each HED. The format used for the HED Report ,
I form with the level of detail discussed above is recommended.
- 7. Verification That Improvements Will Provide the Necessary Corrections Without Introducing New HEDs
- The NRC audit team found that no systematic, rigorous process for veri-l fying HED corrections was developed or e'aployed. In addition, TED's design change process '(via FCRs) did not include a human factors review in verifying design changes. The NRC audit team concluded in its report that a system-atic, rigorous methodology for verifying design improvements should be per-ID
I. . b i formed and that this process should involve human factors specialists as active, integral members of the DCRDR team. TED stated in the meeting that ]
! expert judgment with the aid of the control room mock-up seged as the process for verifying some of the " simple" HEDs. For " comp 1'ex" HEDs, such as those involved in SFRCS, criteria were used as the basis of the verification.
TED stated that a human factors specialist will be involved in the FCR
- process during the DCRDR. After the DCRDR, a human factors specialist will i be involved in the FCR process on an as-needed basis. In the C0A, TED provides a fairly detailed description of the approach it will take to verify f
design improvements (Appendix C.S.1, p.14 ). In general, the approach described consists of the following steps: I i - e- Application of NUREG-0700 criteria by human factors specialists.
} e " Checks" made in the special studies to ensure that changes are consistently made across groups of related components.
[ e In the special studies, final verification of proposed HED cor-rections in the mock-up whenever applicable. - 9 o Verification of FCRs by human factors specialists, o Post-implementation verification of HED corrections by the multi-disciplinary team. Implementation of this verification approach will resolve NRC concerns g regarding TED's fulfillment of this requirement of Supplement I to NUREG-0737.
- 8. Coordination of the DCRDR With Other Improvement Programs The NRC audit team concluded from its findings that, although Davis-Besse's organizational structure should enhance TED's ability to coordinate improvement programs, there was no evidence that any coordination had
! occurred other than the use of E0Ps as the basis of the SFTA. A systematic approach to integrate the improvement programs had not been established. In the meeting. TED cited its ability to coordinate the improvement programs i
through its organizational structure and the FCR process. However, the f 11
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- - actual points of integration or interfaces and the iterative processes among the improvement programs appeared to be uncertain. ,
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ll In the COA, TED describes the points of integration of varipus improve- !! ment programs in what could be called loosely a coordinated program. The improvement programs referred to are DCRDR, E0P upgrade, SPDS, and training. il The mechanism in common to changes from these programs is the Facility Change
!I Request (FCR) process. TED's discussion of the points of integration within
- ' these programs and processing of changes through the FCR process demonstrates its knowledge and capability of performing the coordinating function - with
- l one exception - the integration of the Reg. Guide 1.97 instrumentation
- 3 d review. Prior to initiation of the DCRDR, TED did provide the following i discussion of the Reg. Guide 1.97 review in its letter dated April 15, 1983
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- (Reference 5) in response to Generic Letter 82-33:
- "This initiative will be integrated with the DCRDR such
- that methods utilized during the DCRDR to perform system j function reyiews and task analysis will also be utilized .
] for identifying TYPE A variables as part of the Reg. Guide 1.97 review. In addition, the results of the Reg.
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Guide 1.97 review will be factored into ongoing E0P ] development, the control room inventory portion of the il DCRDR and SPDS design." l However, TED presents no explicit discussion in the C0A of the the status and , integration of the results of this review with the other improvement programs. In order for the NRC to close out this requirement of Supplement 1 lI to NUREG-D737. TED needs to provide documentation describing the status and _ . ! integration of the results of the Reg. Guide 1.97 review with the other improvement programs. i SL* MARY AND CONCLUSIONS e TED has addressed all of the concerns identified in the pre-implemen-tation audit report relative to DCRDR requirements. In addition, TED has updated operator comment forms, has ensured all HEDs identified in the
- operator forms are documented, and is establishing human factors standards L 12 w -g-wi ,--e rww-+---g-- yp ey-r w w - 'v*Tv79N---"W*vWNv-WNet-g M -n'---@ -
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1 and conventions for some aspects of the Davis-Besse control room design. Based on the documentation provided in the COA, TED has committed to the f
! following milestones: .. ,y
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! e Completed during current outage:
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- Implementation of corrections to safety-significant HEDs associated with SFRCS. FW, and PAM e Completed during current outage o_r fifth refueling stage (expected in 1986/87):
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- Implementation of corrections to HEDs categorized as high or medium safety significant in the January 1985 supplementary letter ,
- Upgrade of task analysis, survey of new control room compo-nents, and reassessment of HEDs
- Completion of special studies
- Implementation in the control room of standards for labels and location aids e Completed during sixth refueling outage (expected in 1988) o_r, will be defined in FCR packages for implementation according to the Integrated Living Schedule:
- Implementation of corrections to HEDs categorized as low safety significant in the January 1985 supplementary letter 1
- Implementation of all other HED corrections 1 J M
$ - Completion of the DCRDR , With the exception of the implementation of corrections to the low safety-significant HEDs, these milestones appear to be the same as those discussed I with TED in the meeting. In the meeting, TED appeared to indicate that those i 13
i' particular HED corrections would be implemented by the end of the fifth refueling outage. .
.y Based on discussion with TED in the meeting and a review tf its COA, 1 . NRC conclusions on the status of TED's compliance with the requirements of !
Supplement I to NUREG-0737 and the remaining action items for TED are presented below for each element of the DCRDR requirements.
. 1. Qualifications and Structure of the DCRDR Team
$ TED's commitment to human factors participation in the DCRDR
. satisfies the concerns of the NRC and will meet this requirement. ,
t
- 2. Function and Task Analysis
- f. TED's SFTA upgrade approach will satisfy the NRC's previous con-cerns. The NRC will conclude on the adequacy of the SFTA performed
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to satisfy DCRDR requirements after TED receives NRC approval of the SFTA performed to develop the plant-specific E0Ps. i
- 3. Comparison of Display and Control Requirements With a Control Room Inventory TED's verification approach will satisfy the NRC's previous con-cerns. However, the adequacy of the verification process will be dependent on the adequacy of the SFTA relative to the upgraded plant-specific E0Ps.
f . i 4. Control Room Survey TED's additional survey activities will satisfy the concerns of the NRC and will meet this requirement. e
- 5. Assessment of HEDs ,
TED's additional HED assessment activities will satisfy the con-cerns of the NRC and will meet this requirement. In order to close 14 i
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out this requirement. TED needs to identify by HED number which HEDs are to be corrected in the current outage. t
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- 6. Selection of Design Improvements
TED has satisfactorily demonstrated the capability for considering cumulative and interactive effects of individual HEDs. In order to progress towards the resolution of NRC concerns and to close out this requirement. TED needs to provide the following documentation: 4 - e The work plans for the special studies (except for the SFRCS panel) . e Several sample HEDs which demonstrate the upgrading of HED documentation (e.g., examples of "before and after"). e All the proposed corrections to HEDs, including those to be performed during the current outage and afterwards. , e Justifications to all those HEDs not corrected or partially corrected. e An implementation schedule for each HED correction, including the rationale for schedule dalays beyond the sixth refueling outage. i
- 7. Verification That Improvements Will Provide the Necessary Corrections Without Introducing New HEDs TED's implementation of the HED correction verification approach described in the C0A will satisfy the concerns of the NRC and will meet this requirement.
- 8. Coordination of the DCRDR With Other Improvement Programs TED's discussion of the points of integration within these programs and processing of changes through the FCR process demonstrated its kno'wledge and capability of performing the coordination function.
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' In order to close out this requirement, TED needs to provide docu-l mentation describing the status and integration of the results of j the Reg. Guide 1.97 review with the other improvement programs.
.. , .4--
j In summary, in order to complete NRC~ review of the Davis 4 esse DCRDR
~ ; and conclude on the adequacy of TED's plans for upgrading instruments, j controls, and equipment in the control room, TED needs to provide the docu-mentation described above. TED's methodology for resolving the human
! factors deficiencies related to the operator interface associated with the June 9,1985 event (e.g., SFRCS) is acceptable to the NRC if implemented as 1, described in the C0A. j .. o I ) } } l ) _
- e e
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t REFERENCES
- 1. " Appendix C.5.1 Specific Actions 1telated To Control Rocheficien-
! cies," Appendix to Revision 4 to the Davis-Besse Course of Action (C0A), attachment to letter from J. Williams, Jr., TED, to H.R. Denton, USNRC, dated November 16, 1985. ? 4 l
- 2. " Pre-Implementation Audit of the Detailed Control Room Design Review of f f
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the Davis-Besse Nuclear Power Station," attachment to memorandum from W.H. Regan, Jr., USNRC, to W.T. Russell, USNRC, dated June 18, 1985. l l t 3. ,", Minutes of NRC Meeting with Toledo Edison Concerning the Detailed
! Control Room Design Review of Davis-Besse Nuclear Power Station "
attachment to memorandum from W.H. Regan, Jr., USNRC, to J.F. Stolz, USNRC, dated November 8,1985. l
. 4. " Supplement 1 to NUREG-0737 Detailed Control Room Design Review Imple-mentation Schedule," attachment to letter from R.P. Crouse, TED, to J.F. ,I Stolz, USNRC, dated January 31, 1985.
f
- 5. " Response to Supplement No.1 to NUREG-0737 Requirements for Emergency Response Capability (Generic Letter No. 82-33)," attachment to letter from R.P. Crouse. TED, to D.G. Eisenhut USNRC, dated April 15, 1983.
- 6. NUREG-0737. Supplement 1. " Requirements for Emergency Response Capa-bility," USNRC, Washington, D.C., December 1982, transmitted to reactor ;
licensees via Generic Letter 82-33, December 17, 1982.
- 7. NUREG-0700, " Guidelines for Control Room Design Reviews," USNRC, Washington, D.C., September 1981. l l
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Davis-Besse Tac No. 51154 - - SAIC/1-263-07-557-16 Contract No. NRC-03-82-096 17
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