ML20205A824

Forwards Line-By-Line Evaluation/Response to NRC Staff Review of Clinton Power Station Detailed Control Room Design Review Program, Per Comments During 850228 Meeting

ML20205A824
Person / Time
Site:	Clinton
Issue date:	04/24/1985
From:	Spangenberg F ILLINOIS POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML20205A825	List: ML20205A824 ML20205A827
References
RTR-NUREG-0737, RTR-NUREG-737 U-0817, U-817, NUDOCS 8504260122
Download: ML20205A824 (3)

Text

o . U-0817 L30-85(04-24)-L 1A.120 ILLINO/S POWER COMPANY IP CLINTON POWER STATION. P.o. BOX 678, CLINTON. ILLINOIS 61727 April 24, 1985 Docket No. 50-461 Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555 Subj ect: Clinton Power Station Unit #1 Responses to NRC Staff Review Comments on the Detailed Control Room Design Review (DCRDR)

Dear Mr. Schwencer:

Illinois Power (IP) Letter U-0741, dated September 28, 1984, provided the CPS Detailed Control Room Design Review (DCRDR) Program Plan to the Staff. As a result of the Staff's evaluation, comments on the DCRDR Program Plan were provided to IP by letter dated January 9, 1985. A meeting was held on February 27, 1985, in Bethesda, MD between the NRC and Illinois Power to discuss the Staff's comments. The NRC meeting summary letter, dated March 6, 1985, notes that IP's presentation addressed all of the Staff's concerns.

During this meeting, IP committed to provide the following information:

1. A description, in the DCRDR Summary Report, of any review method-ologies used that differ from those described in the DCRDR Program Plan;

2. Inclusion in the DCRDR Summary Report of a more thorough description of how information and control requirements and associated control and display characteristics were identified independent of the existing control room design;

3. Line-by-line evaluation responses to the NRC Staff's comments on the ,

DCRDR Program Plan; and

4. A list of the Selected Operating Events (SOEs) to be used in the System Function and Task Analysis (SFTA).

In addition, subsequent to the 2/27/85 NRC/IP meeting, a telecon with Ann Ramey-Smith (NRC/HFEB) indicated that the Staff's interpretation of NUREG-0737 Supplement #1 would require the SFTA to include an evaluation of all operator tasks / actions during emergency operations of the plant. That is, if a system is used during emergency operations, the operator tasks associated with the use of that system should be analyzed. .

Items 1 & 2 will be addressed in the DCRDR Summary Report, as governed by the Emergency Response Capability Implementation Program (ERCIP), and as such, are not further addressed in this letter. Item 3 is attached, entitled "Line-by-line Evaluation / Response to NRC Staff Review of the CPS Detailed 8504260122 850424 PDR ADOCK 05000461 ppg F PDR

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Control Room Design Review (DCRDR) Program Plan". This response is thorough and references applicable material from the 2/27/85 NRC/IP meeting on the

,DCRDR Program Plan. Item #4 (List of SOEs) is affected by the Staff's position on task analysis including all operator tasks during emergency operations. The increased. scope affects the number of SOEs required and the criteria for their selection. IP commits to perform the following scope on

-operator task analysis during emergency operations:

1. The SOEs will be chosen to ensure that a system function and task analysis is performed on all operator tasks during emergency operations;

2. The task analysis will cover those sections of all Emergency Operating Procedures (EOP) - referenced plant procedures . (System Operating Procedures and Off-Normal Procedures) as required for the SOEs;

3. Once a particular section of an operating procedure is tasked-out for one SOE, it will not be re-tasked if referred to in another SOE; and

4. If different sections of the same E0P-referenced procedure are identified in different SOEs, each of these sections will be tasked-out as they apply to the specific SOE and the assumptions of the SOE.

'The SOEs to be used in the task analysis portion of the DCRDR are developed

- through the process described on page 3-17 of the DCRDR Program Plan. A list of the SOEs to be used will be submitted to the Staff by the end of April, 1985.

As a result of the staff's expanded SFTA requirements a course of action was established in order to increase program efficiency and maintain a reasonable schedule while still fulfilling the NRC's requirements. The course of action for the SFTA activities is summarized as follows (tasking of E0Ps is currently on-going):

1. Identify SOEs/SOE flow paths thru E0Ps.

2. Determine the applicable sections of all the E0P-referenced Operating Procedures (ops) to perform emergency tasks.

3a. Continue " tasking" of E0Ps identifying information and control needs.

3b. " Task out" applicable sections of ops identifying information and control needs.

4. Merge the results of 3a and 3b in the data base to produce the

" tasked-out" SOEs.

5. Identify Control Room devices to accomplish task / steps.

6. Compare "needed vs. existing" information and control needs.

7. Verify instruments for E0Ps and SOEs.

8. Address / resolve E0P and SOE instrument discrepancies.

9. Complete Verification and Validation activities.

s This action plan differs somewhat from the plan discussed with the NRC on February 27, 1985, in the following three areas:

1. The E0Ps will now be tasked out in parallel with appropriate sections of the referenced ops (steps 3a and 3b);

2. E0P discrepancies will be resolved along with any additional SOE discrepancies after completion of the SFTA activities; and

3. Identification of Control Room devices to accomplish task / steps will now be done once, af ter E0P and SOE tasking is complete.

The staff's primary requirements of " independence from the Control Room" and

" addressing all emergency operations tasks" are still being satisfied with this course of action.

Due to the increase in scope of the SFTA activities and estimated completion time of properly documenting these activities, it is anticipated that the results of the validation activities for the E0Ps and the DCRDR along with some Control Room Survey items (e.g. lighting, communication, HVAC) will not be incorporated into the summary report to be submitted to the Staff in July 1985. The results of these activities will be addressed in a supplemental report to the Staff, scheduled for September 1985. The July report will contain the results of the Operating Experience Review (OER),

Control Room Survey (CRS), Control Room Inventory (CRI), SFTA data sheets / methodology, verification results of the SFTA, and the evaluation, resolution, and implementation schedule for any Human Engineering Discrepancies identified in the OER, CRS, and SFTA. The contents of this July report will still allow the Staff to carry on with their evaluation of the CPS DCRDR as previously scheduled and the September supplement will allow IP the time necessary to meet the Staff's requirements.

If you should have any remaining concerns regarding the line-by-line evaluations / responses attached or the course of action we are taking for the SFTA activites, please contact me.

Sincerely yours,

/ A s.N, -

F. A. Sp ge erg, Director - Nuclear icensing l

and Configuration Nuclear Station Engineering TLR/ lab t

Attachment l cc: B. L. Siegel, NRC Clinton Licensing Project Manager i

NRC Resident Office Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety t

t