ML20141C617
| ML20141C617 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah  |
| Issue date: | 06/23/1997 |
| From: | Hernan R NRC (Affiliation Not Assigned) |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| References | |
| TAC-M95676, TAC-M95677, TAC-M95678, TAC-M95756, TAC-M95757, NUDOCS 9706250341 | |
| Download: ML20141C617 (5) | |
Text
J Mr. Oli er D'. Kingsley, Jr.
trbutikn:
President, TVA Nuclear and SQN Reading File L. Campbell Chief Nuclear Officer BFN Reading File E. Ford Tennessee Valley Authority PUBLIC S. Black 6A Lookout Place S. Varga J. Johnson, RII 1101 Market Street J. Zwolinski ACRS Chattanooga, TN 37402-2801 Docket File OGC
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - TECHNICAL SPECIFICATION CHANGE REQUEST TS 95-19 FOR SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 AND CHANGE REQUEST TS-372 FOR BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 (TAC NOS. M95756, M95757, M95676, M95677, AND M95678)
Dear Mr. Kingsley:
The staff is reviewing the subject proposed Technical Specification (TS) change requests submitted by the Tennessee Valley Authority (TVA) in letters dated June 6 and June 7, 1996. The purpose of the proposed changes is to revise Section 6 of the TS (Administrative Controls) for the Sequoyah and Browns Ferry nuclear plants to be more closely aligned with the Revised Standard TS. The proposed TS changes are being reviewed concurrently with our review of Revision 7 to the TVA Nuclear Quality Assurance Plan (NQAP),
submitted to the NRC by letter dated October 11, 1996.
During our review process, we have identified the need for additional information in order to complete our review of the TVA request. Our request for additional information (RAI) is enclosed.
These questions were discussed with your staff during a telephone call on February 10, 1997.
Note that many of these questions are the result of inadequate justifications provided for the TS amendment requests and the proposed NQAP.
TVA did not provide a clear reference to requirements relocated to the NQAP, and often did not provide any justification for changes to the relocated requirements.
Also, coherent review was not possible when the amendment submittals were received, because the proposed NQAP revision was not submitted concurrently with the amendment requests.
Please contact me at (301) 415-2010 or Joseph Williams at (301) 415-1470 if you have any questions.
Sincerely, M
Original signed by Ronald W. Hernan, Senior Project Manager
)
Project Directorate II-3
\\
Division of Reactor Projects - I/II g
Office of Nuclear Reactor Regulation 2b,OO31 Docket Nos. 50-327, 50-328, 50-259, 50-260, and 50-296
Enclosure:
Request for Additional Information cc w/ enclosure:
See next page EC HLE CENTER COPY DOCUMENT NAME:
G:\\SQN\\95756.RAI TO GET a copy of this document,inecete in the boa: 'C' = Copy without ettechment/ enclosure "E" = Copy with ettechment/ enclosure
'N' = No copy 2
PDII-3/LVl PDII-3/PD-C l
0FFICE PDII-3/PN PDII-3/PM NAME RHernan /Aff JWilliamsf/F BClayf6'n FHebdon-k
_DATE 6/.Q3/97 '
6/ I3/97/'
6/7Q97 6/.u /97 9706250341 970623
- FICIAL RECORD COPY PDR ADOCK 05000327 P
. ~ -.
911Nr D. Kingsley, Jr.
BROWNS FERRY NUCLEAR PLANT l
Tennes%eV111eyAuthority SEQUOYAH NUCLEAR PLANT 4
cc:
Mr. O. J. Zeringue, Sr. Vice President General Cour.sel Nuclear Operations Tennessee Valley Authority Tennessee Valley Authority ET 10H 4
6A Lookout Place 400 West Summit Hill Drive 1101 Market Street Knoxville, TN 37902 Chattanooga, TN 37402-2801 M". Raul R. Baron, General Manager i
Mr. Jack ' A. Bailey, Vice President Naclear Assurance and Licensing 1
Engineering & Technical Services Tennessee Valley Authority j
Tennessee Valley Authority 4J Blue Ridge i
6A Lookout Place 1101 Market Street 3
1101 Market Street Chattanooga, TN 37402-2801 Chattanooga, TN 37402-2801 Mr. Pedro Salas, Manager Mr. Timothy E. Abney, Manager Licensing and Industry Affairs Licensing and Industry Affairs Tennessee hlley Authority Browns Ferry Nuclear Plant 4J Blue Ridge Tennessee Valley Authority 1101 Market Street i
i P.O. Box 2000 Chattanooga, TN 37402-2801 Decatur, AL 35609 i
Mr. Masoud Bajestani, Plant Manager Regional Administrator Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission Tenussee Valley Authority Region II P.O. Box 2000 61 Forsyth Street, SW., Suite 23T85 Decatur, AL 35609 l
i Atlanta, GA 30303-3415 Mr. R. J. Adney, Site Vice President 1
Chairman Sequoyah Nuclear Plant Limestone County Commission Tennessee Valley Authority 310 West Washington Street P.O. Box 2000 Athens, AL 35611 Soddy Daisy, TN 37379 Mr. Ralph H. Shell, Manager Mr. J. T. Herron, Plant Manager Licensing and Industry Affairs Sequoyah Nucleaf Plant Sequoyah Nuclear Plant Tennessee Valley Authority TennesseeValleyAuthority P.O. Box 2000 P.O. Bcx 2000 Soddy Daisy, TN 37379 l
Soddy Daisy, TN 37379 County Executive
=
Mr. Michael H. Mobley, Director Hamilton County Courthouse oivision of hadiological Health Chattanooga, TN 37402-2801 i'
3rd Floor, L and C Annex 401 Church Street Mr. Leonard D. Wert Nashville, TN 37243-1532 Senior Resident Inspector Browns Ferry Nuclear Piarit Mr. Helvin C. Shannon U.S. Nuclear Regulatory Commission Senior Resident Inspector 10833 Shaw Road Sequoyah Nuclear Plant Athens, AL 35611 U.S. Nuclear Regulatory Commission 25Q0 Igou Fer y Road Mr. C. M. Crane, Site Vice President Soddy Daisy, TN 37379 Browns Ferry Nuclear Plant State Health Officer Tennessee Valley Authority P.O. Box 2000 Alabama Department of Public Health Decatur, AL 35609 434 Monroe Street Montgomery, AL 36130-1701
I RE00EST FOR ADDITIONAL INFORMATION TENNESSEE VALLEY AUTHORITY SE000YAH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NUMBERS 50-327. 50-328 BROWNS FERRY NUCLEAR PLANT. UNITS 1. 2. AND 3 DOCKET NUMBERS 50-259. 50-260. AND 50-296 Browns Ferry and Seauovah 1
On Page 22 of 136 (second paragraph from the bottom) of the proposed revision to the Tennessee Valley Authority (TVA) Nuclear Quality Assurance Plan (NQAP), what does the "or equivalent" mean and permit?
The NRC position, as delineated in Standard Review Plan (SRP) 13.4, is that personnel performing the independent safety engineering (ISE) function should meet the requirements of Section 4.4 of ANS 3.1, which does not provide for "or the equivalent." Please clarify the intent of this NQAP requirement.
2.
TS Section 6.3.1 (SQN) and 6.3 (BFN) - The revised TS Section, as proposed, is not consistent with NUREG-1431 or NUREG-1433.
These NUREGs provide current staff positions on TS content, and include references to RG 1.8 and ANSI [ STANDARD NUMBER). Therefore TVA is requested to add RG 1.8 to the TS wording.
3.
TS Section 6.4 - The requirements being removed from TS (retraining and replacement training facility staff) do not appear to be in Revision 7 of the NQAP.
TS Section 6.5.'2.1 - Provide reference to NQAP sections containing 4.
requirements equivalent to TS 6.5.2.1.
Justify any differences between the current requirements and the proposed NQAP requirements.
5.
TS Sections 6.5.2.4; 6.5.2.5, and 6.5.2.6 - Where are current TS Sections 6.5.2.4 (WSRB Consultants), 6.5.2.5 (NSRB Meeting Frequency),
and 6.5.2.6 (N58 Quorum) addressed in the revised NQAP7 Justify any differences Ntween the current requirements and the proposed NQAP requirement,.
6.
TS Sectian 6.5.2.7.a - The current TS Section 6.5.2.7.a requirements have b0en reduced in their relocation to the proposed Revision 7 of the NOAP (Section 4.1.3.B.5.b.1).
Present TS would require a review of all safety evaluations.
In the relocation of these requirements to proposed Revision 7 of the NQAP, the relocation appears to have reduced the review scope and would only require a review of complaisd 50.59 evaluations on a sample basis. Justify the reduced scope of safety evaluation reviews by the NSRB.
l i
2 7.
TS Section 6.5.2.7.i - Justify removal of requirements for NSRB review of PORC meeting minutes in the proposed NQAP.
8.
TS Sections 6.5.2.10.a and 6.5.2.10.b - Justiff the extension from 14 to 30 days for preparation, review, and forwarding of Nuclear Safety Review Board (NSRB) minutes and reports.
4 9.
TS Section 6.5.2.10.c - Provide references to equivalent requirements in the proposed NQAP, and justify any differences beiween the current requirements and the proposed NQAP requirements.
10.
TS Section 6.10 - Provide references for records retention requirements proposed to be relocated to the NQAP. Justify any differences between the current requirements and the proposed NQAP requirements.
11.
TS Section 6.13 (SQN), 6.11 (BFN) - The staff's position regarding the Process Control Program (PCP) is that the controls for the review and approval of future changes to the PCP should be addressed by the licensee in a document controlled under 10 CFR 50.54(a).
Please incorporate appropriate PCP requirements into the proposed NQAP.
Seauovah Plant-soecific auestions 1.
TS Section 6.2.3 - ISE function. This section was to be incorporated into the TVA NQAP.
Section 4.1.3.C.7.b.16 of the NQAP appears to be the section to which these TS requirements were relocated.
The following changes (between the current TS and revised NQAP) were noted that are not soecifically discussed in the TS 95-19 submittal:
a.
The words " independent technical review" are used instead of "ISE" in the NQAP.
b.
It appears that the personnel involved in the ISE function report
" Site Manacjer, Liceneing and Industry Affairs" in the NQAP rather than the " Manager, independent Review and Analysis" as stated in the current TS.
c.
The independent technical review function (ISE in the TS) is the responsibility of the " Site Nuclear Assurance and Licensing (NA&L)
Manager." This apparent reorganization is not discussed or explained in the submittal for TS 95-19.
d.
The NRC staff was unable to find the equivalent of TS 6.2.3.2,
" COMPOSITION," (of the ISE) in the revised NQAP.
Provide a discussion of these differences between the current SQN TS and Revision 7 to the NQAP.
2.
Proposed Revision 7 to the NQAP (see paragraph 4.1.3.C.7.b on Page 22),
lists qualifications for Nuclear Assurance and Licensing (NA&L) technical reviewers. What is the basis for these proposed qualffications for personnel performing the ISE functions (e.g., ANSI N18.7-1976)?
i 3
Browns Ferry - Plant-Soecific Ouestigni 1.
Changes to TS 6.7.1.a and 6.7.1.c propose changing a reference to the Senior Vice President, Nuclear Power to the Site Vice President.
Provide justification for assigning these responsibilities to a lower level within the TVA organization.
2.
Deletion of TS 6.9.1.1 regarding startup report requirements. What mechanism exists to provide information to the staff for power level, fuel design, or thermal-hydraulic changes?
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