ML20098E174
| ML20098E174 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/28/1992 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20098E172 | List: |
| References | |
| CON-TVA-SQN-TS-92-06, CON-TVA-SQN-TS-92-6 NUDOCS 9206020012 | |
| Download: ML20098E174 (13) | |
Text
-.
ENCLOSURE 1 PROPOSED TECIINICAL SPECIFICATION (TS) CHANGE SEQUOYAll NUCLEAR PLANT UNITS 1 AND 2 DOLKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-92-06)
LTST OF AFTECTED PAGES UniLl 3/4 6-5 3/4 6-6 3/4 6-23 UniL2 3/4 6-5 3/4 6-6 3/4 6-24
'9206020012 920528 PDR ADOCK 05000327
.p PDR
ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING (ISE)
FUNCTION 6.2.3.1 The ISE shall function to examine plant operating characteristics, NRC issuances, industry advisories, licensee Event Reports and other sources which may indicati areas for improving plant safety.
COMPOSITION 6 ?.3.2 The ISE shall be composed of at least 3 dedicated full-time engineers la:ated ansite.
These engineers will be supplemented as necessary by full-time of 5 full-time engineers performing the ISE functiuns applicable ggn s
R_ESPONSIBILITIES 6.2.3.3 activities to provide independent verification
- that these activities are perfornad correctly and that human errors are reduced as much as practical.
^UTHORITY 6.2.3.4
' "quipment modifications, or other means of improving plant safety to t
- n e
.:nagcr ;f clear Manager *4eview Croup. -
6.2.4 SHIFT TECHNICAL ADVISOR (STA)
Yw iw AcG% NucIehR h,Evieu)s 6.2.4.1 The STA shall serve in an advisory capacity to the Shif t Supervisor on matters pertaining to the engineering aspects of assuring safe operation of lR15' the unit.
R16 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each mober of the facility staff shall meet or exceed the minimum qualifi-R78 cations nf-AM&f-fEfhl-1971-for comparable positionwend-the-supplemental-
--eeeui-remen trc-spec 4f4 e bi n4ec t i o n a and.-C-of-4440s MRC lettee-to-aM-licensees -except-fon-th%54te-Rawe--1 ef-the March-24v-199n
--who-s ha ll-mee t-o r-e x c e ed-the-q ua14 f4 ca t4ons-o f-R eg udiologicabControbManageo-v atory4uide-178 R15t
4eptembee-1975.
h6 Sf E C 1 Ft E O w
++W TVA Nuc lwe que1 A nawa Pha.
3 1
- Not responsible for sign-of f function.
i SEQUOYAH - UNIT 1 6-5 Amendinent No. 12, 58, 74, 119 152 g l p.'
ADMINISTRATIVE CONTROLS 6.4 TRAINING 6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Plant Manager and shall meet or l R15 exceed the requirement 5,w++eeommendat-iens-ef-Seetion-5-5 of-ANil-M18.1-1971
-and-AppewlW' of 10 CFR Part 55 and thedropplemental-requirefrents-specit-iet
-indettion-A -end-O-of-Enclosure 1 of-the-H reh-2&r-1980-NRC-letter-to aH-
-'icen:cc 4 and shall include familiarization with relevant industry operational experience.
TVA Aluc ic a e cashry 6.6 REVIEW AND AUDIT
[f f u AW C E b4A/j 6.5.0 The Senior Vice President, Nuclear Power is responsible for the safe R78 operation of all TVA power plants.
6.5.1 PLANT,WERATIONS REVIEW COMMITTEE (PORC)
FUNCTION 6.5.1.1 The PORC shall function to advise the Plant Manager on all matters related to nuclear safety.
R6(,
COMPOSITION I
6.5.1.2 The PORC shall be composed of the:
Chairman:
Plant Manager l R156 Member:
Operations Manager Member:
Site Radiological Control Manager Member:
Maintenance Manager Member:
Technical Support Manager Member:
Quality incering and Monitoring petvisoe--
R156 Member:
Nuclear Engineering Representative
)
/
ku DIT
/{lJwAGM i
i r
SEQUOYAH - UNIT 1 6-6 Amendment No. 58, 74 R78 1s2
- ggg,
4 gMINISTRATIVECONTROLS en%
6.10.2 The following records shall be retained for the duration of the Unit Operating Licanse: -
a.
Records and drawing changes reflecting unit design modifications made to systams and equipment described in the Final Safety AnaJysis Report.
b.
Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories, c.
Records of radiation exposure for all individuals entering radiat*
contrul areas.
d.
Records of gaseous and liquid radioactive material released to the
- environs, e.
Records of transient or operational cycles for those unit components identified in Table 5.7-1.
f.
Records of reactor tests and experiments.
g.
Records of t.
ining and quaiification for current members of the facility staff.
R78 h.
Records of in-service inspections performed pursuant to these Technical Specifications.
1.
Records c' Qualit" Assurance activities required for lifetime reten-4 R62 tion by ts NuclearQualityAssurance-Manuej j.
Records of reviews performed for channes made to procedures or equipment or reviews of tests and experiments pursuant to,10 CFR 50.59.
k.
Records of meetings of the PORC, SQN RARC, and the NSRB.
R62 1.
Records of analyses required by the radiological envircaental monitoring program.
m.
Records of secondary water sampling and water quality.
n.
Records of the service life monitoring of all safety-related hydraulic and mechanical snubbers, required by' T/S 3.7.9, including the main-tenance performed to renew the service life.
o.
Records for Environmental Qualification which are covered under the R62 provisions of Paragraph 2.c.(12)(b) of License No. DPR-77, p.
Records of reviews performed for changes made to the 0FFSITE DOSE R
CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.
l SEQUOYAH - UNIT 1 6-23 Amendment No. 42, 58, 74, 148 NOV
~ ' ' '
h ADMINISTRATIVE CONTROLS
(
~
6.2.3 INDEPENDENT SAFETY ENGINEERING (ISE)
FUNCTION 6.2.3.1 The ISE shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources which may indicate areas for improving plant safety.
COMPOSITION 6.2.3.2 The ISE shall be composed of at least 3 dedicated full-time engineers located onsite.
These engineers will be supplemented as necessary by full-time engineers shared among all TVA nuclear sites to achieve an equivalent staffing R108 of 5 full-time engineers performida the ISE functions applicable to Sequoyah.
RESPONSIBILITIES 6.2.3.3 The ISE shall be responsible for maint/ining surveillance of plant activities to provide independent verification *.nat these activities are performed correctly and that human errors are reduced as much as practical.
AUTHORITY 6.2.3.4 The ISE shall make detailed recommendations for revised procedures, I
equipment modifications, or other means of improving plant safety to the
-H anager-o f-H ue4 ea4nagees-Rev4ew-Gr4up,-
T w' Ahapacee, mudEM. )he ws 6.2.4 SH!FT TECHNICAL ADVISOR (STA) 6.2.4.1 The STA shall serve in an advisory capacity to the Shift Supervisor on
\\R142 matters pertaining to the engineering aspects of assuring safe operation of the unit.
R66 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications ef MS! M19.1-1971 fer comparable positiorsAmd th ;spp4emental--
--requiremen ts-4 pec44f ed-4 n-Sec t4 on-A-and-C--o f-Enc 4 o s u rel-o 1 -March-2S, 1000-NRC--
--4ettee-to414-41consees -except40r-thMite-Radiologica1--Sontro4-Managee-lR14' r
-who-sha14-meet-or-exceed-the -qua14 f4 cat 4ons-of-Regulatory-4ulde-la r
--September-1975r-N OEcinEo tx THE TVA Nucmbt funhPf Assaisce Plini.
I
- Not responsible for sign-off function.
SEQUOYAH - UNIT 2 6-5 Amendment No. 50, 66, 14?,
108 gc
ADMINISTRATIVE CONTROLS
(
- 6. 4 TRAINING 6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Plant Manager and shall meet or exceed the requi rements and-recomendations-of-Section-Gr6-of-ANEHH&-1-lWi-jiau
-and-Append 4*-4'1 of 10 CFR Part 55 and thcAsupplemental-requirements--specified-
-in-Section a 14mf-Emlosure-14f-the-Arch-28 -1980-NRC-4ettemtoall--
1 licensassr.and shall include familiarization with *elevant industry operational R50 experience.
T vi; tju citi Ail cQunin11?
ASTWPANCE h/f4 l
6.5 REVIEW AND AUDIT 6.5.0 Senior Vice President, Nuclear Power is responsible for the safe opera-tion of all TVA power plants.
P. 66 6.5.1 PLANT OPERATIONS REVIEW COMMFiu
- SORQ, FUNCTION 6.5.1.1 The PORC shall function to advb. :, Plarit Manager on ali matters related to nuclear safety.
Pl'0 COMPOSITION
/
6.5.1.2 The PORC shall be composed of the:
h Chai rman:
Plant Manager Member:
Operations Manager ggg',
4 Member:
Site Radiological Control Manager Memter:
Maintenance Manager Member:
Technical Support Manager RM2 Member:
QualityAEmyineeHng and Monitorin ervisor Member:
Nuclear Engineering Representative t
(
fmy(
NANA&E&
(,
SEQUOYAH - UNIT 2 6-6 Amendment No. 50, 66, 142 AUG 9
ADMINISTRATIVE CONTROLS
~
i 6.10.2 The following records shall be retained for the duration of the Unit R28 Operating License:
a.
Records and drawing changes reflecting unit design modifications made to systen.s and equipmen; described in the Final Saf ety Analysis Report, b.
Records of new and irradiated fuel inventory, fuel transfers and
- sssembly burnup histories.
c.
Records of radiation exposure for all individuals entering radiation control areas, d.
Records of gaseous and liquid radioactive material releasec to the environs.
e.
Records of transient or operational cycles for those unit components identified in Table 5.7-1.
f.
Records of reactor't'ests and experiments.
g.
Records of training and qualification for current members of the facility staff.
h.
Records of in-service inspections performed pursuant to these Technical Specifications.
9 i.
Records of Quality Assurance activities required fo 1 etime reten-R50 tion by the Nuclear Quality Assurance L u ul.-
/g j.
Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
R50 k.
Records of meetings of the PORC, SQN RARC, and the NSRB l.
Records of analyses required by the radiological environmental monitoring program.
m.
Records of secondary water sampling and water quality, n.
Records of the service life monitoring of all safety-related hy-draulic and mechanical snubbers, required by T/S 3.7.9, including the maintenance performed to renew the service life, o.
Records for environmental qualification which are covered under the R34 provisions of paragraph 2.C.(10)(b) of license No. OPR-79, E13' p.
Reccrrds of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.
(
R134 SEQUOYAH - UNIT 2 6-24 Amendment No. 28, 50, 66, 134,
,]
34
ENCLOSURE 2 PROPOSED TECllNICAL SPECIFICATION (TS) CllANGE SEQUOYAll NUCLEAR PIANT UN11S 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (IVA-SQN-TS-9 2-06 )
DESCRIPTION AND JUSTIFICATION FOR PROPOSED CitANGE TO SPECIFICATIONS 6.2.3.4 6.3.1. 6.4.1, 6.5.1.2, AND 6.10.21 4
-_.m__-.u____.-_-_._______
ENCLOSURE 2 i
j
. Description _ oL_ Change Tennessee Valley Authority (TVA) proposes to modify the Sequoyah Nuclear Plant (SQN) Units 1 and 2 technicci specifications (TS) to revise Specification 6.2.3.4 to reflect a restructuring within IVA's Nuclear Power organization. The proposed administrative change specifically addresses Independent Safety Engineering (ISE) with regard to the title of the manager to whom ISE reports.
The proposed change to Specifications 6.3.1 and 6.4.1 reflects that the staf f qualification and training progrmn requirements are specified in the Nuclear Quality Assurance Plan.
The proposed changes to Specifications 6.5.1.2 and 6.10.21 are minor administrative changes that reflect the current IVA organizationni nomenclature for the Nucluar Quality Assurance plan and update the title for the Quality Assurance (QA) Manager currently serving on the Plant Operations Review Connittee (PORC).
Recanlor_ Change As part of an organizational change in September of 1991. TVA brought the corporate Nuclear Experience Review function into the Nuclear Managers Review Group (NMRG). At that time, TVA changed the nar.e of the group from NMRG to Nuclear Reviews to more accurately reficct the expanded organizational responsibilities. That change did not impact ISE in that the smne reporting relationships were maintained. The organizational changes within the management structure of IVA's Nuclear Power organizatisu have been made to provide a sharper focus on oversight and assessment functions.
As part of an effort to make the TS consistent with the Nuclear Quality Assurance Plan and current regulatory guidance, TVA proposes to change Specifications 6.3.1 and 6.4.1, to reflect current staff qualifications and training requirements.
TVA meets the requirements of Regulatory Guide (RG) 1.8 Revision 2, with alternatives as specified in the Nuclear Quality Assurance Clan.
The title of the QA Manager serving on PORC as specified in Specification 6.5.1.2 is being updated to reflect the current title for this position.
The title change was a result of increased
~
)
responsibilities recently added to this position.
Specification 6.10.21 is being revised to reflect the current title given to the document that sunnarizes the QA program at TVA.
Justif.ication_for_ Change The proposed change to Specification 6.2.3.4 reflects the current TVA Nuclear Power organization.
The organization maintains the appropriate level of independence with regard to ISE's review and auditing functions within TVA'c Nuclear Power program.
ISE will continue to perform on-site independent reviews of plant operations under the manager, Nuclear
l 2-Reviews, within the corporate Nuclear Assurance organization. This change maintains compliance with NUREG-0737 guidance and the standard TS to ensure that ISE reports to a high-level corporate official in a technically-oriented position who is not in the management chain for power production and not an integral part of the QA organization.
The proposed change to Specification 6.3.1 reflects WA's commitment to meet the requirements of RG 1.8 Revision 2 (4/87) for all new personnel qualifying on positions identified in Regulatory Position C.1 after January 1, 1990. - lersonnel qualified on these positions before this date will still meet the requirements of RU 1.8, Revision 1-R (5/77).
As specified in Regulatory Position C.2, all other positions will meet the i
requirements of American National Standards Institute /American Nuclear Society N18.1-1971. This commitment is currently reflected in the TVA l
Nuclear Quality Assurance Plan (TVA-NQA-PLN 89-A).
The proposed change to-Specification 6.4.1 is to reflect that in 1987 10 CFR 55 was revised to allow facilities to substitute programs based on j
a systematic approach to training methodology and conducted using a
. plant-referenced simulator certified to FRC, for the existing regulatory based programs.
This revision was promulgased to reflect the Commission'a acceptance of industry initiatives in the training arena and is 4,ntended to provide flexlhility to liccusees who maintain accreditation through the National Academy for Nuclear Training and conduct training of operators on certified, plant-referenced simulators. This revision eliminated Appendix A of 10 CFR 55 and superseded the operator licensing requirements of NUREG 0737 and 0094 Clarification to the rule was provided in industry meetings throughout the United States and the questions and answers from these meetings were published in NUREG - 1262.
In NUREG - 1262, Questions 1 through 4 clarify the issue of which requirements were superswed by this revision.
Training program structure and content guidance continue to 1,o governed by the corporate-level training program procedures contained in the Nuclear j'
Power-Training Manual. These program procedures,;which are quality-related, are subject to review in accordance with 10 CFR 50.59.
Additionally, these procedures describe the programs accredited by the National Academy for Nuclear Training. Accreditation is not granted or maintained unless compliance with the academy-published guidelines is established. These guidelines are consistent with, and in many areas, exceed-the regulatory requirements previously required.
The proposed change to Specification 6.5.1.2 is to reflect the title change of a PORC member from, " Quality Engineering and Monitoring Supervisor" to " Quality Audit and Monitoring Manager." This is a title change only, and the duties and functions-of this member remain the same.
In conclusion, the proposed change to Specification 6.2.3.4 still ensures l
l that the independent assessment of plant activities by.ISE meets or exceeds the requirements of NUREG-0737.
Proposed changes to specifications 6.3.1 and 6.4.1 are-reflective of current regulatory guidance. Other proposed changes.are for consistency with TVA's nomenclature and organizational structure as shown in the Nuclear Quality Assurance Plan that was received and approved by NRC letter dated March 3, 1992.
l.
y J
q.y-..eeny-
- y-q
-+i-e,--
p
.-+--7,gw
.e4p+.%
-pg %mege1-.s
+-.-.----n.<y.--s.gg.w--.9-w g-9m9 y
w-y-
yw-wypa..wwp g + y7e c yy a-t99 -y
4 EnvironmentaLImpac tlvaluat ion The proposed change request does not involve an unreviewed environmental question because operation of SQN Uni.ts 1 and 2 in accordance with this change would not 1.
Result in a e,ignificant increase in any adverne environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the staff's testimony to the Atomic Safety and Licensing r,oard, supplements to the FES, environmental impact appraisals, or decisions of the Atomic Safety and Licensing Board.
2.
Result in a significant change in efflu;nts or power levels.
3.
Result in matters not previously reviewed in the licensing basis for I_
SQN that may have a significant environmental impact.
~
E
\\
4 e
ENCLOSURE 3 4
PROPOSED TECilNICAL SPECIFICATION (TS) CilANGE SEQUOYAll NUCLEAR FIANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (WA-SQN-TS-92-06)
DETERMINATION OF NO SIGNIFICANT !!AZARDS CONSIDERATIONS l
i.
ENCh0SURE 3 SIGNIFICANT HAZARDS EVA1.UATION TVA has evaluated the proposed technical specification change and has determined that it does not represent a significant hazards consideration based on criteria established in 10 CFR 50.92(c).
Operation of Sequoyah Nuclear Plant (SQN) in accordance with the proposed amendment will nott (1)
Involve a significant increase in the probability or consequences of an accident previously eveluated.
The proposed title change of the corporate of ficial to whore Independent Saf ety Engineering (ISE) makes recommendations has no effect on the safe operation of SQN.
This change is administrative in nature and serves to reflect recent organizational changes within TVA's Nuclear Power program. The proposed change to Specifications 6.3.1 and 6.4.1 reficcts consistency with the Nuclear Quality Assurance Plan and current regulatory guidance. The proposed changes to Specifications 6.5.1.2 and 6.10.21 are nomenclature and title changes only.
Since the proposed amendment will not result in any changes to hardware, operating procedures, or accident analyses, the probability or consequences of an accident previously evaluated have not been increased.
(2) Create the possibility of a new or dif f erent kind of accident f rom any previously analyzed. The proposed change to Specification 6.2.3.4 provides a change in the title of the corporate of ficial to whom ISE makes recomn endations.
This change is an administrative change that reflects realignment of the management structure within TVA's Nuclear Power organization.
The proposed change to Specifications 6.3.1 and 6.4.1 reflects consistency with the Nuclear Quality Assurance Plan and current regulatory guidance. The proposed changes to Specificationa 6.5 1.2 and 6.10.21 are nomenclature and title changes only.
The proposed amendment does not involve a physical change to the facility; therefore, no new or different kind of accident is created.
(3)
Involve a significant reduction in a margin o."
safety.
The proposed revision to administrative Specification 6.2.3.4 reflects recent restructuring within TVA's Nuclear Power organization.
This change in no way affects the physical facility design or safe operation of SQN.
The function of ISE continues to conform with NUREG-0737 guidance for performing independent review of plant activities.
The proposed change to Specifications 6.3.1 and 6.4.1 reficcts consistency with the Nuclear Quality Assurance Plan and current regulatory guidance. The proposed changes to rpecifications 6.5.1.2 and 6.10.21 are nomenclature and title changes only.
Because compliance with the regulatory requirements has not been compromised and because these changes did not alter the facility or its design, there is no reduction in the margin of safety.