ML20237K035
| ML20237K035 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/24/1987 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20237K029 | List: |
| References | |
| GL-83-28, NUDOCS 8708270026 | |
| Download: ML20237K035 (4) | |
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SAFETY EVALUATION BY THE 0FFICE OF SPECIAL PROJECTS RELATING TO GENERIC LETTER 83-28, ITEMS 3.2.1 AND 3.2.2 TENNESSEE VALLEY AUTHORIT_Y_
SE000YAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328
1.0 INTRODUCTION
Generic Letter (GL) 83-28 was issued by the staff on July 8, 1983.
It described intermediate-term actions to be taken by the licensees and applicants to address the generic issues raised by the two Anticipated Transients Without Scram (ATW3)
Events that occurred at Unit 1 of Salem Nuclear Power Plant.
Items 3.2.1 and 3.2.2, of the generic letter required licensees and applicants to submit results of their review of test and maintenance procedures and vendor and engineering recommendations to assure that appropriate test guidance' is included in the' test and maintenance procedures or the Technical Specification, where required.
By letter dated November 7,1983, Tennessee Valley Authority (TVA), the licensee for Sequoyah Nuclear Plant, provided information regarding its compliance with Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1 of GL 83-28. The staff has evaluated the licensee's responses to the above items against the NRC positions described in the GL for completeness and adequacy. We found the licensee's responses to be acceptable for Items 3.1.1, 3.1.2 and 4.5.1, but the responses to Items 3.2.1 and 3.2.2 were incomplete, thus requiring additional information to determine acceptability.
A Safety Evaluation (SE) for the above items and a Request for Additional Information were transmitted to the licensee by NRC letter dated December 18, 1986.
The licensee submitted supplemental responses for Items 3.2.1 and 3.2.2-in a letter dated February 11, 1987. Our evaluation of these responses follows.
2.0 EVALUATION By letter dated November 7,1983, TVA responded to the requested information concerning the status, plans, and schedules for conformance with the NRC positions contained in GL 83-28. Our evaluations revealed that Items 3.2.1 and 3.2.2 were incomplete, thus requiring more information. A subsequent licensee letter dated February 11, 1987, provided sufficient additional information to allow an evaluation to be made against the NRC positions as stated in the generic letter.
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l Delineated below are the results of NRC's evaluation of Items 3.2.1 and 3.2.2 of GL 83-28.
Item 3.2.1 Review of Test and Maintenance Procedures (All Othe Safety-Related I
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Components)
Item 3.2.1 requires licensees and applicants to submit a report documenting the extending of test and maintenance procedures and Technical Specifications review to ensure that post-maintenance operability testing of all safety-related equipment is required to be conducted and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to tervice.
The licensee stated in its initial response dated November 7, 1963, that its Nuclear Power Operation Quality Assurance Manual (00AM) and Standard Practice SOM2 required maintenance instructions to contain appropriate requirements for post-maintenance operational testing of~ Critical Structures, Systems and Components (CSSC) prior to being returned to service; however, an NRC site inspection revealed that these requirements were not being implemented in all cases.
The licensee's supplemental response dated February 11, 1987, confirmed l
that it has a controlled review process for all plant procedures to ensure i
One of the control procedures adequate testing and equipment reliability (.AI) AI-4, " Preparation Review, identified was Administrative Instruction and Use of Plant Instruction," which states that all Sequoyah procedures are reviewed for technical and organizational accuracy at least every 2 years. Also, the supplemental response indicated that testing procedures at Sequoyah fall under three categories listed below:
(1) Procedures which function as post-maintenance testing procedures (2) Procedures which directly implement surveillance requirements within Technical Specifications (3) Procedures which contain work activities with specific provisions for post-maintenance testing with the procedure The supplemental response further indicated that Sequoyah was developing a procedure which gives specific guidance to maintenance planners for the type of post-maintenance testing to be considered and if an existing procedure is available. The licensee had scheduled the initial draft to be complete by March 20, 1987.
The licensee's response did not actually state that a review of irdividual post-maintenance testing procedures was performed to determine if the testing actually demonstrated that the equipment would perform its intanded safety function; however, the licensee reviewed controlling procedures and confirmed that the current and continuous review of its program ensures that adequate post-maintenance testing is and will continue to be performed.
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, 1 Based on the above, the licensee's response for Item 3.2.1 meets the intent of GL 8?-28 and is acceptable, b.
Item 3.2.2, Check of Vendor and Engineering recommendations for Test and Maintenance Procedures (All Other Safety-Related Components)
Items 3.2.2 requires licensees and applicants to submit the results of their check of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications, where required, j
The licensee stated in its initial response dated November 7, 1983, that Sequoyah performed a 2 review of procedures and instructions as required by the 00AM. This response did not clearly state whether TVA actually checked or reviewed vendor and engineering recommendations to ensure that appropriate test guidance was included in the test and
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maintenance procedures. An NRC letter, dated December 18, 1986, j
requested the licensee to confirm that the 2 year review adequately verified that appropriate vendor and engineering recommendations had
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been incorporated into the procedures, or if not, to submit a schedule when the review would be completed.
l TVA responded to our request for additional information by letter dated February 11, 1987.
This response stated that the 2 year i
review of procedures at Sequoyah was not designed to ensure that vendor recommendations were specifically incorporated into the procedures, but was designed to route technical information to responsible sections for review and use, if appropriate. NRC site inspection revealed that some pertinent vendor recommendations had not been incorporated into plant procedures.
The supplemental response indicated that the licensee is upgrading its vendor manual control program as comitted to in TVA's Corporate Nuclear Performance Plan. The result of this comitment is that Sequoyah has initiated a two-phase program, pre-restart and post-restart, which requires the plant to perform reviews of procedures to ensure that vendor information is up to date, The pre-restart program, which includes Technical Specifications and Environmental Qualification requirements, is presently being implemented. The licensee has scheduled phase two, post-restart review, to be in compliance with the NUTAC recommendations on vendor information by January 31, 1988.
Based on the above description of the licensee's upgrade program, the implementation of phase one, and the comitment to extend the program to include a technical review of existing and incoming vendor infortnation by January 31, 1988, the response is acceptable.
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3.0 CONCLUSION
S Based on the above statements, the staff finds the licensee's responses and meet the intent of GL 83-28. The licensee has established a control review process which, if implemented, ensures adequate post-maintenance testing and equipment reliability. The licensee has a continuous procedure review program in operation.
In addition, they have a two phase program in operation, a pre-restart program and a post-restart program to ensure that vendor and engineering information and recommendations are reviewed and incorporated into test and maintenance procedures, as appropriate. Although the licensee's reviews are not all complete, the staff considers the licensee's responses to be acceptable.
Principal Contributor:
T. E. Conlon Dated August 24, 1987 l
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