ML19250B918
| ML19250B918 | |
| Person / Time | |
|---|---|
| Issue date: | 10/22/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Kennedy R NRC COMMISSION (OCM) |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-01.047, RTR-REGGD-1.033 NUDOCS 7911060171 | |
| Download: ML19250B918 (2) | |
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Central files M. Grot.
H. Berkow/U. Russell C. Kammerer, OCA l
NRR R/F T. Schultze D. Muller J. Fouchard, OPA LLTF R/F H. Denton D. Eisenhut D. Skovholt EDO OCT 2 2 1979 E. Case R. Mattson W. Haass ED0 R/F L. Gossick F. Schroeder G. Arlotto pPOR T. Rehm D. Vassallo W. Morrison LPDR R.. Smith J. Milhoan E. Wenzinger G.Ertter(EDO-7523)
V. Stello R. Minogue, OSD LLTF HE:ivhA::vD;. FJd: Co,:uissioner Kennecy Cpir l
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Lee V. 60ssick, Executive Director for Operatio;.s FAu:::
darola n. venton, Director of fice et iiuclear Keactor Regulation SU; JECT:
I;.sEPCnvE: T CHECKS OF VnLVE ALIU...J:;T I..
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i Ia your memoranuua of October 0, 1979, you indicated that you were convinceo i
that a requireacnt fur two indepencent checks of valve align..:ent in safety-relatec syste:..s. particularly subsequent tu aaintenance or testing operations, is necessary. You indicateo that you were pleased to learn that :JiR is currently re-evaluating the neea for such a requirenant and you requested to be advised of a plan to deal with this natter and the steps that will be takea by October 20, 1979, t
I rresent regulatory guidance on the subject of equipuent control, which incluces independent verificatiun of correct implementation of measures proviaco for control of equipment, is provided in degulatory duiue 1.33,
" quality assurance Progra:. hequirecents (uperation)," through endorsenent
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of ndSI Hiv.7-1976/s S-3.2, "Acainistrative Controls ana Quality !sssurance for tr.e operational Phase of i;uclear Power Plants." Section 5.2.6 of the n:.SI :llu.7-1975/A::S 3.2 incard adaresses equipocat control proceoures in general ter ;s.
With regaro to misalignment of valves, the A:SI taJ.7-1976/nt;S 3.2 stancard states that proccoures shall be proviced fcr control of equipment to c.intain personnel ano reactor safety and to avoid i
l unauthorizeo operation of equip.. lent anc shall require incepenaent verifi-cations, where appropriate, to ensure that necessary ceasures such as ta3;in3 equipnent have been properly inplemented. In tne latest revisica of r gulator3 Luide 1.33. issueo for public co. ment on Octocer 6,19/;,
it is stated that inuepene it verification of correct inplecentation of ceasures provicac for control of equipuent shoula oe perfor..eu in all instances. Tnus, general guioance in this area is already available.
riowever, a prvcle..i crists in implementation of the guicaace.
The Lessons Learneo Task Force accresses the subject of verification of correct performance of operating activities in its final report. The Task Force concludea that a nore effective syste 1 of verification of correct perfor;.;ance of operating activities is neeaed in order to provice aneansofreducinghumanerrorsandimprovingthequalitg nor 1 operations D *
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to reduce the frequency of occurrence of situations that could result in or contribute to accidents. It recommends that such a verification system include automatic system status monitoring and human verification of opera-tions and maint nance activities independent of the people perfoming the activity. With respect to automatic status monitoring, the Task Force recom-mends that Regulatory Guide 1.47, " Bypassed and Inoperable Status Indication for Nuclear Power plant Safety Systems," be backfit to plants not already required to meet it.
The implementation of Regulatory Guide 1.47, while augmenting human verifica-tion of certain operations and maintenance activities, does not eliminate the need for such verification in all instances. Therefore, the Task Force recom-mends that each licensee be required to review its procedures for maintenance, test, surveillance and other normal plant operations activities to delineate each activity that requires independent verification because of its importance to safety, to identify the personnel responsible for conduct of the verifica-tion and to describe the method of documenting performance of the verification.
The Task Force also recomends that the results of the above work be submitted to NRC for use in the development of minimum acceptance criteria for operations verification procedures, probably in the fom of a Regulatory Guide.
Implementation of the Task Force recomendation by licensees would contain two phases, namely before and after implementation of status monitoring equipment in conformance with Regulatory Guide 1.47. We urge your support of the Task Force recomendation including support for its prompt implementation.
One point of clafification in your October 9,1979, memo is in order. You stated a requirement for two independent checks of valve alignment in safety systees is necessary. We agree that two checks of valve alignment are neces-sary.
(First, a. check by the persons perfoming the work and then an independ-ent check by persons other than those perfoming the work.) Thus our objective is to have the two checks be independent of one another. As an aside, we under-stand some operating utilities plan to use the shift technical advisors for the second check of valve positions. We believe this is appropriate and will encour-age such use of shift technical advisors on all plants.
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,oe Offlee of Nuclear Reactor Regulation cc: Chaiman Hendrie A. Kenneke, OPE Comissioner Gilinsky L. Bickwit, OGC Comissioner Bradford S. Chilk, SECY 1977 123 Comissioner Ahearne R
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