NRC-93-0106, Responds to NRC 930722 Request for Identification of Any Priority III Heds Which Were Evaluated & Dispositioned Differently from Heds Identified in Dcrdr Summary Rept & Two Suppls

Responds to NRC 930722 Request for Identification of Any Priority III Heds Which Were Evaluated & Dispositioned Differently from Heds Identified in Dcrdr Summary Rept & Two Suppls

ML20056F840
Person / Time
Site:	Fermi
Issue date:	08/27/1993
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-93-0106, CON-NRC-93-106 TAC-M86938, NUDOCS 9308310193
Download: ML20056F840 (2)

Text

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Dowglas Ft. Gipson Senca ', ce Premde nt f

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August 27, 1993 NRC-93-0106 U. S. Nuclear Regulatory Commission i Attn: Document Control Desk Washington, D. C. 20555 l

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) NRC letter dated July 22, 1993

Subject:

Detailed Control Room Design Review (DCRDR) t Priority III Human Engineering Discrepancies (HEDs)

(TAC No. M86938)

This letter is in response to your Reference 2 request that Detroit Edison identify any Priority III Human Engineering Discrepancies  ;

(HEDs) which were evaluated and dispositioned differently from the HEDs identified in our Detailed Control Room Design Review (DCRDR)  !

Summary Report and its two supplements. The final HED dispositions I with the associated t.echnical bases were also requested. Our response was requested within 30 days of receipt of Reference 2, which is ,

August 28, 1993 j We have found it impractical to provide the requested information within the desired time frame. Instead, wc wish to propose an alternative course of action. I l

We believe the purpose of the Reference 2 request was to allow the NRC l i

staff an opportunity to assess changes in t.he disposition of HEDs between what,was submitted by Detroit Edison in 1986-87 (and subsequently approved by t,he NRC in March 1990) and what was finally ,

implemented. j Thi .abmitted DCRDR program indicated that HEDs were considered living documents and subject to change based upon continued review and i analyses of the Fermi 2 Control Room and other HEDs. As such, Detroit 1 Edison continued the evaluation process from the DCRDR submittal ]

through t.he final implement,ation of Priority III HEDs. These i evaluations were performed by a team of engineering and operations representatives augmented by a human factors consultant. These evaluations were well documented.

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As a result of this continuing evaluation a substantial fraction of the Priority III HEDs were in some way revised over the nearly six year period. These revisions vary from the strictly editorial to a small number of HEDs which were re-categorized as Priority IV.

Because of the extent of these revisions, we believe the most effective method for the NRC staff to resolve their concerns is to  ;

examine the DCRDR documentation files here at Fermi 2. Alternatively, we would be glad to meet with the NRC staff in Rockville to discuss their concerns and review representative changes in HED dispositions.

The cover letter to the NRC's March 28, 1990 Safety Evaluation of the i DCRDR program indicated that disposition of HEDs other than described in the DCRDR or its supplements would require full documentation and >

NRC review and approval. This statement was noted and thought to be l' Informally resolved with the NRC staff at that time. Since the NRC-approved DCRDR program contained the provisions to revise HEDs, it was felt that HED revisions in accordance with the program would not require NRC approval.

In any case, we are confident that the goals of the Ferni 2 DCRDR program have been met and are willing to take the necessary actions to provide assurance of the same to the NRC staff. If you have any questions, please contact Mr. Glen D. Ohlemacher at (313) 586-4275. i Sincerely, 1

J f' 2 17 cc: T. G. Colburn -

W. J. Kropp J. B. Martin

,[ D M. P. Phillips l

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