ML20235G288
| ML20235G288 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/10/1987 |
| From: | Goodman C NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20235G281 | List: |
| References | |
| NUDOCS 8709290545 | |
| Download: ML20235G288 (12) | |
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NUCLEAR REGULATORY COMMISSION l
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WASHINGTON, D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF SPECIAL PROJECTS SUPPORTING AMENDMENT NO. 58 TO FACILITY OPERATING LICENSE NO. DPR-77 AND AMENDMENT NO. 50 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET N05. 50-327 AND 50-328
1.0 INTRODUCTION
1 By letter dated May 18, 1987, as supplemented June 4,1987, Tennessee Valley l
(TVA, the licensee) requested amendments to the Administrative Controls l
Authority (Section 6) of the Technical Specifications (TS) for Sequoyah Nuclear Section Plant, (SQNP) Units 1 and 2.
The proposed TS changes include:
(1)anupdate of Section 6 to reflect the new onsite and offsite organizational structure being implemented for SQNP, (2) changes to the Plant Operations Review Consnittee i
(PORC) to delete several review responsibilities and replace them with an
" independent qualified review," (3) changes to the composition of the Independent Safety Engineering Group (ISEG), (4) changes to the titles of the members of the Radiological Assessment Review Committee (RARC) and (5) deletion of the Shift Supervisor as a member of the fire brigade for Unit 1.
The May 18, 1987 submittal also withdrew all previous submittals for the Administrative Controls technical specifications (References 1 through 7 of May 18, 1987 letter).
2.0 EVALUATION 2.1 Specification 6.1, Responsibility Specification 6.1.1 and other applicable Specifications are requested to be revised to change " Plant Superintendent" to " Plant Manager." Specification 6.1.2 has been revised to change " Chief, Radiological Hygiene Branch" to
" Manager of Radiological Control." Specification 6.1.3 and other applicable Specifications have been revised to change "NUC PR Division Director" or
" Director. Nuclear Power Division" to " Site Director." These changes are acceptable because they represent title changes only.
Specification 6.1.2 has been changed to delete reference to Table 6.1-1.
This change is acceptable since Table 6.1-1 will be deleted.
(See Section 2.4 below).
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2-2.2 Specification 6.2.1, Organization Offsite Specification 6.2.1.2 is deleted. This Section referred to Figure 6.2-3 which described the organization for ndiological environmental monitoring and dose calculations. Thic change is acceptable since Figure 6.2-3 will be deleted
'(see Section 2.4 below).
. Figure 6.2-1 is revised to reflect the TVA corporate offsite r.uclear organization for facility management and technical support. The corporate level changes represent a restructuring of the corporate offsite organization to provide for centralized direction and contrcl of nuclear activities. Each of the offsite corporate departments shown in Figure 6.2-1 will be responsible for direct support of the sites in their areas of responsibilities. The TVA corporate organization was developed so that support to each of the sites follows clear lines. The new figure describes the new TVA offsite nuclear organization, as detailed in Revision 4 of the TVA Corporate Nuclear Performance Plan (March 26, 1987). The staff has reviewed this revised organization and has found it accept-able(NUREG-1232). The Technical Specification change to. include the new organization meets the acceptance criteria of Sections 13.1.1 and 13.1.2 of the Standard Review Plan (SRP) and is, therefore, acceptable.
In a number of places in the TS the title " Manager of Power" is replaced with
" Manager of Nuclear Power." This is a title change only and is, therefore, acceptable.
2.3 Specification 6.2.2, Unit Staff Specification.6.2.2.c and other applicable Specifications are revised to change i
" health physics technician" to " radiological control technician." This change is acceptable since its represents a title change only, f
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Specification 6.2.2.e for Unit 1 only is requested to be revised to change the number "3" to "the Shift Supervisor and 2 other" thereby restricting the members of the shift crew who may serve on the Fire Brigade. The change does not alter I'
the numbers of shift members who may serve on the Fire Brigade, but it is more restrictive in that the Shift Supervisor is specifically prohibited from serving as a Fire Brigade member. The staff agrees that the Shift Supervisor should not be a Fire Brigade member. The change is, therefore, acceptable.
Figure 6.2-2 is revised to reflect the new TVA site organization for Sequoyah, as detailed in the latest revision of the Sequoyah Nuclear Performance Plan (SOMPP), Volume 2, submitted to NRC on April 1,1987. The Sequoyah site support organization has been reorganized into functional departments that generally parallel the functional departments in the headquarters of the Office of Nuclear
-Power. The SQNPP describes the plan for providing management control and performing specific actions to correct past problems at Sequoyah. Specifically, the SQNPP outlines the management approach for overcoming past problems and improving regulatory performance at Sequoyah. This TS change revises the organization chart in the TS to be consistent with the organization necessary to carry out the improvements specified in the SQNPP.
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The Plant Manager is responsible for conducting day-to-day plant operation in compliance with licensing and regulatory requirements. A plant management organization has been implemer.ted with a unit superintendent assigned to each of the units. As a result of the reorganization, the Plant Manager is free to concentrate his attention to the actual conduct of plant operations.
Due to the reorganization many position titles have changed. Of these, the l
most significant are the following:
1 Previous Title New Title Assistant Director of Sequoyah Site NuclearPower(Operations)
Director i
Plant Superintendent Plant Manager Assistant Plant Superintendent Nuclear Power Plant Superintendent or Maintenance Superintendent Health Physics Radiological ~ Control l
Supervisor l
Quality Assurance Site 0A Manager Supervisor In conclusion, Figure 6.2-2 represents the Sequoyah organization which mansgement control at the site, (3)g, (2) provides a higher level of (1) reflects an increase in staffin shows improved management involvement in plant operations, (a) has distinct functional areas that are separately supervised, (5) meets the acceptance criteria of Section 13.1.2 of the Standard Review Plan (SRP) and (6) is consistent with the Sequoyah organi-zational structure presented in the SONPP. Therefore, the changes to Figure 6.2-2 are acceptable.
2.4 Specification 6.2.1.2, Figure 6.2-3 and Table 6.1-1 The licensee proposed to delete Figure 6.2-3 and Table 6.1-1.
Figure 6.2-3 l
l described the offsite organization for radiological environmental monitoring and dose calculations, while Table 6.1-1 detailed the radiological environ-mental surveillance requirements.
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. The staff does not require that the Technical Specifications include a listing of the radiological environmental surveillance requirements. This information has been deleted from Revision 5 of the Standard Technical Specifications (NUREG-0452).
Therefore, deletion of Figure 6.2-3 and Table 6.1-1 from the Technical Specifications is acceptable.
[E, l 2.5 Specification 6.2.3,-Independent Safety Engineering Group (ISEG) l l Specification 6.2.3.2 is revised to change the Independent Safety Engineering Group (ISEG) so that it would be composed of three dedicated full-time engineers located onsite, supplemented by two full-time corporate engineers which are shared among all the TVA nuclear-sites, in place of the present requirement that the ISEG be composed of at.least five dedicated full-time engineers located at Sequoyah.. This change would decreaseithe onsite full-time ISEG coverage.
It is, however, consistent with requirements for t.n ISEG that the staff has~ required of other utilities having multiple nuclear units at more than one site. 'The nominal requirement for an ISEG at a single site, required for each plant licensed since the TMI-2 accident, has been five full-time individuals. For utilities with multiple sites, however, the staff has accepted an ISEG site.
complement of three engineers backed up by at least two additional engineers at the corporate level.. To date, TVA has been required to have an ISEG only at the Sequoyah site. However, TVA is now restructuring its ISEG program such that.the ISEG will report at the corporate level to the Director of Nuclear Safety and Licensing-(Division).. This change will make all of the TVA's nuclear sites consistent.; Browns Ferry Nuclear Plant will have an ISEG before Unit 2 restart.
In addition, an ISEG will be required at Watts Bar at such time as a Watts Bar unit is licensed. Thus, the individual site ISEGs for TVA plants will henceforth report to and be supported by personnel at the corporate. level on the staff of the Director of Nuclear Safety and Licensing. This proposed change is in accordance with provisions for ISEG coverage that have previously been approved by the staff for other utilities with multiple sites. Therefore, we find this arrangement provides for an acceptable ISEG and we conclude that
'the proposed change to the TS meets the guidance in the SRP Section 13.4 and is acceptable.
Proposed Specification 6.2.3.4 changes the " Assistant Director for Maintenance and Engineering of the Division of Nuclear Power" to the " Director of Nuclear Safety and Licensing," as the individual to whom the ISEG reports. This proposed change is consistent with the revised TVA nuclear organization and with the staff requirement that the ISEG report to a high level, technically oriented corporate position not in the management chain for power production.
The change is, therefore, acceptable.
2.6. Specification 6.3, Qualifications Specification 6.3 is changed to replace " Health Physicist" with " Site Radiological Control Superintendent." This change is acceptable since it represents a title change'only.
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. I 2.7 Specification 6.4, Training Proposed Specification 6.4 changes " Assistant Plant Superintendent" to " Nuclear Power Plant (NPP) Superintendent." In the new TVA organization, the previous position of Assistant Plant Superintendent was deleted. The new organization provides for an NPP Superintendent, a Maintenance Superintendent, and a Site Radiological Control Supervisor who jointly discharge most of the responsibilities previously assigned to the Assistant Plant Superintendent. The staff has determined that the NPP Superintendent is the appropriate individual to maintain cognizance of the retraining and placement training program for the Sequoyah staff. The proposed change is, therefore, acceptable.
The proposed change to Specification 6.4.1 would delete the words " identified by the ISEG" regarding training on relevant industry operational experience.
Deletion of these words is acceptable since relevant industry operational experience might also be identified by other than ISEG personnel.
2.8 Specification 6.5, Review and Audit Proposed Specification 6.5 changes " Manager of Power" to " Manager of Nuclear Power" and " Office of Power" to " Office of Nuclear Power." This title change is consistent with the new TVA organization and is, therefore, acceptable.
2.9 Specification 6.5.1.2, Plant Operations Review' Committee (PORC) l Composition The proposed changes in Specification 6.5.1.2 to the Plant Operations Review Committee (PORC) Composition make the membership consistent with the reorgani-zation discussed in Section 2.3.
The revised committee membership includes the l
Plant Manager as' Chairman and the following members: Superintendent (NPP or Maintenance); Operations Group Manager or Assistant Operations Group Manaaer; Site Radiological Control Superintendent; Maintenance Group Manager, (I),'(E) or (M); and Quality Engineering and' Control Manager.
The revised PORC membership provides a broad cross-section of expertise from l
the plent staff, therefore, preserving interdisciplinary reviews of the subject matter.
Ir, :ddition, the PORC membership will maintain a diversity of back-grounds among its members (i.e., operations, engineering, maintenance, and qualityassurance). We find that these proposed changes to the PORC membership meet the accentance criteria of SRP Section 13.4 and the relevant requirements of Regulatory Guide 1.33 (R.G.1.33). Therefore, these proposed changes are acceptable.
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. 2.10' Specification 6.5.1.6, PORC Responsibilities and new Specification 6.5.1A,
, Technical Review and Centrol i
The-licensee proposed to revise Specification 6.5.1.6 and to. add a new Speci-fication 6.5.1A.. As discussed in detail below, several review responsibilities of PORC would be to be transferred to designated technical reviewers. The new proposed process of Specification 6.5.1A will establish an " independent qualified review" and a. cross + disciplinary review and approval to support cer-tain changes currently under PORC review responsibility..The PORC review-responsibility for tests and experiments that affect nuclear safety and changes to Appendix "A" TS remains unchenged.
The following PORC responsibilities are proposed to be teleted from Specifica-tion 6.5.1.6 as discussed below.
o Review and approval of procedures required by Specification 6.8.1 and other procedures which affect plant nuclear safety and changes thereto will be controlled under the new Specification 6.5.1A,
" Technical Review and Control."
o Review of all programs required by Specification 6.8.5 and changes thereto will be controlled under the new Specification 6.5.1A.
Specification 6.8.5 is being revised to include this review.
Review of any other proposed procedures or changes thereto as deter-
.o mined by the Plant Manager to affect nucleer safety will be deleted.
However, Specification 6.5.1.6.h will be relabeled as f and gives the Plant Manager the authority to escalate any item to be reviewed by PORC.
-o Review of all proposed changes or modifications to unit. systems or equipment that affect nuclear safety will be controlled under the new Specification. 6.5.1A.
Additionally, Quality Engineering and Control will review all workplans before initial approval. The Plant Manager, NPP Superintendent, or Maintenance Superintendent must provide final approval of the change.
o Review of the Plant Physical Security Plan, the Site Radiological Emergency Plan, and implementing procedures is also covered by Spec-ification 6.8.1.
Review and approval of changes to these procedures will be done in accordance with new specification 6.5.1A.
Also, an audit under the cognizance of the Nuclear Safety Review Board (NSRB) will be performed at least once every 12 months of the Plant Physical Security Plan, the Safeguard ~ Contingency Plan, the Site Radiological Emergency Plan, and all implementing procedures. All changes to the Sequoyah Site Radiological Emergency Plan will be approved by the Deputy Manager of the Office of Nuclear Power or his designee, o
Review of changes to the radwaste treatment systems are now covered by Specification 6.15.
Review and approval of these changes will be done in accordance with the new Specification 6.5.1A.
Additionally, Quality Engineering and Control will review all changes before being approved. The Plant Manager, NPP Superintendent, or Main-tenance Superintendent must provide final approval of the change.
4 o Review of meeting minutes of the Radiological Assessment Review Committee (RARC) is no longer needed under the new organization.
i Technical and administrative review used to be split between two separate TVA organizations, one non-nuclear.
PORC review was necessary to oversee the technical review don hy RARC. The new organization has brought the technical expert.- under the nuclear organization that PORC is under, thus deleting the need for PORC review. PORC and RARC are equal-level comittees subject to the same governing upper-tier nuclear procedures. Reports and meeting i
minutes of both committees are reviewed under cognizance of NSRB.
The following PORC responsibilities would be revised in Specif hation 6.5.1.6 as discussed below:
o The proposed change to item "e" replaces the word " investigate" with the word " review" to more accurately reflect the PORC function 1
intended for review of Technical Specification violations.
It is not practical for PORC to perform investigation of the violation.
Investigation and preparation of reports covering evaluations and recommendations to prevent recurrence are performed by the appropriate line organization. PORC will provide oversight to ensure the evalua-tions and recommendations are sufficient and complete, o
The proposed change to item "f" will require PORC to review all reportable events. A reportable event is defined by the Technical Specifications as those conditions specified by section 50.73 to 10 CFR Part 50. The change will be consistent with Specification 6.6, " Reportable Event Action," and is consistent with the Westinghouse Standard Technical Specification (NUREG-0452).
The following PORC responsibilities would be added to Specification 6.5.1.6 as discussed below:
o PORC will provide an oversight review of selected safety evaluations which are prepared per Specification 6.5.1A to detennine the adequacy of the qualified review process. The review will be performed on a monthly basis and shall screen a minimum of 10 percent of the applicable safety evaluations. A list of activities reviewed and the results of the review, including deficiencies or problems noted, will be reported to PORC at scheduled monthly meetings.
This report will become a part of PORC meeting minutes, along with any actions to be taken from the report.
Individuals performing oversight review shall meet the qualifications specified'in Administrative Instruction, AI-43.
o PORC will provide a 100-percent review of proposed procedures and changes to procedures, equipment, systems, or facilities which involve an unreviewed safety question as defined in 10 CFR 50.59.
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. Specification 6.5.1A, Technical Review and Control, is added to describe the -
new technical review and control process. The new process establishes an
" independent qualified review" and provides the opportunity for a cross-disciplinary review and approval that supports changes to procedures and plant changes or modifications to plant nuclear safety-related structures, systems and components. On September 4, 1987 the staff discussed with the l
licensee a minor change to clarify proposed Specification 6.5.1A.b so that it is consistent with Specification 6.5.1A.a.
The change will amend Specification 6.5.1A.b to have any changes to both procedures and structures, systems and components that affect plant nuclear safety controlled by Specification 6.5.1A.
This change was acceptable to the licensee. This change is minor, to J
I clarify Specification 6.5.1A.b to be consistent with Specification 6.5.1A.a.
and, does not change the nature of the amendment request to warrant renoticing 4
this change.
l Each procedure required by Specification 6.8.1 of the TS will be reviewed by an individual other than the preparer. The reviewer may be from the same organiza-tion or from a different organization.
Each review will include a determination
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of whether or not a cross-disciplinary review is necessary.
If so a cross-disciplinary review will be conducted.
Each proposed change or modification to plant nuclear safety-related structures, systems and components will be reviewed bj a reviewer designated by the Plant Manager. Each modification will be reviewet by an individual or group other than the person (s) which designed the mod',fication. The Plant Manager, NPP Superintendent or Maintenance Sererintendent will approve the modifications and the implementing workplans prior to implementation.
A new Administrative Instruction, AI-43 (Independent Review), will establish requirements for Technical Review and Control. AI-43 establishes qualifi-cations and training requirements necessary for qualified reviewers. Every qualified reviewer will receive training in how to determine if an inter-disciplinary review is necessary. Specific guidelines are given for performing the independent qualified review, including the cross-disciplinary review, and the appropriate level of management to approve changes is specified. AI-43 will contain a clause which allows the qualified reviewer or the responsible manager approving the procedures or procedure change the right to request PORC review.
AI-4, " Preparation, Review, Approval, and Use of Plant Instructions," will require review and approval in accordance with Al-43. Appropriate managers responsible for approval of different groups of procedures will be designated within their field of responsibility. Quality Assurance (0A) will be given the option to review all changes. Additionally, Al-4 will require a larger review and higher level of management approval for designated administrative instruc-tions and procedures affecting safety-related functions.
After revising the PORC, the members will have a reduced administrative burden and, therefore, will have more time available for the review of significant issues.
This amendment permits PORC members to focus their attention on the safety significance of the issues essential to the operation of the plant, thereby
. improving PORC's effectiveness. This aspect is increasingly important because of the growing number of procedures, procedural changes, and modifications that must be reviewed. PORC will now be responsible for providing an oversight i
review of selected safety evaluations reviewed under the new process.
The proposed changes will allow for the use of individual qualified techni-cal reviewers who can spend more time on the review. The detailed techni-
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ca1' reviews of procedures can be accomplished by qualified technical reviewers not encumbered with other managerial duties, but possessing the technical expertise to conduct a thorough review. The proposed changes allow for an independent technical and cross-disciplinary review and approval.
The current TS requirement for review of changes is actually satisfied by individuals of a similar responsibility level, however, considerable management time is consumed in the assigning of these personnel to review each item, collecting results from those reviews, and finally attending a fonnal meeting to reconnend a disposition. The method requested by this amendment eliminates
-much of the unnecessary effort and at the sane time provides for a more consistent and timely review and approval process.
It will focus responsibility and accountability to the technical reviewers and provide a better review.-
Cross-disciplinary review 3111 also be improved from current methods since reviewers will be able to concentrate on their particular areas of expertise.
The proposed changes have been designed so as to improve PORC operations. The above changes are acceptable since they (1) are consistent with the acceptance criteria of SRP Section 13.4, (2) meet the objectives of Regulatory Guide 1.33 which requires that decisions affecting safety are made at the proper level of responsibility and with the necessary technical advice and review, (3) provide the opportunity for interdisciplinary review of the subject matter, (4) allow for independent technical review cnd approval, and (5) provide qualified designated reviewers.
2.11 Specifications 6.5.1, 6.8, 6.13 and 6.15 Proposed Specifications 6.5.1.7, 6.5.2.7. 6.8.1, 6.8.2, 6.6.5, 6.13 and 6.15 would revise the TS to be consistent with the above discussed changes to PORC responsibilities. On September 4, 1987, the staff discussed with the licensee adding 6.5.1.6(a) to Specification 6.5.1.7.a.
This change would clarify the items that the PORC recomnends for approval or disapproval in writing to the Plant Manager to be consistent with the responsibilities of the PORC in Specification 6.5.1.6.
The licensee agreed to this change. This change is minor, to clarify Specification 6.5.1.7.a to be consistent with Specification 6.5.1.6, and, therefore, does not need to be submitted or noticedrunder 10 CFR 50.90 and 50.91. Therefore, for the same reasons as those given above, we find the proposed changes acceptable.
2.12 Specification 6.5.2, Nuclear Safety Review Board Specifications 6.5.2.1 and 6.5.2.7 are revised to avoid confusion in interpreting the way the Nuclear Safety Review Board (NSRB) review is required to be conducted.
NSRB delegates the review through use of appointed subconnittees. The proposed change clearly states NSRB's responsibility to be cognizant of the identified review items. The wording change is consistent with SRP Section 13.4 and is, therefore, acceptable.
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.*. 2.13 Specifications 6.5.2.71 and 6.5.3' Throughout these sections, wherever the term "RARC" is used, the licensee proposes to add the' acronym "SQN" before "RARC" to indicate that the Sequoyah
. Radiological Assessment Review Committee (RARC) is being addressed. This addition is merely a' clarification of what is intended by the Specification and is acceptable.
2.14 Specification 6.5.3', Radiological Assessment Review Committee (RARC)
Specification 6.5.3.1 sets forth the functional requirements for SQN RARC.
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~ The committee shall advise the Radiological Control Manager and the Plant Manager on all matters related to radiological assessments involving dose calculations and projections and environmental monitoring. The Plant Manager has the authority to request PORC review of any significant items.
In Specification 6.5.3.1, the words "and the Plant Manager" are added. This change would result in the RARC advising the Plant Manager on all matters related to radiological assessments involving dose calculations and projections and environmental monitoring, as well as the Manager, Radiological Control..
Since the SQN RARC activities are concerned with the Sequoyah plant, the Plant Manager should be aware of these activities. This change is, therefore.
-acceptable.
In Specification 6.5.3.2, the licensee proposes to change the titles of the SON RARC members to be consistent with the positions responsible for those functions in the new organization.
In the process, a fifth Committee member is also added. This is an administrative change only and is acceptable.
Specification 6.5.3.4 specifies that the RARC would meet "at least once per six months and as convened by the RARC Chairman or his designated alternate." -The licensee proposes to modify this wording so that the "SQN RARC shall meet at least once per six months or as requested by the SON RARC Chairman, his designated alternate, or a plant representative." The revised wording would allow plant management to request a SQN RARC meeting. This should result in the SQN RARC being more responsive to plant needs. Thus, we find this change acceptable.
The minimum quorum, as given in proposed Specification 6.5.3.5 for conduct of SQN RARC activities would be changed from the Chairman or his designated alternate and three members, to the Chairman or his designated alternate and four members..This change recognizes the increase in the SQN RARC membership J
(seeitemabove)andisacceptable. Further, the change would require that at least one of the members of the minimun quorum be a plant representative. This change should assure that the plant has input to and is aware of SON RARC activities. We consider it to be an improvement to the plant and, therefore, j
acceptable.
j The wording of Specification 6.5.3.6.c is proposed to be changed from " Review of the results of any audits of the Quality Assurance Program for effluent and environmental monitoring." to " Review for information purposes of the
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. results of any audits,- reviews or evaluations of the Quality Assurance Program
-for effluent and environmental monitoring and radiological assessments involving dose evaluations and projections." The added words (underlined) would clarify the intent of this specification and would expand the range of SQN RARC reviews to include reviews and evaluations as well as formal QA audits, and radiological assessments involving dose evaluations and projects as well as Quality Assurance Program findings. This expansion of SQN RARC activities should help the SQN RARC stay better attuned to radiological control matters at Sequoyah. The change is, therefore, acceptable.
The proposed change to Specification 6.5.3.6.d would insert the word " radio-logical" between " environmental" and " monitoring." The revision would assure that the SQN RARC is responsible for review of Technical Specification changes related to environmental radiological monitoring rather than to all environ-mental monitoring. This is consistent with the mission of the SON RARC and the change is, therefore, acceptable.
A further change to specification 6.5.0 7.a would add the Plant Manager as a recipient of SQN RARC recommendations. Since the SQN RARC is dealing with Sequoyah plant matters, the Plant Manager should be aware of committee recom-mendations. This change is, therefore, acceptable.
2.15 Specification 6.8.3, Temporary Chances to Procedures The new proposed Specification 6.8.3 would allow temporary changes to the intent of the original procedure with approval by two reviewers who meet i
the requirements of Specification 6.5.1A, one of whom holds an SRO. Temporary approval of procedure changes would be allowed even when the intent of the original procedure is changed. This proposed change would not be consistent with Revision 5 of the Westinghouse Standard Technical Specifications, NUREG-0452.
All procedures where the original intent of the procedure is changed need a complete review.. Specification 6.8.2 provides for the acceptable method to review procedures where the intent of the procedure is being altered or changed. Therefore the proposed changes to Specifications 6.8.3, 6.8.3.a and 6.8.3.b are denied. Temporary changes, where the intent of the original procedure is not altered or changed, would still be allowed. The change to Specification.'8.3.c is acceptable since the msponsibilities of the PORC have been revised as discussed in Section 2.10.
2.16 Specification 6.10.2
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The licensee proposed to add the words "for lifetime retention" to help define L
those Quality Assurance records which are to be retained for the duration of the unit operating licenses. These added words clarify what was intended %
this section and are acceptable.
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The title " Operational Quality Assurance Manual" is proposed to be changed to
" Nuclear Quality Assurance Manual." This change is consistent with the revi-sions to the Quality Assurance program, and corrects what otherwise would be an incorrect reference.
It is, therefore, acceptable.
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. 3.0
SUMMARY
The proposed amendments to Section 6. " Administrative Controls" revise the TS changes to the Plant Operations Review Comittee (PORC)yah plant organization, for both Units 1 and 2 to reflect the new TVA and Sequo, a restructuring of the Independent Safety Engineering Group (ISEG) and changes to the Radiological Assessment Review Comittee (RARC).
The proposed changes to Specifications 6.8.3, 6.8.3.a, and 6.8.3b are denied so as to maintain full and complete review of temporary intent changes to procedures. The staff concludes for the reasons stated in the above evalua-tion that all the remaining proposed changes are acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
S These amendments relate to changes in recordkeeping, reporting or administrative procedures or requirements. The Comission has previously issued a proposal finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly these amendments meet the eligibility criteria for categorial exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.
5.0 CONCLUSION
We have concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conoucted in compliance with the Comission's regulations, and the issuance of these amendments will not be inimical to the common defense and security nor to the health and safety of the public.
Principal Contributor:
C. Goodman Dated: September 10, 1987
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