View source for A04135, Advises That Due Date for Submittal of Crdr Summary Rept, Including Schedule for Resolutions of Human Engineering Discrepancies,Postponed from 890228 to 891030 Due to Commitment to Implement New Emergency Operating Procedures

{{Adams
| number = ML20235U031
| issue date = 02/28/1989
| title = Advises That Due Date for Submittal of Crdr Summary Rept, Including Schedule for Resolutions of Human Engineering Discrepancies,Postponed from 890228 to 891030 Due to Commitment to Implement New Emergency Operating Procedures
| author name = Mroczka E, Sears C
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000245
| license number = 
| contact person = 
| case reference number = RTR-NUREG-0737, RTR-NUREG-737
| document report number = A04135, A4135, NUDOCS 8903090026
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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[om .,"1.ans     m                                         HARTFORD, CONNECTICUT 06141-0270 k    k   J           .       e.co. cow ,                                 (203) 665-5000 February 28, 1989 Docket No. 50-245 A04135 Re: NUREG-0737, Supplement 1 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Millstone Nuclear Power Station, Unit No. I Supplement I to NUREG-0737 Control Room Desian Review Summary Report The purpose of this letter is to revise the due date from February 28, 1989, to October 30, 1989, for submittal to the Staff of the Control Room Design Review (CRDR) Summary Report, including a schedule for resolutions of Human Engineering Discrepancies (HEDs), for Millstone Unit No.1. It is our under-standing, based on discussions with NRC Staff, that this requested extension is acceptable.
The Summary Report could have been submitted as originally scheduled on February 28, 1989, but this wouggve resulted in a partial report. In light of the NRC Staff's preference                          to extend the due date for the entire Summary Report to prevent receipt of information in a piecemeal manner, we have discussed with the NRC Staff the appropriateness of extending in part or total the February 28, 1989, CRDR Summary Report submittal date.
Backaround In a {{letter dated|date=June 12, 1984|text=letter dated June 12, 1984}},(3) the NRC Staff issued an Order confirming various commitments made by Northeast Nuclear Energy Company (NNECO) on behalf of Millstone Unit No. I regarding the implementation of Supplement I to NUREG-0737.            This Order required the submittal by March 2,1987 of the CRDR program plan, and a schedule for the submittal of the CRDR Summary Report.
(1)    E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Control Room Design Review, Revision to Confirmatory Order," dated January 29, 1988.
(2)   S. A. Varga letter to E. J. Mroczka, " Modifications of Commission's Order dated July 2, 1986 Confirming Completion of the Detailed Control Room Design Review (TAC No. 56128)," dated February 25, 1988.
(3)    D. M. Crutchfield letter to W. G. Counsil, " Orders Confirming Licensee Commitments on Emergency Response Capability (Generic Letter 82-33, NUREG-0737)," dated June 12, 1984.
8903090026 890228                                                                                       '\
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l U.S. Nuclear Regulatory Commission A04135/Page 2 February 28, 1989 Accordingly, in a {{letter dated|date=March 2, 1987|text=letter dated March 2, 1987}},(4) NNEC0 forwarded the Implemen-tation Plan for Millstone Unit No.1.
In that submittal, NNECO committed to submit the CRDR Summary Report for Millstone Unit No.1 by February 28, 1989. NNEC0 wishes to extend this due date to October 30, 1989 for the following reasons. The NRC Staff conducted an audit of Millstone Unit No.1 Emergency Operating Procedures (EOPs) in June 1988, including detailed technical review and procedure walkthroughs. Based on that audit, NNECO committed to implement new E0Ps based on Revision 4 of the BWR Owners' Group (BWR0G) Emergency Procedure Guidelines (EPGs) by September 1,    1989 or three months after the 1989 refuel outage (curren estimatedtooccurfromApril1,1989toMay1989),whicheveroccurslater.gy Later,followingrecgigtoftheNRCStaffE0PInspectionwrittenreport, September 23,              NNE00 submitted the required 30-day response,dated dated 19' October 28, 1988. g Contained within the summary section of that responso, we reiterated our Revision 4 E0P implementation pursuit, acknowledged NRC Staff s desire for earlier implementation, and announced the effort to " pursue a coal of implementing Revision 4 E0Ps by start-up from the 1989 refueling outage."
We then emphasized several factors that could delay the implementation of our Revision 4 E0Ps.
Although NNECO had attempted to implement the Revision 4 E0Ps by start-up from the 1989 refueling outage, we now believe that training of personnel will best be accomplished if the implementation is scheduled for 3 months after start-up or September 1,1989, whichever occurs later. We understand the Staff finds this approach acceptable.
Planned deviations from Revision 4 to the BWROG EPGs are scheduled to be prepared in March of 1989. NNEC0 believes it would be advantageous to meet with the Staff to discuss these planned deviations during the month of April 1989. This meeting would, hopefully, resolve all Staff concerns to preclude CRDR Summary Report submittal schedule impact. Significant Staff concerns would almost certainly cause further delays in the schedule for CRDR Summary Report submittal.
(4) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Supplement I to NUREG-0737, Control Room Design Review Implementation Plan," dated March 2, 1987.
(5) L. H. Bettenhausen letter to E. J. Mroczka, " Resident Inspection 50-245/
88-25," dated February 2, 1989.
(6) S. A. Varga letter to      E. J. Mroczka, " Emergency Operating Procedures                                                         ;
Inspection (Inspection Report 50-245/88200)," dated September 23, 1988.
(7) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Millstone Nuclear Power Station, Unit No.1 Emergency Operating Procedures," dated October 28, 1988.

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l U.S. Nuclear Regulatory Commission A04135/Page 3
         ' February 28, 1989 The ittegral relationship between the Revision 4 E0Ps, the verification and validation efforts, the CRDR task analysis, and the correction of HEDs was identified and discussed in the Millstone Unit No. I tegrated Safety Assess-ment Program (ISAP) report, dated November 9,1988               The task analysis of the CRDR has been preliminarily conducted based on the draft Revision 4 version of the E0Ps. But the time necessary to develop approved Revision 4 E0Ps has resulted in the need to extend the due date of the CRDR Summary Report beyond the February 28, 1989 due date.          This potential was previously identified to NRC Staff, wholly or in part, in our July 29, 1988, October 28, 1988, and {{letter dated|date=November 9, 1988|text=November 9, 1988 letter}}s.
Once the CRDR is complete, the proposed resolutions for all HEDs will be                                    I evaluated in ISAP, and the schedule for correction will be established in the Integrated Implementation Schedule (IIS). Accordingly, to allow time to finalize Revision 4 to the E0Ps (currently scheduled to be completed in May 1989) for operator training, complete the CRDR based upon these finalized E0Ps, identify HED resolutions, and schedule those resolutions in the IIS via ISAP, the submittal date for the Millstone Unit No.1 CRDR Summary Report, including the proposed schedule for HED corrections, is being extended to October 30, 1989.
Based upon discussions with the NRC Staff, it is our understanding that this deferral of the CRDR Summary Report submittal is acceptable to the NRC Staff.
We will proceed on that understanding unless informed otherwise by the Staff.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY.
E , d i bacr E. J. Mroczka Senior Vice President                                             I WL By:   C. F. Sears Vice President cc:   W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos.1, ?, and 3 L. Kolownauski, Resident Inspector, Millstone Unit No.1 (8)  E. J. Mroczka letter to U.S. Nuclear Regulatory Commis,sion, " Millstone Nuclear Power Station, Unit No.1 Integrated Safety Assessment Program (ISAP)," dated November 9, 1988.
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