ML20196L140
| ML20196L140 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/28/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807070249 | |
| Download: ML20196L140 (3) | |
Text
_ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _
,.c.
TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 374ol SN 157B Lookout Place
.lllN 281988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 centlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327/87-30, 50-328/87 USE OF AUXILIARY VERBS IN PLANT DOCUMENTS
References:
1.
Letter from R. Celdley to NRC dated November 10, 1987, "Sequoyah Nuclear Plant (SQN) Units 1 and 2 - NRC Inspecti.u Report No. 50-327. -328/87 Revised Response to Notica of Violation (NOV) 50-327, ~328/87-30-02 and 50-327, -328/87-30-07" 2.
Lettet from F. R. McCoy to S. A. White dated February 25, 1988, "Notice of Violation (NRC Inspection Report Nos. 50-327/88-02 and 50-328/88-02)"
3.
Letter from S. D. Richardson to S. A. White dated May 16, 1988, "Report Nos. 50-327/87-30 and 50-328/87-30" In reference 1. TVA denied example 2 of violation 50-327. -328/87-30-07.
The denial was based on the fact that the particular step of Surveillance l
Instruction (SI) 196 not followed used the word should, which indicates a recommendation rather than a requirement. A conscious decision had been made by personnel performing the SI that the step in question did not need to be performed.
As a result of NRC concerns regarding test activities, a procedure, Administrative Instruction ( AI) 4 7, "Conduct of Testing," was written to specifically address test activities and as an enhancement specifies that, if steps containing the word should are omitted, documentation of the basis for omitting the step is required in the test package. TVA's response was evaluated by NRC; violation 50-327, -328/87-30-07 was closed by reference 2; and NRC further addressed acceptance of the denial in refarence 3.
However, in reference 3 NRC additionally questioned why TVA has limited this enhancement to test instructions and requested that TVA address how it intends to treat the word should in other plant documents (instructions, procedures, workplans, etc.).
As such, we are providing the following information.
O
_8807070249 880628 h
f PDR ADOCK 05000327 I
Q PDC An Equal Opportunity Employer
o O
s s
U.S. 'Juclear Regulatory Commission American National Standard Institute (t3NSI) Standard N18.7-1976/ANS-3.2, "Administrative Controls and Quality Assurance for the Ooerational Phase of Nuclear Power Platits," defines shall as Jonoting a requirement and should es denoting a recommendation. These same definitions are specified in TVA's Nuclear Quality Assuranco Manual and are utilized in quality affecting procedures, which are developed in accordanco with ANSI N18.7-197f.
Instructions and procedures are prepared with sufficient detail for a qualified individual to perform the required function. This detail includes those steps that shall be followed for prerequisites, precautions, and performances. The word should is used to define those actions that ought to be taken to better facilitate proceduro performance; however, steps utilizing this auxiliary vorb could be omittod without affecting the safo operation of the plant. The evaluation of the need to follow a should statemant is within the ability of the qualified individual utilizing the doeuraent.
The inclusion in AI-47 of a requirement for documenting the basis for not performing should steps is an enhancement, which was incorporated into the AI as part of a general test activities upgrado effort being implemented at that timo.
Information regarding this action was provided in previous TVA responso to address specific NRC concerns regarding test activities. To address NRC's i
more recont question (reference 3), an application of a similar enhancement for other documents, e.g., maintenance, modification, and administrativo documents, would have to be addressed under different mechanisms than AI-47 and would require individual consideration to evaluate benefit and practicality. At this time TVA has not identified an immediato need for this enhancement in other plant documents. Use of should and shall in plant documents will be consistent with the program establistied as part of the procedures upgrado program described in section VI.C.I of the Nuclear performance Plan, Volume 1.
If you have any questions, please telephono M. A. Cooper at (615) 870-6549.
Very truly yours, TENNESSEE VALLEY AUTHORITY
,/.
v R. Gridley, Di'ector Nuclear Licensing and Regulatory Affairs cc:
See page 3
F:
9' t
' U.S. Nuclear Regulatory Commission lJN 281988 cc:
Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Ms. S. C. Black, Assistant Director for Projects TVA Projects Di'llsion U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Fcery Road Soddy Daisy, Tennessee 37379 l
i l
l I-w
-