ML20150D381
| ML20150D381 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/30/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20150D373 | List: |
| References | |
| GL-88-06, GL-88-6, NUDOCS 8807130447 | |
| Download: ML20150D381 (12) | |
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SAFETY EVALUATION BY THE OFFICE OF SPECIAL PROJECTS SUPPORTING AMENDMENT NO. 74.T0 FACILITY OPERATING LICEhSE NO. DPR-77 AND AMENDMENT NO. 66 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328
1.0 INTRODUCTION
By letters dated April 17, 1987 and March 1 and June 13, 1988, the Tcnnessee Valley Authority (the licensee) proposed changes to the Sequoyah (SQNP) Units 1 and 2 Technical Specifications (TS). The changes are to Section 6 incorporate site organizational and title changes, 2)primarily 1) to Administrative Controls, of the TS.
The changes are to delete the organization charts in accordance with Generic Letter (GL) 88-06, and 3) to revise the list of primary coolant sources outside conta.inment in the section.
The revision to the list of primary coolant sources outside containment applies only to the Unit 1 TS. This corrects errors in the list of systems outside of containment that could contain radioactive fluid after an accident.
The application dated June 13, 1988 was supplemented by the licensee's letters dated June 22 and 24, 1988, 2.0 E R VATION 2.1 Application Dated April 17, 1987 By letter dated April 17, 1987, the licensee submitted proposed changes to Section 6.8.5.a of the Unit 1 TS to correct errors in the list of systems outside of containment that could contain radioactive fluid after an accident.
Section 6.8.5.a identifies systems outside of containment that could contain primary coolant after a Design Basis LOCA. The proposed change jeletes references to the charging system, the iodine cleanup system and the hydrogen recombiner system and adds the Reactor Coolant System (RCS) sampleisystem to the section.
Section 6.8.5.a of the Unit 1 TS erroneously includes the charging system, iodine cleanup system and the hydrogen recombiner system and excludes the RCS Sample System from the list of systems outside of containment that could i
contain primary coolant after a LOCA. The charging system is part of the Chemical and Volume Control System which is already referenced in Section 6.8.5.a.
The Sequcyah plant does not contain art iodine cleanup system. The i
Sequoyah Hydrogen Recombh.ers are internal to the containment; therefore, they have no components outside containment.
The RCS sample system can transport primary coolant vutside containment after a LOCA; therefore, it should be included in Section 6.8.5.a.
8807130447 800630 PDR ADGCK 05000327 P
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1 2-Based on the' improvement in accuracy of Section 6.8.5.a provided by this TS change, thc proposed change is acceptable.
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2.2 Application Dated March 1, 1988 By letter dated March 1, 1988, the licensee requested changes to the j
The proposed changes Administrative Controls section (Section 6) of the TS.
are to reflect corporate and site organizational changes for the units.
2.2.1 Figures 6.2.1 and 6.2-2 The request to revise Figures 6.2-1 and 6.2-2 was withdrawn in the licensee's application dated June 13, 1988.
See Section 2.3 of this evaluation below.
2.2.2 Specifications 6.2, 6.3, 6.4, 6.5.2.8 and 6.10.2 The license.e has proposed several changes to use the word "facility" when refer. ing to both units and the word "unit" when referring to only one of the two units.
As an example, in Specification 6.3.1, the "facility" staff is proposed in place
- of the "unit" staff because the staff of both units is being referred to. These changes are acceptable.
The request to revise Section 6.2 was withdrawn in the licensee's application dated June 13, 1988.
See Section 2.3.3 e
of this evaluation below.
2.2.3 Specification 6.2.3.4, Authority The licensing staff title was c' hanged from Nuclear Safety and Licensing to Nuclear Licensiag and Regulatory Affairs. This was done to clarify.he independence of the Nuclear S,afety Review Board from the licensing staff. There are no changes in lines of authority or responsibility relate o these TS changes.
d This change is acceptable because it iu,,,esents a title change l
only.
2.2.4 Specification 6.5.1, Plant Operations Review Committee.(PORC)
The licensee has requested that as part of the technical support reorganization, the PORC composition be revised to reflect the superintendent positior.s as members. The Operations Manager and Quality Engineering (CE) Manager are also retained as members.
A Division of Nuclear Engineering representative is added as a PORC member to provide engineering expertise.
This change is acceptable to the staff because with the proposed reorganizaticn it maintains the PORC composition consistent with the PORC responsibility to provide a diverse, upper management oversight review of activities affecting nuclear safety.
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2.2.5 Specification 6.5.1A, Technical Review and Control, The licensee has proposed revisions to section 6.5.1A because the Plant Mar eger and the plant superintendents are ultimately responsible for the safe operation of the plant. As such, the activities that affect nuclear safety are under their supervision and control. The Site Director is deleted from the authority of designating the appropriate responsible manager to approve procedures and of approving designated Administrative Procedures. The Technical Support Superintendent and Site Radiological Control Superintendent are added to the individuals who may (1) approve Administrative Procedures and (2) propose modifications and implementing work plans to structures, systems, and ccmponents that affect plant nuclear safety.
Further, a minor word addition is made in Section 6.5.1A.1.c for consistency with other wording in the Section. The staff agrees that the changes are consistent with the intent of this specification and are, therefore, acceptable.
2.3 Application Dated June 13, 1988 On March 22 -1988, the staff issued GL 88-06 entitled "Removal of Organization charts from Technical Specification Administrative Control Requirements." The staff used GL 88-06 as guidance in reviewing the licensee's application dated
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June 13, 1988 for changes to TS Section 6.
By letter dated June 13, 1988, as supplemented June 22 and 24,1988, the licensee submitted a request for changes to Section 6, Administrative Controls, of the TS to incorporate GL 88-06.
The first proposed change would replace.the organization charts currently in the TS with more gereral organizational requirements. Most of these elements are already required by regulation, other TS or the Final Safety Analysis Repcrt, as described below.
The.sr general requirements capture the essence of those organizational features depicted on the charts that are important to the NRC for ensuring that the plant will be l
operated safely.
In addition, the licensee proposed to make several other l
changes to Section 6.
These include:
chnging references of Manager of Nuclear Power to "Senior Vice President, duelear Power" in different> places in the TS; and changing references of "shift and "control room" to "unit.' shift" and "unit control room" in TS Section 6.2.2.
Because the first proposed change ideletion of organization charts from TS) is the most significant of those in the amendrrent request, the next several pages of this Safety Evaluation are devoted to an evaluation of this issue, with a d' cussion of applicable regulatory require 7 nts, past practice, and safety considerations. The remaining TS changes proposed by TVA are then evaluated.
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.4 2.3.1 Figures 6.2-1 and 6.2-2 Section 6.0 of the licenste's TS is required to contain the details of tho_se administrative controls necessary to assure safe operation of the facility. For the first change, TVA proposed to replace Sequoyah TS 6.2.1, TS Figure 6.2-1 (the figure showing the offsite organization), and TS Figure 6.2-2 (the figure showing the unit onsite organization) with more general organizational requirements. These general requirements capture the essene.e of those organizational features depicted on the charts tha, are important to the NRC for ensuring that the plant will be operated safely.
TVA stated that the proposed changes are justified because they are administrative in nature and do not affect plant operation.
TVA notes that, in addition to being required by the TS, the important organizational features depicted on the organization charts are also required or controlled by other regulatory (QA) control mechanisms.
For example, TVA's Quality Assurance Program for Sequoyah is required by 10 CFR 50, Appendix B, to include similar information relating to the organizational structure.
The licensee contends that changes to these charts have resulted in processing unnecessary amendments by both TVA n d the NRC.
The licensee has stated that deletion of the organization charts will, therefore, eliminate needless expenditure of resources for both organizations.
2.3.1.1 Regulatory Requirements Applicable to Organizational Structure I
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l 10 CFR 50.36, "Technical Specifications," which implements Act, was promulgated by the l
Section 182a of the Atomic Energy (33 FR 18610).
Comission on December 17, 1968 This rules l
delineates requirements for determining the contents the TS. The TS set forth the specific characteristics of the facility and the conditions for its operation that are required to provide adequate protection to the health and safety of the public.
Specifically, 10 CFR 50.36 requires that:
1 Each licensee authorizing operation of a production or i
l utilizatior< facility of a type described in Section 50.21 or 50.22 will include Technical Specifications.
The l
Technical Specifications will be de','ived from the analyses i
l and evaluation included in the safety analysis report, and l
amendments thereto, submitted pursuant to 50.34.
The l
Comission may include such additional TS as the Comission l
finds appropriate.
The regulation further states that the TS will include, among other things, items in the following category:
3 Administrative Controls: Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe Each licensee shall submit any reports to the manner.
Comission pursuant to approved Technical Specifications as specified in Section 50.4.
2.3.1.2 Past Practice Review of the organization, personnel qualifications, education, experience, training, and their overall capacity to operate a plant safely has always been of concern to the NRC, and its predecessor, the AEC.
Before a plant is licensed to operate, a finding is made that the applicant's staff is capable of operating the plant safely.
In the past, the organization charts were included in the TS so that changes made after operation began would require prior NRC approval. This was dorfe to preserve certain specific features of the licensed organization.
While the regulation does not specifically require that the TS contain organization charts the practice of including organization charts in the TS began in the late 1960s. These charts nre used as an aid in depicting the organizational and managementrelationshipsthouc(httobeneededtomeettheThe practice of provisions of 10 CFR 50.36(c) 5).
organization charts in the TS has continued since4 Organization charts do depict the reporting chain for some organizational functions.that must be independent' of scheduling and operating pressures. Until 10 CFR Part 50, Appendix 8, -
"Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," was adopted in 1970, organization charts were partially relied on by the staff for assuring.this function.
As stated in 10 CFR 50, Appendix B, Criterion I, "0iganization:"
Such persons and organizations performing auality assurance functions shall report to a management level such that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
Appendix B further acknowledges that the organizational structures may take many forms, but emphasizes that regardless
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. I of structure. the individuals assigned the responsibility for execution W any portion of the program shall have access to such levels 'of mandg nent as may be necessary to perform this function. The licensee's required QA Program specifies and depicts these organizational relationships in greatcr detail than currently exists in the TS.
The practice of including orgsnization charts in the TS was established before.the advent of 10 CFR 50, Appendix B and other associated guidance documents, such as the Regulatory Guide 1.70, "Standard Format arid Content of Safety Analysis Reports for Nuclear Power Plants," and NUREG-0800 "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants-LWR Edition." A general description of the features needed by the staff to make the findings that the applicant is capable of operating the plant safely is now mandated by Appendix B.
2.3.1.3 Safety Considerations The fundamental safety issue in the proposal to delete organization charts from the TS is whether there can be reasonable assurance that the organization will operate the plant safely and remain effective without requiring prior staff approval for changes reflected in organization charts.
It has been the staff's experience that organization charts by themselves have been little help to reviewers. in assessing the safety significance of changes to the plant and licensee.
Nevertheless, because the charts are in the TS, license amendment requests have been required to effect organizational changes as simple as combining some minor functions under one organizational element shown on the chart. The usefulness of the charts to the staff in recent years has been minimal and the safety relevance of the charts themselves is small.
Specific operational requirements that bear more directly on the 9
safety matters of concern to the staff than the organization charts are required elsewhere in TS.
For example, thei organizational element responsible for the control room comand function is identified separately in the TS, as are.the requirements for minimum staffing under various operating modes.
The organizational management functions for independent reviews and audits, Unit review group and independent safety engineering groups, and shift technical advisor are also specified in other TS. Thus, the organization charts themselves are not needed to support the staff's finding that the organization will operate the plant safely.
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In sumary, the specific details of the operating organization -
are not essential to ;he safe operation of the facility, and the staff corcludes that the details can be modified in many ways while maintaining adequate operations 1 safety. Over the years of experience with the details of operating organizations, the staff has been able to identify those organizational characteristics which are important to assure plant safety.
The important features of a licensee's organization (currently depicted on the TS organization charts, but not already included in other TS) necessary for the staff to find that the organization will operate the plant safely are stated below, Lines of authority, responsibility and comunications shall a.
be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. Those relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of departmental responsibilities and relationships and job descriptions for key personne! positions, or in equivalent forms of documentation.
These organizational relationships will be maintained in a document such as the FSAR or QA Manual.
b.
There shall be an individual executive position (corporate officer) in the offsite organization having corporate responsibility for overall plant nuclear safety.
This individual shall take any measures needed to eitsure acceptable perfonunce of the staff in operating, j
maintaining, and providing technical support to the plant so that continued nuclear safety is assured.,
There shall be an indicidual manaqement position in the c.
onsite organization having respon;ibilities for overall unit safe operation which shall have control over those onsite resources necessary for safe operation and maintenance of the plant.
d.
Although the individuals who train the operating staff and those who carry out the health physics and quality assurance functions may report to the appropriate manager on site, they shall have sufficient organizational freedom to be independent from operating pressures.
Senior Reactor Operator (SR0) and Reactor Operator (RO) e.
licenses shall continue to be required for the positions so indicated on the current TS' organization charts.
. f.
Other TS which reference the current organization charts shall be revised to reference the appropriate functional responsibility or position.
This application dated June 13, 1988 proposed to revise the TS to add statements incorporating the features above to replace the organization charts being deleted.
The licensee has proposed to include the information of item a above in the organization charts and descriptions in Chapter 13 of the Sequoyah Final Safety Analysis Report (FSAR). This is proposed Specification 6.2.1.a.
The licensee's organization will be kept current through FSAR updates rather than through TS changes. The FSAR is updated annually in accordance with 10 CFR 50.71(e). Both an FSAR update and an application for a TS change are submitted to the NRC; however, the FSAR update may be implemented without Comission approval whereas a change to the TS may not be implemented without prior Commissioner approval.
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Therefore, based on the above, the staff concludes that the removal of the organization charts from the TS will not prevent' the licensee from meeting the standards of 10 CFR 50.36 and the underlying statutory requirements.
Moreover, the deletion of unnecessary detail of organization charts will save resources for both the NRC and the, licensee and will allow the staff to focus on issues of importance to the plant's safety. Therefore,
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the licensee's proposal is acceptable.
In the June 13, 1988 application, the licensee initially proposed to identify the management officers by general terminology. However, after discussians with the'NRC staff, the licensee by letter dated June 22, 1988 modified its application to identify the Senior Vice President, Nuclear Power and the Plant Manager in proposed Technical Specification' 6.2.1.b and 6.2.1.c by their titles in accordance with the recomendations of GL 88-06. This change merely adds clarity to the more general terminology issued in the June 13, 1988 request and does not affect the substance of the amendments as noticed.nor the staff's proposed no significant hazards consideration detennination. These proposed changes are acceptable.
2.3.2 Changing References to Manager of Nuclear Power The licensee proposeo to delete reference to the title, "Manager of Nuclear Power" in several different places in the TS and replace it with a reference to ' Senior Vice President, Nuclear Power." These titles are for the same position, head of the Office of Nuclear Power. The title "Senior Vice President, Nuclear Power" becomes effective with the reorganization of the Office of Nuclear Pcwer scheduled for July 1, 1988.
The NRC staff believes that a specific person in the licensee's
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. organization at the Vice President level should carry the responsibility, and that it must be clear who it is.
The staff believes that Senior Vice President, Nuclear Power is an appropriate title for this position, and the licensee's proposal is acceptable.
2.3.3 Specification 6.2 2_
See Section 2.1.2 of this~ evaluation above. The proposed addition of the word "unit" to "shift" and "control room" in Specification 6.2.2 merely adds claritu to this-section and does not affect the substance cf this secti....
Therefore, these changes are acceptable.
2.3.4 Exigent Circumstances In its application dated June 13, 1988, the licensee requested that its proposed administrative changes in this evaluation be processed on an exigent basis.
This request is asking the Comission to act quickly on the licensee's application dated June 13, 1988.
This would not permit a Federal Register notice' to be published, allowing 30 days for public coment prior to the Comission acting on the application, in accordance with 10 CFR 50.91(a)(2)(i).
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In its letters dated June 13 and 24,1988, the licensee explained that the proposed amendment is required to be effective before the Office of Nuclear Power may be reorganized.
The licensee requested imediate action on its proposed amendment. The licensee stated that it was "extremely important" th.at the reorganization of the Office.of Nuclear :d Power be implemented by July 1,1988 in order to.' achieve & more effective and responsive" organization.
The licensee explained that due to the evolving nature of certain of these corporate organization changes and the resulting revisions to its application for a TS change, it was not able to submit its dpplication in time to avoid exigent processing of the amendment.
The Comission has evaluated the licensee's request,and determined that this change should be implemented without unnecessary delay in accordance with 10 CFR 50.91(a)(6). The amendment would permit organizational changes to be made by the licensee as scheduled for July 1, 1988.
Since the proposed changes have no adverse effect on safety and would be beneficial to overall efficiency, such changes should be permitted with minimum delay.
Consequently, the Comission has determined that these exigent circumstances justify reducing the public notice period normally provided for licensing amendments and issuing the amendment at the close of business June 30, 1988. The
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Comission has concluded that the licensee has not failed to use its best efforts to make a timely application in order to create the exigency and take advantage of this procedure.
A legal notice requesting public comments by June 30, 1988 was published in the Chattanooga News-Free Press and the Chattanooga T_j_me on June 24, 1988.
See Section 2.3.6 for the comments rece ved.
2.3.5 Final No Sign E cant Hazards Consideration The revisions to the TS in the application dated June 13, 1988 to delete the organization charts from Section 6.0, change the title of Manage of Nuclear Power to Senior Vice President, Nuclear Power ard add references to the "unit" organization in Specification 6.E.2 'aave been evaluated against the standards of 10 CFR 50.92 and have been determined to not involve a significant hazards consideration. These changes do not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated. This change is administrative in nature and is intended to eliminate the need for NRC approval of a license amendment before implementation of an organization change. The changes to titles and references are also administrative in nature. The functions specified in Section 6.0 important to the safe operation of the plant have not been altered or deleted.
There are no hardware, procedure, personnel or analysis changes represented by this proposal that adversely effect the probability of occurrence or the consequences of an accident previously evaluated in the' plant FSAR.
2.
Create the possibility of a new or different' kind of accident from any previously evaluated.
Since there are no changes in plant design or operation, inclusion of the proposed changes in the TS would not create the possibility of a new or different kind of accident from any previously evaluated.
3.
Involve a significant reduction in a margin ofia safety.
For the reasons previously stated, adoption of the proposed changes would not involve a significant reducticn in safety margin for the plant.
The changes to the TS are administrative in nature, should increase the effectiveness of the utility's management controls and should provide a positive contribution to the safety of the plant and corporate activities. ' Consequently, the staff has made a fiaal determination that the changes in the TS do not m
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t involve a significant hazards consideration as defined by 10 CFR 50.92, 2.3.5 Consultation With State Of Tennessee The State of Tennessee was consulted concerning the TS changes on June 30, 1988 and had no comments.
2.3.6 Comments From The Public 19, 1988, Mr. G. Richard Howard of Chattanooga, On June Tennessee, requested a clarification on the application dated June 13, 1988 as to where the licensee's organization chartsThe would appear if they are deleted from Section 6 of the TS.
staff explained that the proposed TS 6.2.1.a states that the The organization charts would appear in the Sequoyah FSAR.
licensee's organization will be kept current because the FSAR is updated annually in accordance with 10 CFR 50.71(e).
3.0 CONCLUSION
The proposed amendments to Section 6 "Administrative controls" in the licensee's applications dated April 17, 1987 and March 1 and June 13, 1988 revise Section 6 of the TS for both Units 1 and 2.
Based on the above, the proposed changes are acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
S These amendments involve changes in recordkeeping, or administrative procedure The Commission has previously issued proposed findings that or reouirements.
amendments as these involve no significant hazards considerations and there has been no public comment on such findings.
The staff has also determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents tLat may be re' leased offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(10).
Therefore, pursuent to 10 CFR 51.E2(b), no environmental impact statement or environment assessment need be prepared in connec. tion with the issuance of this amendment.
5.0 CONCLUSION
17, 1987 and March 1, 1988, the Commission has For the application dated April previously issued a notice of opportunity for a hearing and a proposed finding that these applications involve no significant hazards consideration and there For the has been no request for a hearing or public comments on these findings.
13, 1988, the Commission's final determination of no application dated June significant hazards consideration is given in Section 2.3.5 of this evaluation above. Therefore, we have concluded, based on the considerations discussed
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above, that (1) these amendments will not (a) significantly increase the probability or consequences of accidents previously evaluated, (b) create the possibility of a new or different accident from any previously evaluated, or (c) significant reduce a margin of safety and, therefore, the amendment does not involve significant hazards considerations; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; and-(3) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendments will not be inimical to the common defense and security nor to the health and safety of the public.
Principal Contributors:
J. 00nohew, M.' Fields and R. Pierson Dated:
June 30, 1988 p
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