ML041100741

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Nuclear Training, Training Materials Coversheet, OPL273C0202, Revision 0
ML041100741
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
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:

Training Materials Coordinator / Date Standardized Training Material Copies to:

TVA 40385 [NP 6-20011 Page 1 of 2 1'

OPL273C0202 Revision 0 Page 13 of 19

5. Regulatory concerns. GL-81-12
  • Appendix R DOES NOT offer manual actions as Slide 16 . . . . -5... . T. . . . .

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 Objective B.3 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.