ML20237H885
| ML20237H885 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/10/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8708170397 | |
| Download: ML20237H885 (3) | |
Text
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e cf TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 374o1 SN 157B Lookout Place 14US 101987 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - 10 CFR 50.49 CLOSEOUT DOCUMENTATION FOR RESTART This letter is to follow up discussions held between TVA and NRC staff regarding closeout of 10 CFR 50.49 affected issues for SQN restart--more specifically, restart 50.49 documentation.
Discussions were held between TVA.
and NRC Environmental Qualification (EQ) project technical personnel, and subsequently between TVA Licensing and NRC SQN project management personnel.
The following provides the substance of the discussions and agreements reached.
By the nature of the SQN 10 CFR 50.49 program, it tends to be on the " tail end" of many problem areas because it is affected by a wide range of problems and their resolution; an example of this is the main steam line break (MSLB) profile inside containment (containment cooling) issue.
Resolution of such issues may result in revisions to technical evaluations, changes in calculations, changes in category and operating times, additions to the SQN equipment list, and possible fieldwork. The process of completing fieldwork and/or documentation changes is handled within the SQN EQ program, ultimately resulting in EQ binder revisions / updates. While the established SQN EQ program utilizes the binders to support qualification of 50.49 equipment, in many cases, documentation supporting qualification--as required by 10 CFR 50.49 -exists before generation of the binder revisions.
In those situations, the binder revision is basically an administrative update.
In consideration of resolution of 50.49 affected technical issues--analysis and/or fieldwork--that may be coming to a close between this time and restart and the time required for the normal administrative binder revision process, TVA proposed establishing a documentation criteria for SQN restact.
This criteria will require documentation levels less than the full administrative process through binder revisions, but a level fully in compliance with 10 CFR 50.49.
TVA wanted to ensure the staff was aware of and in agreement with this decision to avoid confusion or misunderstanding.
TVA is not in any way revising its program, only referencing an intermediate point during the documentation and administrative process where 10 CFR 50.49 compliance is demonstrated.
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l The following provides the general criteria to be used for defining acceptable 2' CFR 50.49 compliance required for restart:
1.
For issues such as containment cooling, TVA's Digital System 1,000 aging calculations for all affected equipment would be placed in "pending" files for each Sinder involved.
Qualification is established at this point in advance of formal issuance of binder revisions. However, any new binders required (e.g., the new binder for lower compartment cooler motor) would have all supporting documentation completed and the binder would be prepared, checked, and reviewed by management, t
2.
For EQ fieldwork, qualification is established upon documented completion of the installation / modification and' acceptable functional testing. This is at a point in advance of revision of the binder (s) to remove the open items from the front of the binder.
1 3.
Required analysis, documentation, or fieldwork that might arise from any
" late breaking" problems that affect 50.49 equipment would be handled in I
accordance with items 1 and 2 above.
As previously stated, this issue and the above criteria have been fully discussed with the NRC technical reviewer for SQN's EQ program, George Hubbard, and we understand both he and his immediate management concur with TVA's usage of this criteria to define 50.49 compliance. It-was subsequently discussed between Marci Cooper, of TVA SQN Site Licensing, and Tom Rotella, NRC SQN project management, in a telephone conversation on July 10, 1987. Following review and discussion of this information with his management, Mr. Rotella indicated the project staff would find usage of this criteria acceptable for restart as long as compliance with 10 CFR'50.49 is assured; i.e.,
TVA must be able to demonstrate environmental qualification of 50.49 equipment through auditable documentation in compliance with 10 CFR 50.49.
Documented compliance with 10 CFR 50.49 is not affected by use of the above criteria.
If you have any questions regarding this letter or previous referenced discussions, please telephone Mike Harding at 615/870-6422.
Very truly yours, TENNESSEE V EY AUTHORITY
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R. Gridley, D rector Nuclear Safet and Licensing cc: See page 3 l
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U.S. Nuclear Regulatory Commission-
/\\lllB 101987
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Mr. G. G. Zech, Assistant Director for Inspection Programs Office of Special Projects U.S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia' 30323 Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects-Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814 Sequoyah Resident' Inspector Sequoyah Nuclear Plant 2600 Jiou Ferry Road Soddy Daisy, Tennessee 37379
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