ML20038B051

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Forwards Response to NRC Re Emergency Procedures & Training for Station Blackout.Encl Also Clarifies Info Discussed W/Nrc in 811118 Telcon
ML20038B051
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 11/19/1981
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: Adensam E
Office of Nuclear Reactor Regulation
References
GL-81-04, GL-81-4, NUDOCS 8111240651
Download: ML20038B051 (2)


Text

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TENNESSEE. VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374ol 400 Chestnut Street Tower II November 19, 19

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Director of Nuclear Reactor Regulation -

5 Attention:

Ms. E. Adensam, Chief NOV 2 41931" i

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Licensing Branch No. 4

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Division of Licensing o*

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U.S. Nuclear Regulatory Commission g

Tfi\\g Washington, DC 20555 et,

Dear Ms. Adensar:

In the Matter of

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Docket Nos. 50-327.

Tennessee Valley Authority

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50-328 In your November 5, 1981 letter to H. G. Parris regarding emergency.

procedures and training for station blackout (B-63), you asked TVA to verify that " procedures exist for Sequoyah units 1 and 2 which guide operator actions necessary to maintain reactor coolant inventory and heat removal with only do power available." Enclosed is our response to your request along.with additional clarifications. Also in your November 5,.1981 letter, you stated the following:

"In response to the the NRC generic letter 81-04 you state that the Special Low Power Test

(#7) satisfies our requirement." The enclosure also provides some additional clarifications in response to that statement. This information was discussed with C. Stahle of your staff in a telephone conversation on November 18, 1981.

Very truly yours, TENNESSEE VALLEY AUTHORITY 1

i L. M. Mills, Manager Nuclear Regulation and Safety Swo'rn d subscribed before me f - day o 981 thi Notary Public MyCommissionExpires9-[-3 Enclosure 0111240651 81111Y II l

PDR ADOCK 05000327-F PE An Equal Opportunity Employer

ENCLOSURB RESPONSE TO NOVEMBER 5,1981 LETTER FROM E. ADENSAM TO H. G. PARRIS EMERGENCY PROCEDURES AND TRAINING FOR STATION BLACK 0UT (GENERIC LETTER 81-04)

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 Special Low Power Test #7 procedure was not intended to satisfy the requirement for a " Loss of All ao Power" procedure. We stated that the test verified that equipment could be remotely operated to achieve core heat removal and reactor coolant system cooldown. As part of that test, we also verified that emergency lighting and ventilation was adequate; however, no action was taken to simulate control of reactor coolant inventory. We stated that current plant operating procedures for natural circulation and system operating instructions for operation of the turbine driven auxiliary feedwater system, coupled with the training and information gained from the special test, are adequate to handle this type of event until a " Loss of All ao Power" procedure is developed. We still believe this to be true.

We are actively involved in the Westinghouse Electric Corporation owners' group (WOG) effort to develop a generic " Loss of All ac Power" procedure guideline. ~

Our efforts include both central office and plant staff participation in the development and review of the generic procedure guideline. In addition, members of both the Watts Bar and Sequoyah plant staffs have participated in the recent WOG Emergency Response Guidelines seminar. The generic " Loss of All ac Power" procedure guideline was reviewed at this seminar. The details and current status of the WOG effort on this project have been sent to NRC by the WOG by letter from R. W. Jurgensen (Westinghouse) to D. G. Eisenhut dated August 7, 1981. A general overview of the procedure guideline and its basis are currently being presented to the Sequoyah reactor operators during this year's requalification program.

Current TVA efforts on p] ant procedures are directed at coluplying with NUREG-0737 item I.C.1.

It is our position that all procedure work must fit into this overall scheme. The plans call for reformatting current plant emergency procedures into Optimum Recovery Guidelines (ORG). The " Loss of All ao Power" procedure that TVA will develop from the WOG guidelines will be included as an Emergency Contingency Action procedure to the ORG. A loss of all ac power procedure will not be prepared separate from the overali integrated ORG L

program.

The entire procedure effort will require a significant amount of manpower for i

the preparation, review, and dissemination of the ORG and training on their use. We do not believe that the " Loss of All ao Power" procedure effort should l

l be a parallel effort. It would result in a duplicate effort in reformatting l

and integration of the procedure into the ORG. More importantly, a duplication i

of effort, and the potential for confusion or distraction of the operator, would result from a parallel training effort.

In summary, TVA has a considerable effort underway in expanding the scope of and reformatting the plant emergency procedures. The " Loss of All ao Power" procedure work is included in the integrated procedure upgrade. TVA and the WOG have done considerable work on the basis for the " Loss of All ao Power" procedure. The plant staff at Sequoyah has been involved in the preparation and review of the generic procedure guideline. They have participated in the WOG Emergency Response Guidelines seminar. The Sequoyah reactor operators have been briefed on the general concepts of the procedure and its basis. The " Loss of All ao Power" procedure will be developed and implemented as part of the ORG, TVA's integrated response to NUREG-0737 item I.C.1.

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