ML20236S408
| ML20236S408 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/01/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20236S331 | List: |
| References | |
| NUDOCS 9807240317 | |
| Download: ML20236S408 (18) | |
Text
'
eaaeg\\
p y
UNITED STATES g
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20046 4001 r%,...../
1 I
l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATEDTO AMENDMENT NO. 233 TO FACILITY OPERATING LICENSE NO. DPR-77 i
AND AMENDMENT NO. 223 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
The Tennessee Valley Authority (TVA, the licensee) requested amendments to Operating Licenses DPR-77 and DPR 79 f',r Sequoyah Nuclear Plant (SQN), Units 1 and 2, respectively, in a letter dated June 7,1996, as supplemented on September 26,1997, January 21,1998, May 28,1998, and June 29,1998. The amendments would revise the SQN Units 1 and 2 Technical Specifications (T6) to eliminate portions of Section 6, " Administrative Controls," and to relocate applicable requirements or specifications to the TVA Nuclear Quality Assurance Plan (NQAP) (TVA-NQA-PLN8PA). Section 6 of the SON TS would then more closely resemble Section 5 of the improved Standard TS (STS) for Westinghouse plants, NUREG-1431, Revision 1, " Standard Technical Specifications - Westinghouse Plants." Requirements for the Plant 3
Operating Review Committee (PORC), the Nuclear Safety Review Board (NSRB), reporting i
requirements, technical review and control, independent safety reviews, and recordkeeping would be relocated to the TVA NQAP and would be subject to the requirements of 10 CFR 50.54, " Conditions of Licenses." Specifically,10 CFR 50.54(a) requires a quality r_ssurance program and specifies the process for making changes to the program, once cpproved by the U.S. Nuclear Regulatory Commission (NRC). Other subjects proposed to be deleted from the SQN TS are based upon direction provided by the NRC staff to the owners group in a letter l
dated October 25,1993, which discussed the content of STS, Section 5.0, " Administrative l
Controls." Subsequently, in April 1995, the NRC issued Revision 2 to NUREG-1431 to incorporate the changes discussed in the October 25 letter. TVA concluded that a significant number of the administrative specifications (Section 6.0 in the SQN TS) can be relocated to other licensee-controlled documents for which those provisions are adequately controlled by other regulatory requirements.
l On October 11,1996, TVA submitted, pursuant to 10 CFR 50.54(a)(3) and 10 CFR 50.55(f)(3),
Revision 7 to the TVA NQAP, which incorporates the requirements and provisions of the quality assurance program that the June 7,1996, application for license amendment proposed removing from the SQN TS. TVA submitted this plan revision for NRC approval because some of the changes in the revision were identified as reductions in commitments. The reduction in 9807240317 980701 i
PDR ADOCK 05000327 P
PDR in I
(
2 commitments involved (1) a reduction in the scope of review of 10 CFR 50.59 evaluations by the Nuclear Safety Review Board (NSRB), (2) deletion of a requirement for the NSRB to review Plant Operations Review Committee (PORC) reports and meeting minutes, (3) a revision in the timeframe for forwarding NSRB reports to management from 14 days to 30 days, (4) deletion of specifying the composition of the independent Safety Engineering (ISE) function, and (5) changes in the audit and oversight programs for the Security and Quality Assurance organizations.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to state TS to be included as part of the license. The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
Additionally,10 CFR 50.36(c)(5) states that, " Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." The specific content of the administrative corW section of the TS is, therefore, that information that the Commission deems essential for the safe operation of the facility that is not already adequately covered by other regulatic.is. Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5) and which are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to I
public health and safety, can be removed from administrative controls.
Other requirements may be relocated to more appropriate documents (e.g., Security Plan, _
Quality Assurance (QA) Plan, and Emergency Plan) and controlled by the applicable re;;ulatory requirement.
3.0 EVALUATION j
This evaluation addresses the TVA license amendment application, the proposed revis!com to the NQAP, and the TVA response, dated September 26,1997, to an NRC request for additional information (RAI) regarding relocation of certain QA-related requirements to the NQAP. As stated in the NRC letter, dated June 23,1997, the request was the result of inadequate justification provided by the licensee for the proposed TS amendment and complementary NQAP revision.
The following areas of the Technical Specifications are addressed by the licensee's RAI response:
Facility Staff Qualifications (TS 6.3.1)
Nuclear Safety Review Board (TS 6.5.2.1,4,5,6,7.a,7.I)
Records (6.5.2.10.a, b, c)
Record Retention (6.5.10)
Process Control Program (TS 6.5.2.8) independent Safety Engineering (6.2.3.2) e
.,4 3
3.1 TS Channes '
The following proposed changes pertain to the TS of both Units 1 and 2 unless othenwise stated.
Section Pfonosed Channe Change 1:
index '
Delete Sections 6.2.3,6.4,6.5,6.10,6.11, and 6.13; the pages will be renumbered as appropriate.
Sta# Evaluation: This change is editorial to be consistent with the other changes discussed below..
Change 2:
1.23 TS page 1-5, the revised specification will delete the definition for the " Process Control Program."
Sta# Evaluation: This change is editorial to be consistent with removal of TS 6.13, " Process Control Program."
Change 3:
6.1.2 TS page 6-1, currently reads:
"A management directive to this effect, signed by the Site Vice President, shall be reissued to all station personnel on an annual basis."
The revised specification will delete the requirement to issue a management directive.
Sta# Evaluation: TS need not require an administrative letter be issued to station personnel on an annual basis describing responsibility of the shift operations supervisor (SOS). The SOS responsibility is adequately described in TVA-NPOD89-A, Section 3.4.6.e. Repeating the i
organization responsibilities via an intemal management directive only increases the l;
. administrative burden on the facility with no resulting benefit. Also, this requirement is not in the STS., For these reasons, the staff finds this change acceptable.
Change 4:
6.1.3 This is a new section, which replaces Section 6.5.0 in its entirety. The revised specification will read: "The Chief Nuclear Officer is responsible for the safe operation of all TVA nuclear power plants."
StaN Evaluation: This change merely moves TS 6.5.0 into TS 6.1.3 and is, therefore, editorial.
Two other editorial changes are elso made to remove an incorrect implication by adding the word " nuclear" before " power" and to replace the obsolete title " President, TVA Nuclear and Chief Nuclear Officer" with " Chief Nuclear Officer," to reflect an organizational change.
Change 5:
6.2.1.a
- TS page 6-1, the last sentence currently reads:
. These requirements shall be documented in the FSAR [ Final Safety Analysis Report) and will be updated in accordance with 10 CFR 50.71(e)."
t 4
The revised specification will change the wording to read: "These requirements shall be documented in the Nuclear Power Organization Topical Report (TVA-NPOD89-A)."
Staff Evaluation: This TS relates to organizational charts, functional descriptions of department responsibilities and relationships of offsite and onsite organizations. The information is documented in the referenced TVA topical report. Although the topical report is incorporated into the FSAR by reference, it is the actual topical report that is periodically updated and not the FSAR. Therefore, the staff considers this change to be acceptable.-
Change 8:
6.2.2.d This TS (page 6-2), currently reads:
"All COR8E ALTERATIONS shall be observed and directly supervised by either a licensed Sedor Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who a.gs no other concurrent responsibilities during this operation."
The revised specification will delete section 6.2.2.d.
Staff Evaluation: The requirements for a senior reactor operator (SRO) to be present during fuel handling and to supervise all core alterations should not be retained in the TS. Duplication in the TS of the regulation provided in 10 CFR 50.54(m)(2)(iv) is not necessary to assure safe operation of the facility. The current regulation states: "Each licensee shall have present,
~ during alteration of the core of a nuclear power unit (including fuel loading or transfer), a person holding a senior reactor operator license or a senior operator license limited to fuel handling to directly supervise the activity and, during this time, the licensee shall not assign other duties to this person." The staff finds this change to be acceptable because it deletes a duplication of a regulation that the licensee is required to comply with.
Change 7:
6.2.3 TS page 6-5, The Independent Safety Engineering (ISE) requirements have been relocated to the TVA NQAP (Section 4.1.3.C.7.b.16).
Staff Evaluation: The licensee's position is that review and audit functions may be relocated from the TS on the basis that they are adequately addressed elsewhere. The TS provisions are not necessary to assure safe operation of the facility, given the requirements in the NQAP implementing 10 CFR 50.54 and 10 CFR Part 50, Appendix B that control the requirements for all review and audit functions.
The ISE requirements currently in TS 6.2.3 were incorporated into Section 4.1.3.C.7.b.17 of the TVA NQAP (Revision 6, dated 8/31/95) in accordance with the STS technical review requirements. This is consistent with the Watts Bar Nuclear Plant TS and the TVA NQAP l
revision approved by NRC.
The current TS requirements reflect the NUREG-0737 requirements defining the function, composition, responsibilities and records associated with the ISE organization. The ISE's function is to examine unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of unit design and operating experience information, including units of similar design, which may indicate areas for improving unit safety The licensee has proposed to relocate these TS requirements to the NQAP and control any subsequent changes in accordance with 10 CFR 50.54(a). The staff has verified that the commitments incorporated into the NQAP adequately address the relocated TS requirements,
t 5
The staff has concluded that the relocation of ISE requirements is acceptable because (1) their inclusion in TS is not specifically required by 10 CFR 50.36 or other regulations, (2) the ISE requirements are rot necessary for operation of the facility in a safe manner, but for
{
increasing unit safety and (3) changes to the ISE provisions, as incorporated into the NQAP,
]
are adequately controlled in accordance with 10 CFR 50.54(a). On this basis, the staff finds the proposed relocation of ISE requirements to the NQAP to be acceptable.
Change 8:
6.3 TS page 6-5, " FACILITY STAFF QUALIFICATIONS," currently reads:
"Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI I
N18.1-1971 for comparable positions except for the RADCON/ Chemistry Control Manager who shall meet or exceed the qualifications of Regulatory Guide (RG) 1.8, September 1975."
l The revised specification will change the wording to read: "Each member of the facility staff shall meet or exceed the minimum qualifications for comparable positions in Regulatory Guide 1.8, Revision 2 (April 1987) for all new personnel qualifying on positions identified in Regulatory Position C.1 after January 1,1990. Personnel qualified on these positions prior to this date will still meet the requirt ments of Regulatory Guide 1.8, Revision 1-R (May 1
1977."
d Staff Evaluation: This TS section is being updated to reflect the staff qualification qualifications suggested in Section 5.3.1 of NUREG-1431, Revision 1, " Standard Technical Specifications - Westinghouse Plants." The staff finds this change acceptable.
Change 9:
6.4 TS page 6-6, the revised specification will delete Section 6.4, " Training."
Staff Evaluation: See evaluation for Change 9 Change 10:
6.5.0 TS page 6-6, the revised specification will delete this section. This J
requirement will be moved to a new section (Section 6.1.3).
Staff Evaluation: See evaluation for Change 5 Change 11:
6.5.1 thru TS pages 6-6 thru 6-12, the revised specification will delete the Plant 6.5.2.10 Operations Review Committee, Technical Review and Control, and the Nuclear Safety Review Board sections from the TS. These requirements have been relocated to the TVA NQAP (Sections 4.1.3.B.5 and 12.2.e.4).
Staff Evaluation: The following points summarize the reasons for removing the review and audit requirements from the TS:
- 1. The onsite and offsito review functions are covered in American National Standards Institute (ANSI) N18.7-1976. The licensee has committed to ANSI N18.7-1976 in the NQAP.
Equivalent change controlis provided by 10 CFR 50.54(a).
2.
Audit requirements are specified in the TVA NQAP to satisfy 10 CFR Part 50, Appendix B, Criterion XVill. Audits are also covered by 10 CFR 50.54(t),10 CFR 50.54(p) and ANSI
4 6
N18.7 and ANSI N45.2 (to which the licensee is committed in the NQAP). Duplication of the requirements contained in the above documents by the Administrative Controls se:: tion of the TS does not enhance the level of nuclear safety for the plant. Therefore, the TS provisions relating to audits are not necessary to assure safe operation of the faci:ity.
- 4. The review and approval process and the temporary change process for procedures are adequately addressed in Revision 7 to TVA-NQA-PLN89-A (the NQAP), submitted with the subject TS revision. In addition, these processes are also addressed in SQN plant procedures. This proposalis based on the existence of the following requirements which l
duplicate 10 CFR 50.36 in these areas.
l The requirements for procedure control are mandated by 10 CFR Part 50, Appendix B, Criterion ll and Criterion V. ANSI N18.7-1976, which is an NRC endorsed document used in the development of many licensee QA plans, also contains specific standards related to
. procedures. ANSI N18.7-1976, Section 5.2.2, discusses procedural adherence. This section cleariy states that procedures shall be followed, and the requirements for use of procedures shall be prescribed in writing. ANSI N18.7-1976 also discusses temporary changes to procedures, and provides for review and approval of procedures to be defined. ANSI N18.7-1976, Section 5.2.15, describes the review, approval, and control of procedures. This section describes the standards to control and coordinate the approval and issuance of documents, including changes thereto, which prescribes all activities affectirig quality. The section further states that each procedure shall be reviewed and approved prior to initial use.
The provisions in the NQAP commit to ANSI N18.7-1976 and implement the Commission's regulations pertaining to the control of documents such as instructions, procedures, and drawings, including changes thereto. The procedure review and approval functions current'y in TS define an administrative framework to ensure that documents are reviewed for adequacy and approved for release by authorized personnel. The required control of these processes in the regulations and revised NQAP is considered to be redundant and functionally equivalent to the provisions currently in TS. The staff has determined that the procedure review and approval functions are adequately addressed by existing regulations and the related NQAP revisions. Based upon the relocation of the procedure review provisions to the NQAP, it is not necessary to include redundant or additional requirements in the TS administrative controls.
The licensee will continue to implement an NQAP in accordance with the requirements of 10 CFR Part 50, Appendix B, which provides appropriate controls for the review and approval of procedure changes. The staff concludes that these regulatory requirements provide sufficient control of these provisions and removing them from the TS is acceptable. Future changes to the review and approval process for procedure changes can be adequately controlled under 10 CFR 50.54(a).
Change 12:
6.8.1.d,.e Unit 1 TS page 6-15 and Unit 2 TS page 6-14, the revised specification will delete these sections in their entirety. These line items require written procedures for implementation of the Plant Physical Security Plan and Site Radiological Emergency Plan, respectively. (Section 9.9.7.A)
Staff Evaluation: The licensee has proposed that the Security and Emergency Plan Program requirements be relocated from the TS to their respectivs plans in accordance with NRC Generic Letter (GL) 93-07. Any changes made to these plans, including audit and review requirements, must be made in accordance with 10 CFR 50.54(p) for the security plan and 10 CFR 50.54 (q) for the emergency plan. Depending on the nature and extent of such
7 changes, prior NRC approval may be required prior to implementation of the changes. The extensive requirements for emergency planning in 10 CFR 50.47 and 50.54 and for security in 10 CFR 50.54 and 10 CFR 73.55 for drills, exercises, testing, and maintenance of the program, provide adequate assurance that the objective of the previous TS for a periodic review of the program and changes to the program will be met. Therefore, duplication of the requirements contained in the regulations does not enhance the level of nuclear safety.
Such an approach results in an equivalent level of regulatory authority whiie providing for a more appropriate change control process. The not effect of the change is that the level of safety of plant operation is unaffected and NRC and facility resources associated with processing license amendments to this administrative control are optimized.
The staff concludes that the requirements for emergency planning in 10 CFR 50.47, and 50.54, and for security in 10 CFR 50.54 and 73.55 for drills, exercise.*, testirig, and maintenance of the program are sufficient and, therefore, removing these duplicsh. provisions from the TS is i
acceptable.
Change 13:
6.8.1.g Unit 1 TS page 6-15 and Unit 2 TS page 6-14, the proposed revision to the specification would delete this line item (Section 9.9.7.A).
Staff Evaluation: The licensee proposes to remove the reference to the Process Control Program (PCP) in TS 6.8.1.g and the PCP change process TS 6.13 from TS on the basis that the PCP and appropriate plant procedures contain the current formulas, sampling, analyses, tests, and determinations, to ensure that processing and packaging of solid radioactive wastes will be accomplished in compliance with 10 CFR Parts 20,61, and 71. These regulations govem the disposal of solid radioactive waste. This requirement has been relocated to the NQAP. The program is also referenced in the FSAR.
The PCP does not involve plant systems or components that initiate conditions for a design-basis transient or a design-basis accident, nor does it involve a primary success path to mitigate a design-basis accident. Thus, the PCP is not necessary for operation of the facility 1
in a safe manner.
The staff concludes that the requirements for a PCP are contained in 10 CFR Parts 20,61, and 71; therefore duplicate requirements may be removed from the TS. In addition, these administrative controls are not, for the reasons discussed above, required to be in TS by 10 CFR 50.36(c)(5). Finally, because these requirements are part of the FSAR and NQAP, the Staff concludes that 10 CFR 50.59 and 10 CFR 50.54 provide adequate regulatory control for future changes to the PCP and implementing procedures.
l Change 14:
6.8.2,.3 TS page 6-15, the proposed revision to the TS would delete these sections in their entirety. The subject of these sections is review of procedure changes (Appendix B, item 2.a).
Staff Evaluation: The review and approval process and the temporary change process for procedures are adequately addressed in Revision 7 to the NQAP, dated October 11,1996 and I
submitted with the subject TS revision. In addition, these processes are also addressed in Sequoyah plant procedures. This proposalis based on the existence of the following requirements which duplicate 10 CFR 50.36 in these areas, a
o 8
The requirements for procedure control is mandated by 10 CFR Part 50, Appendix B, Criterion ll and Criterion V. ANSI N18.7-1976, which is an NRC endorsed document used in the development of many licensee QA plans, also contains specific standards related to procedures, ANSI N18.7-1976, Section 5.2.2 discusses procedural adherence. This section clearly states that procedures shall be followed, and the requirements for use of procedures shall be prescribed in writing. ANSI N18.7-1976 also discusses temporary changes to procedures, and provides for review and approval of procedures to be defined. ANSI N18.7-1976, Section 5.2.15 describes the review, approval, and control of procedures. This section describes the standards to control and coordinate the approval and issuance of documents, including changes thereto, which prescribes all activities affecting quality. The section further states that each procedure shall be reviewed and approved prior to initial use.
The provisions in the NQAP commit to ANSI N18.7 and implement the Commission's regulations pertaining to the control of documents such as instructions, procedures, and drawings, including changes thereto. The procedure review and approval functions currently in TS define an administrative framework to ensure that documents are reviewed for adequacy and approved for release by authorized personnel. The required control of these processes in the regulations and revised NQAP is considered to be redundant and functionally equivalent to the provisions currently in TS. The staff has determined that the procedure review and approval functions are adequately addressed by existing regulations and the related NQAP revisions. Based upon the relocation of the procedure review provisions to the NQAP, it is not necessary to include redundant or additional requirements in the TS administrative controls.
The licensee will continue to implement an NQAP in accordance with the requirements of 10 CFR Part 50, Appendix B, which provides appropriate controls for the review and approval of procedure changes. The staff concludes that these regulatory requirements provide sufficient control of these pmvisions and removing them from the TS is acceptable. Future changes to the review and approval process for procedure changes can be adequately controlled under 10 CFR 50.54(a).
Change 15:
6.8.4 TS page 6-15, currently roads:
"The following programs shall be established, implemented, maintained, and changes thereto made in accordance with Section 6.5.1.A."
The revised specification will change the wording to read:
i j'
"The following programs shall be established, implemented, and maintained."
l Staff Evaluation: See evaluation for Change 15 Change 16:
6.8.4.b TS page 6-16, the proposed TS revision would delete this section in its entirety.
The subject is the in-plant radiation monitoring program.
Staff Evaluation: The in-Plant Radiation Monitoring Program provides controls to ensure the capability to accurately determine the airbome iodine concentration in vital areas under accident conditions. This program was developed to minimize radiation exposure to plant personnel following an accident. The in-Plant Radiation Monitoring Program administrative control does not involve monitoring process variables that are initial conditions for a design basis transient or accident, nor does it involve a primary success path to mitigate a design-Q
9 l
basis accident. Therefore, this program has been relocated to a number of different plant procedures, the bases of which are located in Sections 12.1.4 and 12.1.5 of the FSAR. The retraining aspect is contained in the training program for personnel. The provisions for monitoring and performing maintenance of sampling and analysis equipment are addressed in I
the chemistry and radiation protection procedures.
This proposal is consistent with the guidance provided in the NRC letter dated October 25, 1993. The staff concludes that these provisions are not required to be in the TS under 10 CFR 50.36(c)(5). Thus, the In-Plant Radiation Program is not necessary for operation of the facility in a safe manner. Therefore, the staff concludes that these provisions may be removed from
- the TS and that 10 CFR 50.59 provides adequate control for future changes to the in-Plant j
Radiation Monitoring Program.
l Change 17:
l 6.8.4.g TS pages 6-18 and 6-19 (Unit 2 only), the revised specification would delete this section in its entirety. The subject of this section is the Radiological Environmental Monitoring Program.
)
Staff Evaluation: The Radiological Environmental Monitoring Program requires that procedures be prepared for monitoring the radiation and radionuclides in the environs of the plant consistent with the guidance specified in 10 CFR Part 50, Appendix 1. These procedures i
l are developed to ensure that radioactive effluents are restricted to levels as low as reasonably L
achievable, and are not necessary to assure safe operation of the facility. The details and description of the program are already contained in the Offsite Dose Calculation Manual, as specified by existing TS 6.8.1.1 and as described in Generic Letter 89-01, " Implementation of l
Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative l
Controls Section of Technical Specifications and Relocation of Procedural Details of RETS to l
the Offsite Dose Calculational Manual or the Process Control Program." As concluded in the j
model safety evaluation report enclosed with Generic Letter 89-01, control of radioactive i
effluents continues to be limited in accordance with 10 CFR 20.1302,40 CFR Part 190,10 CFR I
50.36a, and Appendix l to 10 CFR Part 50. Accordingly, the NRC staff finds that there is no impact on plant safety, and staff finds the proposed changes acceptable.
Change 18:
6.9.1.1,.2,.3.TS page 6-19, the revised specification will delete these sections in their entirety.
l The subject of these sections is submittal of startup reports to the NRC.
Staff Evaluation: The requirement to submit a startup report has been deleted from the improved TS. The report was a summary of plant startup and power escalation testing following: (1) receipt of the operating license, (2) an increase in licensed power level, (3) the
. installation of nuclear fuel with a different design or manufacturer than the current fuel, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. The report provided a mechanism for the staff to review the appropriateness of licensee activities after-the-fact, but contained no requirements for staff 6pproval. The approved 10 CFR Part 50, Appendix B, the TVA NQAP, and the Sequoyah Start-up Testing Program (Chapter 14 of the Updated Final Safety Analysis Report) provide assurance that the listed activities are adequately performed.
Because this report was required to be provided to staff within 90 days following completion of the respective milestone, and because there was no requirement for the staff to approve the
10 report, the startup report is clearly not necessary to assure operation of the facility in a safe manner. Therefore, the removal of these sections from the TS is considered acceptable.
Events (2), (3), and (4) above do, in fact, require pdor NRC approval in the form of a license arnendment under the provisions of the operating licenses,10 CFR 50.44,10 CFR 50.46, Appendix K to 10 CFR Part 50, and 10 CFR 50.59.
Change 19:
6.10 TS Unit 1 pages 6-22 and 6-23 and TS Unit 2 pages 6-23 and 6-24, the revised specification will delete this section in its entirety. The subject of this section is record retention.
Staff Evaluation: The licensee proposes to remove the TS requirements on record retention on the basis that they are adequately addressed by the required QA Program (10 CFR Part 50, Appendix B, Criterion XVil) and Revision 7 of the TVA NQAP. Facility operations are performed in accordance with approved written procedures. Areas include normal start-up, operation and shutdown, abnormal conditions and emergencies, refueling, safety-related maintenance, surveillance and testing, and radiation control. Facility records document appropriate station operation and activities. Retention of these records provides documentation and capability for its retrieval for review of compliance with requirements and regulations.
Postcompliance review of records does not directly assure operation of the facility in a safe manner, as activities described in these documents have already been performed.
The provisions in the TVA NQAP implement the Commission's regulations pertaining to the l
maintenance of records related to activities affecting quality. The required controls related to I
record retention specified in various regulations and the provision incorporated into the NQAP are considered to be redundant to the requirements currently in TS. The staff has determined I
that record retention requirements are adequately addressed by existing regulations and the l
related NQAP commitments. Based upon the relocation of the record retention provisions to the NQAP, it is not necessary to include redundant or additional requirements in the TS l
administrative controls.
I The staff concludes that the regulatory requirements under 10 CFR Part 50, Appendix B, l
provide sufficient control of the plant records, and sufficient regulatory controls exist for future changes to the program pursuant to 10 CFR 50.54(a). In addition, numerous other regulations such as 10 CFR Part 20, Subpart L, and 10 CFR 50.71 require the retention of certain records related to operation of the nuclear plant. The staff concludes that these regulatory requirements provide sufficient control of these recordkeerMg provisions and removing the record retention requirements from the TS is acceptable.
Change 20:
6.11 TS Unit 1 page 6-24 and Unit 2 page 6 25, the licensee proposed removal of this section from the TS in its entirety. The subject of this section is the Radiation f
Protection Program.
Staff Evaluation: The Radiation Protection Program requires procedures to be prepared for personnel radiation protection consistent with the requirements of 10 CFR Part 20 and is described in the FSAR. The requirements to have procedures to implement Part 20 is also
- contained within 10 CFR 20.1101(b). Periodic review of these procedures is addressed under 10 CFR 20.1101(c). The program requirements specified above are described in the FSAR or appropriate procedures.
11 10 CFR 50.36(c)(5) does not require that these provisions be included in the TS. The requirements of the rule provide sufficient control of these provisions, and 10 CFR 50.59 provides adequate controls for these provisions in the FSAR and plant procedures. The staff concludes that the requirements of the regulations provide sufficient control of the Radiation
?rotection Program, such that administrative controls in the TS are unnecessary. On this basis, the staff concludes that the requirements for the Radiation Protection Program do not have to be controlled by TS, and changes to the Radiation Protection Program are adequately controlled by 10 CFR Part 20 and 10 CFR 50.59.
Change 21:
6.13 TS Unit 1 page 6-25 and Unit 2 page 6-26, the revised specification would delete this section in its entirety. The subject of this section is the Process Control Program.
Staff Evaluation: See evalua5on for Change 15 Change 22:
6.14.1 The subjects of this revision are changes to the Offsite Dose Calculation Manual.
TS Unit 1 page 6-25 and Unit 2 page 6-26, currently read:
"1. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.2.p. This documentation shall contain:
"2. Shall become effective after review and acceptance by the process in Specification 6.5.1.A and the SQN PORC."
The revised specification will change the wording to read:
"1. Shall be documented and records of reviews performed shall be retained in a
- manner convenient for review. This documentation shall contain:
"2. Shall become effective after review and acceptance by the process described in the TVA-NQA-PLN89-A."
i Staff Evaluation: These changes are editorial to conform with changes discussed above (i.e.,
)
deletion of Sections 6.5.1.A and 6.10.2.p from the TS).
I Change 23:
l 6.15.1.
TS Unit 1 page 6-26 and Unit 2 page 6-27, currently read:
"1. Shall be reported to the Commission in the Annual Radioactive Effluent Report for the period in which the evaluation was reviewed in accordance with Section 6.5.1.A. The discussion of each change shall contain:
"2. Sha!! become effective upon review and acceptance in accordance with f
Section 6.5.1.A."
l The revised specification will change the wording to read:
"1. Shall be reported to the Commission in the Annual Radioactive Effluent Report for the period in which the evaluation was reviewed in accordance with TVA-NQA-PLN89-A. The discussion of each change shall contain:
3
12 l
"2. Shall become effective upon review and acceptance in accordance with TVA NQA-PLN89-A."
Staff Evaluation: These changes are editorial to conform with changes discussed above (i.e.,
deletion of Section 6.5.1.A from the TS).
Other changes:
The word "D21sted" has been added to appropriate sections to preserve the section numbering.
j in conclusion, the above Wrmted requirements relating to administrative controls are not required to be in the TS under 10 CFR 50.36(c)(5) or Section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an j
immediate tlirest to the public health and safety.
in addition, the staff finds as discussed above that sufficient regulatory controls exist to assure continued protection of public health and safety. Accordingly, the staff has concluded that these requirements may be relocated from the TS to the above specified documents or i
l
. removed from TS because the specific detailed requirements are already included in NRC l
regulations.
j l
These changes are, therefore, acceptable.
3.2 NOAP Channes and Reasonse to RAI l
This section evaluates the licensee's response, by letter dated September 26,1997, to the staff's request for additional information regarding relocation of certain Technical Specifications to the licensee's quality assurance program. The evaluation supplements and completes the staff evaluation summarized under Section 3.1 as follows:
Facility Staff Qualifications (Section 3.2.1 supplements evaluation of Change g)
Nuclear Safety Review Board (Section 3.2.2 supplements evaluation of Change 12)
Records (Section 3.2.3 supplements evaluation of Change 12)
Record Retention (Section 3.2.4 supplements evaluation of Change 20)
Process Control Program (Section 3.2.5 supplements evaluation of Change 14)
Independent Safety Engineering (Section 3.2.6 supplements evaluation of Change 8) l l
3.2.1 Faciistv Staff Qualifications RAl-2 TS 6.3.1 (Facility Staff Qualifications) - The revised TS is not consistent with the NRC position on TS content delineated by NUREG-1431 (Ref.1); the revised TS shouldinclude references to RG 1.8 and ANSI 18.1, which have been deleted.
~ The licensee had deleted explicit references to RG 1.8 and ANSI 18.1, referring attemately to the NQAP. Since Appendix B, Table 1 of the NQAP documents these commitments, the licensee responds that placing them in the TS would be redundant. Changes to these commitments are controlled by the provisions of 10 CFR 50.54(a)(3).
Conclusion:
Relocation of the specific commitments to the NQAP is consistent with the intent of AL g5-06, The clarificauon provided by the licensee is acceptable.
~
13 3.2.2.' Nuclear Safety Review Board RAl4 TS Section 6.5.2.1 (NSRB Function) - Provide reference to NQAP sections containing requirements equivalent to TS 6.5.2.1. Justify any ditkronces between the current TS requirements and the proposed NQAP requirements.
RAl4 TS 6.5.2.4 (NSRB Consultants), 6.5.2.5 (NSRB Meeting Frequency), TS 6.5.2.6 (NSRB Quorum)- Where are these sections in the revised NQAP? Justify any ditkronces between the current TS requirements and the proposed NQAP
. requirements.
The licensee responds that Section 4.1.3.B.5 of the NQAP makes a specific commitment for NSRB to have technical experience in the areas specified in Section 4.3.1 of ANSI N18.7-1976, which identifies the areas currently specified by TS 6.5.2.1.
Similarly, TS 6.5.2.4,6.5.2.5, and 6.5.2.6 are covered by ANSI N18.7 Sections 4.3.1,4.3.2.2,
{
and 4.3.2.3,' without substantive differences.
Evaluation of Response:
Because the current TS requirements are redundant to the licensee's commitment to RG 1.33 and ANSI N18.7, documented in Appendix B of the NQAP, they may be deleted with no impact I
on plant safety. Since Appendix B of the NQAP documents the regulatory guides and industry standards, with approved exceptions and altamatives, any change in the licensee's conformance status would require repoding through the 10 CFR 50.54(a) process.
==
Conclusion:==
Inclusion of the subject TS requirements in the NQAP would be redundant to existing NQAP commitments. Since changes in these commitments would be reported through the 10 CFR 50.54(a) change process, deletion of this information is acceptable.
RAl4 I
- TS 6.5.2. 7.a (NSRB Review) - The proposed relocation of Section 4.1.3.B.5.b.1 of NQAP, Revision 7 appears to have reduced the scope of reviewin that only a sample of 10 CFR 50.59 safety evaluations would be reviewed. Justify the reduced scope of review.
The licensee desires to have a unifonn commitment in this area for all operating plants. The administrative controls for the Watts Bar Nuclear Plant (WBN) have already been relocated to the NQAP, Revision 5. For WBN, Section 4.1.3.B.S.b.1 of the approved NQAP reads:
l
,e.-
14 Safety evaluations will be screened. Review of representative safety evaluations willbe performed, selected based on safety signi6cance, Ibr (1) changes to procedures, equipment or systems and (2) tests or experiments completed under the provision of 10 CFR 50.59, to verify that such actions did not constitute an unreviewed safety question.
Evaluation of Response The NSRB is an offsite, corporate program, which provides senior level oversight of TVA's nuclear programs. The NSRB committees for all three TVA operating plants are chaired by a single senior manager. It is reasonable to adopt a uniform interpretation of the guidelines of ANSI N18.7, Section 4.3.4, regarding review of NSRB review of safety evaluations written pursuant to the requirements of 10 CFR 50.59.
==
Conclusion:==
The proposed method for NSRB review of safety evaluations has already been I
reviewed and approved by the Commission for Watts Bar. The proposed change j
for Sequoyah is identical with that approved for Watts Bar and, by the same reasoning, would not adversely affect plant safety. The proposed reduction in-commitment is in compliance with Appendix B of 10 CFR Part 50 and applicable codes and standards to which the licensee has committed. In view of the above, the reduction in commitment is acceptable.
RAl-7 TS 6.5.2. 7.I (NSRB Review) - Justify removal of requirements for NSRB review of Plant Operations Review Committee (PORC) meeting minutes.
The licensee responds that PORC minutes will continue to be distributed to the NSRB review for review (per NQAP, Sections 9.9.6.B.7 and 9.9.8.B.6); only the formal requirement for NSRB review has been deleted. This approach is consistent with that already reviewed and approved by the Commission for Watts Bar. Review of PORC minutes is not required by RG 1.33 or ANSI N18.7.
==
Conclusion:==
The proposed reduction in commitment provides uniform administrative requirements concoming this NSRB review requirement for the Watts Bar and Sequoyah plants. There are no general regulatory requirements regarding NSRB review of PORC minutes. Since the NQAP requires distribution, the NSRB has the opportunity to review these documents as part of its general review responsibilities defined under Section 4.1.3.B.5.b of the NQAP and l-Section 4.3.4 of ANSI N18.7. Therefore, deletion of this specific review requirement is acceptable.
i 3.2.3 Records 1
RA14 TS 6.5.2.10.n, b (Distribution of NSRB meeting minutes and review reports) -
Justify the extension from f 4 days to 30 days.
The licensee responds that the safety significant issues identified by the NSRB are entered in the corrective action program for evaluation and subsequent disposition, Therefore, the 14 day requirement is administrative in nature.
l
~
i
,~ *i a
15
==
Conclusion:==
There is no applicable regulatory requirement or guidance on this matter; NUREG-1431 suggests 30 days as an acceptable time frame for distribution of written records of NSRB reviews. Accordingly, this proposed reduction in commitment is acceptable.
RAl-9 7S 6.5.2.10 c (Distribution of audit reports) - Provide rekronce to equivalent NQAP requirements andjustify any ditterences.
The licensee responds that the TS 6.5.2.10.c audits are identified in Section 12.2.E.5 of the NQAP. The requirement to forward audit reports to responsible management within 30 days is identified in Section 4.4 of ANSI N45.2.12-1977, to which the licensee has committed.
i
==
Conclusion:==
The clarification provided by the licensee is acceptable.
3.2.4 Record Retention l
RAl-10 TS 6.5.10 (Record Retention)- Provide reference for the relocated record retention requirements and justify any differences.
The licensee responds that there are no changes in its commitment to ANSI N45.2.9-1974, which identifies record types and minimum retention periods. Clarification of the licensee's conformance status with this standard and RG 1.88 are provided in Appendix B of the NQAP.
==
Conclusion:==
The clarification provided by the licensee is acceptable.
- 3.2.5 Process Control Proaram RAl-11 Controls for the review and approval of future changes to the Process Contml Program should be addressed by the NQAP.
The licensee responds that provisions for review and approval of procedures, including the Process Control Program implementation, are provided in Section 9.9.7.A.7 of the NQAP.
==
Conclusion:==
The clarification provided by the licensee is acceptable.
3.2.6 Independent Safety Engineering (ISE)
The licensee was requested to address the following differences between the current and proposed ISE descriptions.
a) The term ISE has been replaced by " independent technical review."
- The licensee notes that the term is derived from the NUREG-1431, Section 5.5.2.d. " Technical Review Responsibilities," which is descriptive of the ISE function.
(-
,,1 p -
16 4
b) Currently, ISE staW report to the Manager, Independent Review and Analysis;in the revised NQAP, the ISE staff report to the Site Manager, Licensing andIndustry Attairs.
c)
The Independent, technical review function is the responsibility of the Site Nuclear Assurance and Licensing Manager. This apparent reorganization has not been addressed by the subnittal.
- The licensee describes the organizational realignment that resulted in the reporting relationship at the time the proposed TS amendment was submitted. The licensee further describes subsequent realignment (July 1997), which separates the nuclear assurance and licensing functions. This realignment will be reflected in the next periodic update to the NQAP. As a result of the realignment the Site Manager, industry Affairs (ISE function) reports to the Site Manager, Licensing and Industry Affairs (L&lA). The L&lA manager reports offsite to the Corporate Licensing Manager and makes recommendations to the Site Vice President. This reporting relationship makes the independent technical review function independent of both line management responsible for power production and the quality assurance organization.
d)
Address the relocation of the following TS requirement:
TS 6.2.3.2 (Composition) "The ISE shall be composed of at least 3 dedocated full-time engineers located onsite. These engineers will be supplemented as necessary by full-time engineers shared among all TVA nuclearsites to achieve an equivalent statting of 5 full-time engineers performing the ISE functions applicable to Sequoyah "
The licensee responds that the ISE function has been integrated into the independent technical review function as spec'fied by NUREG-1431, Section 5.5.2.d, which reads:
The [ technical) review responsibilities shall encompass:
- 1. Plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources which may indicate areas for improving plant safety.
- 2. Plant operations, modifications, maintenance, and surveillance to independently verify that these activities are performed safely and correctly and that human errors are reduced as much as practical,
- 3. Intemal and extemal operational experience information that may indicate areas for improving plant safety, and i-
- 4. Making detailed recommendations through the (Vice President-Nuclear Opestions) for revising procedures, equipment modifications, or other means of improving nuclear safety and plant reliability.
l The ISE function, as specified by TS 6.2.3.1, is:
,,. f
~~
17
"... to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources which may indicate areas for improving plant safety."
ISE responsibility, as specified by TS 6.2.3.4, is for "... maintaining surveillance of plant activities to provide independent verification that these activities are performed correctly and that human errors are reduced as much as practical."
The ISE function and responsibility has clearty been subsumed within the responsibilities of the
' technical review responsibilities delineated above. There is no NUREG-1431 requirement regarding the composition of the group performing the independent technical review function.
The licensee was requested to further address the TS 6.2.3 ISE composition requirement.
RAl-1 The NRC position, as delineated in Standard Review Plan 13.4, is that personnel performing the independent safety engineering (ISE) function should meet the requirements of Section 4.4 of ANS 3.1, which does not provide for "or the equivalent " The licensee is requested to clarify the equivalency requirement for ISE staff.
The licensee refers to the following ANSI 3.1, Section 4 general qualification provision for waiving educational requirements for nuclear power plant personnel:
Individuals who do not possess the formel educational requirements speci6ed in this section *Quali6 cations"shallnot be automatically eliminated where other factors provide suf6cient demonstration of theirabilities. These otherfactors shall be evaluated on a case-by case basis end approved and documented by the plant manager.
The licensee was further requested to provide the basis for applying the following qualification requirements (Section 4.1.3.C.7.b.16 of the NQAP) to ISE personnel:
Independent review personnel shall have a bachelor's degree in engineering or equivalent and two to fouryears experience in their Meld, including one ortwo years nuclearexperience.
The licensee references its commitments to RG 1.8, Revision 2 and ANSI /ANS 3.1-1981. With the exception of the " equivalent" phrasing, addressed by the licensee's response to RAI-1, the qualification requirements are identical with the applicable acceptance criteria of NUREG-0800, 1
the " Standard Review Plan" (SRP) 13.4 for ISE personnel.
Evaluation of Response:
l The regulatory position concoming the Independent Safety Engineering Group is provided by l
{
NUREG-0737 and delineated by SRP 13.4," Operational Review." NUREG-0800, issued by I
letter dated October 31,1980, provides a basis for evaluating licensee compliance with the regulatory position on ISE requirements. As delineated by SRP 13.4, the ISE group shall be
,.sg'+
i 18 4
comprised of a minimum of five dedicated full-time engineers, located onsite, but reporting to a I
corporate official who holds a high-level, technically oriented position who is not in the management chain for power production.
l The staff's questions regarding ISE organization and reporting relationships are adequately
(
addressed by the licensee's response. The licensee has committed to include the information i
regarding the July 1997 realignment in the next periodic NQAP update.
l The independent function is performed by onsite personnelindependent of plant management i
responsible for power production. The specific ISE functional and responsibility requirements have been relocated intact to the NQAP, Section 4.1.3.C.7.b.16. The licensee's criteria for waiving the formal education requirement for personnel performing the ISE function is consistent with that provided by the general provisions of ANSI 3.1, Section 4.
I Regarding ISE composition requirements, the staff has previously reviewed and accepted elimination of the ISE composition requirement when the group is integrated within a larger, independent review function.
l
==
Conclusion:==
Deletion of the ISE composition requirement is consistent with the description of l
the independent technical review function described in NUREG-1431. The licensee has provided adequate justification for the proposed reduction in commitment regarding ISE composition. Relocation of the ISE specifications to the NQAP is consistent with the guidance of AL 95-06. In view of the foregoing, the response provided by the licensee is acceptable.
4.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments changes recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical 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 the amendments.
5.0 CONCLUSION
The Commission 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, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Ronald W. Heman l
Kenneth C. Heck Dated: July 1, 1998 l
t
.