ML19281C331
| ML19281C331 | |
| Person / Time | |
|---|---|
| Issue date: | 08/15/1980 |
| From: | Devine J NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| To: | |
| References | |
| 801-781-635-432, NUDOCS 8008270421 | |
| Download: ML19281C331 (1) | |
Text
_.
Ms. Vivian Lee Senate Cer:mittee on the Environ.,.ent and Public Works Three Mile Island Investigation 4004 Dirksen Office Building Washington, D. C.
20510
Dear fis. Lee:
In accordance with our telephone conversation on May 19, 1980, I am sending you one copy of the following:
1.
Section 13.5, Plant Proceduras, of Regulatory Guide 1.70, Stancard Fcrmat and Content sf Safety Analysis Reports for Nuclear Pcuer Plants, Revision 3, November 1973.
2.
Section 13.5, Plant Procedur.s. of NUREG-75/087, Standard Review Plan, Revision 1.
As you can see, the NRR review of procedures prior to TMI was e review of the applicant's program to develop and use procedures and did not involve NRR review of the actual procedures.
I am also sending you a ecpy of Section I.C of the May 1980 Draft of the TMI Action Plan. This plan contains short-and long-term actions for igrowing the procedures and the reviews of.the procedures by the Offices of Nuclear Reactor Regulation and Inspection and Enforcement.
In our telephone conversation you' suggested that you had been informed that even before TNI, as an exception, NRR reviewed certain procedures under unique circumstances. The only procedure reviews performed by NRR were infer:ral reviews cenducted by the Operatcr Licensing Branch. These revi:Ns were conducted to ensure that plant procedures were~ accurately incorporated into operator licensing examinations. While some informal cocrxnts may have been provided to the utility during the course of this review, no formal NRR review was conducted, and the procedures were never formally docketed.
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Mcwever, prior to Three Mile Island, plant prececures were revietted by t' e Office of Irspection and Enforcement en an audit basis. Other than n
the IE inspections and the infer:ral reviews conducted by the Operatcr Licensing Branen, I at not aware of other NRR reviews of precedures even under unique circu;: stances.
Sincerely,
~.,;,s W' b
' ' Stephen H. Hanauer, Director Division of Human Facters Safety
Enclosures:
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5/t. u80 5/ 2:700 5/p.. 0 5/q W S3..g. 5../.7/.8 0 NRC FORM 319 (9 761 NRCM 0240 N U.S. GOVER NMENT PN.es f ' t>G OF FICE: 1979 289-369
s Revision 3 November 1978 1.
To review of proposed changes to systems or procedures, tests, and experiments, and 2.
To unplanned events that have operational safety significance.
The description should indicate how qualified members of the onsite operating organization will participate in the review of operating activities, either as part of their individual job responsibilities or as members of a functional review organization, to assist the plant manager.
13.4.2 Independent Review (FSAR)
This section should provide a detailed description of the provisions for performance of independent reviews of operating acti~vities. Infor-mation in this section should describe the organizational method, compo-sition and qualifications of the group, subjects to be reviewed, and the time such program is to be implemented relative to fuel loading of the (first) unit.
13.4.3 Audit Program (FSAR)
This section should provide a detailed description of the procedures and organization employed to implement the audit program with respect to operating activities and to verify compliance with the administrative controls and the quality assurance program.
13.5 Plant Procedures This section of the SAR should describe administrative and operating procedures that will be used by the operating organization (plant staff) to ensure that routine operating, off-normal, and emergency activities are conducted in a safe manner.
In general, the SAR is not expected to include detailed written procedures. The PSAR should provide preliminary schedules for their preparation, and the FSAR should provide a brief description of the nature and content of the procedures and a schedule for their preparation.
13.5.1 Administrative Procedures 13.5.1.1 Conformance with Regulatory Guide 1.33.
Regulatory _ Guide 1.33, " Quality Assurance Program Requirements (Operation)," contains guidance on facility administrative policies and procedures. The SAR should specifi-cally indicate whether the applicable portions of Regulatory Guide 1.33 concerning plant procedures will be followed. If such guidance will not be followed, the SAR should describe specific alternative methods that will be used and the manner of implementing them.
13.5.1.2 Preoaration of Procedures. The PSAR and FSAR should provide a schedule for the preparation of appropriate written administrative proce-dures (see Section 13.5.1.1).
The FSAR should identify the persons (by 13-14 m
a Revision 3 November 1978 position) who have the responsibility for writing procedures and the per-sons who must approve them befcre they are implemented.
13.5.1.3 Procedures (FSAR). A description of administrative proce-dures should be provided and should include:
1.
Standing orders to operations shift supervisors and shift crews including:
a.
The reactor operator's authority and responsibilities.
b.
The senior operator's authority and responsibilities, c.
The responsibility to meet the requirements of 10 CFR 550.54(i), (j), (k), (1), and (m), including a diagram of the control area that indicates the area designated "at the controls."
2.
Sracial orders of a transient or self-cancelling character.
3.
Equipment control procedures.
4.
Control of maintenance and modifications.
(
5.
Master surveillance testing schedule.
5.
Procedures for logbook usage and control.
7.
Temocrary procedures.
13.5.2 Ooerating and Maintenance Procedures (F5AR) 13.5.2.1 Control Room Operating Procedures.
This section should describe primarily the procedures that are performed by licensed opera-tors in the control room. Each such operating procedure should be identi-fied by title and included in a described classification system.
The general format ar.d content for each class should be described. The follow-ing categories should be included, but need not necessarily form the basis for classifying these procedures:
1.
System procedures.
2.
General plant procedures.
3.
Off-normal operating procedures.
4.
Emergency procedures.
5.
Alarm response procedures.
6.
Temporary procedures.
13-15
2 Revision 3 November 1978 In category 5, individual alarm response procedures should not be listed.
However, the system employed to classify or subclassify alarm responses and the methods to be employed by operators to retrieve or refer to alarm response procedures should be described. Immediate action proce-dures required to be memorized should be identified.
13.5.2.2 Other Procedures. This section should describe how other operating and maintenance procedures are classified, what group or groups within the operating organization have the responsibility for following each class of procedures, and the general objectives and character of each class and subclass. The categories of procedures listed below should be included.
If their general objectives and character are described elsewhere in the FSAR or the application, they may be described by specific reference thereto.
1.
Plant radiation protection procedures.
2.
Emergency preparedness proceduras.
3.
Instrument calibration and test procedures.
4.
Chemical-radiochemical control procedures.
5.
Radioactive waste management procedures.
6.
Maintenance and modification procedures.
7.
Material control procedures.
8.
Plant security procedures.
13.6 Industrial Security This section of the SAR should note that the applicant's plans for physical protection of the facility are described in a separate part of the application withheld from public disclosure pursuant to $2.790(d),
10 CFR Part 2, " Rules of Practice." Detailed security measures for the physical protection of nuclear power plants are required by 550.34(c),
of 10 CFR Part 50, " Licensing of Production and Utilization Facilities,"
and applicable sections of 10 CFR Part 73, " Physical Protection of Plants and Materials."
The regulatory position is set forth in Regulatory Guide 1.17, " Protection of Nuclear Power Plants Against Industrial Sabotage,"
and includes an endorsement of ANSI Stant std N18.17-1973, " Industrial Security for Nuclear Power Plants."
13.6.1 Preliminary Planning (PSAR)
At the time of submittal of the PSAR, the applicant's separate sub-mittal should describe plans for the screening of personr.el who are to be employed to work at the proposed plant, including parronnel selection policies, employee performance and evaluation procedures, and the industrial 13-16
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