ML20081D240
| ML20081D240 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 10/28/1983 |
| From: | Giesler C WISCONSIN PUBLIC SERVICE CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| CON-NRC-83-192, RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.6, TASK-TM NUDOCS 8311010079 | |
| Download: ML20081D240 (3) | |
Text
r NRC-83-192 WISCONSIN P U B LI C S E RVIC E CO R PO R ATIO N RO. Box 1200, Green Bay, Wisconsin 54305 October 28, 1983 Director, Office of Nuclear Reactor Regulation Attention:
Mr. D. G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant TMI Action Plan Item I.C.6: Verification of Correct Performance of Operating Activities In the course of a management review of our commitments made in response to NUREG 0737 requirements, we have identified an area that warrants further discussion.
NUREG 0737 provided licensees with a compilation of the TMI-Action items that have been approved by the Commission for implementation.
Included in the document was item number I.C.6 entitled " Guidance on Procedures for Verifying Correct Performance." The intent of this item was to require that licensees procedures be reviewed and revised as necessary to assure that an effective system of verifying the correct performance of operating activities is pro-vided.
The clarification provided in NUREG 0737 described "an acceptable program for verification of operating activities."
Included in the clarification is a reference to Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)" and ANS 3.2 " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." Reg. Guide 1.33 endorses ANS 3.2 subject to several supplemental provisions. Of particular interest to WPSC is the following provision:
(5) For the return-to-service of equipment important to safety, a second qualified operator should verify proper systems kO 8311010079 831028 PDR ADOCK 05000305 P
Mr. D. G. Eisenhut October 28, 1983 Page 2 i
alignment unless functional testing can be performed without compromising plant safety, and can prove that all equipment, valves, and switches involved in the activity are correctly aligned.
NOTE: A licensed operator possessing knowledge of the systems and the relationship of the systems to plant safety would be a
" qualified" person. The staff is investigating the level of qualification necessary for other operators to perform these l
functions.
Our letter dated September 10, 1981, from' E. R. Mathews (WPSC) to S. A. Varga (US NRC), informed you of our intent to perform independent verification of valves important to safety when our on-shift staff is increased. An addi-tional operator was added to the on-shift staff on January 2, 1983.
The operations department procedures and surveillance procedures were reviewed to identify important manual valves which could render a train or system ino-perable and the procedures were revised to require independent verification of these valves.
In addition, we have also implemented a bi-weekly (once every i
two weeks) procedure which provides an additional independent check of these l
valves.
Administrative Control Directive (ACD) 4.3 entitled 'Tagout Control' was also revised.
The Tagout Control Directive identifies those systems for which independent verification is required and provides exceptions for which physical independent verification is not required (i.e. functional test, high radiation, etc.). These procedures and directives control the activities of control room operating crew. This method of implementation was given interim approval by your Safety Evaluation Report (Reference 3) which stated we would be in full conformance when an additional qualified person / operator is on-shift on January 3, 1983.
We believe we have fully satisfied our connitments in regard to this item.
However, it has become apparent through the aforementioned management review that there are additional areas of activity performed by personnel not in the operations group that should be included in this. program of independent veri-fication.
Some of these additional areas have been automatically included via the Tagout Control procedure. Other activities which may'be applicable to this requirement are not subject to the Tagout Control procedure.
In order to address this item completely, WPSC will take the following actions:
1.
The ecuipment subject to independent verification will be iden-tifiec. Based on our preliminary discussions, we believe it is appropriate to limit this equipment to that required for containment integrity and core-cooling in the event of an accident. This will involve the following systems:
---Reactor Coolant System j
--Safety Injection System l
--Residual Heat Removal Sy.; tem
--Internal Containment Spray i
--Auxiliary Feedwater System 7
n s
Mr. D. G. Eisenhut October 28, 1983 Page 3
--Diesel / Generator
--Containment Isolation Valves
--certain portions of Service Water System
--certain portions of Component Cooling System
--certain portions of Chemical and Volume Control System
--certain instrumentation associated with the above systems, including Engineered Safety Feature Actuation Instrumentation 2.
The activities subject to independent verification will also be iden-tified. These include, and are expected to be limited to, routine activities covered by Surveillance Procedures, Preventive Maintenance Procedures, and Instrument and Control Procedures, non-routine acti-vities covered by Maintenance Work Requests, Special Test procedures, and Construction Procedures (Design Changes would fall under the latter category), and jumper and lifted lead control.
3.
The procedures governing the activities identified in step two will be reviewed by the appropriate group to assure that the intent of the independent verification requirement is met.
Guidance will be deve-loped by WPSC to be used in this review.
This guidance will include a discussion on what constitutes an independent verification (e.g.:
Tagout Control, functional test, or checklists), the proper qualifi-cations for the person performing the independent verification, and the affected equipment.
(It should be noted that based on our prelim-inary work on this item, it appears that the NRC's guidance on
" qualified operator"--that is, a licensed operator--may not be appropriate for all of these activities.) Additionally, an Administrative Control Directive will be developed to provide guidance to personnel involved in the preparation of special test and construction procedures, and the existing ACD on Jumper Control will be revised to include lifted lead control.
WPSC has already begun taking these actions.
However, because of the magni-tude of the work involved, and in order to proceed on an orderly basis without unduly taxing the resources of any individual or group, we are planning on incorporating the procedure review into our normal 2-year review process.
Accordingly, we expect to have the appropriate equipment identified and the required ACD revisions completed by January 1, 1984.
The procedure reviews will begin by January 1, 1984 and will be complete by January 1, 1986.
In the interim, our current practices comply with our previous commitments in this regard.
Very truly yours, hgn NL i
C. W. Giesler Vice President - Nuclear Power CAS/js I
cc - Mr. S. A. V6rga, US NRC Mr. Robert Nelson, US NRC l
L