ML20211B537
| ML20211B537 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/11/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Youngblood B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, NUDOCS 8702190439 | |
| Download: ML20211B537 (5) | |
Text
e TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374ol SN 157B Lookout Place FEB 111987 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Office of Nuclear Reactor Regulation Washington, D.C.
20555 Attention:
Mr. B. J. Youngblood In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT - ADDITIONAL INFORMATION FOR GENERIC LETTER 83-28, ITEMS 3.2.1 AND 3.2.2 In response to your December 18, 1986 request for additional information on the above subject, TVA is submitting a statement to confirm that Sequoyah is in compliance with Action Item 3.2.1 and a schedule for completion of Action Item 3.2.2.
Sequoyah's resolution to action item 3.2.1 was identified as a commitment under section 2.4 of Sequoyah's Nuclear Performance Plan and therefore does not constitute a new commitment.
Sequoyah's resolution to Action Item 3.2.2 constitutes a new commitment for complying with the Nuclear Utility Task Action Committee (NUTAC) recommendations on vendor information by January 31, 1988.
If you have any questions concerning these action items, please call Don Goodin at (615) 870-7462.
Very truly yours, TENNESSEE V LLEY AUTHORITY R. Cridley, Director Nuclear Safety and Licensing Enclosures cc: See page 2 07021
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An Equal Opportunity Employer
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. -FEB 111987 U.S. Nuclear Regulatory Commission cc (Enclosures):
U.S. Nuclear Regulatory Commission Region II Attn:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. J. Holonich Sequoyah Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. G. G. Zech, Director TVA Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37319
ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SEQUOYAH NUCLEAR PLANT GENERIC LETTER 83-28, ITEMS 3.2.1 AND 3.2.2 A.
Item 3.2.1 - Review of Test and Maintenance Procedures and Technical Specifications (All other safety related components)
REQUEST It was concluded from review of your submittal dated November 7, 1983, that the Nuclear Power Operational Quality Assurance Manual (OQAM) requires maintenance instructions to contain requirements for postmaintenance operational testing of critical structures systems and components (CSSC) prior to the equipment being returned to service.
It is also understood that the OQAM requires maintenance requests to be reviewed by the responsible section and Field Quality Engineering Section prior to the performance of maintenance on CSSC.
However, it could not be determined from your response whether the postmaintenance test procedures were actually reviewed to determine if the testing adequately demonstrates that the equipment is capable of performing its intended safety functions. If the above review was performed, you need to submit an unambiguous statement confinming that postmaintenance test procedures were reviewed to ensure that the testing demonstrates that the equipment is capable of performing its intended safety functions.
RESPONSE
In response to this issue, Sequoyah is providing the following statements which confirm the existence of a controlled review process for all plant procedures to ensure adequate testing and equipment reliability.
Sequoyah's administrative instruction AI-4 entitled, " Preparation, Review, Approval and Use of Plant Instructions, Revision 57," states that all Sequoyah procedures receive a " review for technical adequacy and organization accuracy" not less than once every two years to determine if changes are "necessary or desirable." Procedures which function as postmaintenance test (PMT) procedures at Sequoyah fall under three categories:
(1) procedures which directly implement surveillance requirements within technical specifications; (2) procedures which function as PMT procedures; and (3) procedures which contain work activities with specific provisions for postmaintenance testing within the procedure. The two-year technical adequacy review ensures that these PMT procedures perform their intended function and that when the procedure is used to satisfy technical specifications, the test methodology fully implements the SRs.
Sequoyah's plant procedures are presently undergoing review and update as required by AI-4.
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e To improve methods of identifying which PMT procedure or applicable portion of a procedure may be required following a specific maintenance activity, Sequoyah is developing a plant procedure on PMTs. This procedure will provide specific guidance to the maintenance planners by outlining in matrix form the types of postmaintenance testing that should be considered versus the types of maintenance performed. The end product of this program will be to (1) provide clearer guidance to planners for the type of PMT to be considered, and (2) identify to the planner if an existing PMT procedure is available.
The initial draf t of this procedure is scheduled for completion by March 20, 1987.
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Item 3.2.2 - Check of Vendor and Engineering Recommendations for Testing and Maintenance (All Other Safety-related Components)
REQUEST You indicated that a two-year review of procedures and instructions is required by the OQAM to determine if changes are necessary or desirable.
However, it is not quite clear from this response whether this review entailed a check of vendor and engineering recommendations to ensure that appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications.
If the two year review does adequately verify that appropriate vendor and engineering recommendations have been incorporated into procedures, you need to provide a statement confirming that the requirements of Action Item 3.2.2 have been completed.
If not, you should submit a schedule for when this review will be completed.
RESPONSE
The two-year review of procedures at Sequoyah was not designed to ensure that vendor recommendations were specifically incorporated.
Vendor information was routed to each affected plant section and was utilized and incorporated into a procedure if it was deemed appropriate by the responsible section.
Sequoyah is presently making changes to its vendor manual control program as necessitated by commitments made in TVA's Corporate Nuclear Performance Plan (NPP),Section VI E.4.
The Sequoyah vendor manual program was revised in 1984 to upgrade the existing program to agree with the Nuclear Utility Task Action Committee (NUTAC) report on Ceneric Letter 83-28, Section 2.2.2, Vendor Equipment Technical Information Program. This revision included issuance of 4
Quality Notice NQAM, Part V, Section 6.2 (ID-QAP-6.2) entitled, " Vendor Manual Control."
As a result of organizational and vendor manual control commitments made in l
the NPP, Sequoyah is now implementing a two-phase program. The first phase is a prerestart phase which was initiated under Quality Notice NQAM, Part I, Section ID-QAP-6.2, Revision O.
This phase requires that the plant perform a preliminary review of procedures which implements technical specification or environmental qualification (EQ) requirements to ensure that vendor l
information is up to date.
The second phase is a postrestart phase which extends the program to include i
technical review of existing and incoming vendor manuals by TVA's Division of Nuclear Engineering (DNE).
The postrestart phase is scheduled to be in compliance with the NUTAC recommendations on vendor information by January 31, 1988.
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