ML19296B042
| ML19296B042 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/14/1980 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Rubenstein L Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8002190747 | |
| Download: ML19296B042 (21) | |
Text
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400 Chestnut Street Tower II February 14, 1980 Director of Nuclear Reactor Regulation Attention:
Mr. L. S. Rubenstein, Acting Chief Light Water Reactors Branch No. 4 Division of Project Management U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Rubenstein:
In the Matter of the Application of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 As requested by you during our telephone conversation of February 13, 1980, enclosed is the TVA positien of items identified as open or in progress during the NRC staff briefing to the Commissioners on February 12, 1980.
For each item, the enclosure gives a reference to our previous submittals and repeats any pertinent information from the previous submittals.
Very truly yours, TENNESSEE VALLEY AUTHORITY O
r L,
N\\ W.JA L. M. Mills, Manager Nuclear Regulation and Safety Enclosure f
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A I.A.l.3 SHIFT MANNI!G (A)
SRO, RO IN CONTROL ROOM Reference Letter L. M. Mills to L. S. Rubenstein, 12/14/79, on NUREG 0585 Item 2
Response
TVA's nuclear plant shift operations staffing provides for a licensed senior reactor operator (i.e., shift engineer) who is in charge of the station operations to be present at all times.
In addition, TVA's staffing requires that an additional licensed senior reactor operator (i.e., assistant shift engineer) be onsite for each licensed unit. The normal work station for this individual is in the control room of his assigned unit.
However, this individual is not required to be present in the control room at all times. This provides the flexibility necessary to permit this individual to give first-hand attention to conditions associated with his unit which are external to the control room.
Additionally, each control room is staffed with one more licensed reactor operator (i.e., unit operator) than there are licensed units.
The extra reactor operator assists the reactor operator assigned to each unit in normal operational activities and provides relief for meals and other purposes, o
I.A.1.3 SHIFT MANNING (B) OVERTIME RESTRICTIONS Reference Letter L. M. Mills to L. S. Rubenstein 12/14/79, NUREC 0585 Item 3
Response
TVA administrative procedures meet the intent of this position. Through negotiated labor agreements, TVA makes every effort to evenly distribute and limit overtime worked by licensed operators.
Because of these labor agreements and the normal shift staffing, the need for a licensed operator to work two consecutive shifts in excess of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is extremely infrequent.
It must be recognized that flexibility in this policy is necessary due to the complexity of the* labor agreements and the need to adequately staf f the station during unusual circumstances.
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I.B.1.1 ORGANIZATION AND MANACDENT CRITERIA 1.
Senior Personnel (SS and above) current PWR operation experience.
Response
During fuel loading and ' low power testing, TVA will provide, on each shif t one or more employees with significant experience in the operation of pressurized water reactors. These employees will be on duty during fuel loading or whenever the plant average reactor coolant temperature is greater than 350 F or the reactor is critical.
TVA has contracted for Westinghouse employees to support the special test program. Westinghouse staff includes two nuclear operations engineers and one functional analysis engineer.
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1.B.1.1 ORGANIZATION AND MANAGEMENT CRITERIA 2.
Plant Organization Needs Clarification
Response
The plant organization is as dascribed in the Sequoyah Nuclear Plant FSAR.
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I.B.1.1 ORGANIZATION AND MANAGEMENT (3) Training of Emergency Response Teams
Response
The responsibilities, tr'aining, composition, command lines, etc.,
are described in DPM N80A4, " Emergency Response Teams."
I.B.1.1 ORGANIZATION AND MANAGEMENT CRITERIA (4) Onsite Safety Review Group Reference
' Letter L. M. Mills to L.,S. Rubenstein 1/11/80, NUREG 0578
Response
In response to TVA's commitment to provide a separate safety review group during the special low-power physics testing program, the following section was included in Appendix A of the Sequoyah Nuclear Plant OQAM, Part II, Section 4.2:
Central Office Observers Engineering personnel who are not a part of the plant staf f (and do not have direct test responsibility) shall be on each day shift during the special test program to act as independent observers. The duties and responsibilities of these engineers are as follows:
Be cognizant of the scope and intent of the special test program.
He cognizant of the test being conducted.
Be familiar with the operation of a PWR-type reactor.
Provide daily status reports to the Assistant Director of Nuclear Power (Operations). These reports shall be made by the engineer designated as lead observer on each day shift.
I.B.l.1 ORGANIZATION AND MANAG'11ENT (5) Qualification of Shift T.chnical Advisors Reference Letter L. M. Mills to L. S. Rubenstein 2/7/80
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Response
In response to the NRC request, the following information has been forwarded for NRC review.
Shift Technical Advisor The qualification of STA's and their responsibilities and duties are speciit, in the TVA Division Procedures Manual (DPM No. N79A15).
Another Division Procedures Manual (DPM No. N72A39) defines the organizational relationship of the STA and other groups conducting a nuclear experience review. This procedure states that appropriate licensee event reports will be sent from the Nuclear Experience Review Panel (NERP) to the STA, Plant Operations Staff, and the training center.
The short-term training for STA included 112 hours0.0013 days <br />0.0311 hours <br />1.851852e-4 weeks <br />4.2616e-5 months <br /> of academic training and 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of simulator training.
Academic Training Technical Specifications, Safety Analysis Report, Operating Instructions, Abnormal Operating Instructions, Reactor Coolant System, Chemical Volume Control System, Residual Heat Removal System, Primary / Secondary Contain-ment, Ice Condensers, Containment Spray Systems, Main Steam and Steam Dump Systems, Condensate System, Feedwater and Auxiliary Feedwater Systems, Emergency Raw Cooling Water System, Component Cooling Water System, Reactor Protection System, Engineered Safety Features Actuation System, and Site Radiological Emergency Plan
(5) Qualification.of Shift Technical Advisors (Cont'd.)
Simulator Training Thirty hours of normal operations including startup, shutdown, and power ascension Thirty hours of abnormal operations including accident analyses recogni-tion, instrument failure, and degraded core operation See TVA letter dated 1/25/80, response to NUREG 0578, item 2.2.1.B.
for additional definition of the STA program at Sequoyah Nuclear Plant.
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I.B.l.1 ORGANIZATION AND MANAGEMENT (6) Westinghouse Technical Support for Special Test Program Reference Letter L. M. Mills to L. S. Rubenstein dated 2/13/80
Response
TVA has contracted for Westinghouse employees to support the special test program. Westinghouse staff includes two nuclear operations engineers and one functional analysis engineer.
In addition, Westinghouse has performed safety analysis for the test program and has conducted a review of the test program procedures.
TVA has contracted for a continuing analytical and operational support by the Westinghouse organi-zation during the test program.
The detailed function and role of the Westinghouse employees will be described at the time the detailed test program is submitted.
I.B.l.1 ORGANIZATION AND MANAGDIENT (7) Clarification of Command Lines for Emergency Response Organization
Response
'See (6) above.
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I.B.1.2 SAFETY ENGINEERING GROUP Refer to item I.B.1.1 - Organization and Management Part (4)
Onsite Safety Review Group.
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I.C.5 LICENSEE DISSEMINATION OF OPERATING EXPERIENCES References Letter L. M. Mills to L. S. Rubenstein 1/25/80 - NUREG 0578 Letter L. M. Mills to L. S. Rubenstein 12/14/79 - NUREG 0585
Response
See attached.
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(12/14/79 LETTER L. M. MILLS TO L. S. RUBENSTEIN)
Item 6.2 Providing Information to the Operator
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Each licensee should be required to review, within 90 days, its administrative, procedures to assure that a mechanism exists through which lessons learned from operating experience contained in various publications (such as IE Bulletins,,C,irculars and Notices, and applicable Licensee Event Reports) and from the licensee's own operating experience evaluation group are conveyed to the reactor operators and other affected operations personnel.
Two ways of accomplishing this objective are (1) standard distribution lists or publications and (2) regularly scheduled lectures as part of operations staff retraining. This recommendation is intended to assure that operators and other operations personnel are continually provided with lessons learned from operating experience.
Response
TVA has established a multidisciplinary review group for the purpose of reviewing and disseminating applicable information to the operations personnel and other affected groups. TVA also provides upgrade training weekly to operations personnel using the above information and plant unique activities. TVA further ensures that such information is properly disseminated to and utilized by operating personnel by including appli-cable lessons learned in both the initial trainig and retraining of operations personnel conducted at its F wer Operations Training Center.
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(1/25/80 LETTER L. M. MILLS TO L. S. RUBENSTEIN)
SHIFT TEP: NICAL ADVISOR (2.2.1.b)
SEQUOYAH NUCLEAR PLANT UNIT 1 RESPONSE
SUMMARY
The shif t technical adviser requirements are to be implemented by January 1,1980, or by initial criticality. The Snift technical advisor training will not be complete until January 1981; however, minimum training requirements will be completed.
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1.
Descrit the Shift Technical Advisor position and the operating experience assessment function.
TVA RESPONSE Shift Technical Advisor TVA is providing an on-shift technical advisor to the shift supervisor to support the disgnosis of off-normal events and to advise the shift super-visor of actions to terminate or mitigate the consequences of such events.
The Shift Technical Advisor will have the following qualifications:
(1) training in basic engineering principles, (2) extensive training in plant transient and accident response, (3) technical specification training with emphasis on the basis for limiting conditions for operation, and (4) significant react 6r training on systems and operating procedures.
The duties of the Shift Technical Advisor will include: (1) control room support in the diagnosis of off-normal events, (2) advice to the shift supervisor to terminate or mitigate the consequences of off-normal events, (3) make engincaring evaluations of plant conditions required for maintenance and testing, and (4) cognizant of current information disseminated by TVA's operating experience review group.
As an interim pelicy as of January 1, 1980, degreed shift nuclear engineers will be placed on shift to act as shift technical advisors. These interim STA's will receive additional training in the following areas:
(a) Nuclear Plant Systems (b) Transient and Accident Recognition on Plant Simulator (c) Limiting Conditions for Operations and Bases (d) TVA Emergency Plan (e) Shift Assignments and Responsibilities By January 1., 1981, TVA is optimistic that a substantial portion of the planned Shift Technical Advisor training program can be completed. This program will cover the following subjects as a minimum:
. January 25, 1980
(1/25/80 LETTER L. M. MILLS TO L. S. RUBENSTEIN) 4 1.
Nuclear Plant Systems A.
Emergency Core Cooling Systems D.
Residual Heat Removal Systems E.
Containment Systems F.
Control Rod Dirve Systems G.
Fuel Handlipg,Systees H.
Secondary Side and Auxiliary Systems 2.
Power Plant Operation A.
Startup B.
Shutdown I
C.
Power Operation D.
Integrated System Response 1
3.
Transients and Accidents A.
Licensing Basis Transients and Accidents 1.
Assumptions 2.
Conservatisms 3.
Minimum equipment taken credit for i
B.
Transient and, Accident Recognition and Operator Action 1.
FSAR Chapter 15 events 2.
Instrumentation failures 3.
Degraded conditions of system availability 4.
Limiting Conditions for Operation A. Technical Specification Definition B.
Technical Specification Bases 5.
TVA Operational Practices y
A.
Job Assignments and Responsibilities i
B.
Document Familiarization D.
Clearance Procedures E.
Plant Safety Practices and Procedures TVA believes that the STA must have a basic knowledge of fundamental plant operation to be able to fulfill his advisor function during abnormal events.
Organizationally, the STA will work for the plant Reactor Ragineer, thus, maintaining independence from the operations staff.
Currently, the STA assumes an advisory role only. The ultimate responsibility of plant operations during normal and abnormal events must rest with shift supervisor.
As the STA training program continues to meet the January 1, 1981, goal, we expect to finalize the detailed daily functions and responsibilities of the STA.
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January 25, 1980
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(1/25/80 LETTER L. M. MILLS TO L. S. RUBENSTEIN)
Operating Experience Review TVA believes that a multi-disciplined review group is necessary to adequately investigate LER's.
The Nuclear Experience Review Panel (NERP) ensures that a thorough review of nuclear industry operational experience is conducted by the Division of Nuclear Power central office staff. The review determines whether each problem at other nuclear plants, as reported by Licensee Event Reports or other NRC and industry sources, could be applicable to any of TVA"s~ nuclear plants.
If an item is determined to be applicable, the affected plant is informed through the minutes of the NERP meetings and by involvement in the corrective action process.
Des-criptions of selected operational problems are also sent to the plants for use in periodic operator and Shift Technical Advisor training.
Revisions are in progress to the NERP procedure which will require that central office reviewers of nuclear experience reports also determine and document whether each item should be sent to the nuclear plants for information. Criteria will be established to include descriptions of operational problems, transient events, and equipment malfunctions which did or could have resulted inLoperational problems.
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January 25, 1980
I.C.7 VENDOR REVIEW OF PROCEDURE (B) Low Power Tests
Response
Westinghouse will review the procedures for low power tests (9). The final (approved) procedures will be submitted to the NRC on or before February 29, 1980.
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I.A.l.1 STA STA on Duty
Response
The responsibilities for the STA is specified in TVA Division Procedures Manual (DPM No. N79A15).
By January 1, 1987, the STA's will meet all requirements of DPM N79A15.
As an interim policy, degreed shift nuclear engineers will be placed on shift to act as shift technical advisors. These interim STA's have received additional training in the following areas:
(a) Nuclear Plant Systems (b) Transient and Accident Recognition on Plant Simulator (c) Limiting Conditions for Operations and Bases (d) TVA Emergency Plan (e) Shift Assignments and Responsibilities
I.B.I.4 LICENSEE ONSITE OPERATING EXPERIENCE EVALUATION CAPABILITY Reference Letter L. M. Mills to L. S. Rubenstein 1/25/80, NUREC 0578
Response
TVA believes that a multi-disciplined review group is necessary to adequately investigate LER's.
The Nuclear Experience Review Panel (NERP) ensures that a thorough review of nuclear industry operational experience is conducted by the Division of Nuclear Power central office staff. The review determines whether each problem at other nuclear plants, as reported by Licensee Event Reports or other NRC and industry sources, could be applicable to any of TVA's nuclear plants.
If an item is determined to be applicable, the affected plant is informed through the minutes of the NERP meetings and by involvement in the corrective action process. Descriptions of selected operational problems are also sent to the plants for use in periodic operator and Shift Technical Advisor training.
Revisions are in progress to the NERP procedure which will require that central office reviewers of nuclear experience reports also determine and document whether each item should be sent to the nuclear plants for information. Criteria will be established to include oescriptions of operational problems, transient events, and equipment malfunctions which did or could have resulted in operational problems.
I.C.1 SHORT-TERM ACCIDENT ANALYSIS AND PROCEDURE REVISION (A) SBLOCA (B) ICC
Response
Because there will be no appreciable decay heat, stored heat, or significant fission product inventory associated with the low power test program, further revisions of the current Westinghouse Owners Group guidelines on small break LOCA and Inadequate Core Cooling (ICC) are not necessary.
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I.C TRAINING DURING LOW POWER TESTING
Response
In addition to the operational training to be gained by the tests, the operation staff will receive additional simulator training and classroom training, including two phase flow phenomena.
These tests will provide a demonstration of reactor operation in the natural circulation mode under both normal and certain degraded conditions.
These tests will provide significant operator experience and training with the plant in the natural circulation mode.
Selected tests will be repeated such that all licensed operating employees will participate in the establishment and recognition of natural circulation under normal and certain degraded conditions.
The simulator may be utilized to provide portions of this participation after it has been compared with actual plant response.
Results from these tests will be used to verify the simulator models and training techniques used on the Sequoyah simulator.
II.D.5 RELIEF AND SAFETY VALVE POSITION Reference Letter L. M. Mills to L. S. Rubenstein 2/11/80, NUREG 0578
Response
During hot functional testing at Sequoyah Nuclear Plant, TEC obtained a signature of the frequencies for open relief valve position. This signature was used for calibration and assurance that extraneous and feedback noise is compensated.
Valve position indication for Sequoyah Nuclear Plant meets seismic and environmental qualification requirements as specified for Sequoyah.
A meeting is scheduled f.or February 28-29, 1980, with Technology for Energy Corporatien (TEC), the vendor for the monitoring system, to discuss the qualified life test program. TEC has indicated that after specifics of the program have been determined, tests could be completed in six to nine months.
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II.E.1.2 AFW INITIATION AND INDICATION Control Grade Autostart and Flow Indicators Safety Grade Reference Letter L. M. Mills to L. S. Rubenstein 2/11/80, NUREG 0578
Response
The auxiliary' feedwater flow instrument channels are powered from the emergency buses (120V ac vital instrument buses) consistent with the diversity requirements of the auxiliary feedwater system.
II.A.I.2 UPGRADE EMERGENCY SUPPORT (A) Onsite TSC - Establish Reference Letter L. M. Mills to L. S. Rubenstein 2/7/80
Response
To ensure that TSC employees have access to control room information, a portable closed circuit television camera vill be stored in the TSC.
During an emergency, a hand-held camera will be maintained in the control room to relay pictures of the control room to a monitor located in the TSC. Communications between the TSC and the control room are available to ensure that the camera is focused on the appropriate monitors as a
requested by TSC.
We understand that the NRC resident inspector will verify that the "several minor items" have been completed before fuel load.
The long-range plan for upgrading the TSC will be submitted about June 1980.
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