ML041100741
| ML041100741 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/09/2004 |
| From: | Tennessee Valley Authority |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| FOIA/PA-2003-0358, OPL273C0202, Revision 0 | |
| Download: ML041100741 (2) | |
Text
IV OPL273C0202 Revision 0 Page 1 of 19 SEQUOYAH NUCLEAR PLANT NUCLEAR TRAINING TRAINING MATERIALS COVERSHEET OPERATOR TRAINING - LICENSED PROGRAM LICENSED OPERATOR REQUALIFICATION OPL273 COURSE COURSE NO.
APPENDIX R FIRES (AOP-N.01. AOP-N.08, AOP-C.04)
OPL273C0202 LESSON TITLE LESSON PLAN NO.
INPO ACCREDITED YES X
NO MULTIPLE SITES AFFECTED YES NO X
PREPARED BY Lacy Pauley Signature, Date PROCESS REVIEW Gale Blount Signature
/
Date LEAD INSTRUCTOR/PROGRAM MGR. REVIEW -
Mark Lackey Signature
/
Date PLANT CONCURRENCE Kevin Wilkes Signatuie
/
Date TVAN CONCURRENCE (If applicable)
Signature I
Date Receipt Inspection and Distribution:
Standardized Training Material Copies to:
TVA 40385 [NP 6-20011 Page 1 of 2 Training Materials Coordinator
/
Date
1'
- 5. Regulatory concerns.
Appendix R DOES NOT offer manual actions as an acceptable alternative to comply with the separation requirement of Section III.G.2 of Appendix R.
Supplementary guidance to GL-81-12 DOES allow manual actions for associated circuit resolution for Alternative Shutdown.
During the Appendix R initial review process, NRC approved, via deviation and exemption process, specific manual actions at most utilities on a case by case basis.
Generic Letter GL-81-12 clarification letter allows manual action in lieu of protecting associated circuits if a licensee can: detect and defeat the spurious action.
From a safety system engineering perspective, multiple, complex manual actions appear to present a failure probability greater than having redundant safe shutdown trains separated by the Appendix R, III.G.2 criteria.
Multiple manual actions, in a fire area, can result in being a significant contributor to fire induced core damage failure (CDF).
Recent inspections have found that some licensee's have taken manual action to the extreme interpretation such no wrap is provided with operators solely relying on responding to mal-operations after they occur in III.G.2 areas.
This condition is similar to the condition Brown's Ferry was in prior to the 1975 fire.
GL-81-12 Slide 16 OPL273C0202 Revision 0 Page 13 of 19 T
5...
Objective B.3