ML20009H677

Submits Status of Procedures Required by NUREG-0737 TMI Action Plan Items I.C.2,I.C.3,I.C.4,I.C.5 & I.C.6

ML20009H677
Person / Time
Site:	Comanche Peak
Issue date:	07/31/1981
From:	Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Tedesco R Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.2, TASK-1.C.3, TASK-1.C.4, TASK-1.C.5, TASK-1.C.6, TASK-TM TXX-3379, NUDOCS 8108100352
Download: ML20009H677 (3)

Text

' '

50- W C W4 TEXAS UTILITIES GENERKFING COMIRNY Log # TXX-3379 mn navmowan . nium.mxis n xn Fi1e # 880 July 31, 1981 BILLY R. CLEMENTS VfC.E PetteDR*ff t.n

<5 \ '

/g 2 ,\]~Vf3 5

R[U.f

. 0 p. -

Mr. Robert L. Tedesco ,

Assistant Direc'cor for Licensing AUG 101981 = ,L8 Division of Licensing IL & M n tat * * ^rosss%

poewissue U. S. Nuclear Regulatory Commission N g Washington, D.C. 20555 j dir y pt?

Dear Mr. Tedesco:

h Provided below is clarification and supplemental information on several topics concerning conduct of operations at Comanche Peak Steam Electric Statior (CPSES). This information was requested by members of the NRC staff 17 a meeting with representatises of Texas Utilities Generating Compa y (TUCCo) and Texas Utilities Services Incorporated (TUSI) at Bethesda, Maryland on June 25, 1981.

It is our intention to meet the requirements fo. linimum shift staffir.; by providing two radiation protection te:hnicic m onsite at all times in lieu of one radiation protection technician and one chemistry technician. As a minimum, one radiation protection technician v 4 !1 be qualified to initiate the post accident sampling and analysis process in the event of an accident.

The Independent Safety Engineering Group (ISEG) will consist of five engineers with experience in the areas of electrical, mechanical, and nuclear engineering. At this time, no individuals have been hired to fill positions as ISEG members. We are proceeding immediately to staff the ISEG with the most qualified individuals available. We will require a minimum of three j years engineering experience for all individuals at the time they are assigned to the ISEC and will-immediately involve them in the design, l construction, preoperational testing and initial startup of CPSES to maximize their nuclear porvr plant experience. This program will ensure that when the i ISEG is fully implemented-90 days prior to fuel load, the ISEG members are qualified to carry out their responsibility to improve the overall quality and safety of operations.

The statua of the CPSES procedures required by NUREG 0737, "TMI Action Plaa l Requirements for Applicants for an~0perating License," Items I.C.2 through l I.C.6, is as follows:

t Item I.C.2 As a positive means of accomplishing a transfer of knowledge from

! the offgoing to the oncoming operating shift, a shift and relief turnover procedure has been implemented. The procedure includes l

8108103352 81073f \

PDR AIOCK 03000445 (%n, V PDR L _

Mr. Robert L. Tedesco July 31,1981 Page Two checklists for critical plant parameters, availability and proper alignment of safeguards systems, equipment status and identification of systems and components in degraded operating modes. The procedure also provides a means to evaluate shift relief and turnover effectiveness.

Item I.C.3 The duties, responsibilities and authority of the Shif t Super.isor and control room operators are defined in approved CPSES procedt res.

These procedures have been reviewed and revised to ensure a clear delineation of the command decision authority of the Shift Supervi or and also a definite line of succession. A management directive from the lice President, Nuclear will be issued psior to operation and annuclly thereafter to emphasize the primar' management responsibility of the Shift Supervisor for safe operation af the plant. This directive is currently in draft form.

Item I.C.4 The responsibility and authority for liniting s to the Control Room is delineated in an approved procedure. ae event of an emergency, the spproved CPSES Emergency Plan discates a clear line of authority ind responsibility in the Control Room.

Item I.C.5 The Operations Support Engineering section will perform the technical review of operating : aformation, coordinate the distribution of applicable information to the affected plant personnel and review plant action plans for proper implementation. A procedure is currently being used to review INP0/NSAC reports. This assures that operating information pertinent to plant safety originating outside the TUGCo organization is continually supplied to operators and other applicable personnel. A procedure for assessment of operating information pertinent to plant safety originating within TUCCo will be implemented before fuel load. A draft training procedure has been written to ensure that information received through operational experience is incorporated into training lessons.

The CPSES Startup Program will utilize information gained from operating and testing experience in the Farley and Trojan Nuclear Plants to provide guidance in the development of a test program. LERs dated after January 1, 1978 are being reviewed.

. . . o ,

Mr. Robert L. Tedesco

' July 31, 1981' Page Three 1

Item I.C.6

. Station procedures have been reviewed and revised to provide an ef fective system of verifying the correct performance of operating activities. The latest draft revision to ANS 3.2 has been reviewed and appropritte sections have been included in the procedures. The procedures 's,lress the authority to release systems and equipment for maintenance or surveillance testing and to return them to service. Provisions have been made to ensure that the Shift Supervisor is kept fully informed of system status and that proper system alignment ~is verified by qualified personnel.

If you have any questions, please contact this office.

Yours very truly, 0 re BRC:mkg 6

h I

k i

n m

e

>