ML20028G282

Response to Applicant 820121 Motion for Dismissal of Contention Ivb.Human Factors Design Evaluation Rept, Submitted as Final Detailed Control Room Design Review Rept, Inadequate Per NUREG-0700,Section 5.2.W/Certificate of Svc

ML20028G282
Person / Time
Site:	Harris
Issue date:	02/02/1983
From:	Wilson R WILSON, R.
To:	Atomic Safety and Licensing Board Panel
References
RTR-NUREG-0700, RTR-NUREG-700 ISSUANCES-OL, NUDOCS 8302070590
Download: ML20028G282 (4)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'83 FEB .i NO:37

. ATOMIC SAFETY AND I.ICENSING 110ARD BEFORE ADMINISTRATIVE JUDGES ,

Glenn O. Bright il'"

Dr. James 11. Carpenter James L. Kelley, Chairman In the Matter of 8 CAROLINA POWER f. LICllT COMPANY Docket Nos. 50-400 OL AND NORTil CAROLINA MUNICIPAL POWER 50-401 OL AGENCY No. 3 (Shearon liarris Nuclear Power Plant, Units 1 and 2)

RESPONSE TO APPLICANTS MOTION FOR DISMISSAL OF WILSON CONTENTION IVil In its document entitled Applicants' Response to Intervenor Wilson's Response to Iluman Factors Design Evaluation Report For The Shearon liarris I Control Room, dated January 21, 1982, at 2, the applicants move for dismissal of my content ion IVil on the trounds that. I did not submit any speelfic conten-t ions based on t hat document.

When i submitted my rerponse to the iluman Factors Design Evaluation Report I assumed that it was related to the Detailed Control Room Deuign Review process, but I did ne'. realize that it was the tinal DCDR Report. The AppI! cants' re-sponse to my response now makes it clear that it is t he final, formal DCDR Report.

My confusion was based on the following points:

1. The report submitted by the Applicants was not explicitly titled DCDR Report. No reference in the cover letter or the body of the document was made to NUREC 0700. The report does not follow the format recommended in NUREG 0700.

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2. The report submitted by the Applicants falls short of the standards set forth,in NUREC 0700 in so many ways { sed below) that I did not recognize it as a document intended to meet those standards.

j For these reasons I did not understand, and could not have been expected to understand, that the report submitted by the Applicantu on Dec. 7 was in-tended to be the Detailed Control Room Design Review Report described in Sec-tion 5.2 of NUREG 0700.

Now that 1 do understand their intent, I am submitting on a timely Lauls the following contention baued on the document entitled lluman Factors Design Evaluation Report for the Shearon liarris Unit 1 Control Room, submitted Decem-ber 7, 1982, which the Applicantu intend to serve as the DCDR Report WILSON V The DCDR Report is inadequate to fulfill the specifications and the intent of NUREG 0700.

1. The DCDR Report does not identify the human engineering diacrepancies (llED's) which were revealed by the review process. (Ident.ification is required by NUREG 0700 Section 5.2.)

2. The DCDR Report does not identify proposed or implemented colutions to identified discrepancies with potential safety consequences. The assessment process used to select design solutions is not sunmia r ized .

(Requirements of NUREG 0700 Section 5.2)

3. The DCDR Report does not describe the schedules for implementation of proposed solutions to discrepancies. (Requirements of NUREG 0700, Section 5.2.)

3-4 The DCDR Report does not presant a follow-up plan to verify that the propos'ed solutions do provide adequate solutions to the. human engineering discrepancies that they are intended to address.

(Requirement of NUREG 0700, Section 5.2.)

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5. Although not specifically required by NUREG 0700, a list of the 17 Iluman Engineering Requirements Specifications written by the review team is provided in Section 2 of their report. There seems 4

to be no mechanism in the NRC review process (NUREG 0801) to insure that these llER's,(as opposed to llED's) are adhered to. These llER's

, are a unique and important set of observations and opinions, arising out of an in-depth study of the control and monitoring systems of the Shearon liarris facilities. In the interest of developing a complete record, the llER's written by the review team should be included in their entirety in the DCDR Report.

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UNITED STATES OF AMERICA .

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! In the matter of CAROLID6VliR 6 LICilRO. Et al. ) Dockets 50 400 Shearon llarris Nuclear Power Plant, Units 1 and 2 ) and 50 401 0.L.

CERTIFICAT OF SERVICE I hereby certify that copies of RESPONSE TO APPLICANTS MOTION FOR DISMISSAL OF WILSON CONTENTION IVB' IIAVE Been served this 2nd day of February 198 3 , by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are marked with an asterick, for whom service was accomplished by Judges James Kelley, Glen Bright and James Carpenter (1 copy each)

Atomic Safety and Licensing Board US Nuclear Regulatory Commission W shington, DC 20555 George F. Trowbridge (attorney for Applicants) Wells lildleman Shaw, Pittman, Potts, & Trowbridge 718-A Iredell St.

1800 M. St. NW Durham, NC 27705 Washington, DC 20036 Phyllis Lotchin, Ph.D.

Office of the Executive Legal Director 108 Bridle Run Attn IMckets 50-400/4 01 0. L. Chapel 11111, NC 27514 USNRC Washington, DC 20555 Dan Read CllANCE/ELP Office of the Secretary Box 524 Docketing and Service dLation Chapel 11111, NC 27514 Attn Dockets 50-400/401 0.L.

USNRC Pat 6 Slater Newman Washington, DC 20555 (3 copies) CANP 2309 Weymouth Court John Runkle Raleigh, NC 27612 CCNC 307 Cranville Rd.

Chapel 11111, NC 27514 Travis Payne Edelstein & Payne Certified by

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Box 12643 Raleigh, N.C. 27605 1

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