ML20198K771

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Revised Tech Specs,Reflecting New Organizational Structure, Including Independent Safety Engineering Group,Fire Brigade Membership & Nuclear Safety Review Board
ML20198K771
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 05/27/1986
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20198K746 List:
References
NUDOCS 8606040129
Download: ML20198K771 (52)


Text

.

4 ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANCES SEQUOYAH NUCLEAR PLANT UNIT 1 (TVA SQN TS 60)

Pages for Unit 1 Being Revised:

6-1 6-la 6-2 6-3 6-4 6-5 6-7 6-7a 6-8 6-9 6-10 6-11 6-12 6-13 6-14 6-15 6-19 6-23 6-24

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6. 0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY Onage r-6.1.1 The Plant- -.intmndcnt shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

Vanger oh Ndogowl Cordro) 6.1. 2 The Chicf,

.cdic!cgicc' Mygicnc Brcach, shall be responsible for imple-menting the radiological environmental program and dose calculations and projections as described in the Offsite Dose Calculation Manual (0DCM).

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6.1. 3 The Shift Supervisor (or during his absence from the Control Room, a designated individual) shall be responsible for the Control Room command function.

A management directive to this ef fect, signed by the NUC rn site

-3 Di.ici^ Director, shall be reissued to all station personnel on an annual C

basis.

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6. 2 ORGANIZATION OFFSITE 6.2.1.1 The offsite organization for unit management and technical support shall be as shown in Figure 6.2-1.

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UNIT STAFF 6.2.2 The Unit organization shall be as shown in Figure 6.2-2 and:

Each on-duty shif t shall be composed of at least the minimum shift a.

crew composition shown in Table 6.2-1.

b.

At least one licensed Reactor Operator shall be in the Control Room when fuel is in the reactor.

In addition, while the unit is in MODE 1, 2, 3 or 4, at least one licensed Senior Reactor Operator shall be in the Control Room.

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o ADMINISTRATIVE CONTROLS

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A 'c9 th ?"yric: technician, shall be onsite when fuel is in the reactor.

d.

All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

A Fire Brigade of at least 5 members shall be maintained onsite at e.

all times.

The Fire Brigade shall not include Amembers of the minimum shift crew necessary for safe shutdown of~ the unit or any FP personnel required for other essential functions during a fire emergency.

he hi0 SuperutGov wd 8 o$fr W h,u l Co droI.

  1. The ".r2!t". p"y ic: technician and fire brigade composition may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence provided immediate action is taken to fill

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the required positions.

SEQUDYAH - UNIT 1 6-la CEI*7 $

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i N ear Safety eview Board Manager of Power Operations l

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tage Management clear Training Branch Branch

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Superintendant Sequoyan

  • Responsible for Fire Protection Figure 6.2-1. Offsite Organization for Facility Management and Technical Support.

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MANAGERS CON ST R UC TION OA ENGINEERING SERVIC ES TR AiNING S AFETY & LICENSING Figure 6.2-1 Offsite Organization for Facility Management and Technical Support i

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PLANT SUPERINTENDENT SAFETY SU ISOR ENGINEERING' STAFF

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HEALTH SULTS OPE R NS MAINTENANCE PH YSICS S

VISOR SUP ISOR SUPERVISOR SRO

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HE ALTH PHYSICS TECHNICA OPE R ATIONS MAWTENANCE TECHNICIANS ENGINEERS SUPERVISCR SRO SUPERVISORS TE CHNICI ANS, SHIFT FOREMEN AND FOREMEN AN ENGINEER

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SEQUOYAH - UNIT 1 6-4

TABLE 6.1-1

( VEILLANCE REQUIREMENT 4 PERFORMED BY RADIOLOGICAL HYGJENE BRANCH 4.11.1.2 4.11.1.3.1 4.11.2.1.1 (partial) 4.11.2.1.2 (partial) 4.11.2.2 4.11.2.3 4.11.2.4 4.11.4 4.12.1 4.12.2 4.12.3

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SEQUOYAH - UNIT 1 6-5

ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

FUNCTION 6.2.3.1 The ISEG shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensing Event Reports and other sources which may indicate areas for improving plant safety.

COMPO5ITION 97 Ltan 3 6.2.3.2 The ISEG shall be composed of ;t ?x.,t five dedicated full-time engineers located onsite. These eus9mceMS will be sujojaternented by 2. Full. Tome an9 sneers Shaned among All TVA twclentt.. Sites.

RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of plant activities to provide independent verification

  • that these activities are performed correctly and that human errors are reduced as much as practical.

AUTHORITY 6.2.3.4 The ISEG shall make detailed recommendations for revised procedures, equipment modifications, or other means of improving plant safety to the n. :...... n r.__ _ _. _ __ <__ u.:

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6.2.4 SHIFT TECHNICAL ADVISOR (STA)

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6.2.4.1 The STA shall serve in an advisory capacity to the shift supervisor h

on matters pertaining to the engineering aspects of assuring safe operation of p:

the unit.

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6. 3 UNIT STAFF QUALIFICATIONS p

6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifi-cations of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees, except for the "a? th I'hysicist who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

Site. %diologic.nl Con +ncL Super \\/ISok u

  • Not responsible for sign off function.

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SEQUOYAH - UNIT 1 6-7

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ADMINISTRATIVE CONTROLS 6.4 TRAINING Ope.garoong SupseantendGNT 6.4.1 A retraining and replacement training program for the unit staff shall

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be maintained under the direction of the.b;i; tant Plant apa.-intendens and d

shall meet or exceed the requirements and recommendations of Section 5.5 of and Appendix "A" of 10 CFR Part 55 and the supplemental require- [

ANSI N18.1-1971

)

ments specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC

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letter to all licensees, and shall include familiarization with relevant industry operational experience. :dentificd by the ISEG.

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6.5 REVIEW AND AUDIT Nucu.Mt.

6.5.0 The Manager of Power is responsible for the safe operation of all TVA 3

power plants.

The functional organization for Review and Audit is shown on Figure 6.2-1.

6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

FUNCTION (Ma 6.5.1.1 The PORC shall function to advise the Plant Sup :nnGER.m ancent on all matters related to nuclear safety.

COMPOSITION 6.5.1.2 The PORC shall be composed of the:

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Membe r'.

C!% ROW 5'SloNd bbH. OR A$$ISTANT OPl@TIONS.SUPLMVISol Member Member:

MMo*MWbhKlCCNTRoL SUPLRVISOR.

Member N'NNEM'N NN #^

t Member $

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Member:

Superficer Quality A a m ce starc QuRliTy ENgoneGRINg RNO CCNfgcL $ygggyjggg, SEQUOYAH - UNIT 1 6-7a M I 7 7030

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9 ADMINISTRATIVE CONTROLS ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing by the PORC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

MEETING FREQUENCY

6. 5.1. 4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.

QUORUM

~~

6.5.1.5 The minimum quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions of these technical specifications shall consist of the Chairman or his designated alternate and four members including alternates.

RESPONSIBILITIES l') 6.5.1.6 The PORC shall be responsible for:

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a.

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Review of 1) all procedures required by Specification 6.8.1 and

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changes thereto, 2) all programs required by Specification 6.8.5

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and changes thereto, 3) any other proposed procedures or changes

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thereto as determined by the Plant Succ:intendcnt to affect nuclear 4 p. )

safety.

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b.

Review of all proposed tests and experiments that af fect nuclear safety.

Review of all proposed changes to Appendix "A" Technical Specifications.

c.

d.

Review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety.

Investigation of all violations of the Technical Specifications e.

including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Circctcr, Nucicar

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ca-and to the Chairman of the Nuclear Safety Review Board.

j3ihe l) REctot f.

Review all written reports requiring 24-hour notification to the Commission.

Review of unit operations to detect potential nuclear safety hazards.

g.

SEQUOYAH - UNIT 1 6-8 m

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ADMINISTRATIVE CONTROLS l

h.

Performance of special reviews, investigations or analyses and reports thereon as requested by the Plant Su;crintendent or the Nuclear Safety Review Board.

PlANAS8ft i.

Review of the Plant Physical Security Plan and implementing procedures and shall submit recommended changes to the Nuclear Safety Review Board.

j.

Review of the Site Radiological Emergency Plan and implementing procedures and shall submit recommended changes to the Nuclear Safety Review Board.

k.

Review of every unplanned onsite release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence to the Di ccter, Site 'DsREc70M.

Nuclecr Pcacr Oi.ision and to the Nuclear Safety Review Board.

1.

Review of changes to the radwaste treatment systems, m.

Review of meeting minutes of the Radiological Assessment Review Committee (RARC).

AUTHORITY 6.5.1.7 The PORC shall:

mRn1AGER. t approval or a.

Recommend in writing to the Plant Super:

ntenctn disapproval of items considered under 6.5.1.6(a) through (d) above.

b.

Render determinations in writing with regard to whether or not each item considered under 6.5.1.6(a) through (e) above constitutes an unreviewed safety question.

Si4e Dmsc. tor.

c.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Directer, 'Dc!_c:

IcacrCivi;icaandtheNuclearSp bg w g g e PORC and the Plant S.{ggv gggiew Board of disagree cnt; however, the Plant r-..

..-. dcat shall have responsibility for resolution of such

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disagreements pursuant to 6.1.1 above.

RECORDS 6.5.1.8 The PORC shall maintain written minutes of each PORC meeting that, at a minimum, document the results of all PORC activities performed under the responsibility and authority provisions of these technical specifications.

Copies shall be provided to the Circct - Muc!ccr "cacr C h iuic,T and the Nuclear Safety Review Board.

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6.5.2 NUCLEAR SAFETY REVIEW BOARD (NSRB)

FUNCTION 6.5.2.1 The NSRB shall function to provide independent review and audit of designated activities in the areas of:

SEQUOYAH - UNIT 1 6-9

ADMINISTRATIVE CONTROLS a.

nuclear power plant operations b.

nuclear engineering c.

chemistry and radiochemistry d.

metallurgy e.

instrumentation and control f.

radiological safety g.

mechanical and electrical engineering h.

quality assurance practices COMPOSITION 6.5.2.2 The NSRB shall be composed of at least five members, including the Chairman. Members of the NSRB may be from the Of fice of Power, or other TVA organization or external to TVA.

4 4

QUALIFICATIONS 6.5.2.3 The Chairman, members, and alternate members of the NSRB shall be appointed in writing by the Manager of Power and shall have an academic degree in engineering or a physical science field, or the equivalent; and in addition, shall have a minimum of five years technical experience in one or more areas given in 6.5.2.1.

No more than two alternates shall participate as voting members in NSRB activities at any one time.

CONSULTANTS 6.5.2.4 Consultants shall be utilized as determined by the NSRB Chairman to provide expert advice to the NSRB.

MEETING FREQUENCY 6.5.2.5 The NSRB shall meet at least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per six months thereafter.

QUORUM 6.5.2.6 The minimum quorum of the NSRB necessary for the performance of the NSRB review and audit functions of these technical specifications shall consist of more than half the NSRB membership or at least 5 members, whichever is greater.

This quorum shall include the Chairman or his appointed alternate and the NSRB members, including appointed alternate members, meeting the requirements of Specification 6.5.2.3.

No more than a minority of the quorum shall have line responsibility for operation of the unit.

SEQUOYAH - UNIT 1 6-10

ADMINISTRATIVE CONTROLS REVIEW

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be nespousibLe for the 6.5.2.7 The NSRB shall reviewl0Fl 3

The safety evaluations for 1) changes to procedures, equipment or a.

4 systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.

b.

Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

c.

Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

d.

Proposed changes to Technical Specifications or this Operating License.

Violations of codes, regulations, orders, Technical Specifications, e.

license requirements, or of internal procedures or instructions i

having nuclear safety significance.

f.

Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.

g.

All written reports requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification to the Commission.

h.

All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components i

that could affect nuclear safety.

S9hl 1.

Reports and meetings minutes of the PORC and the RARC.

3 AUDITS

)

6.5.2.8 Audits of unit attivities shall be performed under the cognizance of the NSRB.

These audits shall encompass:

The conformance of unit operation to provisions contained within the a.

i Technical Specifications and applicable license conditions at least i

once per 12 months.

b.

The performance, training and qualifications of the entire unit staff at least once per 12 months.

The results of actions taken to correct deficiencies occurring in c.

unit equipment, structures, systems or method of operation that i

affect nuclear safety at least once per 6 months.

d.

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B",

10 CFR 50, at least once per 24 months.

i l

SEQUOYAH - UNIT 1 6-11 i

on

ADMINISTRATIVE CONTROLS The Site Radiological Emergency Plan and implementing procedures at e.

least once per 12 months.

1 f.

The Plant Physical Security Plan, the Safeguards Contingency Plan, and implementing procedures at least once per 12 months.

Any other area of unit operation considered appropriate by the NSRB g.

or the Manager of Power.

y NucILaR.

h.

The Facility Fire Protection Program and implementing procedures at least once per 24 months.

i.

An independent fire protection and loss prevention program inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

j.

An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.

k.

The radiological environmental monitoring program and the results thereof at least once per 12 months.

1.

The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at

1. cast once per 24 months.

The PROCESS CONTROL PROGRAM and implementing procedures for m.

SOLIDIFICATION of radioactive wastes at least once per 24 months.

The performance of activities required by the Quality Assurance n.

Program to meet the criteria of Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.1,1974 and Regulatory Guide 4.1, j )

Rev. 1, 1975, at least once per 12 months.

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AUTHORITY yucLCRR 6.5.2.9 The NSRB shall report to and advise the Manager of Power on those

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areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.10 Records of NSRB activities shall be prepared, approved and distributed as indicated below:

Minutes of each NSRB meeting shall be prepared, approved and forwarded a.

to the Manager of Power within 14 days following each meeting.

yNucLLAR b.

Reports of reviews encompassed by Section 6.5.2.7 above, shall be j

prepared, approved and forwarded to the Manager of Power within 14

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days following completion of the review.

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NucLEnR.

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ADMINISTRATIVE CONTROLS NUCLL A R.

Audit reports enco passed by Section 6.5 2.8 above, shall be forwarded c.

to the Manager of Power and to the mane ament positions responsible for the areas audited within 30 days arter completion of the audit.

1 i

j 6.5.3 RADIOLOGICAL ASSESSMENT REVIEW COMMITTEE (RARC)

P i

Function The} ARC shall function to advise the 4+nesA N

Mnue4, Radiological q;NYRO[. MRNAglR.

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6.5 1.1

i^r onallmattersrelatedtoradiologicalassessmentsinvolvingdose i,

calculations and projections and environmental monitoring.

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Composition SW 6.5.3.2 The RARC shall be composed of the:

o Tt,tHNICRL A0Sl01RNCE.

Chairman: D ? die'egicel Asses ent Section Supervisor Member:

Health Physicist, Gaseous, Radiological "ygiere Bre-h CONTNola Member:

Health Phys C.oNtROL Meteorologil_ gist, Liquid,RadiologicalHygianeBranch 1

Member:

1 O J _, Air Quality Branch i.

Member:

Chemical Engineer HenHh %ysleisT,&, bult; Section,$p mem W TL9l"b ra m w

'S *%daslogical Gon1RcI Alternates SSN 6.5.3.3 All alternate members shall be appointed in writing by the RARC Chairman to serve on a temporary basis-owever, no more than two alternates 3

shall participate as voting members in nRC activities at any one time.

Meeting frequency SGN 6.5.3.4 The3RARC shall meet at least once per six months e.

on

'Ri

+ as _ guested m. by the RARC Chairman w,his designated alternate 0M A pl4NT 'REF4LSENTATWE..

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j Quorum SQhl 6.5.3.5 The minimum quorum of the RARC necessary for the performance of the SSM l

3 RARC responsibility and authority provisions of these technical specifications i

shall consist of the Chairman or his designated alternate and members (including alternates) 93 LcNg AS ONL is A plRNT REME SENTArtyg, i

Responsibilities 6.5.3.6 The RC shall be responsible for:

I Review of changes to the 0FFSITE DOSE CALCULATION MANUAL.

a.

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b.

Review of-4M-procedures required by Specification 6.8.4 and changes thereto.

FOR INFORmnriant %APcsr pivotws, OK CVRLUAftCNS Review 0t the results of any au.sdits 0t the Quality Assurance Program i

c.

3 4

forettluentandenvironmentalmonltoring Involving dost SVRLunT7oWS RMO 'Pnojscguo 7?nosoA.0$/cnL ASS 4 i

Tious.

SEQUOYAH - UNIT 1 6-13

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ADMINISTRATIVE CONTROLS d.

Review of proposed changes to the Technical Specifications related to radiological assessments involving dose calculations and projections and environmental monitoring.

Anosolog 2nL Authority 6.5.3.7 The RC shall:

RecommendinwritingtotheC""gcRoh 0.cNfRol and & %wT Maun

, Radiological Hygiene M c" a.

rY1ANNgE.g, approval or disapproval of items considered under 6.5.3.6 above.

b.

Render determinations in writing with regard to whether or not each item considered under 6.5.3.6 constitutes an unreviewed safety question.

mpunggg of NUCLLAR. WLY c.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the O!"^cte, ""cl e "

De'er O!"isinn and the Nt gg g{f g gg g $

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~ g g f disagreement the Y. J. _$. h,. h_ _ h.n.. hht!af_rranch shall h'av'e responsibility for

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resolution of such disagreement pursuant to 6.1.2 above.

Records SSM 3#M 6.5.3.8 The RARC shall maintain writt Lminutes of each HARC meeting that at 4

3 a minimum, document the results of all MRC activities performed under the responsibility and authority provisions of these tecnnical specifications.

Copies shall be provided to the 04 mster, ":.cLem Per. "! v k !:m the Nuclear Safety Review Board ThAN4ge/R OY NUCLEAR TOWE,R., PORC, and 6.6 REPORTABLE EVENT ACTION 7g 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

()

a.

The Commission shall be notified and a report submitted pursuant

( g to the requirements of Section 50./3 to 10 CFR Part 50, and

(

7 b.

Each REPORTABLE EVENT shall be reviewed by the PORC and the results b

of this review shall be submitted to the NSRB and the -D""cten, Site VlM070R.

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6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a.

The unit shall be placed in at least HOT STANOBY within one hour, b.

The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within one hour.

The O!~cter "uc ?">v SlT6 Datef0 A.

%Me-and the NSRB shalI be notifled with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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SEQUOYAH - UNIT 1 6-14 "n n t ""

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ADMINISTRATfVE CONTROLS c.

A Safety Limit Violation Report shall be prepared.

The report shall be reviewed by the POPC.

This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, and (3) corrective action taken to prevent recurrence, d.

The Safety Limit Violation Report shall be submitted to the Commission, the NSRB and the Directer, u"c!ee-N'er Divisica within 14 days of the violation.

3N WRCC 70R.

6.8 PROCEDURES & PROGRAMS 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:

The applicable procedures recommended in Appendix "A" of Regulatory a.

Guide 1.33, Revision 2, February 1978.

b.

Refueling operations.

1 Surveillance and test activities of safety related equipment.

c.

d.

Plant Physical Security Plan implementation.

Site Radiological Emergency Plan implementation.

e.

{

f.

Fire Protection Program implementation.

g.

PROCESS CONTROL PROGRAM implementation, j

j h.

Quality Assurance Program for effluent monitoring, using the guidance contained in Regulatory Guide 4.15, December 1977, or Regulatory Guide 1.21, Rev. 1, 1974 and Regulatory Guide 4.1, Rev. 1, 1975.

Q-i 6.8.2 Each procedure of 6.8.1 above, a g ch by the PORC and approved by the Plant-Sup M g thereto, shall be reviewed

.._.._cr.t prior to implementation and reviewed periodically as set forth in administrative procedures.

1 6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided.

a.

The intent of the original procedure is not altered.

b.

The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.

The change is documented, reviewed by the PORC and approved by the c.

i Plant Sufm4ntererkwithin 14 days of implementation.

i mRNAQC R, 6.8.4 Written procedures shall be established, implemented and maintained by the Radiological-41yg(ieae Breach covering the activities aelow:

CN TRQLo

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a.

OFFSITE DOSE CALCULATIONAL MANUAL impicmentation.

- tm. m m,

m, SEQUOYAH - UNIT 1 6-15

^; d ut M:.

O

l ADMINISTRATIVE CONTROLS 1

l 6.10.2 The following records shall be retained for the duration of the Unit Operating License:

l Records and drawing changes reflecting unit design modifications a.

made to systems and equipment described in the Final Safety Analysis Report.

b.

Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories, Records of radiation exposure for all individuals entering radiation c.

control areas.

d.

Records of gaseous and liquid radioactive material released to the environs.

Records of transient or operational cycles for those unit components e.

identified in Table 5.7-1.

f.

Records of reactor tests and experiments.

g.

Records of training and qualification for current members of the unit staff, h.

Records of in-service inspections performed pursuant to these Technical Specifications.

1Gh 1.

Records of Quality Assurance activities required he 0;'eratia"2!

NUCLERR.

1 j

Quality Assurance Manual.

j.

Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

RecordsofmeetingsofthePORC,hARC,andtheNSRB.

k.

1.

Records of analyses required by the radiological environmental monitoring program.

Records of secondary water sampling and water quality, m.

Records of the service life monitoring of all safety-related n.

hydraulic and mechanical snubbers, required by T/S 3.79, including the maintenance performed to renew the service life.

Records for Environmental Qualification which are covered under the o.

provisions of Paragraph 2.c.(12)(b) of License No. DPR-77.

,n

i 6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

y i r;, :nu SEQUOYAH - UNIT 1 6-23 f;.= t = t ue. 'a

ADMINISTRATIVE CONTROLS 6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Special (Radiation)

Work Permit *,

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

A radiation monitoring device which continuously indicates the a.

radiation dose rate in the area.

b.

A radiation monitoring device which continuously integrates the

' radiation dose rate in the area and alarms when a preset integrated dose is received.

Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.

An individual qualified in radiation protection procedures who is c.

equipped with a radiation dose rate monitoring device.

This individual 1

shall be responsible for providing positive control over the activities within the area and shall perform control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility HealthJhysicist in the Special (Radiation) Work Permit.

9'7 EPA 00A0908' W NOL SUPLR.Ve30 R 6.12.2 The requirements of 6.12.1, above, shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrom/hr.

t In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Shif tingineer on duty and/or the Health Jhysicist.Jit6 PnoloLOO/ Col OQVT40, ovPt.RUISoR.

Su PLR.LIISOR 6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 Licensee initiated changes to the PCP:

R46 1.

Shall be submitted to the Commission in the semi-annual Radioactive Effluent Release Report for the period in which the change (s) was made.

This submittal shall contain:

sufficiently detailed information to totally support the rationale a.

for the change without benefit of additional or supplemental information,

'Rndiolon ocnl. QcurnoL 2nnmAcqwnL &inRA

- 2 Health 44ysics personnel or personnel escorted by Health 4hysics personnel in accordance with approved emergency procedures, shall be exempt from the SWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with ap procedures for entry into high radiation areas. proved radiation protection

_Adhnhse,$>

SEQUOYAH - UNIT 1 6-24

ENCLOSURE 2 PROPOSED TECilNICAL CPECIFICATION CifANCES SEQUOYAll flUCLEAR PLANT UNIT 2 (TVA SQN TS 60)

Ear.on for Unit 2_Deint Revisod_:

6-1 6-2 6-3 6-4 6-5 6-9 6-10 6-11 6-12 6-13 6-14 6-15 6-16 6-17 6-18 6-19 6-28 6-29 6-30 1

O I

l i

1 f

6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY MANR9L*k 6.1.1 The Plant Supe-i.terdent shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

The t f ef,RERg^'RndiologfeneionL Gon+Rol 19 nun 6.1. 2

.-.- gica! My, nranch, shall be responsible for implementing the radiological environmental program and dose calculations and projections as described in the Offsite Dose Calculation Manual (00CM). - h se respansibilities iaclude perfer-ance cf serve!1!ance requir ::nt: 1 hted in--

T Ale 5.1-1.

6.1. 3 The Shift Supervisor (or during his absence from the Control Room, a designated individual) shall be responsible for the Control Room command func-tion.

A management directive to this effect, signed by the NUC,"" Oivisiong;1 col #dd/c 4

44*eetm shall be reissued to all station personnel on an annual basis.

1 l*

6.2 ORGANIZATION 5

l 0FFSITE 6.2.1.1 The offsite organization for unit management and technical support shall be as shown on Figure 6.2-1.

i l

l 6_ ? 1

h e effsite crgaaf2atics for the radielegica! ervi e enta! meafter4ag r

a ran e =

=d dose calculaticas sha!' be as sheva ia r!gere 6.2 UNIT STAFF 6.2.2 The Unit organization shall be as shown on Figure 6.2-2 and:

a.

Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

j b.

At least one licensed Reactor Operator shall be in the Control Room when fuel is in the reactor.

In addition, while the unit is in MODE 1, 2, 3 or 4, at least one licensed Senior Reactor Operator shall be in the Control Room.

V 4 Nort:

A dnshed lins m fhie Anunt

}Noien TCS AN ORANnN ZR 770W DJhicH r! e e r ve n SurjefroNnC dire.c,Tica fHom c rvQ_

pH<t nai 2 n rrm our Msce w.s kehrvient.sup6RutStort (Solid lins) FRcm IMinthfA CNAlWIznTitN, a

__t 7 in _t,nnl SEQUOYAH - UNIT 2 6-1

??!"0MEMr '^.

24

~

,,,a

-m eD%.2

ADMINISTRATIVE CONTROLS A RAosologICRL OwtRcL q

hea!th,.hycic -technician shall be onsite when fuel is in the c.

reactor, d.

All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

A Fire Brjgade of at least 5 members shall be maintained onsite at e.

all times.

The Fire Brigade shall not include the Shift Supervisor and the 2 other members of the minimum shift crew necessary for safe shutdown of the unit or any personnel required for other essential functions during a fire emergency.

'RnnicktmienL CcNTROL

  1. Ine-fwS*4Hny44% technician and fire brigade composition may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence provided immediate action is taken to fill the required positions.

SEQUOYAH - UNIT 2 6-2

]

%visco By ATrae.HED Figure s

4 General Manager Nuclear Safety i

Review Staff Manager of f

Power QA Nuclear Safe 1

Staff Review Bo N

Manager of Power Operations l

4 Nuclear Power Civis.on

' Safety Statf

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l 4

~

I Ass t. C. rector N Ass't. Director Maintenance &

Nuciear Operations Engineering Services I

Nuc: ear Mainter ance Nuclear Coerations Branch Coordinator Controls and Nuclear Ocerations l

Test Branen Staff Preoperationai Reactor Engineennq

/

Test Statt Brancn p

/

/

Outage Management Nuclear Training

,/

Brancn Branen

/

~/

Nue: ear Security J

Brancn

/

's

/

/

Su ntendant Se oyan W

'Resor>nsitue for Fire Protection.

Figure 6.2 1. Of fsite Orpnisation for Facihty Management and Technical Succort.'N N

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i N,

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SEQUOYAH - UNIT 2 6-3 1

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C) boARo 0F I

EARECYORS C:

GENER AL M AN AGER

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MANAGER l

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NUCL E AR POW ER DEPUTV M AN AGER NSRG 1

NUCL E AR $4TE DRECTOR OtHECTOR DIRE C T OR DIRE C TOR DRECTOR DREC TOR ORLC TOR $ AND OF OF OF OF OF Of NUCL E AR PROJECT M UC L E A 8' NUCLEAR NUCLEAR NUCLE AR N'JCLE AR NUCLEAR naANAGER$

C ON S T R UC Tag ca E NGIN E E RING

$E R VIC E $

TR AINING SAFETY & LICENSING Figure 6.2-1 Offsite Organization for Facility Management and Technical Support

Bewud By RTTAGH2O FIGURL

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s AS&'T Di OR M AINT E N A ND ENGINEERING S ICES OFFSITE PLANT SUPE RINTE NO

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ONSITE INDE PE NDE NT \\\\

SAFETY ENGINEERING \\

GROUP SAFETY SUPERVISOR ENGINEERING

  • QA STAFF ADlOLO '

ISTANT PLANT ycENE SUPE RINTEN DENT BRANCH

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CA ENGINEERS i

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H E A LTH ESULTS OPE R ATIONS MAIN TEN ANCE l

PHYSICS RVI SUPE RVISOR SUPERVISOR SRO I

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HE ALTH PHYSICS HNICA O R IONS MAWTENCE TECHNICIANS GlN E ER A

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SUPERVISOR %RO SUPE RVISORS

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I TE C'4NICI ANS, SHIFT FOREMEN AND FOREMEN AND ENGINE E R "I

CRAFTSMEN INSTRUMENT

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MECHANICS h

ISTANT SHIFT TECHNICAL j

SHI GIN E E R ADVISO R SRO l

  • Responsebelery for Fire Protecten Program SRk Senior Reactor Operator License RG - Reactor Operator License UNIT OPE R ATR l

' Figure ti.2 2. Facility Orgamzation

/9 N

SEQUOYAH'- UNIT 2 6-4

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SITE o,vis.o,r.on o.=rc o.=Ecroa. o<ws.oe.

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DIRECTOR c o.D.eUC.L.EAM.o.,

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PLANNING & SCHEDUUNCl OtMECTom. Orves.O*4 ggg;y

  • [A PLANT MODIFICATION N

SER ES LICE J ING MANAGER MANAGER MANAGER MANAGER MANAGER l

l PORs

iNotisTR At sArriv el l

l PROJECT 1

ENGINEER l

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OPEM ATIONS RADIOLOGIC AL MAaNTENANCE SUPERsNTENDENT CONTROL SUPERINTENDENT l

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C H E t.11S TR Y j P U B LI C :

TECHNICAL nRo

SAFETY :

SUPPORT

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. n. s t ate r OMLMAriONS s umEMwa som t ar o S e sWT S J P E R'..U O R "O

Re s po n sibility for Fire Prot e c tion Prograrn

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SHIFT SMO - Senior Reactor O pe ra t or Lic e n s e TECHNICAL RO - Reactor Operator Lic e n s e ADASON aw s %n r s.+s t huwt aviscw

  • , n UNtT OPERATOR no FIGURE 6.2-2 FACI LITY ORGANIZATION - SEQUOYAH NUCLEAR PLANT Vile:Pt T Ch r.

t to

/

leb "I !

YbtS b9u FC tS General Manager

/

Occup nal Office of Power Health Safety Division of Nuclear Power i

Radiological Plant Hygiene Superintendant Branch Radiolog' Results Assess t

Section 7"

/

r igure 6.2-3. Offsite Organization for Monitoring Program and Dose Calculati

/

SEQUOYAH - UNIT 2 6-5.

~~

. -=

i

/

1 TABLE 6.1-1 SURVEIL NCE REOUIREMENTS RFORMED BY RA0MLOGICAL HYGIFJfE BRANCH 4.11.1.2 4.11.1.3.1 4.11.2.1.1 (partial)

I 4.11.2.1.2 (partial) 4.11.2.2 4.11.2.3 4.11.2.4 4.11.4 4.12.1 4.12.2 l

4.12.3

\\ MIS Q,bl8 IS E*

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4 i

SEQUOYAH - UNIT 2 6-6

~ ~ - -

ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

FUNCTION 6.2.3.1 The ISEG shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensing Event Reports and other sources which may indicate areas for improving plant safety.

COMPOSITION S

6.2.3.2 The ISEG shall be ccmposed of at least-f4*e-dedicated full-time ineers located onsite. These e eny3tneeb ShARlo Amotug Rll weeRS LUill be. Supplemented by 2 full-Time Br A Nuel 2AR. Sit &S.

RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of plant activities to provide independent verification

  • that these activities are performed correctly and that human errors are reduced as much as practical.

AUTHORITY 6.2.3.4 The ISEG shall make detailed recommendations for revised procedures, equipment modifications, or other means of improving plant safety to the W irt2nt Director fer u jngen ne 3ng gng 275ng af gn gq,5 527 ef uu7 37 j

P===r.DIREc.fCR of NuGLEAR. SAGEnY F}A/O IJcENSINg.

6.2.4 SHIFT TECHNICAL ADVISOR (STA) 6.2.4.1 The STA shall serve in an advisory capacity to the shift supervisor on matters pertaining to the engineering aspects of assuring safe operation of the unit.

6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in Section A and C of Enclosure 1 of March 28, 1980 NRC letter to all licensees, except for the "c2!th hysici;t who shall meet or exceed the qualifications of Regulatory Guide 1.8, Se tember 1975.

biYE.}RdiologienL Control Sunnisor "Not respons1Dle for sign-off function.

SEQUOYAH - UNIT 2 6-9 i

4 a..

e ADMINISTRATIVE CONTROLS 6.4 TRAINING l

6.4.1 A retraining and replacement train 1 be maintained under the direction of the.ggrgfor the unit staff shall

.cnt Superintendent and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55 and the supplemental requirements specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees, and shall include familiarization with relevant industry operational experience identified by the ISEG.

6.5 REVIEW AND AUDIT NucLERQ 6.5.0 The Manager of Power is responsible for the safe operation of all TVA 3

l power plants.

The functional organization for Review and Audit is shown on Figure 6.2-1.

6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

FUNCTION MANAQ6.k 6.5.1.1 The PORC shall function to advise the Plant Supcr'nt nccnt on all matters related to nuclear safety.

CCMPOSITICN l

6. 5.1. 2 The PORC shall be composed of the:

IY1RNn0LR.

Chairman-.

&1MQ"'+M T/CNS DA MAIN T& NAN

' ^ ^ "

^ r " ^ ^. t M

  • Der; CNrAby!Ms_5Giq 1 ce oR. Rssistaur @Rancus Syasossor M ' * * * ' ',

a:T:' :",:T'e T'"

3;ts adic/cgicA4 GwfRol SWeise iyi4kNT4?97419Ci P6WJ30!KL a Wb oId(Y))

d emb r:

NN$Itk IyskNiYt EbIEYb fA0AY SUf5AV'00A' Member:

. Super"isor Quality ^.ssuranCO Sta f f-Quality ENgilv&& RING ANO 0CNtRc/ 00pSRyj$zfg, I

f

? t SEQUOYAH - UNIT 2 6-10

ADMINISTRATIVE CONTROLS ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing by the PORC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

MEETING FREOUENCY 6.5.1.4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.

QUORUM

^

6.5.1.5 The minimum quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or his designated alternate and four members including alternates.

RESPONSIBILITIES 6.5.1.6 The PORC shall be responsible for:

a.

Review of 1) all procedures required by Specification 6.8.1 and changes thereto, 2) all programs required by Specification 6.8.5, and changes thereto, 3) any other proposed procedures or changes thereto as determined by the Plant Sure-intendent to affect nuclear safety.

IUN^#d9Cdb b.

Review of all proposed tests and experiments that affect nuclear safety.

c.

Review of all proposed changes to Appendix "A" Technical Specifications, d.

Review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety, e.

Investigation of all yiolations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Di ector, 'bclear 317dE 2

03

[M Pewer Di"isia and to9the Chairman of the Nuclear Safety Review Board.

f.,

Review all written reports requiring 24 "our notification to the Commission.

g.

Review of unit operations to detect potential nuclear safety hazards.

SEQUDYAH - UNIT 2 6-11

~

ADMINISTRATIVE CONTROLS h.

Performance of special reviews, investigations or analyses and reports thereon as requested by the Plant Succrintendant or the Nuclear Safety Review Board.

/YIAA/A96R i.

Review of the Plant Physical Security Plan and implementing procedures and shall submit recommended changes to the Nuclear Safety Review Board.

J.

Review of the Site Radiological Emergency Plan and implementing procedures and shall submit recommended changes to the Nuclear Safety Review Board.

k.

Review of every unplanned onsite release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence to the-Director, Nuclecr Pcacr Oi.isica and to the Nuclear Safety Review Board.

SifE DIREC TOR.

1.

Review of changes to the radwaste treatment systems.

m.

Review of meeting minutes of the Radiological Assessment Review Committee (RARC).

AUTHORITY

6. 5.1. 7 The PORC shall:

Recommend in writing to the Plant Super'AgCR.u..dcnt approval or

!YAtt!

a.

disapproval of items considered under 6.5.1.6(a) tnrough (d) above.

b.

Render determinations in writing with regard to whether or not each item considered under 6.5.1.6(a) through (e) above constitutes an unreviewed safety question.

&ifE.DiRLc4*C&

c.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the 0;rectcr, Nuciccr Power Of icica and the Nuclear S g between the PORC and the Plant S e. g g w Board of disagreement m.mcat; however, the Plant DWVagcR. Super %ter. dent shall have responsibility for resolution of such disagreements pursuant to 6.1.1 above.

RECORDS 6.5.1.8 The PORC shall maintain written minutes of each PORC meeting that, at a minimum, document the results of all PORC activities performed under the responsibility and authority provisions of these technical specifications.

Copies shall be provided to the Director, "uc!ccr Pcuer Oi.;;ica and the Nuclear Safety Review Board.

SifE DRED.7'oR.

6.5.2 NUCLEAR SAFETY REVIEW BOARD (NSRB)

FUNCTION 6.5.2.1 The NSRB shall function to provide independent review and audit of designated activities in the areas of:

SEQUOYAH - UNIT 2 6-12

..-. ~

ADMINISTRATIVE CONTROLS a.

nuclear power plant operations b.

nuclear engineering c.

chemistry and radiochemistry d.

metallurgy e.

instrumentation and control f.

radiological safety g.

mechanical and electrical engineering h.

quality assurance practices COMPOSITION 6.5.2.2 The NSRB shall be composed of at least five members, including the Chairman. Members of the NSRB may be from the Office of Power, or other TVA organization or external to TVA.

4 Auslew QUALIFICATIONS 6.5.2.3 The Chairman, members, and alternate members of the NSRB shall be appointed in writing by the Manager of Power and shall have an academic degree j

in engineering or a physical science field, or the equivalent; and in addition, shall have a minimum of five years technical experience in one or more areas given in 6.5.2.1.

No more than two alternates shall participate as voting memoers in NSRB activities at any one time.

i CONSULTANTS 4

6.5.2.4 Consultants shall be utilized as determined by the NSRB Chairman to provide expert advice to the NSRB.

MEETING FREOUENCY 6.5.2.5 The NSRB shall meet at least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per six months thereafter.

QUORUM 6.5.2.6 The minimum quorum of the NSRB necessary for the performance of the NSRB review and audit functions of these technical specifications shall consist of more than half the NSRB membership or at least 5 memoers, whichever is greater.

This quorum snali include the Chairman or his appointed alternate and the NSRB members, including appointed alternate members, meeting the requirements of Specification 6.5.2.3.

No more than a minority of the quorum shall have line responsibility for operation of the unit.

i i

SEQUOYAH - UNIT 2 6-13

ADMINISTRATIVE CONTROLS REVIEW be Rsspcasible hoRdtte 6.5.2.7 The NSRB shall reviewj of:

n a.

The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute j

an unreviewed safety question.

b.

Proposed changes to procedures *, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

c.

Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

d.

Proposed changes to Technical Specifications or this Operating License.

e.

Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions l.

having nuclear safety significance.

f.

Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.

g.

All written reports requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification to the Commission.

h.

All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.

SGN i.

Reports and meetings minutes of the PORC and the RARC.

3 AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the NSRB.

These audits shall encompass:

a.

The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions at least l

once per 12 months.

b.

The performance, training and qualifications of the entire unit staf f at least once per 12 months.

i c.

The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months.

d.

The performance of activities recuired by the Operational Quality Assurance Program to meet the criteria of Appendix "B",10 CFR 50, at least once per 24 months.

SEQUOYAH - UNIT 2 6-N

-m e

esi m-

+v e-

-r.m

--7 r

--am W

---p-w--m T'-

ADMINISTRATIVE CONTROLS The Site Radiological Emergency Plan and implementing procedures at e.

least once per 12 months.

f.

The Plant Physical Security Plan, the Safeguards Contingency Plan, and implementing procedures at least once per 12 months.

g.

Any other area of unit operation considered appropriate by the NSRB or the Manager of Power.

y NUCLEAR.

h.

The Facility Fire Protection Program and implementing procedures at least once per 24 months.

i.

An independent fire protection and loss prevention program inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

j.

An inspection and audit of the fire protection and loss preven' tion program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.

~

k.

The radiological environmental monitoring program and the results thereof at least once per 12 months.

1.

The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

The PROCESS CONTROL PROGRAM and implementing procedures for m.

SOLIDIFICATION of radioactive wastes at least once per 24 months.

The performance of activities required by the Quality Assurance n.

Program to meet the criteria of Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.1,1974 and Regulatory Guide 4.1, Rev.1,1975, at least once per 12 months.

R3t AUTHORITY NucLEAbb 6.5.2.9 The NSRB shall report to and advise the Manager of Power on those n

areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.10 Records of NSRB activities shall be prepared, approved and distributed as indicated below:

Minutes of each NSRB meeting shall be prepared, approved and forwarded a.

to the Manager of Power within 14 days following each meeting.

q NUCLEAFL b.

Reports of reviews encompassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the Manager of Power within 14 days following completion of the review.

Vyucigngg

_.. i;, inor SEQUOYAH - UNIT 2 6-15 Amondmont Nn la

ADMINISTRATIVE CONTROLS Audit reports encomg,agd by Section 6.5.2.8 above, shall be forwarded c.

to the Manager ofpowEf'"and to the management positions responsible for the areas audited within 30 days after completion of the audit.

6.5.3 RADIOLOGICAL ASSESSMENT REVIEW COMMITTEE (RARC)

Function SGN nuwaata.

Godnel nND %$

6.5.3.1 The RARC shall function to advi'se the Chief 7 Radiological Hygienc n

, MNTDIArvegE83rznch, on all matters related to radiological assessments involving dose calculations and projections and environmental monitoring.

Comoosition 6.5.3.2 The ARC shall be composed of the:

[Q{ Cal A SlS$RNCEf. :0:: ment Section Supervisor Chairman:

_. _. cT cc.

Member:

Health Physicist, Gaseous, Radiological uygianc Eranch ccMtROL Member:

Health Phys Meteorologigist, Liquid, Radiological Hygicnc Sranch GoNTR.ob Member:

_! Engineer, Air Quality Branch Member:

Chemical Engineer, ' cult: Section -

Hcn\\+h Thy.sicist, e."nv'NZZw.rnL S, Wtenung,Ta bue:

.800 6.5.3.3 All alternate members shall be appointed in writing by the3RARC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in RARC activities at any one time.

3 Meetino Frecuency

  • W O R.

'RE606STED the RARC Cha}irmany his designated alternate,oR. A PLANT 86pR 6.5.3.4 The RARC shall meet at least once per six months me as ca.m.cd oy 3

Sqd Quorum SW 6.5.3.5 The minimum quorum of the RARC necessary for the performance of the SQu g

RARC responsibility and authority provisions of these technical specifications shall consist of the Chairman or his designated alternate and/ memoers(including alternates)a.w LcNg as one. Is a pinNT REPRESEM1Afive, Y

Resoonsibilities Sgg 6.5.3.6 The RARC shall be responsible for:

3 a.

Review of changes to the OFFSITE COSE CALCULATION MANUAL.

b.

Review of ci' procedures required by Specification 6.8.4 and changes m$cernn17cW fURPOSCS u,S, ott EURI@T**MS c.

Review of the results of any audits,of the Quality Assurance Program 3

for effluent and environmental monitoring / ANO radiologcAL ASSassinwG INuchtaug dos & svAlunTooNs AND PRojec7TcNS.

SEQUOYAH - UNIT 2 6-16

ADMINISTRATIVE CONTROLS d.

Review of proposed changes to the Technical Specifications related to radiological assessments involving dose calculations and projections and environmental monitoring.

CAdiolo QiCAl.-

Authority v

S6M 6.5.3.7 The RARC shall:

3 mAningeg oS%diolog.icAL0cutRol and thepinwT a.

RecommerA in writing to the Chief, Radiclegic2! Hygiene Brcb

/7)ANAge# approval or disapproval of items considered under 6.5.3.6 above.

b.

Render determinations in writing with regard to whether or not each item considered under 6.5.3.6 constitutes an unreviewed safety question.

mRNARCR Ch hkcLene c.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Di ec _r,

'!uc ! ca r TotacR r'

n;"ic ~

i and the Nugl g gfg y g vig, g g f g sagreement o

the_[.uh,k__. h. cg :o th. ogM gQk "5

'I ' " " ~ '

..yg 3_.Q_.ich shall have responsibility for ca resolution of such disagreement pursuant to 6.1.2 above.

Records Stl SSA!

6.5.3.8 Th RARC shall maintain writt minutes of each RARC meeting that at 3

a minimum, document the results of all RC activities performed undar the responsibility and authority provisions of these technical specifications.

Copies shall be provided to the nirnetn" 4" clear Pei-!er Di icien, PORC, and the Nuclear Safety Review Board. MAMagcit o y NucicAR. 7"cwe.R 6.6 REPORTABLE EVENT ACTION

.)

L 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

[)

The Commission shall be notified and/or a report submitted pursuant

(

a.

to the requirements of Section 50.73 to 10 CFR Part 50, and N

)

b.

Each REPORTABLE EVENT shall be reviewed by the PORC and t gsults"ucl of this review shall be submitted to the NSRB and the Dir u.,

)

D RECTOR Powc n

.icion y

6.7 SAFETY LIMIT VIOLATION

.e 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a.

The unit shall be placed in at least HOT STANDBY within one hour.

b.

The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within one hour.

The=0irectcc, Nucle 5r S Md

@s.RecfCA3P'

'"i '-i cn and the NSRB shalI be notified with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

t w und n e

'l

!qo'.

SEQUOYAH - UNIT 2 6-17 Aman

  • ant Nn 28 -

ADMINISTRATIVE CONTROLS A Safety Limit Violation Report shall be prepared.

The report shall c.

be reviewed by the PORC.

This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, and (3) corrective action taken to prevent recurrence.

d.

The Safety Limit Violation Report shall be submitted to the Commission, the NSRB and the Director'DIRcetOR.Nuclecr Pcuer Divicicn within 14 days of the violation.

SitL '

6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:

The applicable procedures recommended in Appendix "A" of Regulatory a.

Guide 1.33, Revision 2, February 1978.

b.

Refueling operations.

Surveillance and test activities of safety related equipment.

c.

d.

Plant Physical Security Plan implementation.

Site Radiological Emergency Plan implementation.

e.

f.

Fire Protection Program implementation.

g.

PROCESS CONTROL PROGRAM implementation.

h.

Quality Assurance Program for effluent monitoring, using the guidance contained in Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.1,1974 and Regulatory Guide 4.1, Rev.1,1975.

Gr*

7 6.8.2 Each procedure of 6.8.1 abo by the PORC and approved by the D{ggd chancgthereto, shall be reviewed yfd.N..

Ot prior to implementation g

and reviewed periodically as set forth in administrative procedures.

6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:

The intent of the original procedure is not altered.

a.

b.

The change is approved by two members of the plant management staff, e

at least one of whom holds a Senior Reactor Operator's License on the unit affected.

The change is documented, reviewed by the PORC and approved by the c.

Plant STnA/VAg6ft.erintendent-within 14 days of implementation.

r=;-

3 mee=

SEQUOYAH - UNIT 2 6-18

^ en 9 ent No. "

ADMINISTRATIVE CONTROLS 6.8.4 Written procedures shall be established, implemented and maintained by the Radiological Hy"GONTRDLicnc Brcach-covering the activities below:

OFFSITE 00SE CALCULATIONAL MANUAL implementation.

a.

b.

Quality Assurance Program and environmental monitoring, using the guidance contained in Regulatory Guide 4.15, December 1977.

q,,,

Surveillance requirements and environmental monitoring requirements c.

shown in Table 6.1-1.

6.8.5 The following programs shall be established, implemented, and maintained:

a.

Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels.

The systems include the safety injection system, residual heat removal system, chemical and volume control system, containment spray system, and RCS sampling system.

The program shall include the following:

(i) Preventive maintenanc.e and periodic visual inspection requirements, and (ii) Integrated leak test requirements for each system at refueling cycle intervals or less.

b.

In-Plant Radiation Monitoring A program which will ensure the capability to accurately determine the airborne iodine concentrations in vital areas under accident conditions.

This program shall include the following:

(i) Training of personnel, (ii) Procedures for monitoring, and (iii) Provisions for maintenance of sampling and analysis equipment.

c.

Secondary Water Chemistry A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation.

This program shall include:

(i) Identification of a sampling schedule for the critical variables and control points for these variables, (ii)

Identification of the procedures used to measure the values of the critical variables, (iii)

Identification of process sampling points,

\\

SEQUOYAH - UNIT 2 6-19 Am:ntment No. 34-

'nuar; 11, inos

'~

ADMINISTRATIVE CONTROLS

[Mer '

G.10.2 The following records shall be retained for the duration of the Unit Operating License:

Records and drawing changes reflecting unit design modifications made to a.

4 j

systems and equipment described in the Final Safety Analysis Report.

i b.

Records of new and irradiated fuel inventory, fuel transfers and 4

assembly burnup histories.

l Records of radiation exposure for all individuals entering radiation c.

control areas, i

d.

Records of gaseous and liquid radioactive material released to the

)

environs.

l e.

Records of transient or operational cycles for those unit components j

identified in Table 5.7-1.

f.

Records of reactor tests and experiments.

g.

Records of training and qualification for current members of the unit staf f.

h.

Records of in-service inspections performed pursuant to these Technical Specifications.

Nucl&RQ i.

Records of Quality Assurance activities required by the Operat:ca2!

Quality Assurance Manual.

j.

Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

Records of meetings of the PORC,.S$nr k.

hRARC, and the NSRB.

1.

Records of analyses required by the radiological environmental monitoring program.

t l

's.c.. ar 23, 1034 -

SEQUOYAH - UNIT 2 6-28

'a nmunument nu

. ~.

ADMINISTRATIVE CONTROLS 6.10.2 (Continued)

Records of secondary water sampling and water quality, m.

Records of the service life monitoring of all safety-related hy-n.

draulic and mechanical snubbers, required by T/S 3.7.9, including the maintenance performed to renew the service life, Records for environmental qualification which are covered under the

{}

o.

provisions of paragraph 2.C.(10)(b) of license No. OPR-79.

lpg4 y

6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Special (Radiation)

Work Permit *.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

A radiation monitoring device which continuously indicates the a.

radiation dose rate in the area.

b.

A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.

Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.

An individual qualified in radiation protection procedures who is c.

equipped with a radiation dose rate monitoring device.

This individual shall be responsible for providing positive control over the activities within the area and shall perform control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Hez!th Dhysicist in the Special (Radiation) Work Permit.

Slfe 1Adiolo(3icAL dcaracL Supe ^v/ Sc6

%dicicaionL Omtnol mndiolcaicnL OcatAri

  • "c2!!N"ohysics-personnel or personnel escorted by Hea!th Thysics personnel in accordance with approved emergency procedures, shall be exempt from the SWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

u-11, v.

SEQUOYAH - UNIT 2 6-29 AmendmonL Nu.

34

~

ADMINISTRATIVE CONTROLS 6.12.2 The requirements of 6.12.1, above, shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr.

In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Shift Enaineer on duty and/or the Health oh"sicist.

3 5 vsso n SiwbdIolctgianL GcutRol Sop 6Rvis ce t

6.13 PROCESS CONTROL PROGRAM (PCP)

~)

6.13.1 Licensee initiated changes to the PCP:

{TEK 1.

Shall be submitted to the Commission in the semi-annual Radioactive Effluent Release Report for the period in which the change (s) was made.

This submittal shall contain:

1 a.

sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information, b.

a determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and c.

documentation of the fact that the change has been reviewed and found acceptable by the PORC.

2.

Shall become effective upon review and acceptance by the PORC.

6.14 0FFSITE DOSE CALCULATION MANUAL (0DCM) 6.14.1 The ODCM shall be approved by the Commission prior to implementation.

6.14.2 Licensee initiated changes to the ODCM:

1.

Shall.be submitted to the Commission in the next Semi-Annual

')'

Radioactive Effluent Release Report pursuant to Specification iEF4 6.9.1.9.

This submittal shall contain:

a.

sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information.

Information submitted should consistent of a package of those pages of the ODCM to be changes with each page numbered and provided with an approval and date box, together with appropriate analyses or evaluations justifying the change (s);

b.

a determination that the change will not reduce the accuracy or reliability of dose calculations or setpoint determinations; and c.

documentation of the fa, that the change has been reviewed and found acceptable by th RC.

la rv 14, 1906 4

SEQUOYAH - UNIT 2 6-30 Amendment Hu. 34

O 4

9 ENCLOSURE 3 DESCRIPTION AND JUSTIFICATION OF PROPOSED TECl{NICAL SPECIFICATION CHANGES FOR SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 (TVA SQN TS 60) f e

__ ~

-a

This chtngs to technical spscifications is an administrative change intended to make the Administrative Controls Section of Plant Technical Specifications (section 6) consistent with the new organizational structure in the Office of Nuclear Power (ONP).

For clarity, the change will be divided into 6 items as follows:

Item Title A

Office of Nuclear Power (ONP) Reorganization B

Plant Operations Review Committee (PCRC)

C Independent Safety Evaluation Group (ISEG)

D Radiological Assessment Review Committee (RARC)

E Fire Brigade Members F

Nuclear Safety Review Board (NSRB)

A separate section of this package will be dedicated to each item which will address the description, reason, and justification for each of these changes.

Further, an overall determination of significant hazards consideration will be included addressing all 6 items in accordance with 10CFR50.91 and 92 as Attachment A.

Item A - Office of Nuclear Power (ONP) Reorganization Description of Change This administrative change is being made to change the title of Plant Superintendent to Plant Manager.

The plant manager will report directly to the site director.

The title of Assistant Director of Nuclear Power (Operations) is being changed to Site Director.

The chief officer of the ONP is now titled Manager of Nuclear Power.

Any references to the Manager of Power are changed to read Manager of Nuclear Power.

The Health Physicist is now titled Site Radiological Control Supervisor.

The reference to the offsite organization for radiological environmental monitoring program and dose calculations (item 6.2.1.2), Table 6.1-1, and figure 6.2-3 are being removed.

The site organization includes the new Plant Operation Review Staff (PORS).

The PORS is a staff reporting to the assistant plant manager.

For additional detail see attached marked-up pages from technical specifications.

Reason for Change

?

The above changes are proposed in order to make the technical specifications consistent with the proposed organization for the ONP.

Several positions currently in technical specifications no longer (or will no longer) exist after the current reorganization This change will identify the positions currently responsible tor those functions.

l

Removing the offsite organization for radiological environmental monitoring program and dose calculations will eliminate unnecessary, redundant information from technical specifications and avoid potential future amendment proposals due to realignment of referenced organizations.

The responsibilities of the PORS will include, but not be limited to, preparing LERs, investigation of potential reportable occurrences, and technical specification special reports as assigned.

Justification for Change The changes proposed are being made to improve the responsiveness of the organizations in the ONP.

This reorganization is intended to improve performance in every area of plant operation by clearly defining the lines of responsibility and accountability.

The information on the offsite organization for radiological environmental monitoring program and dose calculations is discussed in section 6.3.2 under the Radiological Assessment Review Committee.

Item 6. 2.1. 2, figure 6. 2.3, and Table 6.1-1 provide unnecessary detailed information.

This information is subject to change due to organizational realignments resulting in the need for unnecessary and avoidable technical specifications amendment proposals.

This information is omitted in revison 5 of Westinghouse Standard Technical Specifications, which indicates that the evaluation of this information as being superfluous is correct.

No function previously identified as important to safety has been deleted.

Only a realignment of functions into positions of realigned responsibilities has taken place.

Item B - Plant Operations Review Committee (PORC)

Description of Chang This change is being made to accurately reflect the titles of the regular members of PORC.

They are as follows:

Position Title in Current Technical New Title Specifications Chairman Plant Superintendent Plant Manager Member Operations Supervisor Operations Supervisor Member Results Supervisor Technical Support Supervisor Member Maintenance Supervisor Maintenance Supervisor (I),

t (E), or (M)

Member Assistant Plant Superintendent Operations Superintendent or Maintenance Superintendent Member Health Physicist Site Radiological Control Supervisor Member Supervisor Quality Assurance Quality Engineering and Staff Control Supervisor

For further detail see attached marked-up pages.

4 Reason for Change Due to the reorganization, titles for each position responsible to perform reviews for PORC have been changed.

This change is intended to clearly i

define those key positions as related to PORC.

Justification for Change The purpose for PORC is to advise the plant manager on all matters related to nuclear safety.

By the original technical specifications, SQN identified the positions that held the expertise necessary to complete the reviews to J

advise the plant manager on these matters. This change will only serve to correctly identify those positions holding this expertise under the new organization.

Item C - Independent Safety Eva_luation Group (ISEG1 Description of Change The composition of the ICEG for SQN uhould be changed from 5 dedicated full-time onsite engineers to 3 dedicated full-time onsite engineers supplemented by 2 full-time engineers located in corporate headquarters shared by all TVA nuclear facilities.

The ISEG will also now report to the Director of Huclear Safety and Licensing Division.

For further detail see attached marked-up pages.

Reason for Change 4

This change will allow TVA to better utilize the expertise availabic for all its nuclear sites. This will also allow the ISEG organization to better maintain cognizance of issues which are potentially generic to TVA's nuclear sites.

Just}fication for Change This change will bring all TVA's nuclear sites into consistency with the organization already proposed by Watts Bar Nuclear Plant.

By utilizing the 3 onsite full-time dedicated engineers supplemented by 2 offsite full-time engineers it will be possible to better communicate information on issues of l

generic applicability and, at the same time, fulfill the function of the ISEG fully with the available personnel.

In case of an immediate need for offsite support this support will be easily accessible.

The administrative move of the ISEG to report to the Director of Huclear Safety and Licensing Division is consistent with the intent of ISEG and the proposed alignment in standard technical specifications (revision 5) which proposes that the ISEG report to a high level corporate official in a technically oriented position outside the management chain for power production.

._.,r.,

_._r_m,

.r.-_.

._.__.~,_._____y

_ _ ~ - - _ _

=__ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _

\\

-S-Justification for Change The shift supervisor is responsible for the overall safe operation of the plant.

For this reason it is imperative that he remain in the main control room as much as possible without the distraction of intimate involvement in fire fighting efforts.

l This change is more restrictive (i.e., more conservative) than currently configured in unit 1 Lechnical specifications.

Unit 2 technical specifications currently are configured this way.

The fire brigade is shared between the two units, as is the shift supervisor, and this rule, being the more restrictive of the two, is already being followed.

This change will, for clarification purposes, bring unit 1 technical specifications into agreement with the comparable specification for unit 2.

This change will also make SQN's Technical Specifications consistent with Westinghouse Standard Technical Specifications, Revision 5.

Item F - Nuclear Safety Review Board (NSRBl Description of Change Change the qualifications of the members of the NSRB to reference ANSI N18.1-1971.

For further details see attached marked-up pages.

Reason for Change i

This change would allow an individual of noted technical expertise or extensive industry experience in an area (or areas) of NSRB review to be a member of the Board although his background may not include a technical degree.

Justification for Change This change will enhance the flexibility of the NSRB by allowing an individual with noted expertise or experience to be a member of the board.

This addition of flexibility should add to the capability of the NSRB by allowing an

)

individual with demonstrated expertise gathered, for example, in nuclear power plant operations by years of apprenticeship, experience, and training to participate in review without an academic degree.

This individual despite lacking a degree would be an asset to the Board, rather than a detriment.

The additional reference to ANSI N18.1-1971 is consistent with Sequoyah's current commitment for unit staf f qualifications (section 6.3).

Each of these changes has been evaluated pursuant to 10 CFR 50.92 and no nignificant hazards consideration are involved.

The significant hazards consideration determination performed pursuant to 10 CFR 50.92 la provided in attachment A.

i l

1 1

O

, Item D - Radiological Assessment Review Committee ( RARCl Description of Change The administrative change is to change the titles of the members of the NARC to be consistent with the positions responsible for those functions under the new organization.

The RARC provides reports to the Manager of Radiological Control (formerly the Chief, Radiological Hygiene Branch) and the Plant Manager. Any reference to the Chief, Radiological Hygiene Branch should now read Manager of Radiological Control, and any reference to the Radiological Hygiene Branch should read Radiological Control.

For further details see attached marked-up pages.

Reason for Change Due to the proposed reorganization, the positions identified in the current revision of technical specifications will no longer exist. This change is intended to identify equivalent positions.

Justification for Change The purpose of the RARC is to advise the Manager of Radiological Control and the plant Manager on all matters related to radiological assessments involving dose calculations and projections and environmental monitoring.

This change serves to identify the positions which serve to provide this expertise and provide the functions necessary to perform and document this role. The changes in 6.5.3.4, meeting frequency, as an alternative allows credit to be taken for any meeting requested and subsequently convened by the RARC Chairman or a plant representative to satisfy the requirement to meet at least every six months.

The changes in 6.5.3.5, quorum, ensures that a plant representative is in attendance at each meeting in order to satisfy plant manager responsibilities.

The changes in 6.5.3.6, Responsibilities, clarify our understanding of the defined responsibilities.

Item R - Fire Brigade Members Description of Change For unit 1 technical specifications, change 6.2.2.e to specify the shift supervisor as 1 of the 3 excluded personnel from membership in the fire brigade.

For further details see attached marked-up pages.

Reason for Change This change will make unit 1 technical specifications consistent with unit 2 technical specifications.

^^~~

e jl i Justification for Change 4

The shif t supervisor is responsible for the overall safe operation of the plant. For this reason it is imperative that he remain in the main control i

room as much as possibic without the distraction of intimato involvement in j

fire fighting efforts.

l i

This change is more restrictive (i.e., more conservative) than currently configured in unit 1 technical specifications.

Unit 2 technical specifications currently are configured this way.

The fire I

i brigade is shared between the two units, as is the shif t supervisor, and this rule, being the more restrictive of the two, is already being followed.

This change will, for clarification purposes, bring unit I technical specifications into agreement with the comparable specification for unit 2.

j This change will also make SQN's Technical Specifications consistent with j

Westinghouse Standard Technical Specifications, Revision 5.

l Item F - Nuclear Safety Review Board {USRB) a i

Description of Change Change the qualifications of the members of the NSRB to reference l

ANSI N18.1-1971.

For further details see attached marked-up pages.

i j

Reason for Change This change would allow an individual of noted technical expertise or extensive industry experience in an area (or areas) of NSRB review to be a l

j member of the Board although his background may not include a technical degree.

Justification for Change This change will enhance the flexibility of the NSRB by allowing an individual

]

l with noted expertise or experience to be a member of the board. This addition of flexibility should add to the capability of the NSNB by allowing an individual with demonstrated expertino gathered, for example, in nuclear power plant operations by years of apprenticeship, experience, and training to 1

participate in review without an academic degree.

This individual despite lacking a degree would be an asset to the Board, rather than a detriment.

The j

additional reference to ANSI N18.1-1971 is consistent with Sequoyah's current commitment for unit staff qualifications (section 6.3).

Each of these changes has been evaluated pursuant to 10 CFR 50.92 and no e

significant hazards consideration are involved. The significant hazards consideration determination performed pursuant to 10 CFR 50.92 is provided in 1

attachment A.

i 1

1 4

)

i

. = -

e 9

9 ATTACHMENT A SIGNIFICANT IIAZARDS CONSIDERATIONS 1.

Is the probability of an occurrence or the consequences of an accident previously evaluated in the safety analysis report significantly increased?

No.

This change is intended to accurately reflect the changes to the Administrative Controls Section (section 6) of Technical Specifications due to the realignment of the ONP.

The functions specified in section 6 important to the safe operation of SQN have not been altered or deleted.

The changes to this section merely reflect the new positions that hold the expertise to perform these functions. The roles of PORC, RARC, NSRB, and the ISEG are advisory roles to provide technical assistance to those individuals charged with the responsibility of safe operation of this facility.

This change better identifies those positions occupied by individuals quallflod to provide this technical assistance.

There are no hardware, procedure, personnel, or analysis changes represented by this amendment proposal which

'j adversely affect the probability of occurrence or the consequences of an accident previously evaluated in the safety analysis report.

The revision to unit one fire brigade membership serves only to make the technical specificiations for both units consistent. This change, in excluding the shif t supervisor from membership in the brigade, ensures that the individual specified in 6.1.3 as being responsible for the control room command function is not distracted by this peripheral responsibility. This change does not adversely affect the safety analysis.

2.

Is the possibility for an accident of a new or different type than evaluated previously in the safety analysis report created?

No.

This change represents only a change in the administrative process in that new positions are identified for review functions of organizations such as p0RC, RARC, NSRB, and ISEC.

This review function will continue to be performed by those individuals who are technically competent to perform these review or advisory roles; therefore, the potential for the increase of a possibility of an accident or a new or different type accident from an inadequate review is reduced rather than increased due to having the appropriate personnel designated for these functions.

3.

Is the margin of safety significantly reduced?

No.

The changes in this amendment proposal serve only to clarify those positions responsible for key safety functions specified in section 6 of technical specifications.

No function has been impaired or deleted by this change.

On the contrary, those functions are enhanced by additional i

clarity afforded by the reorganization.

i

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