ML20235E537
| ML20235E537 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/02/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20235E539 | List: |
| References | |
| PROC-870702, NUDOCS 8707110104 | |
| Download: ML20235E537 (19) | |
Text
{{#Wiki_filter:- _ _ _ _______ _ _ REVISION 2 J U L Y 19 8 7'. .] I I REVISED SEQUOYAH NUCLEAR: . I PERFORMANCE PLAN l 1 l O l l
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4 J TENNESSEE VALLEY AUTHORITY - JUL Y 1986 O hD ADO K O 27 . p PDR
Revision 2 TABLE OF CONTENTS (continued) 15.0 Miscellaneous Programs III-66 15.1 Miscellaneous Civil Engineering Issues III-66 15.2 Moderate Energy Line Break Flooding III-67 15.3 Containment Coatings III-67 15.4 ECCS Water Loss Outside Crane Wall III-68 15.5 Platform Thermal Growth III-68 15.6 Heat' Code Traceability III-69 IV.
SUMMARY
OF SEOUOYAH ACTIVITIES l 1.0 Description of Sequoyah Activities List IV-1 1 2.0 Methodology Used to Identify Restart Items IV-2 !
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3.0 Sequoyah Activities List (SAL) IV-il
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N V. OPERATIONAL READINESS l 1.0 Introduction V-1 l 2.0 Purpose V-1 l 3.0 Scope V-1 4.0 Method 1 5.0 Implementation V-2 I l 5.1 SNPP Volume 2 V-2 5.2 Performance Objectives Evaluation V-2 5.3 Restart Prerequisite Verification V-3 I 6.0 Reporting V-3 l 7.0 Independent Readiness Review
'.l V .4 I s 8.0 Nuclear Safety Review Board V-4 REFERENCES APPENDIX 1 - TVA Response to NRC Request for Information Under 10 CFR 50.54(f) on Sequoyah Nuclear Plant APPENDIX _2 - Additional Sequoyah Actions to Improve Plant Performance APPENDIX 3 - List of NRC Correspondence Pertinent to Sequoyah Nuclear Plant i
1i1 l
Revision 2 LIST OF TABLES
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- 1. Sequoyah Site Organization II-4
- 2. Sequoyah Nuclear Plant Organization II-5
- 3. Site Quality Organization II-18
- 4. Site Licensing Organization II-21
- 5. Sequoyah Staff Qualifications 11-28
- 6. Systems Required to Mitigate FSAR Chapter 15 Events and Safely Shutdown the Plant III-13
- 7. Restart Requirement Criteria IV-13 l 0 1
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l l l 4 i O e
I Revision 2 The program exists in the form of a Sequoyah Engineerin ! f f ' Project Manual, EQP Manual, and site procedures (e.g., g I standard practices and administrative instructions). Howeve., certain activities associated with the implementation of these ' program requirements are in' progress or under review. These l incicde: ' The SQN site maintenance groups are reviewing the new qualification maintenance data sheets (QMDSs) that are 1 Jocated in Tab G of the EQ binders and comparing them to the existing program to ensure that qualification is i maintained by performing the required EQ maintenance. ; Essential EQ maintenance will be' performed or verified as I having been performed prior to restart. Those ! requirements thdt have an expiration date after restart ! will not necessarily be performed prior to restart. ' Field work to implement essential EQ maintenance is . approximately 99-percent complete.
- Open items in the issued EQ binders will be closed before restart. As an example, EQ binders have been issued to the site with identified field work-related open items identified on an open item sheet in the front of the binder. This sheet includes a' description of the open items. When the outstanding field work is corrolete, an ;
Environmental Quality.Information Release (EQIR) is (. j Initiated to update the binder with the necessary j documentation. The closure process for field corrective i actions is about 92-percent complete. SQN.will review corrective actions r6sulting from items i discussed in Sections III.2.0 and III.4.1 of this l performance plan for impact on program requirements or design inputs. As the process of documenting the qualification of electrical equipment in the scope of 10 CFR 50.49 progressed, various technical issues and discrepancies requiring resolution were identified. These problem l areas involved both equipment-related problems, many of which required field corrective action, and issues regarding the required support documentation, for the EQ program including a few remaining items from NRC's previous inspection. Although most of'these items have been resolved, there are still some open items. '
.A significant problem area addressed by the EQ Progran, was damage due to localized areas of high temperature in '
the main steam valve vaults (MSVVs). Damage was i identified in cables serving equipment-in the east and West MSVVs. This damage was attributed +o exposures to l temperatures higher than the. design ambient. An O III-6
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Revision 2 Involve DNE into the procurement process as an integral l r function.
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The Replacement Items Project activities have been structured { into the following major elements to implement the program: { Prior to restart, review the plant's maintenance history to identify the activities that have replaced safety-related components or items.
- t Prior to restart, perform an evaluation on previously installed 10 CFR 50.49 (environmentally qualified) i replacement items and on seismically sensitive components i that are installed within the Phase I DB&VP boundary.
Dedicate commercial grade material installed or currently in stock for use in safety-related applications. Prior to restart, establish a conditional release program ~ for Quality Level II items. This conditional release
-l program permits these items to be issued and installed l prior to the closure of the dedication process for those items. These items are tracked from issuance to their specific application to ensure. future evaluation.
After restart, evaluate commercial-grade items located in l the power stores warehouse. The purpose is to determine what may be released and used for present maintenance. (A) After restart, perform an engineering evaluation of the ! other safety-related replacement items. After restart, develop pre-engineered specifications detailing technical and quality requirements, source audit and inspection requirements, receipt inspection requirements, part conditioning requirements, and, if applicable, post-maintenance testing requirements. 12.3 Program Implementation Documentation necessary to establish replacement item qualification is developed through an engineering review and evaluation by DNE. Installed safety-related replacement items are identified through a compl'ete evaluation of the plant equipment maintenance history. This is accomplished in a phased approach through a review of maintenance requests, preventive maintenance activities, surveillance instructions, and workplans. Procurement documents for replacement items are identified and reviewed by DNE before release. An engineering evaluation is performed to ascertain that the installed item is suitable for its intended application. The qualification status verification has, as its final product, a ( v) previous procurement substantiation package. This package e 111-59
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. 1 Revision 2 4
IV.
SUMMARY
OF SE0VOYAH ACTIVITIES I
1.0 DESCRIPTION
OF SEQUOYAH ACTIVITIES LIST The Sequoyah Activities List (SAL) is a list of all actions (including TVA commitments) applicable to SQN unit 2 that are ' considered important to the restart of SQN unit 2 or to the implementation of programmatic issues identifled in the SNPP which are not required to be completed before the restart of SQN unit 2. y The SAL is ncit a detailed punchlist and it does not include all 9 actions to be completed after restart of SQN unit 2. Therefore', updating of the SAL will be discontinued when all the identified issues on it are closed. The corrective actions for each restart SAL ltem provide the appropriate details for ensuring that the full scope of the SAL item is properly addressed. Each SAL ttem is classified as restart or nonrestart. The SAL reports the status of . those items which have been closed and is further defined and , l,'j tabulated in section IV.3.0. - The SAL represents a snapshot in time and therefore will change >as , time progresses. As a result, the SAL is maintained separately from !
-the controlled version of the SNPP, and. updates of the restart items are periodically provided to NRC.
,1 SAL restart items and associated commitments, other than TVA i Corporate Nuclear Performance Plan (CNPP) commitments, are grouped l Into major program areas. These program areas are as follows: I Environmental Qualification
- Design and Configuration Control
- Cable Tray Support Analysis
. Design Calculations Review Alternately Analyzed Piping and Supports
- Main Steam Temperature
- Fire Protection, 10 CFR 50 Appendix R
- Helding Program Review
- = Sense Line Issues
- Hall. Thinning Assessment Program i
. Restart Test Program I
- Component Piece Part Qualification
- Electrical Issues Containment Isolation Design Review Misc.ellaneous Programs Employee Concerns Program Maintenance
- Quality Assurance Identified Additional NRC Requirements Miscellaneous SAL Items TVA commitments which correspond to SAL items are denoted by a commitment number. Commitments are tracked by TVA on its corporate commitment tracking system (CCTS). SAL items with no commitment l
O number are activities which TVA management considers necessary to implement the changes and improvements described in the SNPP. IV-1
L 1 . l Revision 2 O Restart SAL items and the associated plans and goals listed or l b) Stated in the revised SNPP, which are not classified as commitments, may be changed by TVA as appropriate to reflect experience gained through the improvement programs. Any such changes would be part of the updates to the SAL which TVA periodically provides to NRC. l Included in section IV.3.0 is the list of CNPP commitments pertaining to SQN. This listing correlates the CNPP commitment to the appropriate CNPP page number and identifies each action as to status relative to SQN: ongoing, complete, restart, or long term. l 2.0 METHODOLOGY USED TO IDENTIFY RESTART ITEMS l A special Sequoyah Restart Task Force was established by S. A. White, TVA Manager of Nuclear Power, on March 19, 1986, to l verify the identification of problems and initiate action for ., l resolution, where necessary, before restart of SQN. This task force-was composed of high-level management from TVA and outside i i consultants with extensive nuclear experience in operations, quality assurance, design, construction, and project management. The task force examined SQN issues to ensure that the actions to be taken at ' SQN would suitably address the root cause of identified problems. This section describes the methodology by which issues were identified for inclusion on the original SAL and sets forth the
/' criteria used to evaluate each issue to determine which items would
( be required to be resolved before the restart of SQN. This section also contains a description of the processes and controls used to revise the SAL and to ensure closure of each SAL item consistent with its intent. A. Development of the SAL The CNPP (Volume 1) established the direction and the objectives for the SNPP. The task force used that evaluation and others to focus attention on issues and programmatic problems requiring resolution before restart. Under the guidance of the task force, the line organization began development of a list of all issues or conditions which would need to be resolved or corrected before the restart of either SQN unit. To establish a baseline, the restart and potential restart items from the following sources were placed on the Sequoyah Restart List (SRL):
- 1) Nuclear Engineering Restart List - Items were identified by the Division of Nuclear Engineering (DNE) from a review of all open significant condition reports (SCRs),
nonconformance reports (NCRs), engineering change notices (ECNs), NRC and internal inspection reports, NRC commitments, and action items on the Tracking and g Reporting of Open Items system (TROI). Those items that i V 4 were considered to be significant were listed and then each item was evaluated for its importance to restart. IV-2 1 L _-__-_-
Revision 2
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- 11) Division of Nuclear Quality Assurance (DNQA) - DNQA
( provided a list of items from a Quality Assurance (QA) ) report on operational readiness which addressed DNQA audits, the corporate Institute of Nuclear Power Operations (INP0) evaluation report, all open corrective action reports (CARS), all open discrepancy reports (DRs), all open Nuclear Safety Review Staff.(NSRSJ issues, and' the findings from studies performed by outside engineering fl.rms such as Gilbert Commonwealth, Black and Veach, and Stone and Webster. 111) Project 2 (P/2) Outage Schedule - Key activities were il included _from the then current P/2 scheduled outage work which was scheduled to be completed before restart. 7
.d iv) Corporate Commitment Tracking System (CCTS) - This included NRC commitments required to be completed before .
restart or by the end of the current outage as planned at
- that time.
v) Employee Concerns - All issues identified by the Employee Concern Program as applicable to SQN were evaluated to determine the safety significance and were included if judged to be important to restart. vi) The NRC "Stello" Plan - This was reviewed, and the O activities required to support NRC's review were identified to ensure consistency and completeness. vil) NRC OIE. inspection reports - Items from the Systematic. Assessment of' Licensee Performance.(SALP). report and other inspection reports issued'between September-17, 1985, and April 1986 that were restart issues were' included.
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After this process, a baseline was established which identified-approximately 560 potential restart items. The task force reviewed the list and interrogated the responsible line managers and lead engineers to ensure that:
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- 1) all potential restart issues were identified;
- 11) the methodology used to evaluate restart items was sound-and addressed the full issue; ill) the resolution of issues integrated input from all appropriate disciplines and had Quality Assurance (QA) participation and input; and tv) control systems.were established to appropriately track and close each issue or item.
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4 Revision 2 I ( As'the list evolved, the task force developed a set of restart I ( screening criteria to provide written guidance for the line organization to use in identifying restart issues. These criteria, as pre'iented in the SNPP, were structured to identify programmatic deficiencies having a high probability of causing a specific deficiency which, in turn, would be a restart issue and to provide a sound method for evaluating specific deficiencies to identify safety significant conditions. Additional criteria were provided to ensure that personnel health and safety, radiological controls, and regulatory requirements were also considered in establishing the SRL. In an April 1986 :..emorandum, the Site Director required all responsible supervisors to use the restart screening criteria to verify the SRL. In addition, he also directed them to review new ;
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and unresolved items in their area of responsibility and to present { these items for review by the task force. Th'e development of the l SRL was being performed concurrently with a complete rewrite of the., 4 SNPP; and, during this time, it was decided to expand the SRL to include activities and issues from the revised SNPP and other sources and thereby expand the list beyond " restart items" to include issues considered important to the implementation of the SNPP. This new list was called the SAL and classified items as restart or nonrestart. The task force provided the guidance and the responsible line O organizations within the Office of Nuclear Power (ONP) identified additional issues and activities. As issues were identified, h responsible supervisors used the restart criteria to determine which items should be completed before restart. Their recommendations were presented to the task force for review, and the SAL was revised l accordingly. The following are examples of some of the actions to I ensure that the SAL was comprehensive: I i) CCTS entries opened after September 17, 1985, were reviewed by responsible organizations and added to the list as appropriate.
- 11) The NRC correspondence, including the September 17.-1985 10 CFR 50.54(f) letter, was reviewed to ensure that NRC concerns had been identified and an appropriate SAL action item existed or was added.
111) Commitments and major issues from the text of the revised SNPP were added, and the SAL was organized into program areas based on the special programs of the revised SNPP, section III. iv) Newly identified issues from further review of the Watts Bar Employee Concern Special Program or from the newly established ONP Einployee Concern Program were evaluated and added to the list. O IV-4 )
Revision 2
/ As a result of these actions, a draft SAL was published and Q circulated to all divisions and sites for review and comment.
comments were incorporated and a revised draft was then reviewed, The item by item, during a meeting of all responsible organizations with Mr. White. This process produced the SAL that was submitted to the NRC in July 1986 as part of the revised SNPP. That list was comprised of 702 restart and nonrestart items applicable to SQN units 1 and 2. i Based on the' number and scope of the areas evaluated for potential SAL items, the numerous requests by the task force and TVA management for potential SAL items, and the expertise of the task force, TVA is confident that the SAL submitted with the SNPP in July 1986 encompassed all the restart issues applicable to SQN unit 2 and known to TVA at that time. B. Process for Revision of the SAL . Shortly after the SNPP was submitted, SQN management established a process for controlling revisions to the SAL and for scheduling'and tracking actions required to resolve each issue on the SAL. These processes were described in a memorandum from the Site Director to those managers responsible for ensuring that particular SAL items were resolved and corrective actions completed. The Planning and Scheduling staff was assigned the responsibility for control of revisions to the SAL and the use of the P/2 scheduling program to track completion progress. The emphasis at SQN shifted from problem identification to implementation of the SNPP, evaluation and resolution of appropriate corrective actions for the problems identified on the SAL, and the preparation and conduct of the special programs described in the SNPP section III. As these efforts proceeded, additional technical I issues were identified and brought to the attention of the Site ) Director ard the task force. The Site Director's weekly review l meetings and progress reports to the task force served as another l forum to identify additional issues requiring resolution before i restart of SQN unit 2. These meetings continue to be held by the I Site Director along with the progress reporting to the Manager of Nuclear Power. As the action plans and implementati.on schedules for resolution of SAL ltems or execution of the programs described in the SNPP were l developed, they were submitted to the Planning and Scheduling staff l and entered into P/2 in conjunction with the applicable SAL item. The task force evaluated action plans, program changes, and the restart determination proposed by line management to address the basic issues that had been identified in the SNPP. 4 IV-5
Revision 2
't A set of written SAL policies evolved in August 1986 requiring that changes to the restart list be submitted to the Planning and Scheduling staff which ensured that the change was reviewed by the Site Director or the restart director and the task force. It is important to note that ONP managers were' directed and encouraged to identify new potential restart activities and that the Site Director or task force continued to review restart determinations made by the line managers.
The SAL is periodically updated for all changes and provided to the responsible managers to ensure it is regularly reviewed for accuracy. The first such update was accompanied by a transmittal memorandum which also provided written SAL policies for making j changes to the SAL. The importance of maintaining the list using approved policies was also reemphasized in a later meeting of nearly 100 managers and senior engineers. This frequent emphasis on accuracy of the SAL and the formalized policies provided assurance', ' that new issues were identified, evaluated, brought to the attention of TVA management, and added to the SAL with a restart or nonrestart designation. The common criteria used to guide the line organizations in raising issues and making recommendations to management and the task force l have been the restart requirement criteria set forth in table 7 of section IV of the SNPP. These criteria were initially established by the task force and were subsequently refined to reflect input
/9 from the Browns Ferry Nuclear Plant task force and adopt a C/ consistent format. In December, a memorandum from the Site Director
, to principal managers at SQN was issued to formalize these ! i criteria. This was not a relaxation of the criteria, and no SAL l l item was removed from the listing. Effective March 10, 1987, these criteria were made applicable as the unified restart requirement , criteria for all TVA sites. Table 7 (page 13) provides the full l text of these criteria. Line management has been instructed to use these criteria to determine which issues or corrective actions ' require resolution or completion before restart of SQN unit 1 or 2. The restart criteria in table 7 are applicable to hardware items. i l However, the principles embodied in the restart criteria can readily ' be applied to other activities, such as maintenance programs, training programs, and the procedure upgrade efforts to determine what is necessary to be completed before restart. Judgment is used when reviewing restart requirements for nonhardware-related activities. Where judgments have been made not to complete programmatic activities before restart, those judgments are reviewed by the Manager of Nuclear Power in the context of issuing the SNPP and any subsequent revisions to it. n U IV-6
Revision 2' O On March 5, 1987, the Sequoyah Restart Task Force was disestablished by Mr. White after having completed its assigned responsibilities. The methodology for identifying restart items after disestablishing the task force remains essentially as discussed in the preceding paragraphs except that the task. force review of restart ' determinations made by the line managers has been assumed by the Site Director and his designees. All potential SAL items are identified either through engineering review program recommendations or through the new Condition Adverse to Quality Report (CAQR) process. Each potential SAL item or CAQR is evaluated using the unified restart requirement criteria to determine whether associated corrective action is required to be ' completed before restart of SQN unit 2. Those items determined through these evaluations to be restart issues are presented to the Site Director's staff for approval. The Site Director is responsible for approval of particular items
- that must be resolved before restart and for ensuring that each SAL item is properly dispositioned. The Site Director has designated either the Restart Director or Assistant to the Site Director to evaluate proposed new activities and ascertain that these activities meet the restart criteria.
C. Coordination of Sequoyah Restart Activities O Following approval of a SAL item, responsibility is assigned to appropriate line managers for definition and implementation of corrective action. All SAL items are dispositioned in accordance with a SQN site procedure. Only the Manager of Nuclear Power can delete items from the activities' list that have been designated as-restart items. As noted in paragraph B, the Site Director has identified a Restart Director who is responsible for coordinating management of the restart effort. The Restart Director reports directly to the Site Director and has responsibility and authority to establish specific schedule priorities, ensure that line managers are coordinating their activities to complete all restart actions, establish site goals as appropriate to achieve a safe and timely restart, call and conduct restart schedule status meetings, and ensure performance of the individual grcups and integrated work activities. These efforts by the Restart Director have been established in order to ensure that all restart requirements are properly completed in an integrated fashion and on a timely basis. Through the activities of the Restart Director, the Site Director is provided with an early
, signal of potential problem areas ~and is able to take prompt action.
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l Revision 2 ) p s D. SAL Item Closure Process l In November 1986, the SQN Site Director initiated action to I establish a standard practice to govern the review and closure of restart SAL items. A procedure was developed, piloted, revised, and issued in December 1986. This procedure (SQA190) became effective on January 6, 1987. While the initial intent of SQA190 was to govern the closure process, it has also been useful in identifying issues and directing management attention to actions that are required to resolve issues and complete corrective action plans as ! set forth in the SNPP and related SAL ltems. The procedure 'l specifies that closure of each restart SAL ltem is accomplished !{ through an independent review by the Division of Nuclear Safety and ) Licensing (DNSL). This review encompasses the documentation that ;{ initiated the corrective action and the records that provide tj objective evidence that the corrective actionsuwere completed or ; that the issue was resolved. - As noted, the initial issue of SQA190 specified the process for i review and closure of SAL items; it also included a paragraph to ensure that potential restart SAL items would be evaluated using the restart criteria. The detailed administrative controls were set forth in the SAL policies described in paragraph B of this enclosure. Controls were established through SQA190 to ensure that none of the restart SAL items were deleted or reclassified without proper review and approval. The process established at SQN for identification and closure of activities and corrective actions required to be completed before restart of SQN unit 2 has produced the following results:
- Issues requiring resolution are identified and clearly classified as restart or nonrestart using a single, uniformly applied criteria.
- The SAL is organized by major program area in order to facilitate closure reviews of each program and each class of issue with NRC.
The closure process requires corrective actions to be * ' established, approved, and communicated to those who are responsible for the implementation. The procedure also causes corrective actions to be classified as restart or nonrestart using the restart criteria.
- The procedure requires that individuals who are responsible for each step of the process from issue identification, through implementation, to closure be identified.
- The review of closure documentation has identified problems early enough to permit TVA management to take appropriate measures.
v IV-8
l Revision 2' The individual closure packages are prepared and prechecked to O facilitate an effective review process with TVA management. These packages also identify those SAL items for which- ll postrestart corrective actions-have been specified. H At restart, TVA management will be able to have a precise and highly reliable assessment of the status of each activity on the SAL. Significant progress has been made with the completion and closure of SAL ltems. The status as of May 10, 1987, was: ;! Total number of Restart SAL items 486 Restart SAL items with restart corrective d actions complete 325 Restart SAL ltems reviewed and signed by DNSL 296 g E. Improvements to the SAL Revision and Closure Process :I In February 1987, TVA implemented its new corrective action j procedure, Nuclear Quality Assurance Manual (NQAM) Part I, section 2.16, at SQN through the issuance of SQN procedure AI-12. This { ' procedure has benefitted the process for identifying potential new I SAL ltems by consolidating, into one process, the various methods that had previously existed at SQN and elsewhere in ONP for identifying, evaluating, and determining corrective actions for O- Conditions Adverse to Quality (CAQs). Additionally, the responsibility for maintaining the list of identified CAQs and for tracking the evaluation and corrective actions has been centralized within DNQA. Thus, TVA has three basic methods of identifying potential new SAL items: engineering and management recommendations arising from the various programs that TVA is implementing, licensing commitments, and CAQRs. Each CAQR issued under the new procedure and the associated corrective actions will be evaluated as a potential restart issue utilizing.the restart criteria set forth in the SNPP. This review will be retroactive for all open CAQRs issued under the new procedure (AI-12). A revision to the SQN procedure SQA190 is being made to enhance the closure process and improve the controls over the process by which potential SAL 1.tems are identified and evaluated using the restart criteria. The most important changes ! are: Addition of a form to document the restart /nonrestart determination for engineering recommendations and CAQRs that have been evaluated using the restart criteria and to ensure :s adequate management review and approval. O \ IV-9
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- l Revision 2 l
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() (m Proceduralizing the requirement for approval by the Manager of Nuclear Power to remove a restart SAL item. Addition of guidance for managing the completion and ) closure of SAL items that are large in scope or are programmatic and involve many subtasks or issues, each i of which requires evaluation, resolution, and potential I corrective action (tracking SAL items).
. q Addition of guidance and requirements that are intended -l to facilitate the closure of those restart SAL items having associated ECNs.
As an added measure, the SQN Site Director initiated a review .j of the processes that have been in use at SQN over the past (' eight months to identify and evaluate potent'lal. SAL items. This review will provide an independent assessment for the . Site Director of whether the restart criteria have been - ( appropriately applied to the screening of potential restart l SAL items and associated corrective actions. This review was conducted by QA on a sample be. sis and the findings are now being evaluated. l These actions and changes to the procedure will: ensure that issues continue to be reviewed and added to the SAL, if appropriate; improve TVA's accountability over tr.e work O required to implement the SNPP; and make more manageable the 1 I i V completion and closure process--thus helping to ensure that l the overall objectives of the SNPP will be achieved. '
'J IV-10 E _ _----__ - - - - - - -
Revision 2 3.0 SEOUOYAH ACTIVITIES LIST (SAL) o The SAL contains the following information for each entry: ;
- Unique I.D. Number ,
- Description - paraphrasing the actual scope statement I from the source document :
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Restart Classification (Yes or No)
- Commitment Number from CCTS, if applicable ..
- Volume 2 Reference, if applicable -{
Unit 2 Status The status column contains one of four categories as follows: Closed - All corrective actions have been accomplished and j documented. j i i
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Restart Complete - All corrective actions that have been specified to be completed before restart are accomplished and documented. Remaining corrective ' actions have been identified and are being tracked in CCTS or P/2. l Duplicate - The scope of the SAL item is the same as, or falls ' within the scope of, another SAL item. Open - Corrective action is incomplete. In assigning a " closed" status to restart items in the SAL, the following definitions were used:
- Review of SCRs/NCRs, CAORs, Technical Evaluations, Surveys / Audits of Systems and Programs, Technical Issues Resolution, etc., Not Directly Covered by Design Change Requests (DCRs)/ECNs These items can be classified as closed on the activities list once the actual review, evaluation, survey, audit, etc., has been completed to the point where the task requires no further corrective action by l anyone and the acceptable results of these tasks have been documented. This includes actions identified to prevent recurrence if such actions are required.
Work Associated with Restart DCRs/ECNs These items can be classified as closed on the activities list once the task defined by the DCR/ECN has been completed to the point where the system can be declared operable. In addition, the following steps are required: drawings in the main control room have been O IV-11
Revision 2-properly marked, all required plant procedures have been. O revised and issued or a temporary change is in place and approved, and the workplans are signed as being complete I I by the cognizant workplan engineer and Operations Section personnel, or a partial' modifications completion form has been initiated and approved.
. Work Associated With Restart DCRs/ECNs Not Requiring 1 Physical Work on Plant Systems ;
These items can be classified as closed in the activities list once the work required for restart has been completed to the point where the task requires no l further corrective actions by anyone and results of the i q accomplished work have been adequately documented as acceptable. -
- l In general, restart items which were closed before March 1986 do not appear on this list. The purpose of listing closed items is to indicate the progress which has been made on restart items since March 1986.
Activities list items associated with issues identified in the.
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Employee Concerns Program are annotated by an asterisk which follows the item description.
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l i b IV-12 .
Revision 2 Table 7 RESTART RE0VIREMENT CRITERIA H The following criteria shall be used in evaluating whether a particular , item must be resolved before restart of unit 2 at SQN. L
- 1. The item identifies a specific deficiency which has significant d probability of leading to the inoperability of a system required for- p' restart or operation by the appropriate technical specifications. '
- 2. The item identifies t programmatic deficiency which has a high probability of causing or has caused a specific deficiency which meets No. I above.
NOTE: To assist in the determination of required for restart relative to technical specifications as in criteria No. I and No. 2 above, an affirmative answer to any of the following
- questions requires consideration of the item for restart based on technical specification requirements. '
- a. Does the item directly and adversely affect safety-related equipment function, performance, reliability, or response time? <
- b. Does the item indirectly and' adversely affect O safety-related equipment power supply, air supply, cooling, lubrication, or ventilation?
- c. Does the item adversely affect primary containment integrity? )
- d. Does the item adversely affect secondary containment integrity?
- e. Does the item adversely affect control room habitability?
- f. Does the item adversely affect systems used to ;
process radioactive waste? i
- g. Does the item adversely affect fire protection or fire loads?
- h. Does the item adversely affect the ability of a i i
system or component to meet its safety function !
.during a design basis event by impacting the seismic j analysis, single failure criteria, separation criteria, high energy line break assumptions, or equipment qualification?
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. i IV-13 !
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Revision 2 i Table 7 (continued) h %/ Are the programs such as Radiological Health, 1. Security, Radiological Emergency Preparedness, or Quality Assurance which are necessary for safe conduct of cperation of the plant adversely affected?
- j. If not corrected before restart, could it lead to an uncontrolled release or spread of radioactive contamination beyond the regulated area?
- 3. The item identifies a specific deficiency that results ,
i in a failure to comply with.NRC regulations and no variance has been approved by NRC.
- 4. TVA has committed to NRC to complete the. item before restart. ,
- 5. The item identifies a specific deficiency which has a significant probability of leading to a personal injury during plant operation. <
- 6. The item identifies a specific condition which has a forced outage risk (probability X outage length) during the next cycle in excess of the critical path time to correct the condition before restart.
O IV-14}}