ML20062E748

Forwards Proposed Integrated Schedule of Work Activities for Unit 1 Over Next 18 Months.Final Integrated Schedule for Unit 2 Work Activities Expected by First Wk in Feb 1983

ML20062E748
Person / Time
Site:	Sequoyah
Issue date:	08/06/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8208100315
Download: ML20062E748 (21)

Text

._.

.,A-TENNESSEE VALLEY AUTHORITY CH ATTA NOOG A TENNESSEE 37401 400 Chestnut Street Tower II August 6, 1982 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Denton:

In the matter of the

)

Docket Nos. 50-327 Tennessee Valley Authority

)

50-328 Late in 1981 we met with representatives of NRC to discuss the integrated schedule concept for Browns Ferry Nuclear Plant. The reason for the development of this schedule was that the number of modifications and magnitude of the required modification work to comply with NRC requirements and NRC commitments was beyond the capabilities of the plant to reasonably manage. Sequoyah unit 1 is scheduled to begin its first refueling outage in September of this year and is having sitt.ilar scheduling problems as those encountered at Browns Ferry. The effects of proceeding with the present Sequoyah schedule include the following.

1.

Extended periods of overtime worked by employees resulting in a deteriocation in employee alertness and subsequently more personnel errors.

2.

Plant staff's participation in modification-related activities places an additional burden on personnel to the detriment of the operation of the plant.

3 The high level of work activity imparts a near impossible procedural, testing, and maintenance change preparation load as well as additional training.

4.

Large numbers of employees result in increased security, health physics, and QA deviations as well as LERs.

Enclosed is our proposed integrated schedule of work activities at Sequoyah unit 1 over the next 18 months. This schedule was the result of a multi-step review of all required unit 1 work activities over this time-frame. This review included:

(1) prioritization of the work activity h0N 8208100315 820806 l-PDR ADOCK 05000327 P

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' Mr. Harold R. Denton August 6, 1982 1

according to safety significance (NRC commitments were considered high priority), (2) review of each activity to determine the status of required design information, availability of materials, required manpower, etc., (3) establishment of management limitations on the extent of work activities and manpower levels, and (4) development of a final integrated schedule based on steps 1 through 3 A final integrated schedule including unit 2 work activities will be submitted by the first week of February 1983; however, we do not expect the enclosed schedule to change.

Many NRC modification mquirements for Sequoyah, due to license requirements and compliance with NUREG-0737, are very extensive and require extremely high manpower levels. Many of these commitments were made by TVA at a time when the requirements were poorly defined and therefore final design and procurement time estimates were extremely rough at best. The result of these uncertainties and procurement problems is that many major modifications will have to be delayed and will now have to be worked concurrently with those requiring a plant outage to satisfy existing licensing conditions and commitments. The outage has been extended from 45 days required to refuel to 104 days to accommodate NRC commitment modification work. As shown by the enclosed schedule, several license condition modifications will require deferral beyond the existing requirement date.

The following is a list of enclosures which provide the results of our review. - Manpower Levels Before and After Deferrals - Modification Schedule For Major Commitment Items Over Next 18 Months

! - List of Deferred Commitments l - Additional Justifications For Commitment Deferrals We will make every possible effort to meet the schedules outlined in the enclosures; however, many things can happen that may impact these schedules. Such things as equipment procurement problems, undefined or changing design scopes, and unit outages could positively or negatively affect our fbture schedules. We will inform you of any such problems; and, if necessary, we will request schedule adjustments on a case-by-case basis.

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e Mr. Harold R. Denton August 6, 1982 We believe that the integrated process described above will be very beneficial to TVA and NRC. Your cooperation in this matter will be greatly appreciated. We will be glad to meet with you to discuss these matters at your convenience.

Very truly yours, TENNESSEE VALLEY AUTHORITY 0

L. M. Mills, M& nager Nuclear Licensing Sworn d subsc bed before me this day of 1982 Notary Public A

My Comission Expires Y"[E Enclosures cc:

U.S. Nuclear Regulatory Conslission Region II Attn:

Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

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4 Deferred Modification Commitments

~l-1.. Emergency Lighting in the Auxiliary Jontrol Room Relay Rooms - Through NRC review of Sequoyah against 10 CFR ' 50, Appendix R, Fire Protection Requirements, TVA committed verbally to install additional emergency lighting in the auxiliary control room relay rooms (reference letter from.L. M. Mills to E. Adensam dated October 1, 1981).

2.

Reactor Vessel Level Indicating System - Required by unit 1 operating license condition 2.C.23.II.2.

3.

Additional Accident Monitoring Instrumentation - Required by unit 1 operating license condition 2.C.23.D.2a and c.

4.

Post-Accident Sampling - Required by unit 1 operating license condition 2.C.23.F.

5.

Low Temperature Overpressure Protection - Required by unit 1 operating license condition 2.C.20.

6.

Upgrade Emergency Support Facilities - Required by' unit 1 operating license condition 2.C.23.I and by letter from L. M. Mills to II. R. Denton dated June 2, 1981.

7.

One-inch Chemical Feed Line Modifications - Required for unit 2 by operating license condition 2.C.9, but committed.t'o for unit 1 by letter from L. M. Mills to E. Adonsam dated May 29, 1981.

8.

Environmental Qualification - Required by license condition 2.C.12 (c).

A license amendment was submitted requesting revision to this requirement (reference letter from L. M. Mills to E. Adensam dated May 25, 1982)..

9.

Westinghouse W-2 switch modification - Committed by letters from L. M. -

Mills to J. P. O'Reilly dated December 12, 1980 (response to IE Bulletin 80-20) and November 9, 1981.

10.

Reactor Coolant System High Point Vent - Required along with vessel head vent by unit 1 operating license condition 2.C.23.E.

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Additional Justifications For Commitment Deferral 1.

Emergency Lighting Modification - see Note.

2.

Reactor Vessel Level Indicating System - 2.C.23.H.2 The reactor vessel level system has been scheduled for installation during the second refueling outage due to its severe impact on work activities, and because it is our understanding that the system cannot be turned on until emergency procedures utilizing the level system are developed, approved by NRC, and subsequent operator training completed.

The Sequoyah procedure guidelines are being developed as a generic effort through the Westinghouse Owners' Group. Based on the present Owners' Group schedule, we estimate the procedures cannot be in place and operator training completed until fall of 1983 The level system, therefore, if installed during this outage, could not be used until very late into cycle 2 assuming an optimistic schedule. Delays in procedure development or NRC approval could easily prevent use of the level system until cycle 3 Westinghouse has indicated that additional analysis will be necessary for plants utilizing ice condensers and/or upper head injection. Sequoyah incorporates both in its design. The magnitude of this work and the schedule for completion has yet to be determined.

3 Wide Range Containment Pressure Monitor - 2.C.23.D.2.C The design for a wide range (minus 5 to plus 60 psig) containment pressure monitoring system qualified to the appropriate sections for Regulatory Guide 1.97 as listed in Appendix B of NUREG-0737 has been completed for Sequoyah Nuclear Plant. The equipment consisting of transmitters, power supplies, recorders, and indicators qualified to IEEE 323-1974 was put out on bid invitation; the first bid invitation was opened January 8, 1981. Three bids were received, but none were responsive since they could offer only IEEE 323-1971 qualification.

The second bid invitation was opened on May 5, 1981. Only one bid was received and it was for IEEE 323-1971 equipment. The third bid invitation was opened on July 16, 1981 with only one bid and the same results.

Westinghouse is presently testing equipment to meet IEEE 323-1974 requirements. The equipment failed the first test, and it is estimated that the retest will be finished "sometime" in September 1982.

Even if the retest is successful, TVA will receive the equipment too late for installation during the first refueling outage.

Note: No additional justification provided for these items. Additional justification is provided for those items for which scheduling factors exist over and above those outlined in the cover letter.

I

2-In the interim, TVA has installed redundant wide range containment pressure indication utilizing IEEE 323-1971 equipment. Pressure is indicated in the main control room. Other than in areas of qualifications and the inability to record, the system meets the NRC requirements.

Iodine Radiation Monitors - 2.C.23.D.2a TVA has not been able to procure an integrated monitoring assembly which will monitor particulate, iodine, and noble gases, and meet our design criteria. Through discussions with NRC staff, several.

monitors were identified which NRC has found acceptable.for satisfying NUREG-0737 requirements. TVA will be selecting one of these designs, and procurement is expected within the next nine to twelve months.

In the interim, Sequoyah will have installed high range noble gas effluent monitors as follows:

A.

Monitors will be placed on the shield building vent and the condenser vacuum pump exhaust.

B.

Each monitor will consist of two General Atomic Company monitors as follows:

1.

Model RD-1 with a range of 10-1 to 10t4MR/hr i

2.

Model RD-23 with a range of 103 o 10 MR/h'r 7

t The model RD-1 and RD-23 monitors each utilize an ionization chamber for the detector, f

C.

The instrument readouts with continuous display and recording will be located in the main control room.

D.

The source of power for monitors will be pre'ferred power (vital j

instrument bus).

4 Post-Accident Sampling - 2.C.23.F The post-accident sampling facility is expected to require a total of 30,000 man-hours of non-outage work and 10,000 man-hours of outage work (mostly inside containment). -In addition, uncertainties exist as to the availability of some of the required materials in the timeframe required for installation at the first refueling outage. Based on our established manpower limits, it will.not be possible to complete this Work ouring the first refueling outage. All reasonable attempts will 1

be made to complete the inside containment. work to allow completion of the -facility before the second refueling outage. However, this may not be possible.

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.. In the interim, as indicated in our response to NUREG-0578 and -0737, procedures have been established to evaluate the primary coolant system activity depending on the accessibility of the sampling stations for,

particular degraded conditions. TVA's response to NUREC.0578 contained a copy of Technical Instruction 66, Post-Accident Sampling and Analysis Methods.

5.

Low Temperature Overpressure Protection - 2.C.20 Deferral of implementation of the low temperature overpressure mitigation system (OMS) on unit 1 is required due to problems encountered with obtaining adeauate operating times for the pressurizer PORVs at low pressures and on TVA's decision to use the pressuvizer-PORVs as a pressurizer vent system. TVA modified the air supply to the PORVs at Sequoyah unit 2 in an attempt to reduce the operating times'to meet the 2 seconds operating time required by the Westinghouse analysis. The modification reduced the operating time to 2.8 seconds and resulted in TVA requesting a reanalysis of the setpoint. Based on the unit 2 modification, we cannot be certain that modification of the present valves will enable them to meet the times specified in the Westinghouse setpoint study. TVA has decided to replace the-air-operated PORVs presently installed at Sequoyah unit 1 with electric solenoid-operated PORVs to be used as a " qualified" pressurizer vent system. These new PORVs have operating times of 1.0 second in both the opening and closing directions which is well within the setpoint limitations.

The time required for delivery by the manufacturer is ; expected to be six months to one year plus the time required for TVA to prepare the.

specifications to be sent to the manufacturer.

In the interim, operators have been trained in the concerns involved with low temperature overpressurization, an alarm has been installed to alert the operator when pressure has exceeded the normal range

( 380 psig) during solid system operation, and a nitrogen cover gas is used in the pressurizer to avoid solid system operation to the extent

)

possible. In addition, we believe that neutron damage suffered during i

the first and second fuel cycles will be minimal so that an l

overpressurization event that could damage the vessel during this time-frame is not credible.

l 6.

Technical Support Center 2.C.23.I. (1)

In the response to NUREG-0694, TVA committed to installing the permanent technical support center by June 30, 1983 Subsequent j

license conditions were put in the unit 2 operating license and later i

included _in the unit 1 operating license to require installation by the i

L

. first refueling outage or the first scheduled five-week outage after May 1, 1982. Since these license conditions were established, equipment deliveries and design work have not kept pace with the expected schedule and will not be available to allow completion during the first refueling.

In addition, the TSC codification will require approximately 25,000 man-hours of work to complete and has a significant impact on manpower levela (average of 45 additional craft personnel). To maintain our established manpower limits, we will not be able to complete the outage required work at the first refueling outage should the required design work and material be available.

The relay room, which is adjacent to the main control room, is being used as the temporary Sequoyah Technical Support Center (TSC). The TSC meets the same habitability requirements as the main control room and is large enough to accommodate up to 25 people. The TSC co=munications include PAX telephones and Bell telephones. The Bell telephones are administratively controlled, and system services can be reallocated during an emergency. Reference materials, including the REP, implementing procedures, plant drawings, FSARs, and selected plant procedures are present. Respiratory protective devices are available, if needed.

7.

One-inch Chemical Feed Line Modifications - See note.

8.

Environmental Qualification Extension granted by Commission order pending resolution of final schedule ruling. In addition, numerous procurement problems have developed for required equipment as identified in our NUREG-0588 response.

9.

Westinghouse W-2 Switch Modification TVA expects to have most of this modification complete befcre startup after the first refueling outage; however, several additional switches have had to be procured, and delivery dates are uncertain.

In the interin, as indicated in the letter referenced in enclosure 3, a special maintenance instruction is in place at the plant to inspect the switches every 31 days and after every operation of the switch.

10.

Reactor Coolant System High Point Vent - 2.C.23.E In response to HUREG-0737, TVA committed to installing reactor vessel head vents by the first refueling outage of sufficient duration. In subsequent letters to NRC, TVA indicated that the pressurizer PORVs would be utilized as high point vents. This system meets the NUREG-0737 requirements with the exception of environmental qualifica-tion. As indicated in item 5 of this enclosure, the TVA plans to

, replace the existing PORVs with electric solenoid-operated valves which will be environmentally qualified. We anticipate having these valves available by 1983 and installation complete before startup after the second refueling outage. TVA will have a qualified head vent system installed before startup after the upcoming refueling.

O

o TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 37401 400 Chestnut Street Tower II August 6, 1982 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, DC 20555

Dear Mr. Denton:

In the matter of the

)

Docket Nos. 50-327 Tennessee Valley Authority

)

50-328 Late in 1981 we met with representatives of NRC to discuss the integrated schedule concept for Browns Ferry Nuclear Plant. The reason for the development of this schedule was that the number of modifications and magnitude of the required modification work to comply with NRC requirements and NRC commitments was beyond the capabilities of the plant to reasonably manage. Sequoyah unit 1 is scheduled to begin its first refueling outage in September of this year and is having similar scheduling problems as those encountered at Browns Ferry. The effects of proceeding with the present Sequoyah schedule include the following.

1.

Extended periods of overtime worked by employees resulting in a deterioration in employee alertness and subsequently more personnel errors.

2.

Plant staff's participation in modification-related activities places en additional burden on personnel to the detriment of the operation of the plant.

3 Tne high level of work activity imparts a near impossible procedural, testing, and maintenance change preparation load as well as additional training.

4.

Large numbers of employees result in increased security, health physics, and QA deviations as well as LERs.

Enclosed is our proposed integrated schedule of work activities at Sequoyah unit 1 over the next 18 months. This schedule was the result of a multi-step review of all required unit 1 work activities over this time-frame. This review included:

(1) prioritization of the work activity An Equ:d Oppc-tumty EmWovet

... Mr. Hsrold R. Denton August 6, 1982 according to saft.ty significance (NRC cormitments were considered high priority), (2) review of each activity to determine the sta*,us of required cesign information, availability of materials, required manpower, etc., (3) establishment of management limitations on the extent of work activities and manpower 7.evels, and (4) development of a final integrated schedule based on steps 1 through 3 A final integrated schedule including unit 2 work activities will be submitted by the first week of February 1983; however, we do not expect the encloud schedule to change.

Many NRC modification requirements for Sequoyah, due to license

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requirements and compliance with NUREG-0737, are very extensive and reouire ext:emely high manpower levels. Many of these commitments were made by TVA at a time when the mquirements were poorly defined and therefore final design and procurement time estimates were extremely rough at best. The result of these uncertainties and procurement problems is that many major modifications will have to be delayed and will now have to be worked concurrently with those requiring a plant outage to satisfy existing licensing conditions and coimaitments. The outage has been extended from 45 days required to refuel to 104 days to accommoaate NRC commitment modification work. As shown by the enclosed schedule, several license condition modifications will require deferral beyond the existing requirement date.

The following is a list of enclosures which provide the results of our review. - Hanpower Levels Before and After Deferrals - Hodification Schedule For Major Commitment Items Over Next 18 Months - List of Deferred Comitments - Additional Justifications For Commitment Deferrals We will make every possible effort to meet the schedules outlined in the enclosures; however, many things can happen that may impact these schedules. Such things as equipment procurement problems, undefined or changing design scopes, and unit outages could positively or negatively affect our future schedules. We will inform you of any such problems; and, if necessary, we will request schedule adjustments on a case-by-case basis.

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a e, Mr. Harold R. Denton August 6, 1982 We believe that the integrated process described above will be very beneficial to TVA and NRC. Your cooperation in this matter will be greatly appreciated. We will be glad to meet with you to discuss these matters at your convenience.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Licensing Sworn to d subscr bed before me thish day of

,ua;23 1982 0(Luh9$,Y.

Yb NoYary Public

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My Constission Expires 8'

Enclosures cc:

U.S. Nuclear Regulatory Commission Region II Attn:

Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 i

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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II-August 6, 1982 i

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Denton:

In the matter of the

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Docket Nos. 50-327 Tennessee Valley Authority

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50-328 Late in 1981 we met with representatives of MRC to discuss the integrated schedule concept for Browns Ferry Nuclear Plant. The reason for the

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development of this schedule was that the number of modifloations and magnitude of the required modification work to comply with NRC requirements and NRC commitments was beyond th capabilities of the plant to reasonably I

manage. Sequoyah unit 1 is scheduled to begin its first refueling outage in September of this year and is having similar scheduling problems as those encountered at Browns Ferry. The effects of proceeding with the present Sequoyah schedule include the following.

1.

Extended periods of overtime worked by employees resulting in a deterioration in employee alertness and subsequently more personnel errors.

2.

Plant staff's participation in modification-related activities places an additional burden on personnel to the detriment of the operation of the plant.

3 The high level of work activity imparts a near impossible procedural, testing, and maintenance change preparation load as well as additional training.

4.

Large numbers of employees result in increased security, health'

. physics, and QA deviations as well as LERs.

Enclosed is our proposed integrated schedule of work activities at Sequoyah unit 1 over the next 18 months. This schedule was the result of a multi-step review. of all required unit 1 work activities over this time-frame. This review included:

(1) prioritization of the work activity An Equal Opportunity Empicyer

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. Mr. Harold R. Denton August 6, 1982 according to safety significance (NRC comitments were considered high priority), (2) review of each activity to determine the status of required design information, availability of materials, required manpower, etc., (3) establishment of management limitations on the extent of work activities and manpower levels, and (4) development of a final integrated scheoule based on steps 1 through 3 A final integrated schedule including unit 2 work activities will be submitted by the first week of February 1983; however, we do not expect the enclosed schedule to change.

Many URC modification requirements for Sequoyah, due to license requirements and compliance with NUREG-0737, are very extensive and require extremely high mannwer levels. Many of these constitments tere made by TVA at a time when the requirements were poorly defined and therefore final design and procurement time estimates were extremely rough et best. The result of these uncertainties and procurement problems is that many major modifications will have to be delayed and will now have to be worked concurrently with those requiring a plant outage to satisfy existing licensing conditions and comaitments. The outage has been extended from 45 days required to refuel to 104 days to accommodate NRC comitment modification work. As shown by the enclosed schedule, several license condition modifications will require deferral beyond the existing requirement date.

The following is a list of enclosures which provide the results of our review. - Manpower Levels Before and After Deferrals - Modification Schedule For Major Comitment Items Over Next 18 Months - List of Deferred Commitments - Additional Justifications For Coc:mitment Deferrals l

We will make every possible effort to meet the schedules outlined in the l

enclosures; however, many things can happen that may impact these i

schedules. Such things as equipment procurement problems, undefined or changing design scopes, and unit outages could positively or negatively affect our !bture schedules. We will inform you of any such problems; and, if necessary, we will request schedule adjustments on a case-by-case basis.

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. Mr. Harold R. Denton August 6, 1982 We believe that the integrated process described above will be very beneficial to TVA and NRC. Your cooperation in this matter will be greatly appreciated. We will be glad to acet with you to discuss these matters at your convenience.

Very truly yo%rs, TENNESSEE VALLEY AUTHORITI L. H. Hills, Hanager Nuclear Licensing Sworn d subscr bed before me this cay of _.

al/ 1982 01 I

l Notary Public My Commission Expires N'

Enclosures co:

U.S. Nuclear Regulatory Commission Region II Attn:

Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 i

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