ML20246E409
| ML20246E409 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/05/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246E402 | List: |
| References | |
| NUDOCS 8907120227 | |
| Download: ML20246E409 (3) | |
Text
__ _ _ _ _ _ _ - _ - _ _ _ _ _
r
[pR #f Cg o, UNITED STATES y i 3ks NUCLEAR REGULATORY COMMISSION y, ?-
WASWNGTON. D. C. 20555 k..u EhCLOSURE 3 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.119 TO FACILITY OPERATING LICENSE NO. OPR-77 AND AMENDMENT NO.108 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 letter dated April 17, 1989, the Tennessee Valley Authority (TVA) proposed changes to Section 6, Administrative Controls, of the Sequoyah Nuclear Plant, Units 1 and 2, Technical Specifications (TS).
The proposed changes are to revise Specifications 6.2.3.2 and 6.2.3.4 to reflect the current restructuring of TVA's nuclear power organization.
The proposed administrative chan specifically addresses the Independent Safety Engineering Group (ISEG)gewith regard to site and corporate staffing and the corporate official to whom ISEG makes recommendations.
The ISEG would provide its recommendations to the Manager of the Nuclear Maneger's Review Group instead of the current Director of Nuclear Licensing and Regulatory Affairs.
In addition, TVA is proposing to rename ISEG to Independent Safety Engineering (ISE).
By phone conference calls on June 12 and 15, 1989, TVA clarified their proposed change to Specification 6.2.3.2 by revising the' proposed phrase "to achieve a staffing of 5 engineers" to read instead "to achieve an equivalent staffing of 5 full-time engineers performing ISE functions applicable to Sequoyah."
This clarification, for ihe TS changes being proposed by TVA, did not change (1) the substance of the. 5 oposed action in the Federal Register Notice (54 FR 21316) published n b y 17, 1989 or (2) the staff's initial determina-l tion of no significant bszards consideration in that notice.
2.0 BACKGROUND
In its letter dated April 17, 1979, TVA stated that organizational changes l
within its nuclear power organization would place ISEG within the Nuclear Hanager's Review Group under the newly formed Nuclear Assurance and Services Organization (NAS0).
This was discussed in the meeting of April 10, 1989 wfth TVA. The meeting summary was issued by the staff on April 26, 1989.
This summary includes organization charts in the handout from TVA in the meeting.
This organization realignment would have the ISEG submit their recommendations to the Manager of the Nuclear Manager's Review Group instead of the current TS requirement to the Director of Nuclear Licensing and Regulatory Affairs.
^
8907120227 890705 l
PDR ADOCK 05000327 P
PDC C
a
. TVA stated in its application that this new organization will continue to provide the appropriate level of independence with respect to ISEG's review and auditing functions.
It will continue to perform onsite independent reviews of plant operations.
It will continue to comply with NUREG-0737 requirements that it reports to a high-level corporate official in a technically oriented position not in the management chain for power production.
TVA further stated that the proposed change to the composition of the ISEG clarifies the staffing requirements if more than three full-time engineers are assigned at both the Sequoyah and Browns Ferry sites.
The manager of ISEG would be located at the TVA corporate offices and would serve a generic function to support both TVA operating plant sites, %quoyah and Browns Ferry.
3.0 EVALUATION The staff has reviewed TVA's application dated April 17, 1989. The requirements for the ISEG were established in Section I.B.1.2 of NUREG-0737,
" Clarification of TMI~ Action Plan Requirements," dated November 1980.
The proposed changes do not affect the functions or the responsibilities of ISEG.
The composition of ISEG in Specification 6.2.3.2 is proposed to be changed' to (1) delete the reference to a specific number of full-time engineers shared among all the TVA nuclear sites and (2) add a reference to full-time engineers shared among all the TVA sites, as necessary, to achieve a staffing of five engineers. The intent of this proposed change was discussed with TVA by phone conference calls on June 12 and 15,1989. The staff stated that it was not clear that there would be the equivalent of five full-time engineers performing the ISEG function and responsibilities for Sequoyah.
TVA stated that its intent was to have the equivalent of five full-time engineers performing the ISEG function and responsibilities for Sequoyah as required in NUREG-0737.
There would be at least three dedicated full-time engineers located onsite at Sequoyah and additional engineers offsite to have the equivalent of five full-time engineers for Sequoyah. TVA stated that, to clarify its intent, they propose for Specification 6.2.3.2 that the engineers onsite "will be supplemented as necessary by full-time engineers shared among all TVA nuclear sites to achieve an equivalent staffing of five full-time engineers performing ISE functions applicable to Sequoyah." This clarification by TVA assures that there will be an equivalent of five full-time engineers in the group for Sequoyah.
Because this specification requires that at least three engineers will be located onsite, engineers would also be located offsite to have the staffing of an equivalent of five full-time engineers for ISEG. The manager of ISEG is located at the TVA corporate offices.
This proposed change maintains the requirement of five-full time engineers in ISEG in the TS and meets the requirement of a minimum of five full-time engineers for ISEG in NUREG-0737; therefore, we conclude that this change is acceptable.
The authority of ISEG in Specification 6.2.3.4 is proposed to be changed to state that the group will make its recommendations to the Manager of Nuclear l
Managers Review Group, instead of the Director of Nuclear Licensing and Regulatory Affairs.
TVA explained in the meeting of April 10, 1989 that ISEG is being relocated into the new NASO and it will report to the Manager of Nuclear Manager's Review Group.
This manager is separate from the quality
s
..f
., assurance function of NAS0 and is at a corporate level equal to the Director of Nuclear Licensing and Regulatory Affairs, both report to Vice Presidents in the TVA Nuclear Power Organization.
Therefore, in accordance with NUREG-0737, the ISEG reports to a TVA corporate official who holds a high-level, technically oriented position that is not in the management chain for power production and is not an integral part of the quality assurance function in the TVA Nuclear Power organization. Therefore, we conclude that the change is acceptable.
TVA has also proposed to change the name of ISEG to Independent Safety
. Engineering (ISE). This change is an administrative change and does not affect the function and responsibilities of the ISEG. We conclude that this proposed change is acceptable.
3.0 ENVIRONMENTAL CONSIDERATION
The amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eli criteria for categorical exclusion set forth in 10 CFR Section 51.22(gibility 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 amendment.
4.0 CONCLUSION
The Comission made a proposed determination that the amendment involves no significant hazards consideratic.n which was published in the Federal Register (54 FR 21316) on May 17, 1989 end consulted with the State of Tennessee.
No public comments were received and the State of Tennessee did not have any comments.
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 dCtivities will be Conducted in compliance with the Commission's regulations, and the issuance of the amendments will not be inimical to the common defense and security nor to the health and safety of the public.
Principal Contributor: Jack Donohew Dated: July 5, 1989 i
i i
E _ _ _________
nI