ML20137F828
| ML20137F828 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/21/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8508270096 | |
| Download: ML20137F828 (5) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374ol 1630 Chestnut Street Tower II August 21, 1985 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 Supplement 1 to NUREG-0737 Requirements for Emergency Response Capability, contains the requirement to upgrade the emergency operating procedures to function-oriented procedures which do not rely upon the need to diagnose specific events. As stated in the April 15, 1983 letter from L. M. Mills to NRC, Sequoyah will use the Westinghouse Owners' Group (WOG) generic guidelines as the basis for the Sequoyah procedures. The Procedures Generation Package which outlined the method to convert the WOG guidelines to Sequoyah procedures was submitted to NRC by letter from L. M. Mills dated October 31, 1983.
As stated in the Procedures Generation Package, the WOG guidelines are used as the basis for the Sequoyah procedures.
The list of WOG guidelines is shown in Table 1 (enclosed). From the list of WOG guidelines, however, only the Function Restoration Guidelines are function oriented. Sequoyah has completed the training on all Function Restoration Guidelines and will implement these guidelines in August 1985. As a compliment to the function-oriented guidelines, Sequoyah has completed the training for the WOG event-based nominal emergency / upset response (E-series) procedures and event-specific subprocedures (ES-series).
The E/ES procedures were implemented in October 1984.
In addition to the E/ES event-based procedures, the WOG guidelines have included Emergency contingency Action (ECA) guidelines. We have presented the multiple failure ECA guidelines to the operators for training and validation / verification of the guidelines. However, based on the review by the operators, the ECA guidelines appear to be of such low probability and event specific that the inclusion of these guidelines is detracting from the more probable E/ES procedures and the Function Restoration Guidelines.
I Also, because the ECA guidelines are so event oriented, we do not believe that inclusion of Emergency Contingency Action guidelines is necessary for compliance with Supplement 1 to NUREG-0737 for the upgrade to i
function-oriented procedures.
Therefore, although ECA guidelines are contained in the WOG guidelines, we do not plan to implement the guidelines l
listed in Table 2 (enclosed).
8508270096 850821 l
PDR ADOCK 05000327 dg l
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An Equal Opportunity Employer
s,. Director of Nuclear Reactor Regulation August 21, 1985 The ECA-0.0 for loss of all ac power and two recovery guidelines will be implemented by the end of August 1985 because of the requirement of NRC Generic Letter 81-04.
We understand that the other vendor generic guidelines do not include multiple failure, event-based procedures; therefore, we believe that we are consistent with the other vendor's approach to satisfying Supplement 1 to NUREG-0737.
Very truly yours, l
TENNESSEE VALLEY AUTHORITY J. A. Domer, Chief Nuclear Licensing Branch Sworn t pn subscribeh before me this,
/ _ day of
/ /RA. 1985 h
Notary Public~
~
My Commission Expires Enclosures cc (Enclosures):
U.S. Nuclear Regulatory Comission Region II Attn:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Carl Stahle Sequoyah Project Manager U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue Bethesda, Maryland 20814
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TABLE 1 WOG FUNCTION / SYMPTOM GUIDELINES FR-S.1:
Response to Nuclear Power Generation /ATWS FR-S.2:
Response to Loss of Core Shutdown FR-C.1:
Response to Inadequate Core. Cooling FR-C.2:
Response to Degraded Core Cooling FR-C.3:
Response to Saturated Core Cooling FR-H.1:
Response to Loss of Secondary Heat Sink FR-H.2:
Response to Steam Generator Overpressure FR-H.3:
Response to Steam Generator High Level FR-H.4:
Response to Loss of Normal Steam Release Capabilities FR-H.5:
Response to Steam Generator Low Level FR-P.1:
Response to Imminent Pressurized Thermal Shock Condition FR-P.2:
Response to Anticipated Pressurized Thermal Shock Condition FR-Z.1:
Response to High Containment Pressure FR-Z.2:
Response to Containment Flooding FR-Z.3:
Response to High Containment Radiation Level FR-I.1:
Response to High Pressurizer Level FR-I.2:
Response to Low Pressurizer Level FR-I.3:
Response to Voids in Reactor Vessel m
G O
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.i TABLE 1 (Continued)
WOG EVENT GUIDELINES E-0: Reactor Trip Or Safety Injection ES-0.0:
Rediagnosis ES-0.1:
Reactor Trip Response ES-0.2:
Natural. Circulation Cooldown ES-0.3:
Natural Circulation Cooldown With-Steam Void In Vessel (With RVLIS)
ES-0.4:
Natural Circulation Cooldown With Steam Void In Vessel (Without RVLIS)
E-1: Loss Of Reactor Or Secondary Coolant ES-1.1:
Post LOCA Cooldown And Depressurization ES-1.3:
Transfer To Cold Leg Recirculation ES-1.4:
Transfer To Hot Leg Recirculation E-2: Faulted Steam Generator Isolation E-3: Steam Generator Tube Rupture ES-3.1:
Post-SGTR Cooldown Using Backfill ES-3.2:
Post-SGTR Cooldown Using Blowdown ES-3.3:
Post-SGTR Cooldown Using Steam Dump ECA-0.0:
Loss Of All AC Power ECA-0.1:
Loss Of All AC Power Recovery Without SI Required ECA-0.2:
Loss Of All AC Power Recovery With SI Required ECA-1.1:
Loss Of Emergency Coolant Recirculation ECA-1.2:
LOCA Outside Containment ECA-3.1:
SGTR With Loss Of Reactor Coolant-Subcooled Recovery Desired ECA-3.2:
SGTR With Loss Of Reactor Coolant-Saturated Recovery Desired ECA-3.3:
SGTR Without Pressurizer Pressure Control A
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TABLE 2 EMERGENCY CONTINGENCY ACTION GUIDELINES 1.
ECA-1.1 Loss of Emergency Coolant Reciculation 2.
ECA-1.2 LOCA Outside Containment 3.
ECA-2.1 Uncontrolled Depressurization of All Steam Generators 4.
ECA-3.1 SGTR With Loss of Reactor Coolant -
Subcooled Recovery Desired 5.
ECA-3.2 SGTR With Loss of Reactor Cooland -
Saturated Recovery Desired 6.
ECA-3.3 SGTR Without Pressurizer Pressure Control
.E 0
0