ML20064E086
| ML20064E086 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/09/1978 |
| From: | Gilleland J TENNESSEE VALLEY AUTHORITY |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7811140134 | |
| Download: ML20064E086 (15) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374o1 830 Powei~, Building ;
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,,2, Noirember 9, 1978-y 44 Director of Nuclear Reactor Regulation Attention:
Mr. S. A. Varga, Chief Light Water Reactors Branch No. 4 Division of Project Management U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Varga:
In the Matter of the Application of
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Docket Nos 50-327
(
Tennessee Valley Authority
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' - 28 Enclosed are our responses to your requests for additional information concerning the Sequoyah Nuclear Plant (SNP) Radiological Emergency Plan and the quality assurance program for SNP, forwarded by your letter to N. B. Hughes dated September 20, 1978. These responses will be documented in Amendment 58 of the SNP Final Safety Analysis Report.
Very truly yours,
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[. E. Gil} and Assistant Manager of Power Enclosures i
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An Equal Opportunity Employer
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1.
The emergency plans submitted for Sequoyah and Watts Bar are very (EP) similar except for site specific information. As a result of the Watts Bar review, 59 questions were asked in the area of emergency planning.
In our judgment, modifications to TVA's plans in the Watts Bar case will logically require some revisions to the Sequoyah plans. We require therefore that TVA commit to amending their emergency plans for Sequoyah prior to the issuance of the operating license to rectify those deficiencies found in the Watts Bar review which are also applicable to Sequoyah.
Response
The Sequoyah Radiological Emergency Plan (REP) will be amended by February 1, 1979, to reflect NRC review of the Watts Bar REP.
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2.
With regard to the initial test program, our review of the test
_(QAB) descriptions modified in amendment 48 disclosed that the description of SU-9.4, Plant Trip From 100% Power, is not sufficiently descriptive to conclude that satisfactory acceptance criteria have been established.
Modify the test abstract to:
(1) identify the variables or parameters to be monitored for each trip; (2) provide assurance that test results will be compared with predicted results for.the actual trips to be performed (vice accident analysis predictions); and (3) provide quantitative acceptance criteria and their bases for the required i
degree of convergence of actual test results with predicted results for the monitored variables and parameters for each trip.
Response
l The TVA response will be submitted on or before November 17, 1978.
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3.
The review and audit program submitted in Section 16.6 is not (QAB) entirely consistent with that described in Section 13.4 of your application. Please clarify your position on the applicability of each of these sections of your FSAR.
Response
Sequoyah Nuclear Plant (SNP) technical specifications, as submitted July 1, 1978, in chapter 16 of the SNP Final Safety Analysis Report, are no longer applicable. Until the operating license (0.L.), chapter 16 will be deleted in Amendment 57 and wil. be replaced with a sheet referring to the latest NRC draft to the standard technical specification for the Sequoyah Nuclear Plant. After 0.L., chapter 16 will reference Appendix A to the license.
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4 TVA's exception to separate procedures for each alarm annunciation (QAB)
(specified in Regulatory Guide 1.33) is unacceptable.
It is the staff position that instructions for safety-related alarms in system operating instructions is not an acceptable alternative to a written procedure for each safety-related annunciator requiret by Regulatory Guide 1.33.
Please provide a commitment to Revision 2 of Regulatory Guide 1.33 or provide some other alternative for the staff's evaluation.
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Response
See revised page 17.2-1 of FSAR and revised table 17.2-1, item F.,
of Topical Report TVA-TR75-1.
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Please provide assurance that every item listed in Section 3 of (QAB) the Sequoyah SAR is requiring control under TVA's QA program is included in Table 17.2-1, " Critical Structures, Systems, and Components."
Response
See section 17.2-2, page 17.2-16, of Topical Report TVA-TR75-1.
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17.0 Q'Ja LITY t.556Tt'_NCI. ;'i/_. P.A! FOR ShIl0N OKRATION Chapters 17.0 and 17.2 of IVA Topical Report - TVA-TR-75-IA, " Quality As:urance ProPram Lescription for Design, Construction, and Operation of TVA Nuclear Power Plants" with the following changes presents an accurate and complete description of the quality assurance program for operation of Sequoyah Nuclear Plant:
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The plant instrument enginer and/or plant electrical engineer shall super-vise the calibration of plant instrumentation.
1$. Table 17.2-5, Part II, Section 4 should read as follows:
4.1 Preoperational Test Program 4.2 Plant Startup Test Program 55 4.3 Prefuel-Loading Functional Test Program 4.4 Hot Functional Test Program 4.5 Plant Surveillance Test Program 4.6 Special Tests and Experiments t
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Sequoyah Nuclear Plant takes the following exception to Item Q of Table 17.2-7:
Sequoyah complies with the requirements of Draf t 11 of ANSI N45.2.9.
17Property "ANSI code" (as page type) with input value "ANSI N45.2.9.</br></br>17" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..2-1 July 28, 1978
a TVA-TR75-1 Rav 2 T A B T.E 17.2-7 (Continued)
TOPIC COMMENT
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ANSI N18.7-1976 ref erences certaan "w.u A s t y A s a u t asice PrOgrJm Pequirements other St.sndards to which TVA takes p,34r tanus)" ( Fndor ses At:31 Hl 8. 7-1976) exception.
TVA's exception and appro-priate alternatives to the following standards are 1 Lated in this table in the appropriate location:
2 ANSI Ne 5. 2. 2 ANSI N95.2.3 ANSI N45.2.4 ANSI N45.2.5 ANSI N45.2.6 ANSI Nu$.2.9 L. 3.a l at..rv Gu i de 1.37, March 16, 19 7 3 "Qualit y No exctptions.
A.esus.mee I<equirements tor Cleaning ot riutd
- .ynt oms anst Associated Component s of Wat er -
.. a l e.1 tiocleta r Powe r Plants" (endor ses N45. 2.1-1973) h.
- g. 3.s l..e..r y.iu n d e 1.)H, (Revis ton 2), May 1977 -
1.
TVA does not utilize l2
- me i t a t y Ar.s.ur.mce I.ojutrements ror Packaging, Shipping, specific levels of 14 tavar.g Stor. ore,.tn.1 Itandling of I tems f or Wa ter-Cooled classificat ion f or pur-Nuclear Powe r 1 larit a" (endorses N45. 2. 2-19 72)
[oses of packagtng, shipping, recetving, storage and tundling (ArisI t:45.2.2, section 2. 7).
All purchased it ems undergo receiving inspection. This inspection versites that items have teen prpperly packaged for snipment and will assure that any special protective measures specified in the standard to prevent damage, detertoration, or cont amination wt11 be imposed until the item or comt>onent is issued for use.
2.
TVA takes exception to tr.e r equirement (ANSI Ng5.2.2, Section 6. 2. 4 ) that salt-tablet dis-rense r in any storage area shall not be permitted. TVA Power Stores Unit stores salt-tablet dispensers in sealed containers for use outside of the storage a rea only.
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14.0 Safety Injection System 15.0 Residual Heat Recioval Sys tem 16.0 Containment Sgray System 17.0 Ice Condenser System 18.0 Chemical and Volume Control System 19.0 Component Cooling Systems 20.0 Essential Raw Cooling Water System (Includes Auxiliary Essential Raw Cooling Water System) 21.0 Radioactive Waste Systems 21.1 Radioactive Liquid Waste System 21.2 Radioactive Caseous Waste System 22.0 Instruments and Controls 22.I' Seismically-Qualified Cabinets, Panels, and Instrument Racks 23.0 Emergency Power System 23.1 Diesel Generator System 23.2 Distribution System 23.3 125-Volt vital Battery System 23.4 120-Volt A.C. Vital Instrument Power System 23.5 Emergency Lighting 24.0 Upper Head Injection System 25.0 F_ ire Protec tion snd Detection Systems _ in Areas Containing Saf ety-Related Equipment 25.1 High-Pressure Fire Protection Systems (From Intake Structure through Fire Stations in Auxiliary Building, Control Building, Reactor Building, and Diesel Generator Building) 25.2 Carbon Dioxide Protection Systems (Supply to Spreader Rooms, Auxiliary Instruments Rooms, and Diesel Generator Building) 26.0 Flood Mode Boration and Hakeup 27.0 Radioactive Material Shipping Containers 27.1 Spent Fuel Cask's 27.2 Radioactive Waste Casks 17.2-6
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6.
TVA's letter of January 24, 1977 to NRC fire protection for 1
(QAB) Sequoyah (and Watts Bar) does not indicate whether the QA program for fire protection during design and construction is under the management control of the QA organization. This control consists of (1) formulating and/or verifying that the fire protection QA program incorporates suitable requirements and is acceptable to the management responsible for fire protection and (2) verifying the effectiveness of the QA program for fire protection through review, surveillance, and audits.
Performance of other QA program functions for meeting the fire protection program requirements may i
be performed by personnel outside of the QA organization. The QA program for fire protection should be part of the overall plant j
QA program. These QA criteria apply to those items within the scope of the fire protection program, such as fire protection systems, emergency lighting, communication and emergency breathing apparatus as well as the fire protection requirements of applicable safety-related equipment.
We find that the letter does not describe sufficient detail to 4
address the ten specific quality assurance criteria in Branch Technical Position APCSB 9.5-1 during design and construction.
In order for the QAB to fully evaluate your plan to meet these criteria, additional detailed description is necessary.
Examples of the detail we would expect TVA to provide are given in Attachment 6 to Mr. D. B. Vassallo's letter of August 29, 1977.
If, however, you choose not to provide this detail, you may apply the same controls to each criterion that are commensurate with the controls described in your QA program description, Section 17.lA.
These controls would apply to the remaining design and construction activities of Unit Nos. 1 and 2.
If you select this method, a q"
statement to this effect would be adequate for our review of the QA program for fire protection.
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Response
The QA program for fire protection has been reviewed by appropriate TVA management including the QA organization to verify that the program _
incorporates suitable requirements and is acceptable, The appropriate QA personnel are responsible for verifying the effer.civeness of the program through periodic audits.
The QA criteria apply te all fire protection related systems equipment and components,within the scope of the fire protection program including fire protection systems, emergency lighting, conmunication, and emer-gency breathing apparatus, to'the extent that they may affect the fire a
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protection for nuclear safety-related plant features. Our submittal of January 24, 1977, to the llRC will be revised as follows to reflect a more detailed discussion of the existing procedures and programs within the Office of Enginering Design and Construction (0EDC) that are required for fire protection related systems:
C.
_uality Assurance Q
TVA Compliance As indicated in the response to item A.1, Personnel, and as amplified in our response to Quality Assurance Branch question 1, TVA has delegated the responsibilities associated with the various aspects of fire prevention and protection to or-ganizations which have pef sonnel qualified to handle those functions.
The responsibility for the operational aspects of fire pro-tection has been delegated to the Division of Power Production in TVA's Office of Power. The Of fice of Power utilizes TVA's established QA program designed to meet the requirements of Appendix B to 10CFR Part 50. This program applies, for the operational phase of TVA's nuclear power plants, to the activities affecting the quality of those critical structures, systems, and components (CSSC) whose satisfactory performance is required for safe plant operations; to prevent accidents that could cause undue risk to the health and safety of the public; and to mitigate the consequences of such accidents in the unlikely event that they should occur. Those fire protection features protecting critical structures or areas will be included in the CSSC list and as such will fall under TVA's operational QA program. The operational QA program is described in the Sequoyah fluclear Plant Final Safety Analysis Report (FSAR), section 17.
Responsibility for the design and construction aspects of fire protection has been delegated to the Office of Engineering Design and Construction (0EDC). OEDC has documented procedures and specifications which govern its activities and which apply to all systems for which OEDC has responsibility.
These procedures are aimed at ensuring that the design and construction of TVA facilities result in a reliable and quality product.
As applied to fire protection, these documents will require, in part, that the actions required in C.1 through C.10 below be accomplished.
C.1 Design Centrol and Procurement Document Control TVA Compliance All fire protection related design criteria and procurement documents be reviewed by appropriate qualified indi-viduals to ensure that applicable regulatory and design requirements are properly and adequately specified and, as appropriate, quality standards such as fire
protection codes and independent laboratory testing are included. All changes to these documents and deviations therefrom, including requests for field changes, are reviewed in a similar manner.
The above includes appropriate design reviews to verify separation and isolaon requirements as they relate to fire protection.
C.2 Instructions, Procedures, and Drawings TVA Compliance The design, installation, and tests associated with fire protection related systems be accomplished in accordance with written and approved instructions, procedures, and drawings. These documents must be reviewed by qualified personnel to ensure that applicable regulatory and design requirements are properly and adequately specified. This documentation includes any specialized training requirements for installation.
C.3 Control of Purchased Material and Equipment TVA Compliance f
The procurement of fire protection related material and equipment require either an inspection at the manufacturer's facility or a receiving inspection to verify conformance to procurement requirements.
C.4 Inspection TVA Compliance The installation of fire protection related systems be verified by independent inspection to ensure that it meets the specified requirements and conforms to installation drawings and procedures. The inspection must be conducted in accordance with documented procedures. The procedures controlling inspection activity require that the inspection procedures or instructions shall be available with necessary drawings and specifications to use prior to performing inspection opera t ions. Further, the precedures, instructions, and/or drawings, including revisions, supporting the inspection activities shall be documented. The results of these inspecti.ons shall be recorded.
C.5 Test and Test Control TVA Compliance fire protection systems be tested under TVA's preoperational test program. This program requires that tests be conducted in accordance with written test instructions which are reviewed to ensure that applicable regulatory and design requirements are properly and adequately specified. The acceptance criteria shall be evaluated and documented and all exceptions documented and controlled.
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4 C.6 Inspection, Test, and Operating Status TVA Compliance items that have satisfactorily completed tests or inspections be identified by appropriate means.
C.7 Nonconforming Iteras TVA Compliance t
Nonconforming items be identified and cor trolled to prevent 3
I inadvertent use or installation. This includes documentation of the disposition of the nonconformance. The Thermal Power Engineering (TPE) Design Project shall review all noncon-fonnance reports and may request review by other branches 4
within EH DES as appropriate. The TPE Design Project flanager shall approve the disposition of the nonconformance.
C.8 Corrective Action TVA Compliance Significant and repetitive conditions adverse to fire protection such as nonconfonnances with installation drawings and deviations from specifications be controlled and appropriate corrective action taken and documented.
Conditions involving fire incidents and the corrective actions taken shall be promptly reported to a cognizant level of management for review and assessment.
C.9 Records TVA Compliance Records be maintained for fire protection systems to document conformance to the prescribed criteria. These records must include review of criteria, procurement documents and drawings, inspections, test-results, non-conformances, and modification records.
C.10 Audits TVA Compliance Independent audits by QA personnel be conducted annually in accordance with written procedures to ensure conformance to procedural requirements applicable to fire protection related systems. The audits must be documented along with the corrective action taken and reviewed by the appropriate level of management to ensure that the program is effective.
TVA proposes to implement additional nodifications resulting from commit-ments made in our responses to the following questions as soon after initial fuel loading for unit I as.is practical, but prior to return to power af ter the first refueling outage for the first unit:
Response to ASB question 4 - Additional fire retardant cable coating Response to ASB question 6A - Self contained 8-hour battery pack emergency lighting.
I Response to ASB question 9D - Additional and/or relocation of sprinklers.
Response to ASB question 118 - 1" mineral wool blanket between trains in ERCW junction box and additional suppression for junction box and conduit.
Response to ASB question 12 - Additional suppression systems.
Response to ASB question 13B - Sprinkler systems for auxiliary feedwater pumps.
Response to ASB question 13C - Sprinkler systems for component cooling water pumps.
I Response to ASB question 130 - Fixed water spray sy3 tem for component cooling wa,ter pumps Response to ASB question 13F - Additional detection.
Response to ASB question 26 - These equipment houses presently contain 250 feet of 2-1/2-inch hose on a wheeled cart, I to 2-1/2-inch variable fog nozzle, I hydrant wrench, 2-coupling spanners, and 1-wheeled fire extinguisher rated 320 B:C. Additional equipment listed in our response will be installed according to the above schedule.
All modifications resulting from commitments made in our submittal of January 24, 1977, shall be implemented prior to the initial fuel loading of each raspective unit.
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7.
Item 25 of Table 17.2-1 (Amendment 55) of the Sequoyah SAR lists (QAB) the fire protection and detection systems that ar;e treated under the operational QA program. Confirm that the applicable QA program for fire protection during the operations phase will include fire protection and detection systems protecting all areas containing safety-related equipment.
Response
See revised table 17.2-1, item 25.0.
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