ML20205E803

Responds to 850830 Concerns Re Suggestion in Author to Util That Util Should Consider Licensing Facility Control Room Design on Preliminary Design Analysis,As Opposed to Dcrdr Basis

ML20205E803
Person / Time
Site:	Perry
Issue date:	10/11/1985
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
References
NUDOCS 8510170477
Download: ML20205E803 (4)

Text

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• ' o3 UNITED STATES 3 NUCLEAR REGULATORY COMMISSION

$ n$ WASHINGTON, D. C. 20555

• • • • • • • M5 OCT 11 -

Docket No.: 50-440 Ms. Susan L. Hiatt OCRE Representative 8275 Munson Road Mentor, Ohio 44060

Dear Ms. Hiatt:

This is in response to your letter dated August 30, 1985, in which you expressed a concern regarding the suggestion made in my letter to the Cleveland Electric Illuminating Company (CEICO) dated August 26, 1985, that CEICO should consider licensing Perry Unit I control room design on a Preliminary Design Analysis or PDA basis, as opposed to CEIC0's intent to license on a Detailed Control Room Design Review or DCRDR basis.

made which I believe summarizes the essence of your concern as follows 1.

_Less stringent basis for licensing encouraged to avoid licensing delays -

paragraph 2, line 5 of your letter Two issues are involved. They are:

a.

Licensing on the basis of a Preliminary Design Assessment versus a Detailed Control Room Design Review n b.

Correction of Human Engineering Discrepancies (HEDs) per commitment With respect to the first issue, the actions which must be taken for close-out of the Perry DCRDR are identified in the staff's evaluation report enclosed with my letter to CEICO dated August 26, 1985. Each action involves completion of an activity already well underway. CEICO must negotiate a schedule for completion of those actions if it elects to receive a license on the basis of a PDA. The staff will assure that safety is a key issue in any such negotiation.

to low power licensing. Sofae actions would be required to be completed prior Others would be required to be completed prior to full power licensing or prior to start-ur Or the second operating cycle depending upon their safety significan%

CEICO agrees to take. id upon interim measures that License cond M B q ould be developed to assure each activity is completed on schedule t R ld be noted that, in the staff's experience, some DCRDR activities 2.e W . completed after licensing. For example, accurate environmental surveys (heat, humidity, noise, and light) cannot be completed until the control rcom is free of construction and test activities.

have been at Perry) and final surveys are takenThe after final licensin surveys have typically been confirmatory, but utilities are required to ancies within a reasonable time. assess discrepancies from accepted guid 8510170477 851011 DR ADOCK 050 0

Ms. Susan L. Hiatt I i

With respect to the second issue, satis' faction of CEICO's commitments fo correction of HEDs is a key issue in licensing regardless of whether that licensing is on the basis of a DCRDR or a PDA.

CEICo has comitted to DCRDR Sumary Report prior to low power Thus, notlicensing.

only will a correc 10, 1985 of the actions necessary to correct problems identi also be complete.

4 In sumary, the staff's review indicates that, given the extent of DCRDR i

' completion and CEICO's comitments for correction of HEDs, certain DCRDR actions might reasonably extend beyond licensing.

1 might, in the staff's judgment, be more appropriate after licensing.In My fac suggestion concerning a PDA was designed to assure that CEICO take a real-

, istic look at the schedule for completing the Perry DCRDR. You may be 4

- assured that licensing than licensing onofthe on the basis basis of a PDA would not be less stringent a DCRDR.

i In either case, commitments for i "~ correction to low of HEDs would have to be satisfied (about 90% corrected prior cycle). power licensing and the remainder prior to start-up for the second 2.

Licensing on a PDA basis may result in a temporary decline in safety due to tne need for control room modifications and the associated

-_for plant operating personnel to relearn maintenance and operating procedures of your letter (i.e., " negative transfer of training") Paragraph 3. Line 1 The staff understands your concern and has an appreciation for the cond

under which the problem occur. As noted above, corrections for over 300 licensHEDsing. arising from the DCRDR must be completed prior to low power minimal by the time power operation begins. Transfer of training ef Certain HEDs may not be iden-

' tifiable prior to power operation.

i (as discussed above) are an example, but correction of environme i should not expected. require relearning and thus no negative transfer of training is The continuing DCRDR at Perry may identify a few new HEDs not related to environmental conditions. CEICO is required to provide a schedule for correcting any new HEDs or a justificat them.

review, be found reasonable and acceptable.

determining cases where HED correction might result in neCEICO will be respons training, and for developing means to combat those cases.gative transfer However, cor- of relearning.rection of many types of HEDs other than environmental HEDs ;

i i

Again, no ne(e.g., corrections which improve consistency in the control roo gative transfer of ~ training is expected.

3 of correcting such HEDs is a reduced probability of operator error and aThe im consequent improvement in safety.

3.

Taregraph 4. Line 2 of your letterThere is no valid reason to defer reso As noted in the discussions above, the staff has found that certain DCRDR and test activities (i.e., typically after full power The licensi example cited was completion of environmental surveys, but other possibil-

Ms. Susan L. Hiatt OCT11 1985 ities do exist. In cases where a DCRDR activity is to extend beyond licen-sing the staff requires interim activities prior to low power licensing.

Given completion of that interim activity, correction of safety significant HEDs, and commitment to a reasonable schedule for completing the activity, there is frequently little reason to delay licensing. In the case of Perry, the staff believes that it may be reasonable to continue some DCRDR activi-ties beyond licensing. If such a schedule is requested and justified by CEICO, completion of some DCRDR activities will be addressed by license con-ditions. The possible deferral of DCRDR completion does not negate the value of the review already completed, nor does it negate CEICO's commitment to correct over 300 HEDs prior to low power licensing. The possible deferral does, however, recognize that some DCRDR activities are iterative and that the final iteration might best be perfonned at a date which follows licensing.

I hope that this response will allay your concerns regarding the Perry control room design review process.

Sincerely, I % sic:;zog7, Olsw B.J.nYoungblood,- Chief S Licensing Branch No. 1 Division of Licensing cc: See next page DISTR"BUTION:

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OCT 11 1985 Mr. Murray R. Edelman The Cleveland Electric Perry Nuclear Power Plant Illuminating Company .

Units 1 and 2 cc:

Jay Silberg, Esq.

~

Shaw, Pittman, & Trowbridge Mr. Larry 0. Beck 1800 M Street, N. W. The Cleveland Electric Washington, D. C. 20006 Illuminating Company P. O. Box 97 E-210 7 Perry, Ohio 44081 Donald H. Hauser, Esq.

The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 Resident Inspector's Office U. S. Nuclear Regulatory Connission Pannly at Center Road

_ _._ Perry, Ohio 44081 Regional Administrator, Region III U. S. Nuclear Regulatory Commission

- 799 Roosevelt Road Glen Ellyn, Illinois 60137 Donald T. Ezzone, Esq.

Assistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Ohio 44077 Ms. Sue Hiatt o OCRE Interim Repr,esentative 8275 Munson Mentor, Ohio 44060 Terry J. Lodge, Esq.

618 N. Michigan Street Suite 105 Toledo, Ohio 43624 John G. Cardinal, Esq.

Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047