ML20235K167

Safety Evaluation Supporting Proposed Amends to License DPR-77 & DPR-79,updating Section 6 to Reflect New Onsite & Offsite Organizational Structure & Changing Plant Operation Review Committee to Delete Several Responsibilities

ML20235K167
Person / Time
Site:	Sequoyah
Issue date:	07/09/1987
From:	NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20235K147	List: ML20235K144 ML20235K167
References
NUDOCS 8707160183
Download: ML20235K167 (13)

Text

_-

.* [eatoo ~o, , UNITED STATES 8" o NUCLEAR REGULATORY COMMISSION

$ WASHING TON, D. C. 20555 h

SAFETY EVALUATION BY THE OFFICE OF SPECIAL PROJECTS SUPPORTING AMENDMENT NO. TO FACILITY OPERATING LICENSE N0. DPR-77 SUPPORTING AMENDMENT NO. TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

By letters dated May 18, 1987 and June 4, 1987, Tennessee Valley Authority (TVA, the licensee) requested amendments to the Administrative Controls Sec~cion (Section 6) of the Technical Specifications (TS) for Sequoyah Nuclear Plant, (SQNP) Units 1 and 2. The proposed TS changes include: (1) an update of Sec-tion 6 to reflect the new onsite and offsite organizational structure being implemented for SQNP, (2) changes to the Plant Operations Review Committee (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. -

2.0 EVALUATION 2.1 Specification 6.1, Responsibility Specification 6.1.1 and other applicable Specifications have been 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 Specifica-tions have been revised to change "NUC PR Division Director" or " Director, Nuclear Power Division" to " Site Director". These changes are acceptable since they represent tttle 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 has been deleted. (See Section 2.4 below.)

2.2 Specification 6.2.1, Organization Offsite Specification 6.2.1.2 has been deleted. This Section referred to Figure 6.2-3 which described the organization for radiological environmental monitoring and dose calculations. This change is acceptable since Figure 6.2-3 has been deleted (see Section 2.4 below).

8707160183 870709 7 DR ADOCK 0500

1

\

s Figure 6.2-1 (enclosed) has been revised to reflect the TVA corporate offsite i nuclear organization for facility management and technical support. The corporate level changes represent a restricting of the corporate offsite organization to provide for centralized direction and control 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 responsi-bilities. 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 acceptable (NUREG-1232). The Technical Specification change to include the new organization meets the acceptance criteria of Section 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 to be replaced with " Manager of Nuclear Power." This is a title change only and is, i therefore, acceptable.

2.3 Specification 6.2.2, Unit Staff i

Specification 6.2.2.c and other applicable Specifications have been revised  ;

to change " health physics technician" to " Radiological Control technician."

This change is acceptable since its represents a title change only.

Specification 6.2.2.e for Unit 1 only has been revised to change "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 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. % e staff agrees that the Shift Supervisor should not be a Fire Brigade me'1be. The change results in the Unit 1 Technical Specifications being consistent with the Unit 2 Technical Specifications. The change is, therefore, acceptable.

Figure 6.2-2 (enclosed) has been revised to reflect the new TVA site organiza-tion for Sequoyah, as detailed in the latest revision of the Sequoyah Nuclear i Performance Plan (SQNPP), Volume 2, submitted to NRC on April 1, 1987. The l Sequoyah site support eganization has been reorganized into functional l departments that generally parallel the functional departments in the head-quarters of the Office of Nuclear Power. The SNPP 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.

$ p R R N E

u IO A

E C

e S

I C F L L l E

n OC

& a e

U T c D N i T

E n F h

. A c 5

e T

d n

a t

n R R G e O A N m T

C FO L N E I I

e g

E C A RI U R a D N I n

a M

y t

i l

i c

a F

r R n S A E o

O f I E C C F L

I V n I

E OC U R o RI E i D N $ t a

z in a

- g r

O R

E R R e G E E i s A W G Q s O n N R O A

R N Ns f

O A E P N f R G O A n A r o CE M A F O

R A

M I

C F I E O O L N A I E n n A A t V E OC N 1 R t a E M i C

I U

ne D

II II G

a 2 N U P t E

E 4 E G

e D 6 e

r u

i F

t t R l R U Al S I N C l l

t i A L a CG t h e

i ti D t k

N R O t

t O t i t A C CF E ull t

e OIC i ls U Se O N t O

C T

0 CE tt i A ta J S S O R S et E A

A R P G E oM A l

L A N 9

1

( m O C O < b I ,*C 2~4- g C C E E A d

U R N e Ce l

D U H

J I

~

lll 1

• io t L R i

'C E

,,ps RN PE AO T

" R *

" C SI O la V t P l

At f n C 4

lie e f

n CP E o "

t r L

_. o.

0R EU C t g

en*

w.".

s 4 MS tOO 4

HS A tE AeI oe oe

.s f.

i Sc 4 tt aV re CI n.c7u 'taaH EHR T  :

Pno H

! Af l oM1h v ca 4 L P no i o e^, ltPt C s'

J l sc -

uM f A

loL e o

E S t H cE R uS l E T

0 I

l 't HD

" O ors 4 t

S teo t n A N i

I H1 E4 E k"4nR ve ca e D T NR l 1n e rrc AO

• HR tE S r Pet pL P A

P M u E E H y ot T Mu S

e S R eor r o V R r o if E SO L TS I n o 7, TE r i rt f T .

o o AO A ACl o a A l

snj IEV C JR l r A oo icA s E r oe R N

sa.vs.T. rH L P OE o ap T SO os",

o lo A

A LR SRP PU f

eO I AO I

, oM I R

E yH N T M T CS l r I C s IR V I

I r o l

l O t MN u I TR b c D U o

s CE llna a A F t EP n ee D oSR s

I

- LU 4

- L ES p-e t

E -

- 4 f

4 f

A e G -

- CL ROO E O rE O RR L ET HG -

IG R

• S TC AA T

lO_ 4 IB 1E LN Ol IO i

f PA DC D M A L R AT CR l I l O o 4 s

e s

bI liPP l

t u CU

• o E

ES T

H c

sR s s EE R a bos O OA P Y o

e nHA T I

t E Et t

s e su l H

I ITu A -

SC t

s y E

R l I E H S WE O oe Ptts t

I a

n Y k e R L L Es T T C P S uu H s I I

Fe sH M sSe E

l t 1 A R o E C

n o

e.

i. o n E,oA csU se v e gH

• O O O O ne c oeo u A R RR RR iRR w u NS S

SOS PS OS S

rOS s

ap 7

. OIV rVl es Sv I

N' i TR tR a

TE R

N SE tE S

SP P SP NS AU S

U S

SU AS nt tiO.COMfD t a cDtn e

~

aeU

~

1 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 implemented with a unit superintendent assigned to each  ;

of the units. As a result of the reorganization, the Plant Manager is free l to concentrate his attention to the actual conduct of plant operations.

Due to the reorganization many position titles have changed. Of these, the most significant are the following:

Previous Title New Title Assistant Director of Sequoyah Site Nuclear Power (Operations) Director Plant Superintendent Plant Manager Assistant Plant Superintendent Nuclear Power Plant Superintendent or Maintenance Supertintendant Health Physics Radiological Control Supervisor Quality Assurance Site QA Manager Supervisor In conclusion, Figure 6.2-2 represents the Sequoyah organization which (1) reflects an increase in staffing, (2) provides a higher level of j management control at the site, (3) shows improved management involvement i in plant operations, (4) has distinct functional areas that are separately l 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 SQNPP. Therefore, Figure 6.2-2 is acceptable.

2.4 Specification 6.2.1.2, Figure 6.2-3 and Table 6.1-1 Figure 6.2-3 and Table 6.1-1 have been deleted. Figure 6.2-3 described the offsite organization for radiological environmental monitoring and dose calculations, while TabTe 6.1-1 detailed the radiological environmental l

surveillance requirements.

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

m___________ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ . _ _

. l l

2.5 Specification 6.2.3, Independent Safety Engineering Group (ISEG)

Specification 6.2.3.2 has been 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 I decrease the onsite full-time ISEG coverage. It is, however, consistent {

with requirements for an 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 e s Plant will have an ISEG. 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 sup-ported 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 l for other utilities with multiple sites. Tterefore, l we find this arrange-ment provides for an acceptbale ISEG and we conclude that the proposed change to,the TS meets the guidance in the SRP and is acceptable.

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.

During a telephone conference on May 4,1987 TVA requested and the NRC staff granted verbal authorization to implement the abole described ISEG.

2.6 Specification 6.3, Qualifications Specification 6.3 has been changed to replace " Health Physicist" with " Site Radiological Control Superintendent." This change is acceptable since it represents a title change only.

2

__ . , _ _ _ _ _ _ _ _ . - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ .]

i

( -

l

, 2.7 Specification 6.4, Training 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 has been deleted. The new organiza-tion 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 considers 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 also 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 Specification 6.5.0 changes " Manager of Power" to " Manager of Nuclear

. Power" and " Office of Power" to " Office of Nuclear Power." This change is consistent with the new TVA organization and is, therefore, acceptable.

2.9 Specification 6.5.1.2, Plant Operations Review Committee (PORC) '

Composition The proposed changes to the Plant Operations Review Comittee (PORC)

Composition make the membership consistent with the reorganization discussed in Section 2.3. The revised committee membership includes the Plant Manager as Chairman and the following members: Superintendent (NPP or Maintenance);

Operations Group Manager or Assistant Operations Group Manager; Site Radiological Control Superintendent; Maintenance Group Manager, (I), (E) or (M); and Quality Engineering and Control Manager. l 1

The revised PORC membership provides a broad cross-section of expertise from j the plant staff, therefore, preserving interdisciplinary reviews of the subject ]

matter. In addition, the PORC membership will maintain a diversity of back-  !

j grounds among its members (i.e., operations, engineering, maintenance, and I

quality assurance). Wa+ find that these proposed changes to the PORC membership meet the acceptance criteria of Section 13.4 of the SRP and the relevant I requirements of Regulatory Guide 1.33 (R.G. 1.33). Therefore, these proposed i I

changes are acceptable.

1 I

i

2.10 Specification 6.5.1.6, PORC Responsibilities and new Specification 6.5.1A, Technical Review and Control The responsibilities of the PORC would be revised as follows:

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 new specification 6.5.1A, "Techni-cal Review and Control."

o Review of all programs required by specification 6.8.5 and changes thereto will be controlled under new specification 6.5.1A. Speci-fication 6.8.5 is being revised to include this review.

o Review of any other proposed procedures or changes thereto as deter-mined by the Plant Manager to affect nuclear safety will be deleted.

However, specification 6.5.1.6.h (will be relabeled as f) gives the Plant Manager the authority to escalate any item to be revised by PORC.

, o Review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety will be controlled under 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 pro-vide final approval of the change.

i o Review of the Plant Physical Secur~ity 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 l 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 chuges to the radwaste treatment systems are now covered I

by Specification 6.15. Review and approval of these changes will be done in accordance with 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.

o Review of meeting minutes of the Radiological Assessment Review Committee (RARC) is no longer needed under the new organization.

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 done by RARC. The new organization has brought the technical expertise under the nuclear 1

O organization that PORC is under, thus deleting the need for PORC f review. PORC and RARC are equal-level committees subject to the same governing upper-tier nuclear procedures. Reports and meeting minutes of both comittees are reviewed under cognizance of NSRB. l o The proposed change to item "e" more accurately reflects the PORC function intended for review of Technical Specification violations.

It is not practical for PORC to perform investigation of the viola-tion. Investigation and preparation of reports covering evaluations and recommendations to prevent recurrence are performed by the l appropriate line organization. PORC will provide oversight to ensure the evaluations and recommendations are sufficient and complete.

o The proposed change to item "f" requires PORC review of all reportable events. Reportable event is defined by the Technical Specifications as those conditions specified by section 50.73 to l 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).

i The following PORC responsibilities will be added to specification 6.5.1.6:

o PORC will provide an oversight review of selected safety evaluations which are reviewed per specification 6.5.1A to determine the adequacy of the qualified review process and ensure that a quality level review is being accomplished. The review will be performed on a monthly basis and shall screen a niinimum of 10 percent of the applicable safety evaluations. A list of activities reviewed and the results of the review, including deficiencies or problems J noted, will be reported to PORC at scheduled monthly meetings. l This report will become a part of PORC meeting minutes, along with I any actions to be taken from the report. Individuals perfonning 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.

Specification 6.5.1A, TIchnical Review and Control has been added to describe the new technical review and control process. The new process establishes an " independent qualified review" and cross-disciplinary review and approval that supports changes to procedures and plant changes or modifications to plant nuclear safety-related structures, systems and components.

Each procedure required by 6.8.1 of the TS will be reviewed by an individual other than the preparer. The reviewer may be from the same organization or from a different organization. Each review will include a determination of whether or not a cross-disciplinary review is necessary. If so a cross-disciplinary review will be conducted.

,e i

Each proposed change or modification to plant nuclear safety-related structures, systems and components will be reviewed by a reviewer designated by the Plant Manager. Each modification will be reviewed by an individual or group other than the person (s) which designed the modification. The Plant Manager, NPP Superintendent or Maintenance Superintendent 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 l 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 i will contain a clause which allows the qualified reviewer or the responsible manager approving the procedures or procedure change the right to request i 1

PORC review.

AI-4, " Preparation, Review, Approval, and Use of Plant Instructions," will require review and approval in accordance with AI-43. Appropriate managers responsible for approval of different groups of procedures will be designated within their field of responsibility. QA will be given the option to review all changes. Additionally, AI-4 will require a larger review and higher level I of management approval for designated administrative instructions and procedures affecting safety-related functions.

After revising 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 l

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 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 spent more time on the review. The detailed techni-cal reviews of procedures can be accomplished by qualified technical reviewers not encumbered with othfr 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. l The current TS requirement for review of changes is actually satisfied by ,

individuals of a similar responsibility level, however, considerable management l time is consumed in the assigning of these personnel to review each item,  ;

collecting results from those reviews, and finally attending a formal meeting to recommend a disposition. The method requested by this amendment eliminates much of the unnecessary effort and at the same time provides for a more consistent and timely review and approval process.

l It will focus responsibility and accountability to the technical reviewers and provide a better review. Cross-disciplinary review will 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 chances 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 I which requires that decisions affecting safety are made at the proper level of l responsibility and with the necessary technical advice and review, (3) provide  !

for interdisciplinary review of the subject matter, (4) allow for independent technical review and approval, and (5) provide qualified designated reviewers.

l Specifications 6.5.1.7, 6.5.2.7, 6.8.1, 6.8.2, 6.8.5, 6.13 and 6.15 would be revised to be consistent with the above discussed changes to PORC j responsibilities. Therefore, for the same reasons as named above, we find l these proposed changes acceptable.

2.11 Specification 6.5.2.7, Review (Nuclear Safety Review Board)

Specification 6.5.2 is being 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 subcommittees. The proposed change clearly states NSRB's responsibility to be cognizant of the identified review items.

The wording change is consistent with the intent of the staff regarding NSRB responsibilities, and is, therefore, acceptable.

2.12 Specification 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 Comittee (RARC) is being addressed. This addition is merely a clarification of what is intended by the specification and is acceptable.

2.13 Specification 6.5.3, Radiological Assessment Review Committee (RARC)

Specification 6.5.3.1 sets forth the functional requirements for SQN RARC.

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 proposed to be 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 RRAC activities are concerned with the Sequoyah plant, it follows that the Plant Manager should be aware of these activities. This cha.ge is, therefore, acceptable.

l I . l In specification 6.5.3.2 the licensee proposes to change the titles of the SQN RARC members to be consistent with the positions responsible for those functions in the new organization. In the process, a 5th Committee member is also added. This is an administrative change only and is acceptable.

Previously, specification 6.5.3.4 specified 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 SQN 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 than would otherwise be the case. Thus, we find this change acceptable.

The minimum quorom, as given in 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 (see item above) and is acceptable. 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 SQN RARC activities. We consider it to be an improvement and therefore acceptable.

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 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 fonnal 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 i matters at Sequoyah. The change, is, therefore, acceptable, j A change to specification 6.5.3.6.d would insert the word " radiological" between

" environmental" and " monitoring." The revision would assure that the SQN RARC is responsible foraeview of Technical Specification changes related to environmental radiological monitoring rather than to all environmental 1 monitoring. This is consistent with the mission of the SQN RARC and the change is, therefore, acceptable. t A further change to specification 6.5.3.7.a would add the Plant Manager as a recipient of SQN RARC recommendations. Since the SQN RARC is dealing with Sequoyah plant matters, we agree that the Plant Manager should be aware of comittee recommendations. This change is, therefore, acceptable.

l

._______ - - -_ _ _ O

I l

l 2.14 Specification 6.8.3, Temporary Changes to Procedures The new proposed Specification 6.8.3 would delete temporary changes. However, temporary approval of procedure changes would be allowed even if the intent of the original procedure is altered or changed. This proposed change would not be consistent with revision 5 of the Westinghouse Standard Technical Specifications.

All procedures where the original intent of the procedure is changed must receive a full and complcce review. Therefore, the proposed change to Specification 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, would still be allowed.

The change to Specification 6.8.3.c is acceptable since specification 6.5.1.A, as described above, is acceptable.

2.15 Specification 6.10.2 The licensee proposes to add the words "for lifetime retention" to help define I those Quality Assurance records which are to be retained for the duration of the unit operating licenses. These added words clarify what was intended by

, this section and are acceptable.

The title " Operational Quality Assurance Manual" would be changed to " Nuclear Quality Assurance Manual." This change is consistent with the revisions to the Quality Assurance program, and corrects what otherwise would be an incorrect reference. It is, therefore, acceptable.

^

3.0 ENVIRONMENTAL CONSIDERATION

S This amendment relates to changes in administrative procedures or requirements.

The staff has determined that the amendment involves no significant increase in the amounts, and no sigrM(cant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual  ;

or cumulative occupational radiation exposure. The Comission has previously  ;

issued a proposed finding that this amendment involves no significant hazards j consideration and there has been no public coment on such finding. '

Accordingly, this amendment meets the eligibility criteria for categorical i exclusion set forth in 10 CFR 51.22(c)(10) and pursuant to 10 CFR 51.22(b) no i environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

I

4.0 CONCLUSION

l 1

The staff has 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 l will be conducted in compliance with the Commission's regulations and the  ;

issuance of this amendment will not be inimical to the common defense and security of the health and safety of the public.

Principal Contributor: C. Goodman 3 1

Date: j

!