ML20211F672
| ML20211F672 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah  |
| Issue date: | 09/26/1997 |
| From: | Burzynski M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-M95676, TAC-M95677, TAC-M95678, TAC-M95756, TAC-M95757, NUDOCS 9710010160 | |
| Download: ML20211F672 (16) | |
Text
o HA Tennes**e Valley Authority,1101 Market Street, ChattarocQa. Towemie 3740,M801 September 26. 1997 U.S. Nuclear Regulatory Commission ATTH:
Document Control Desk Washington, D.C.
20555 Gentlement In the Matter of
)
Docket Hon. 50-327 50-259 Tennessee Valley Authority )
50-328 50-260 l
50-?96 l
TVA NUCLEAR - RESPONSE TO REVUEST FOR ADDITIONAL INFORNATION -
TECNNICAL SPECIFICATION (TS) CHANGE REQUEST 95-19 FOR SEQUOYAN NUCLEAR PLANT (8QN) UNITS 1 AND 2, CHANGE REQUEST T8-372 FOR BROWN 8 FERRY NUCLEAR PLANT (BFN) UNIT 8 1, 2, AND 3 (TAC NOS.
N95756, N95757, N95676, N95677, AND M95678) AND TVA NUCLEAR QUALITY ASSURANCE PLAN (N04P) TVA-NQA-PLN89-A, REVISION 7 This submittal responds to the NRC letter dated June 23, 1997, in which a requent was made by Mr. Ronald Hernan and Mr. Joseph Williams for additional information on the subject TS change requests.
The enclosure to this lott9r provides the requested information.
The additional information includes references to requirements relocated to the TVA HQAP and, in somo cases, additional discussion and justification for the proposed changes.
The proposed TS changes are consistent with the philosophy of
/
NRC Administrativo Letter 95-06 in that the relocated
/
requirements are adequately controlled by 10 CFR 50 Appendix B,
/
/
TVA's NRC-approved NQAP which commits to Regulatory Guides and industry quality assurance standards, and the established quality assurance change control process in 10 CFR 50.54(a).
TVA believes the proposed TS changes are also consistent with the Improved Standard Techaical Specifications (ISTS) approach in that nontechnical TS provisions are being
- A relocated to other controlled documents.
Typically, this is being accomplished by relocating requirements to the HQAP which, in turn, endorsos establishod industry standards and Regulatory Guides for the detailed program requirements.
9710010160 970926
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U.S. Nuclear Regulatory Commission Page 2 l
September 26, 1997 1
In general, the relocated requirements maintain the equivalent requirements as the existing TS.
For the items which involve I
some change in requirements from the current TS, the enclosure provides an explanation of the reasons for the change Tnd summarizes the benefits associated with the requested change.
In most cases, the same TS changes requested for BFN and SQN have been previously approved for the current Watts Bar Nuclear Plant (WBN) TS, and TVA desires to have uniform TSs in these areas for each of its nuclear-plants.
It is advantageous to TVA to have uniform regulatory requirements for each of the TVA nuclear plants for the type of administrative program areas associated with these TS changes.
consequently, common program and process procedures can be implemented at each site.
Approval of the requested TS changes would support this objective by bringing the BFN and SQN administrative section TS into close conformance with the current WBN administrative TS.
There are no new commitments contained in this letter.
If you have any questions concerning this information, please telephone me at (423) 751-2508.
Sincerely,
,. h11 4
Mark Burzy ki Manager Nuclear Licensing Enclosures
e U.S. Nuclear Regulatory Commission Page 3 September 26, 1997 cc (Enclosures):
l U.S. Nuclear Regulatory Commission Region II l
Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. Ronald W. Hernan, Senior Project Manager U.S. Nuclear Regulatory Commission one White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. M. C. Thadani, Project Manager U.S. Nuclear Regulatory Commission one White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. J. F. Williams, Project Manager U.S. Nuclear Regulatory Commission one White Flint, North 11555 Rockville Pika Rockville, Maryland 20852 NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379 I
TVA Nuclear (TVAN) Response to WRC Request For Additional Information on Sequoyah Technical specification (Ts) Change Request 95-19 and Browns Ferry T5 Change Request 372 and Proposed Revision 7 to the Nuclear Quality Assurance Plan (NQAP)
Browns Ferry (BFN) and so.ggoyah (80N)_
Ouestion No. 1 On page 22 of 136 (second paragraph from the bottom) of the proposed revision to the TVA HQAP, what does the "or equivalent" mean and permit?
The NRC position, as delineated in Standard Review Plan 13.4, is that personnel performing the independent safety engineering (ISE) function should meet the l
requirements of Section 4.4 of ANS 3.1, which does not provide l
for "or the equivalent."
Please clarify the intent of this HQAP requirement.
TVA Response The term "or equivalent" is consistent with previous commitments made by TVA and is also consistent with standard industry practice.
TVA is committed to Regulatory Guide (RG) 1.8, Revision 2, for qualification of personnel which endorses ANSI /ANS 3.1-1981.
In lieu of a Bachelor Degree in Engineering, Section 4.4 of ANS 3.1 allows for a Bachelor Degree in related sciences.
Additionally, the methodology described in ANSI /ANS 3.1-1987 provides guidance for evaluating an individual's work-related experience, training, and formal education for the purpose of determining if the individual has the equivalent of a Bachelor Degree in Engineering.
This is addressed in TVA's HQAP, Appendix B, alternatives for RG 1.8 (page 109 of Revision 7).
The term "or equivalent," as described in the NQAP, is intended to permit TVA's management to place personnel in an independent technical review position who have the equivalent of a Bachelor Degree in Engineering.
The placement of such individuals would only take place after formally evaluating an individual's work experience, training, and formal education.
It should be noted that this area of the HQAP has not changed from the currently approved NQAP, Revision 6.
Ouestion No. 2 TS Section 6.3.1 (SQN) and 6.3 (BFN) - The revised TS section, as proposed, is not consistent with NUREG-1431 or NUREG-1433.
These NUREGs provide current staff positions on TS content and include references to RG 1.8 and ANSI (STANDARD NUMBER).
Therefore, TVA is requested to add RG 1.8 to the TS wording.
I i
TVA Resoonst The referenced Improved Standard Technical Specifications (ISTS) NUREGs require that an overall qualification statement bo provided by referencing the applicable ANSI standards for staff qualifications for tho facility.
The proposed DFN and SQN TS changes require staff qualifications to bo in accordance with the HQAP which, in turn, contains the TVA commitment to RG 1.0, Rovision 2, and the related ANSI Standards for personnel qualification and training requirements.
This commitment is located in Appendix B of the HQAP (pages 101 and 109).
The proposed TS changos simply remove a redundant administrative commitment from the TS an4 refer to an existing equivalent commitment in the HQAP.
Theftfore, TVA believes the proposed TS changes are consiston% v 3h the ISTS approach.
It is noted that the samo TS as those 1equested for BFN and SQN has been previously approved for the current Watts Bar Nuclear Plant (WBN) TS, and TVA desires to hava uniform TSs in this area for each of its nuclear plants.
This proposed TS chango is also consistent with the philosophy of NRC Administrative Lottor 95-06 in that the relocated requirements are adequatoly controlled by 10 CFR 50 Appendix B; TVA's NRC-approved NQAP which commits to RG 1.8, Rovision 2 which endornos ANSI N18.1-1971 and ANSI /ANS 3.1-1981; and the established quality assuranco change control process in 10 CFR 50.54(a).
Based on the above justification, TVA requests that the NRC reconsider its position on this item.
ouestion No. 3 TS Section 6.4 - The requirements being removed from TS (retraining and replacement training facility staff) do not appear to be in Revision 7 of the HQAP.
TVA ReER2 DER Training and retraining requirements for the facility and replacement staff will continue to be as specified in Section 11.0 of the NQAP.
Specifically, Section 11.4 references Appendix B of the NQAP which provides a commitment to RG 1.8, Revision 2, and ANSI N18.1-1971 and ANSI /ANS 3.1-1981 for personnel qualification and training requirements.
Rotraining of personnel is performed in accordance with these commitments in the HQAP.
TVA's requested TS changes are also consistent with other plants' TS which typically provido an endorsement of ANSI N18.1-1971 (or ANSI /ANS 3.1-1981 for later plants) for personnel qualifications and training roquirements).
Approval of the TS change would also provido uniform TSs in this area for each of its nuclear plants.
2
4 The proposed TS change is consistent with the philosophy of HRC Administrative Letter 95-06 in that the relocated requirements are adequately controlled by 10 CFR 50 Appendix B; TVI.'s FRC-approved NQAP which commits to RG 1.8, Revision 2 which endorses ANSI N18.1-1971 and ANSI /ANS 3.1-1981; and the established quality assurance change control process in 10 CFR 50.54(a).
Question No. 4 l
TS Section 6.5.2.1 - Provide reference to NQAP sections containing requirements equivalent to TS 6.5.2.1.
Justify any differences between the current requirements and the proposed NQAp requirements.
TVA Resoonse Section 4.1.3.B.5 of NQAP, Revision 7 (page 16), provides a specific commitment for the Nuclear Safety Review Board (NSRB) to comply with the requirements of ANSI N18.7-1976/ANS 3.2.
This commitment is implemented by the NSRB in accordance with a TVA internal procedure which restates the detailed requirements from ANSI N18.7.
Section 4.3.1 of ANSI N18.7 is equivalent to the current TS Section 6.5.2.1.
TVA is committed to RG 1.33, Revision 2, with no exceptions to Section 4.3.1 of the endorsed ANSI N18.7-1976/ANS 3.2 (page 110 of the HQAP).
This proposed TS change is consistent with the philosophy of the Reviews and Audits section of NRC Administrative Letter 95-06.
It should be noted that this araa of the NQAP has not changed from the currently approved NQAP, Revision 6.
Ouestion No. 5 TS Sections 6.5.2.4, 6.5.2.5, 6.5.2.6 - Where are current TS Sections 6.5.2.4 (NSRB Consultants), 6.5.2.5 (NSRB Meeting Frequency), and 6.5.2.6 (NSRB Quorum) addressed in the revised NQAP?
Justify any differences between the current requirements and the proposed NQAP requirements.
TVA Resoonse Section 4.1.3.B.5 of NQAP, Revision 7 (page 16), provides a specific commitment for the NSRB to comply with the requirements of ANSI N18.7-1976/ANS 3.2.
This commitment is implemented by the NSRB in accordance with a TVA internal procedure which states-the detailed requirements from ANSI N18.7.
Sections 4.3.1, 4.3.2.2, and 4.3.2.3 of ANSI N18.7 are equivalent to the current TS Sections 6.5.2.4, 6.5.2.5, and 6.5.2.6.
TVA is committed to RG 1.33, Revision 2, with no exceptions to Sections 4.3.1, 4.3.2.2, or 4.3.2.3 of the endorsed ANSI N18.7-1976/ANS 3.2 (page 110 of the NQAP).
This proposed TS change is consistent with the philosophy of the Reviews and Audits section of NRC Administrative. Letter 95-06.
3
It should be noted that this area of the HQAP has not changed from the currently approved NQAP, Revision 6.
Question No. 6 TS Section 6.5.2.7.a - The current TS Section 6.5.2.7.a requirements have been reduced in their relocation to the proposed Revision 7 of the HQAP (Section 4.1.3.B.S.b.1).
Present TS would require a review of all safety evaluations.
In the relocation of these requirements to proposed Revision 7 of the NQAP, the relocation appears to have reduced the review scope and would only require a review of completed 50.59 evaluations on a sample basis.
Justify the reduced scope of safety evaluation reviews by the NSRB.
i 1
TVA ResDonse TVA identified this propused change as a reduction in commitment in the october 11, 1996, cover letter which transmitted Revision 7 of the NQAP to the NRC.
Additional discussion and justification for the proposed change is provided below.
Section 4.1.3.B.5 of NQAP, Revision 7 (page 16), and the current NQAP provides a commitment for the NSRB to comply with the requirements of ANSI N10.7-1976/ANS 3.2 including Section 4.3.4 which defines review subjects for independent review organizations.
One of the ANSI review subject areas is the safety evaluations of changes to the facility as described in the Safety Analysis Report.
Presently, the three TVAN plants have three differe.nt TS requirements which further delineate 'he NSRB review scope for safety evaluations. The SQN TS does not require review of all safety evaluations.
Instead, SQN TS 6.5.2.7 states, "The NSRB shall be cognizant of review of the safety evaluations This simply requires the'SQN NSRB to be aware of for.
reviews and does not require NSRB to actually perform any reviews itself.
The BFN TS require the BFN NSRB to review all safety evaluations.
WBN TS directly reference the HQAP for NSRB requirements which are similar to the SQN requirements for the review of safety evaluations.
TVA desires to have a uniform commitment in this subject area so that the three TVAN NSRBs function in the same manner.
The change requested by TVA would cb9nge the BFN and SQN TS to directly reference the NQAP Revision 7 as the sole source for NSRB requirements for the review of safety evaluations using the current WBN NQAP provisions as the model requirements.
The proposed change would primarily affect the current practices of the BFN NSRB which reviews all safety evaluations.
Rather, as proposed in the NQAP change, the NSRB would review a sample of safety evaluations based on safety significance.
We consider tnis approach in keeping with the objectives of ANSI N18.7-1976/ANS 3.2 Section 4.3 regarding responsibilities of the independent review organizations.
Specifically, that the 4
NSRB function is botter fulfilled as an independent oversight role in a'asessing the safety evaluation program and process, rather than by providing a third party after-the-fact review of all safety evaluations as is currently performed by the BrH NSRD.
A more comprehensive review of the overall safety evaluation process can be accomplished by focusing NSRB oversight and resources on the more safety-significant changes as well as the overall implamentation of the 10 CFR 50.59 program.
This l
methodology is consistent with the overall TVAN management philosophy that puts strong emphasis on line self-assessments l
coupled with comprehensive management oversight of the self-assessment activities.
As such, the greatest impact on the quality of the program is achieved by focusing NSRB oversight on broad, programmatic issues and effective monitoring of process controls.
TVA believes that this proposed change represents an improved methodology for NSRB review of the management controls governing plant changes.
The proposed change is also consistent with the currently approved requirements for Plant Operations Review Committee (PORC) oversight of 50.59 safety evaluations.
Due to the j
frequency of PORC meetings, PORC is better structured to find problems prior to implementation of procedure / design changes.
NRC expressed some concern that the words " selected based on safety significance" might result in limiting the scope of review to safety (e.g., safe shutdown) systems.
It is not TVA's intent to limit the scope of review in any manner.
TVA recognizes that the full range of the 50.59 program must be reviewed, from initial screening evaluations through implementation of special requirements identified in the safety evaluations.
Finally, NRC approval of the proposed change would provide uniform requirements for NSRB at all TVA sites.
The proposed change is consistent with the most recently approved NSRB requirements in force at WBN.
Question No. 7 TS Section 6.5.2.7.1 - Justify removal of requirements for NSRB review of PORC meeting minutes in the proposed NQAP.
TVA Resoonse TVA identified this proposed change as a reduction in commitment in the October 11, 1996, cover letter which transmitted Revision 7 of the NQAP to the NRC.
Additional discussion and justification is provided below.
The current TS 6.5.2.7.1 requirement for the NSRB to review PORC minutes and reports is not being relocated to the NQAP since this activity is not a requirement of RG 1.33, Revision 2, or the
endorsed ANSI N18.7-1976/ANS 3.2, Section 4.3.4.
Section 9.9.6.B.7 and 9.9.8.B.6 of the HQAP will, however, continue to require that SQN and BFN PORC meeting minutes be provided to the NSRB.
This affords the NSRB the opportunity to review PORC meeting minutes although not specifically required by RG 1.33 or ANSI N18.7-1976/ANS 3.2.
Considering that ANSI guidance does not include the review of PORC minutes, the removal of the requirement for a formal review of PORC minutes is justified.
In addition, HRC approval of the proposed change would provide uniform requirements for NSRB at all TVA sites.
The proposed change is c>nsistent with the WBN TS and HQAP revision previously accepted by the NRC.
Reports and meeting minutes of the PORC are not included based on Standard TS, Offsite Review Responsibilities.
Question No. 8 TS Sections 6.5.2.10.a and 6.5.2.10.b - Justify the extension l
from 14 to 30 days for preparation, review, and forwarding of NSRB minutes and reports.
TVA Response TVA identified this proposed change as a reduction in commitment in the october 11, 1996, cover letter which transmitted Revision 7 of the NQAP to the NRC.
Additional discussion and justification is provided below.
NSRB is subject to the requirements of TVA's corrective Action Program.
As such, safety significant issues identified by the NSRB are required to be promptly entered into the corrective Action Program for evaluation and subsequent disposition.
The 14-day requirement for issuance of NSRB meeting minutes is administrative in nature and has no bearing on the prompt identification and resolution of safety issues.
Section 4.3 of ANSI N18.7-1976/ANS 3.2 provides requirements for the performance of independent review groups with regard to meeting minutes and reporting; however, no specific guidance is provided with regard to the timing of the preparation of NSRB meeting minutes and reports.
Considering that the existing 14-day requirement in TS is not mandated by RG 1.33, Revision 2, or the endorsed ANSI N18.7-1976/ANS 3.2, TVA believes a 30-day requirement, similar to the timeframe specified for the preparation of audit reports as stipulated in ANSI /ASME H45.2.12-1977 is justified.
This change has been previously approved for WBN, and approval of this proposed change for BFN and SQN would provide uniform requirements in this area for TVA sites.
6
i Ouestion No. 9 TS Section 6.5.2.10.c - Provide references to equivalent requirements in the proposed NQAP, and justify any differences between the current requirements and the proposed HQAP requirements.
TVA REsoonse TS 6.5.2.10.c on audit report distribution is replaced by NQAP, Section 12.2.E.5, and the corresponding commitment in Appendix B of the NQAP to RG 1.144 and ANSI N45.2.12-1977 (page 124).
Distribution of reports and the timing of reports is in Section 4.4.6 of the subject ANSI and is equivalent to the i
wording in TS 6.5.2.10.c with the following exception.
The i
existing TS specifies the TVA management position to which a copy l
is provided, whereas the ANSI references distribution to l
responsible management.
At TVA, audit report distribution is controlled by an internal administrative procedure which includes the President, TVAN and chief Nuclear Officer (formerly Senior Vice President, Nuclear Power).
TVA believes it is not necessary to provide this level of detail regarding audit report distribution in the HQAP.
This is consistent with the ANSI standard guidance and has been previously approved for WBN.
TS 6.5.2.10.c also refers to a specific listing of audits in TS 6.5.2.8.
The same audits in TS 6.5.2.8 are specified in NQAP, Section 12.2.E.4.
Ouestion No. 10 TS Section 6.10 - Provide references for records retention requirements proposed to be relocated to the NQAP.
Justify any differences between the current requirements and the proposed NQAP requirements.
TVA Resconse Record retention source requirements are provided in the NQAP, Appendix B, Revision 7 (pages 119-121 of the NQAP), and by the NQAP endorsement of RG 1.88, Revision 2, and ANSI N45.2.9-1974.
Record types specifically identified in ANSI N45.2.9-1974 that are also listed in BFN TS 6.10.1, SQN TS 6.10.1, and SQN TS 6.10.2 are not repeated in the NQAP.
Although, in some cases, the ANSI wording for the equivalent TS-specified record differs slightly from the current TS wording, TVA considers there are no changes in record-keeping requirements.
The remainder of the record types in BFN TS 6.10.1, SQN TS 6.10.1, and SQN TS 6.10.2 are relocated on pages 119-121 of Appendix B, NQAP, Revision 7.
In summary, the records currently required by the TSs will continue to be maintained.
The specific record types have been relocated in the NQAP or are required by the NQAP commitment to ANSI N45.2.9-1974.
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I e Question No. 11 TS Section 6.13 (SQN), 6.11 (BFN) - The staff's position J
regarding the Process Cantrol Program (PCP) is that the controls 2
for the review and approval of future changes to the PCP should be addressed by the licensee in a document controlled under 10 CFR 50.54(a).
Please incorporate appropriate PCP requirements j
into the proposed NQAP.
l TVA Resoonse l
Requirements for the review and approval of future changes to the PCP have been relocated from TS to the NQAP, Revision 7, for BFN 4
and SQN as follows:
l For BFN, Section 9.9.8.A provides requirements for the i
technical review and approval of procedures listed in Section 9.9.9.A.
Subitem 7 of Section 9.9.9.A is the PCP.
PORC review and Plant Manager approval of PCP changes is required by Sections 9.9.8.B.4.g and 9.9.8.A.4 respectively.
Recordkeeping requirements for PCP changes are listed in Appendix B, page 121, item 9, and are the same as those currently required by TS.
For SQN, Section 9.9.6.A provides requirements for the technical review and control of-procedures listed in Section d
9.9.7.A.
Subitem 7 of Section 9.9.7.A is the PCP.
Review knd approval of PCP changes is required by Section 9.9.6.A.1.
Recordkeeping requirements for PCP changes are listed in Appendix B, page 120, item 14, and are the same as those currently required by TS.
l TVA considers that the current TS requirements for approval of changes to the PCP have been equivalently relocated to the NQAP as described above for BFN and SQN.
These relocated requirements are subject to the establishad quality assurance change control process under 10 CFR 50.54(a).
Therefore, TVA believes that Revision 7 of the NQAP is in conformance with the j
NRC's staff position on this ite.2.
I s
8
o SON Plant-BDecific Ouestions Ouestion No. 1 TS'Section 6.2.3 - ISE function.
This section was to be incorporated into the TVA NQAP.
Section 4.1.3.C 7.b.16 of the NQAP appears to be the section to which these TS requirements were relocated.
The following changes (between the current TS and revised NQAP) were noted that are not soecifically discussed in the TS 95-19 submittalt a.)
The words " independent technical review" are used instead of "ISE"-in the NQAP.
b.)
It appears that the personnel involved in the ISE function report to the " Site Manager, Licensing and Industry Affairs," in the NQAP rather than the " Manager, Independent Review and Analysis" as stated in the current TS.
c.)
The independant, technical review function (ISE in the TS) is the responsibility of the " Site Nuclear Asburance and Licensing (NA&L) Manager."
This apparent reorganization is not discussed or explained in the submittal for TS 95-19.
d.)
The NRC staff was unable to find the equivalent of TS 6.2.3.2.,
" Composition," (of the ISE) in the revised NQAP.
Provide a discussion of these differences between the current SQN TS and Revision 7 to the HQAP.
TVA Resnonse a.)
The term " independent technical review" was derived from the term "(Technical) Review Responsibilities" which is the term used in NUREG 1431, " Standard Technical Specifications for Westinghouse Plants," for ISE review responsibilities.
TVA considers the tern " independent technical review" to be synonymous in meaning to the functions performed by ISE.
The term " independent technical review" was incorporated in a previous revision to the NQAP.
The independent technical review, or ISE review, functions remain the same and would not change as a retult of the proposed revision.
However, the method in which the ISE functions are performed would be changed by the 1"oposed revision, see (d) below.
b.)
The ISE function previously reported to the Manager, Independent Review and Analysis.
At the time of the subject TS submittal an organizational realignment was made (on June 10, 1996) which had the ISE function reporting to the site Manager, Licensing and Industry Affairs (L&IA) and making recommendations to the corporate 9
o Manager, L&IA.
A subsequent reorganization (on July 1,
- 1997) further changed the reporting relationship.
Specifically, this reorganization resulted in separating the NA&L organizations.
Due to this realignment the site Manager, Industry Affairs (ISE function) now reports to the Sequoyah Manager, L&IA, and makes recommendations to the Site Vice President (VP).
The sequoyah Manager, L&IA, reports offsite to the Corporate Manager of Nuclear Licensing.
This new organizational structure will be reflected in the next periodic revision to the HQAP.
This reporting relationship is independent of both the line-management responsible for production as well as quality assurance.
The change in the position to which the independent technical review function makes recommendations is appropriate for the following reasons.
The Site VP has overall responsibility and accountability for site l
functions.
He maintains oversight of nuclear safety and operational issues and is the senior manager best able to ensure tiinely implementation of independent technical review recommendations.
In addition, Site L&IA management maintains the ability to escalate any unsatisfactory site response to offsite senior management.
c.)
See justification (b.) above.
d.)
TVA identified this change as a reduction in commitment in the october 11, 1996, cover letter which transmitted Revision 7 of the NQAP to the NRC.
The composition, as described in the current Sequoyah TS 6.2.3.2, requires the equivalent of five full-time engineers be dedicated to performing the ISE function.
A specific requirement for ISEG composition is burdensome to a licensee as it restricts the capability to utilize resources to their maximum advantage without a resultant increase to the protection afforded to the health and safety of the public.
The proposed change would provide the necessary flexibility for senior management to ensure accomplishment of the ISE functio.' in a manner which maximizes utilization of resources.
The justification for the proposed change is contained in NUREG 1431, as described below.
In addition, the proposed change is consistent with the NRC's previous approval of the WBN Technical Snecifications regarding independent technical review -
described in Section 4.1.3.C.7.b.17 of the NQAP, Revisic.
6.
Also, the proposed change is consistent with the NRC's previous position regarding performance of the ISE function at other utilities.
NUREG 1431 describes the "(Technical) Review P.esponsibilities" in terms of the functions that are to be performed, not in prescriptive terms of how many individuals and what 10
a organization would perform those functions.
The function as described in the current TS 6.2.3.1 is maintained in the HQAP.
NRC's Regulatory Roview Group Report regarding Saabrook, Volume 3, Appendix A; dated August 1993 also found the current TS concerning the Indopondent safety Engineering Group (ISEG) inflexible and provided the Revised Standard Technical Spec!fications as a solution.
Specifically the report statos, ".
. the composition of ISEG providos little flexibility.
However, a Technical Specification chango can be submitted adopting the Improved Standard Technical Specification approach; that would provido considerable flexibility in the implementation of this requirement."
The report concluded, "The Improved Standard Technical Specifications permit the ISEG function to be performed under the vr,iew and audit program.
This permits more flexible methods of performing the ISEG function (i.e., by a standing committee or by assigning qualified individuals capable of conducting these reviews and audits)."
NRC has approved similar requests by ot*-ar licenseos, reference letter from NRC regarding St
- Lucie, l
Unit 2, dated December 22, 1994.
Under the current orga.aizational structure (effective July 1, 1997) the Sequoyah L&IA organization is responsible for the indopondent technical review function and provides the Site VP with recommendations regarding improvements in nuclear safety.
Plant operating t
l characteristics, NRC issuancos, industry advisorios, l
Licensee Event Reports and other sourcos that may indicate areas for improving plant safety are reviewed by the site L&IA organization.
Appropriate controls, such as organizational reporting and implementing procedures, are currently in place and would remain in place to ensure the independence of this function.
This also ensures that recommendations regarding nuclear safety improvements are properly dispositioned.
Ouestion No. 2 Proposed Revision 7 to the NQAP (see paragraph 4.1.3.C.7.b on page 22), lists qualifications for NA&L technical reviewers.
What is the basis for those proposed qualifications for personnel performing the ISE functions (e.g., ANSI N18.7-1976)?
TVA Resnonsq The basis for the qualification is TVA's commitment to RG 1.8, Revision 2, and the endorsed ANSI /ANS 3.1-1981, Section 4.4, (page 109 of the NQAP).
This is consistent with Standard Review Plan Section 13.4 recommended qualific6tions for ISE personnel.
(Also see TVA's response to Question No. 1 for DFN and SQN concerning the use of ANSI /ANS 3.1-1987 for evaluating equivalent-related experience.)
11
i i
i BFM - Plant-Smenifio Questiggg Question No. 1 Changes to TS 6.7.1.a and 6.7.1.c propose changing a reference to the Senior VP, Nuclear Power, to the Site VP.
Provide justification for assigning these responsibilities to a lower-level within the TVA organ:,tation.
TVA Response This change request is being'made to provide consistent reporting standards at all TVA nuclear plants.
Currently, SQN and WBN TS provide for safety limit violations to be reported to the Site VP.
The-Site VP has overall responsibility and accountability for site functions..
Question No. 2 Deletion of TS 6.9.1.1 regarding-startup report requirements.
What mechanism. exists to provide information to the staff for
~
power level, fuel design, or thermal-hydraulic changes?
TVA Resoonse There are several processes and mechanisms by which the NRC is notified of power level, fuel design, or thermal-hydraulic changes.
Significant changes in plant design or operating configurations such as those associated with the rated core thermal power would require TS changes.
Hence, the NRC would be actively involved well in advance of an actual change and be in the approval process for required TS changes.
For example, the NRC has been notified of BFN's plans to request approval of an increase in licensed thermal power and operat..ng cycle length.
A license amendment will be required prior to implementation of these changes.
There-are several other regulations which require reporting of core.and plant design changes.
For example, 10 CFR 50.46 requires an annual report of changes-to Emergency Core Cooling System modeling for Loss-of-Coolant-Accidents analyses.
A periodic report of changes to the facility is required by 10 CFR 50.59.
Similarly, 10 CFR 50.71 requires a periodic update of the UFSAR to reflect changes to the facility.
In addition, a copy of the cycle-specific Reload-Licensing Report is included in Appendix N of the BFN UFSAR.
This report provides a detailed description of the fuel types and core loading for each_ operating-cycle.
The reload report also provides the results of the various transient and accident analyses for the cycle including references to the methodology and core parameters used for the analyses.
Appendix B of the reload report describes a summary of new operating options and 12
analyses for each operating cycle.
It is noted that the NRC approval'for now fuel designs is obtained by the fuels vendors prior to use in plants.
Also, TS 6.9.1.7 requires the submittal of the Coro Operating Limita Report (COLR) and revisions thoroto.
A COLR s
generated for each operating cycle and providos a compilation of the core limits for the fuel designs used for the specific operating cycle.
l In summary, the NRC staff is kept informed of changos to plant I
design and core design via the requiremont-and methods discussed above.
Also, since NRC pro-approval is typically i
required for significant plant changes, the NRC is directly involved through the licensing process.
Thorofore, the deletion of TS 6.9.1.1 is justified and oliminatos redundant reporting requirements.
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