ML20073J963

Forwards Response to Generic Ltr 82-33 Re Suppl 1 to NUREG-0737, Requirements for Emergency Response Capability

ML20073J963
Person / Time
Site:	Sequoyah
Issue date:	04/15/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Adensam E Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8304190474
Download: ML20073J963 (8)

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• TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ol

.- . 400 Chestnut Street Tower II April 15, 1983 Director of Nuclear Reactor Regulation Attention: Ms. E. Adensam, Chief Licensing Branch No. 4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Ms. Adensam:

In the. Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 As requested by D. G. Eisenhut's December 17, 1982 letter to "All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits" regarding Supplement 1 to NUREG-0737 Requirements for Emergency Response Capability (Generic Letter #82-33), we are providing the enclosed response.

Please note under item E.3 of the enclosure that TVA no longer intends to install the data link as described in our response to Generic Letter 81-10 submitted June 1, 1981. Appropriate plant parameters essential for the Emergency Operations Facility (EOF) functions will be provided to the EOF by facsimile transmission.

If you have any questions concerning this matter, please get in touch with Ken Parr at FTS 858-2685.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills,jHanager Nuclear Licensing Sworn - d subsc bed b ore me thisk day of A14 1983 MA W '#Kfi Nitary Public

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My Comission Expires , -

Enclosure cc: U.S. Nuclear Regulatory Comission (Enclosure) OC Region II Attn: Mr. James P. O'Reilly Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 8304190474 830415 PDR ADOCK 05000327 F PDR An Equal Opportunity Employer

ENCLOSURE RESPONSE TO GENERIC LETTER NO. 82-33 SUPPLEMENT 1 10 NUREG-0737 SEQUOYAH NUCLEAR PLANT (SQN)

A. SAFEIT PARANETER DISPLAY SYSTEM (SPDS)

The Technical Support Center /SPDS computer system hardware has been delivered to the plant site. TVA intends to install this hardware and tensinate instranentation inputs to this system such that the system, including SPDS displays, is operable, verified, validated, and operators trained by startup following the second refueling outage for each unit consistent with existing license commitments and our integrated modification schedule.

4 The implementation of SPDS has been reviewed in accordance with the technical specifications and determined not to either involve an unreviewed saf ety question or a change of technical specifications. A written safety analysis for SPDS describing the basis on which the selected paramet'ers are sufficient to assess the safety status of each of the following f unctions will be provided by January 1,1984 for Sequoyah.

1. Reactivity control,

2. Reactor core cooling and heat removal from the primary system,

3. Eeactor coolant system integrity,

4. Radioactivity control, and

5. Containment.

TVA intends to verify the SPDS by performing extensive tests which ensure that the displayed data is accurate and the system performs as specified.

B. _ CONTROL ROOM DESIGN REVIEW Before licensing SQN unit 1, TVA conducted a preliminary review of the unit 1 control room. In addition, IVA participated in a preliminary

[ control room assessment conducted by the NRC staff and assisted by consultants from the Essex Corporation. The objective of these reviews was to assess, before licensing, the degree to which the control room design complied with specific human factors criteria. Several immediate modifications were made to improve communication capabili-t ties, lighting, and noi se levels. In addition, changes were made to control boards to prevent inadvertent activation of controls and to aid in the recognition of system controls, indicators, and ala rms. These changes have been made to both units 1 and 2.

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• RESPONSE TO GENERIC LETTER NO. 82-33 SUPPLENENT 1 10 NURE3-0737 SBQUOYAH NUG. EAR PLANT (SON)

TVA intends to complete the control room design review consistent with a program plan to be submitted two months before the start of the review activity. This review will be completed within six months af ter

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validated, symptom-oriented emergency operating procedures are implemented and will include a control roca task analysis based on the se procedures. . A summary report of the completed review will be submitted within nine months following the completion of the review -

activities.

I C. REGULATORY _ _ GUIDE 1.97 For SQN, our March 15, 1982 submittal (L. M. Mills to E. Adensas) meets the intent of Generic Letter 82-33 with respect to Regulatory Guide 1.97. ,. , ,

Our submittal addressed instrument range, environmental qualification, seismic qualification, quality assurance, redundancy, power supply, and display location. It addressed deviations from the guidance in Regulatory Guide 1.97 (Revision 2), provided justification for the deviations, and showed acceptable alternatives to the guidance given.

We have identified the need to elucidate our submittal with respect to Category 3 instrumentation, i.e., support instrumentation.

Post Accident Monitorias (PAM) consists of a set of process variables along with the instrumentation necessary to monitor the variables in the control room required to ensure safety during and following an accident. Support instrumentation may prcvide additional inf ormation to the operator during and following an accident, but this information is not required.

l Types A, B, and C variables comprise the comple.te set of variables for PAM instrumentation by the f unctional definition of these variable l type s. Types D and E variables are not part of the set of variables l which comprise the set of variables for PAM instrumentation. Types D and E variables are support instrumentation by the functional definition of the variable types.

t Support instrumentation does not sarve a primary safety function; therefore, indication of these variables is not required during and following an accident. These variables are not considered PAM ins trumenta tion, and they only provide additional information by indicating system operating status, diverse variables, and radiation relea se s.

The variables can be used to enhance safety, if the instrumentation is available, by allowing the operator to improve the system operation over the minimum required for design basis behavior or determine what I

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db RESPONSE TO GENERIC LETTER NO. 82-33 SUPPLEMENT 1 10 NUREG-0737 -

SEGUOYAH NUCLEAR PLANT (SQN) system has f ailed. The instrumentation to indicate these variables is

. not essential f or the safety f unctions provided by PAM; therefore, no special design requirements are specified for this instrumentation, but some special design requirements may be utilized for this instrumentation to provide functions not within the scope of saf ety f unctions provided by PAN.

A preliminary design change request has been completed, and we are preparing the preliminary Engineering Change Notice (ECN) which will address costs and equipment delivery. Schedules will be identified for installation or upgrade when equipment delivery dates, outage projec-tions, Icad demand, and manpower requirements are all identified and the Regulatory Guide 1.97 data set is integrated into the control roon design review., At that time, we will modify and submit our integrated schedule as necessary to accomplish the needed installations or upgrade.

As our design and procurement phases progress, we may identify additional deviations or exceptions we must take in the implementation of the regulatory guide.

D. UPGRADED ENERGENCY OPERATING PROCEDURES (EOP_sl TVA is an active member of the Westinghouse Owners' Group (WOG)

Procedure s Subcommittee. The Emergency Response Guideline (ERG)

Program has been in development since early 1981. The ERG program has an overall objective of providing human-f actored, symptom-oriented, emergency operating procedures with improved human reliability and the ability to mitigate the consequences of a broad range of initiating events and subsequent multiple f ailures or operator errors without the need to diagnose specific events as required per NUREG-0737, item I.C.1.

The generic WOG high pressure, Revision 1 ERGS should be available in August 1983. These guidelines (technical guidelines) will be submitted by WOG to NRC some time thereaf ter in the same manner as with the previous submittals. Sequoyah contains evo maj or diff erences from the Westinghouse generic high-pressure reference plant. These differences are the upper head injection (UHI) system and the ice condenser. We have requested Westinghouse to evaluate the generic ERGS taking into account these differences. Westinghouse has indicated that same reanalysis may be required. The UHI/ ice condenser ERGS from which plant-specific emergency operating procedures can be written will not be available before September 1983. Depending on the amount of reanalysis required, completion of the UHI/ ice condenser ERGS may be delayed until 1984.

The procedures generation package includes the following:

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.y RESPONSE TO GENERIC LETTER NO. 82-33 SUPPLEMENT 1 TD NUREG-0737 SEQUOYAH NUCLEAR PLANT (SON)

1. Plant-specific technical guidelines (a description of planned method for developing plant-specific BOPS from generic guidelines),

2. Writer's guide,

3. . Description of program for validation of EOPs, and

4. Brief description of training program for the upgraded EDPs.

The procedures generation package will be submitted to NRC by October 1983 f or Sequoyah.

The upgraded EOPs will be implemented, including completion of

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validation and training, within 12 months af ter completion of any required UHI/ ice condenser reanalysis and issuance of the NRC Safety Evaluation Report (SER) for the WOG generic high pressure Revisian 1 ERG s.

E. ENERGENCY RESPONSE FACILITIES (ERF)

1. Technical Sunnort Center (TSC)_

A description of the TSC has been provided in a previous submittal

, to NRC in response to Generic Letter 81-10. The ISC is operational with the exception of the appropriate data systems in accordance with Sequoyah's integrated plan. The TSC will be fully functional including these data systems, necessary procedure changes, and training related to the data systems by startup following the second refueling outage for each unit consistent with our existing license commitments and our integrated modification schedule. The data systems will include appropriate variables essential for TSC functions.

2. Overstions Suncort Center (OSC)_

The OSC is fully functional.

l l 3. Enernency Operations Facility ( EOF)f l

TVA has implemented a centralized emergency management system to satisfy the EOF requirement for all TVA plants. This operation has received previous Commission approval as indicated in a letter from Darrell G. Eisenhut (NRC). to H. G. Parris (TVA) dated March 19, 1981. This system consists of a Central Emergency Control Center (CECC) located in Chattanooga, Tennessee, and two emergency support I

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. . RESPONSE TO GENERIC LETTER NO. 82-33 SUPPLEMENT 1 10 NUREG-0737 l SEQUOYAH NUCLEAR PLANT (SON) f acilities; the Knoxville Emergency Center (EEC) located in Knoxville, Tennessee and the Muscle Shoals Emergency Center (MSEC) l located in Muscle Shoals, Alabama. i l

To augment these facilities and satisfy the additional elements listed in Mr. Eisenhut's letter to Mr. Parris as well as the requiraments of Generic Letter 82-33, TVA has established a 8' Local Recovery Center (LRC)" at Sequoyah to accommodate an NRC site team.

TVA's off site emergency centers have been described in previous submittals to NRC in response to Generic Letter 81-10 and are applicable to Sequoyah. In that response, TVA describes a data-11ak between the CECC central data processor and the TSC and SPDS data base. ' Meteorological variables are transmitted by an automated data system. TVA provides appropria te plant parameters essential for EOF. functions to the EOF by way of f acsimile transmission (these parameter lists are provided in the Sequoyah Radiological Emergency Plant Lapl ementing Procedures Documents) .

We believe this data transmission system is a fully adequate means of supplying the EOF with the essential parameters for EOF functions in a timely manner. With this data transmission system, the requirements of Generic Letter 82-33 will be met. These facilities will be considered fully operational, and we no longer intend to install the data link as described in our response to

, Generic Let ter 81-10.

F. IN17, GRATED TRAINING PLAN i <

i The integrated program for training the Sequoyah operators on the l upgraded emergency operating instructions, the Safety Parameter Display 1 System, and any plant modifications as a result of the control roon l

design review and Regulatory Guide 1.97 will be conducted as follows. '

i The plant operators will be trained during the regularly scheduled requalification and group training. Specini training sessions will be  !

scheduled as necessary. The simulator will be used extensively in this j effort. .

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l G. INTEGRATION OF ENERGENCY RESPONSE CAPABILITY INITIATIVES '

l Effective haplementation of meergency response capability initieti~es l requires the integration of these capabilities into su sction plan which

! recognizes their interdependence. TVA intends to accomplish this using an integrated action plan which is graphically illustrated in the attached flowchart. This action plan has been simplified to identify fundamental relationships between the initiatives. As such, it does not j show all interactions be tween them.

. RESPONSE TO GENERIC LETTER N3. 82-33 SUPPLEMENT 1 'ID NUREG-0737 SEQUOYAH NUG EAR PLANT (SQN)

It must also be recognized that this is an interactive process.

Implementation of various control room nodifications will be coordinated and integrated with other plant modifications consistent with one inte-gra ted schedule concept. As control room / plant modifica.tions are imple-mented, procedures will be reviewed and revised as necessary and opera-tors trained on these changes consistent with our established operator training programs. Training will thus be an integral activity in the implementation of these initiatives. Implementation schedules will be discussed in response to each of the individual initiatives.

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