ML20323A322

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Amendment 3 to Updated Final Safety Analysis Report, Chapter 13, Conduct of Operations
ML20323A322
Person / Time
Site: Watts Bar  Tennessee Valley Authority icon.png
Issue date: 10/29/2020
From:
Tennessee Valley Authority
To:
Office of Nuclear Reactor Regulation
Shared Package
ML20323A313 List:
References
WBL-20-047
Download: ML20323A322 (21)


Text

WBN TABLE OF CONTENTS Section Title Page 13.0 CONDUCT OF OPERATIONS 13.1-1 13.1 ORGANIZATIONAL STRUCTURE OF APPLICANT 13.1-1 13.1.1 Corporate Organization 13.1-1 13.1.1.1 Design Responsibilities 13.1-1 13.1.2 Nuclear Power 13.1-2 13.1.2.1 Offsite Organizations 13.1-2 13.1.2.2 Onsite Organization 13.1-2 13.1.3 Qualification Requirements for Nuclear Facility Personnel 13.1-2 References 13.1-4 13.2 TRAINING PROGRAMS 13.2-1 13.2.1 Accredited Training Programs 13.2-1 13.2.2 General Employee and Fitness for Duty Training Programs 13.2-1 13.2.3 Other Training Programs 13.2-1 13.3 EMERGENCY PLANNING 13.3-1 13.4 REVIEW AND AUDIT 13.4-1 13.4.1 Onsite Review 13.4-1 13.4.2 Independent Review and Audit 13.4-1 References 13.4-1 13.5 SITE INSTRUCTIONS 13.5-1 13.5.1 System of Site Instructions 13.5-1 13.5.1.1 Conformance With Regulatory Guide 1.33 13.5-1 13.5.1.2 Preparation of Procedures 13.5-1 13.5.2 Administrative Procedures 13.5-1 13.5.3 Operating Instructions and Procedures 13.5-2 13.5.3.1 System Operating Instructions 13.5-2 13.5.3.2 Abnormal Operating Instructions 13.5-2 13.5.3.3 Emergency Instructions 13.5-2 13.5.3.4 General Operating Instructions 13.5-2 13.5.3.5 Annuniciator Response Instructions 13.5-2 13.5.3.6 Fuel Handling Instructions 13.5-3 13.5.4 Maintenance Instructions 13.5-3 13.5.4.1 Equipment Maintenance Instructions 13.5-3 13.5.4.2 Instrument Maintenance Instructions 13.5-3 13.5.4.3 Special Maintenance Instructions 13.5-3 13.5.5 Surveillance Instructions 13.5-4 13.5.6 Technical Instructions 13.5-4 13.5.7 Radiation Control Instructions 13.5-4 13.5.8 Special Test Instructions 13.5-4 13.5.9 Radiological Emergency Plan (REP) Implementing Procedures 13.5-4 13.5.10 Vendor or Contractor Instructions 13.5-4 13-i

WBN TABLE OF CONTENTS Section Title Page 13.5.11 Radwaste Handling & Shipping 13.5-5 13.5-12 Modifications and additions Instructions 13.5-5 13.5-13 Plant Security Instructions/Standard Programs and Process 13.5-5 13.5-14 Periodic Instructions 13.5-5 13.5-15 Safety and Health Manual 13.5-5 13.5-16 Section Instructions, Manuals or Equivalent 13.5-5 13.5-17 Power Escalation Tests 13.5-6 13.5-18 Fire Protection Instructions 13.5-6 References 13.5-6 13.6 PLANT RECORDS 13.6-1 13.6.1 Plant History 13.6-1 13.6.2 Operating Records 13.6-1 13.6.3 Event Records 13.6-2 References 13.6-2 13.7 NUCLEAR SECURITY 13.7-1 13.7.1 Physical Security and Contingency Plan 13.7-1 13.7.2 Personnel and Program Evaluation 13.7-1 13.7.3 Physical Security of TPBARs 13.7-1 References 13.7-2 LIST OF TABLES Number Title 13.5-1 Operating Procedures LIST OF FIGURES Number Title 13.5-1 System of Written Procedures 13.5-2 Unit 1 Control Room Operating Areas 13-ii

WBN 13.0 CONDUCT OF OPERATIONS 13.1 ORGANIZATIONAL STRUCTURE OF APPLICANT 13.1.1 Corporate Organization The information presented in Tennessee Valley Authority Topical Report TVANPOD89, Nuclear Power Group Organization Description Reference [1], is applicable to Watts Bar Nuclear Plant.

13.1.1.1 Design Responsibilities Unit 1 Westinghouse Electric Corporation has contracted to supply TVA with two nuclear steam supply systems. The Nuclear Engineering organization serves as the plant architect engineer for the balance of plant equipment and is responsible for ensuring that the technical requirements of the nuclear steam supply system contracts are met. The New Projects organization was responsible for constructing the plant in accordance with design specifications supplied by Nuclear Engineering.

Westinghouse assists in the plant startup program by providing technical guidance in support of the following operations:

1. The storage, protection, installation, cleaning, initial calibration, testing, and operation of the nuclear system equipment, instrumentation, and material supplied by Westinghouse.
2. The preoperational testing of the nuclear plant systems in which Westinghouse supplied equipment was installed. This included the right of review and comment on the preoperational testing of all plant systems that is related to the safety and performance of the nuclear system.
3. Operational checkouts and startup testing of the nuclear system, the initial fuel loading, and startup to the completion of the warranty demonstration test.
4. The onsite training of TVA personnel during the nuclear systems' preoperational testing, initial fuel loading, and startup activities.
5. Overall fuel management services as part of the initial long-term fuel contract.

Unit 2 For the completion of Watts Bar Unit 2, Westinghouse continued to be the Nuclear Steam Safety System Supplier. The Nuclear Engineering organization served as the Design Authority for the balance of plant equipment. The Nuclear Generation Development and Construction (NGDC) organization was responsible for ensuring that the technical requirements of the nuclear steam supply system contracts are met and that engineering was completed and the plant constructed in accordance with design specifications. The Bechtel Corporation will provide professional engineering, procurement, construction and related services (such as Quality Assurance, Quality Control, and maintenance and modifications work) needed for completion of Watts Bar Nuclear Plant Unit 2.

13.1-1

WBN Westinghouse assists in the plant startup program by providing technical guidance in support of the following operations:

1. Review and comment on site provided refueling procedures and perform lower core plate inspection, initial core load, install upper internals, install reactor vessel head and complete reassembly activities up to and including missile shields.
2. Review and comment on the preoperational testing of all plant systems that are related to the safety and performance of the nuclear system.
3. Westinghouse will provide engineers for onsite engineering support starting approximately one month before initial core loading and continue through the 100%

power, test sequence.

13.1.2 Nuclear Power 13.1.2.1 Offsite Organizations The information presented in Tennessee Valley Authority Organization Topical Report, TVA-NPOD89-A,[1] TVA Nuclear Power Group Organization Description is applicable to Watts Bar Nuclear Plant.

Qualification requirements for positions providing corporate technical support, specifying required education and experience, are maintained in approved position descriptions on file at the site and central office by the Nuclear Human Resources organization. Numbers of positions are contained in approved staffing plans also maintained by the Nuclear Human Resources organization.

13.1.2.2 Onsite Organization The information presented in Tennessee Valley Authority Organization Topical Report, TVA-NPOD89-A,[1] TVA Nuclear Power Group Organization Description is applicable to Watts Bar Nuclear Plant.

13.1.3 Qualification Requirements for Nuclear Facility Personnel Nuclear Power (NP) personnel at the Watts Bar plant will meet the qualification and training requirements of NRC Regulatory Guide 1.8 with the alternatives as outlined in the Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Reference [2].

13.1-2

WBN Below are various onsite and offsite positions correlated to ANSI N18.1-1971 and ANSI/ANS 3.1-1981 positions as appropriate.

TVA Position Title ANSI N18.1-1971 Position Title Plant Manager, Plant Managers Operations Manager Maintenance and Modifications Manager Maintenance Manager System Engineering Manager Technical Manager Operations Superintendent Operations Manager Chemistry Superintendent Radiochemistry Maintenance Superintendent Maintenance Manager (Need not have non-destructive testing familiarity, craft knowledge or complete understanding of electrical, pressure vessel and piping codes.)

Assistant Unit Operator Operators (Unlicensed)

Reactor Engineering Supervisor Reactor Engineering and Physics Electrical, I&C System Manager Instrumentation and Control TVA Position Title ANSI N18.1-1971 Position Title Maintenance and Modifications Manager Technicians Repairmen Offsite Supervisory Personnel Staff Specialists TVA Position Title ANSI/ANS 3.1-1981 Radiological Control Superintendent Radiation Protection Shift Technical Advisor Shift Technical Advisor Shift Manager Shift Supervisor Unit Supervisor Senior Operator Unit Operator Licensed Operators Qualification of Plant Personnel 13.1-3

WBN The qualifications of key personnel are maintained on site and are available for NRC inspection.

1 The position of Radiological Control Superintendent will meet the requirements of RG 1.8, Revision 2, and ANSI/ANS 3.1-1981, for all new personnel qualifying on positions identified in RG 1.8, Regulatory Position C.1, after January 1, 1990 as clarified by Reference 3.

REFERENCES

1. Tennessee Valley Authority Organization Topical Report TVA-NPOD89-A, TVA Nuclear Power Group Organization Description.
2. Nuclear Quality Assurance Program, TVA-NQA-PLN89-A, Appendix B.
3. TVA Standard Program and Processes, NPG-SPP-05.1, Radiological Controls.

13.1-4

WBN 13.2 TRAINING PROGRAMS 13.2.1 Accredited Training Programs The Watts Bar Nuclear Plant (WBN) training programs have been developed in accordance with the Systems Approach to Training as prescribed by the Institute of Nuclear Power Operations (INPO). The National Academy for Nuclear Training, through a formal accreditation process, verifies that WBN training programs meet the established criteria. WBN is a branch of the National Academy and has achieved accreditation of the following programs:

Non-licensed operator Reactor operator Senior reactor operator Continuing training for licensed personnel Shift manager Shift technical advisor Instrument and control technician Electrical maintenance personnel Mechanical maintenance personnel Radiological Control technician Chemistry technician Engineering support personnel Maintenance Supervisor The training programs are periodically reviewed by management for effectiveness. Revisions are made as appropriate. Records are retained as necessary to support management information needs and to provide historical data.

13.2.2 General Employee and Fitness for Duty Training Programs All persons regularly employed at WBN are trained in the following areas commensurate with their job duties:

Fitness for duty Plant Organization and Administration General plant description Job related procedures and instructions Radiological protection Emergency preparedness Industrial safety Fire protection Security Quality Assurance and Quality Control (Including Procedure Overview) 13.2.3 Other Training Programs Responsible managers ensure that personnel performing quality-related activities receive indoctrination and training to ensure that adequate proficiency is achieved and maintained.

13.2-1

WBN 13.3 EMERGENCY PLANNING The TVA Radiological Emergency Plan (REP) has been developed to provide protective measures for TVA personnel, and to protect the health and safety of the public in the event of a radiological emergency resulting from an accident at Watts Bar Nuclear Plant. The REP contains site-specific appendices for each plant. Watts Bar's radiological emergency information is in Appendix C. The REP fulfills the requirements set forth in part 50, Title 10 of the Code of Federal Regulations that an emergency plan be included in the Final Safety Analysis Report and was developed in accordance with the Nuclear Regulatory Commission and Federal Emergency Management Agency Guidance.

The Emergency Plan Implementing Procedures (EPIPs) which implement the REP provide more detailed descriptions of Watts Bar's site emergency organization, emergency response facilities, capabilities, equipment, protective actions, and responsibilities.

The "State of Tennessee Multijurisdictional Radiological Emergency Response Plan for Watts Bar Nuclear Power Plant" is referenced in Appendix E of the REP. The "Georgia Radiological Emergency Response Plan" and "North Carolina Plan for Sequoyah/Watts Bar" are also referenced in Appendix E.

13.3-1

WBN 13.4 REVIEW AND AUDIT 13.4.1 Onsite Review The plant staff organization provides continuing review of operational activities to ensure they are conducted in a safe manner. The Plant Operations Review Committee (PORC) is a multi-disciplined committee responsible for providing an oversight review of programs, documents, and activities required for the safe operation of the plant. The PORC advises the Plant Manager on matters related to nuclear safety. Also, technical reviewers provide for reviews of procedure changes and proposed changes to structures, systems, and components that affect nuclear safety in their area of expertise. These technical reviews determine the need for a cross-disciplinary review and whether NRCs approval prior to implementation is required.

Technical reviewers and PORC shall be qualified, organized, and conduct business as described in Reference [1].

13.4.2 Independent Review and Audit Independent review and evaluation is performed by the Nuclear Safety Review Board (NSRB).

The NSRB is described in Reference [1].

The Nuclear Assurance (NA) organization conducts the audit and assessment program as described in Reference [1].

The Engineering organization performs independent technical reviews as described in Reference [1].

REFERENCES

1. Nuclear Quality Assurance Plan, TVA-NQA-PLN89A.

13.4-1

WBN 13.5 SITE INSTRUCTIONS 13.5.1 SYSTEM OF SITE INSTRUCTIONS 13.5.1.1 Conformance with Regulatory Guide 1.33 The Site Vice President and Plant Manager issues, in the form of administrative instructions, instructions governing employee actions and established standards for plant operation.

Additionally, standard TVA Nuclear (TVAN) administrative procedures are issued by the Vice President, Nuclear Support, which are applicable to all TVA nuclear plants. These procedures are written using the guidelines of Regulatory Guide 1.33, Revision 2, February 1978, with alternatives as shown in the Nuclear Quality Assurance Plan. Figure 13.5-1 shows the organizational structure of these various instructions. Plant operations and other work activities are performed in accordance with these written and approved procedures.

13.5.1.2 Preparation of Procedures Instructions and procedures covering plant operations, maintenance work, tests, equipment changes, and other activities which might affect nuclear safety are put into effect only after being reviewed by an independent qualified reviewer(s), the Plant Operations Review Committee (PORC) when required, and approved by a responsible manager who is designated by the Plant Manager. It is the appropriate responsible manager's responsibility to ensure that required reviews and approvals are completed before authorizing the use of any site procedure.

One-time-only instructions may be generated as described in administrative site procedures for special conditions or when normal instructions are not adequate to accomplish the desired task.

Site procedures may be temporarily changed without delay when the need arises by following the administrative procedure system.

The PORC is responsible for reviewing prepared tests or experiments that affect nuclear safety and proposed instructions and changes to plant procedures within the scope of 10 CFR 50.59 to determine whether a license amendment is required.

13.5.2 Administrative Procedures Instructions, standards, programs, and processes are prepared to govern employee actions and site and plant operation. These instructions contain administrative restrictions and station requirements established to ensure safe operation of the plant within the limits set by the facility license and technical specifications. They provide that plant activities will be conducted in a manner to protect the general public, plant personnel, and equipment.

13.5-1

WBN 13.5.3 Operating Instructions and Procedures Operating instructions are prepared for integrated plant operations such as plant startup power operation, etc., where such instructions are required to ensure safety and reliability ANSI N18.7 and Regulatory Guide 1.33, Rev.2 are used as guidelines in the preparation of operating instructions. Table 13.5-1 lists typical operating procedures.

13.5.3.1 System Operating Instructions Operating Instructions are prepared for system operations and equipment operations to ensure safety and reliability. Some instructions must be followed step-by-step and documented. These requirements are identified within the instruction.

The instructions contain mode of operation of the system such as startup, shutdown, energizing, filing and venting, and standby operation as applicable, conditions for operation and precautions to be observed.

13.5.3.2 Abnormal Operating Instructions Abnormal operating instructions exist for abnormal operation of the unit. Operation of system or equipment in this mode could degrade into an emergency condition. In addition, symptoms of the abnormality, automatic actions that may occur, and operator actions are given.

13.5.3.3 Emergency Instructions Emergency Instructions are prepared for conditions which may possibly lead to injury of plant personnel or to the public or conditions which may possibly lead to the release of radioactivity in excess of established operating limits. These procedures provide a discussion of the postulated event, symptoms of the postulated emergency, automatic actions, and immediate and subsequent operator actions.

13.5.3.4 General Operating Instructions General operating instructions are developed to ensure safe unit startup, shutdown, and load changes and are required to ensure safety and reliability for complex activities that affect many different systems.

13.5.3.5 Annuniciator Response Instructions Annunciator response instructions are written to guide operator response to conditions that result in annunciation of plant conditions.

13.5-2

WBN 13.5.3.6 Fuel Handling Instructions Fuel handling instructions are used to ensure a safe and orderly refueling operations. The instructions specify or make reference to other system operation documents that specify periodic shutdown margin checks, fuel handling techniques, and other precautionary steps to assure that the facility license and Technical Specifications are not violated. Licensed operators will supervise the operations when fuel is received, initially inventoried, stored, removed, or rearranged in the core or when control rods are being installed, removed, or manipulated.

Technical personnel will provide guidance when necessary and will verify that all fuel has the proper orientation and is in the correct location.

13.5.4 Maintenance Instructions 13.5.4.1 Equipment Maintenance Instructions Written maintenance instructions are prepared for critical equipment and for special jobs on safety related systems and 10 CFR 50.49 equipment as the need arises, or systems and equipment expected to require frequent or systematic maintenance. These instructions covering mechanical and electrical maintenance provide information to assure proper coordination of operating and maintenance employees as well as step-by-step actions with allowance for skill of the craft to be followed by the craftsmen doing the work. As operating and maintenance experience is acquired, maintenance instructions are revised and/or new instructions are written to improve the quality of the maintenance program.

13.5.4.2 Instrument Maintenance Instructions Instrument maintenance instructions are written for performing periodic calibration and testing of safety-related plant instrumentation. These instructions ensure measurement accuracies adequate to maintain plant safety parameters within operational and safety limits according to technical specification requirements.

13.5.4.3 Special Maintenance Instructions Special maintenance instructions are developed for special maintenance activities. These instructions are not routinely performed; however, results from these performances may generate routinely performed instructions covered by one of the other types of instructions addressed in Section 13.5.1.

13.5-3

WBN 13.5.5 Surveillance Instructions Instructions are prepared covering the conduct of periodic surveillance tests and inspections designated in the plant Technical Specifications, the Technical Requirements Manual, Offsite Dose Calculation Manual (ODCM), and the plant Fire Protection Report.. These instructions as a minimum specify requirements, precautions, acceptance criteria, necessary step-by-step actions for conduct of the tests and return to normal, data sheets, and documentation by those conducting and reviewing the tests or inspections. Detailed test schedules and records are maintained to assure that scheduled surveillance requirements are conducted in a timely manner and the results are properly documented.

13.5.6 Technical Instructions Instructions are prepared covering routine technical evolutions for tests, inspections, examinations, and special processes as required. Examples of these evolutions are chemistry instructions, and calibration of vital instrumentation.

13.5.7 Radiation Control Instructions Radiation control instructions are maintained and made available to all site personnel. These instructions are written to implement the requirements of 10 CFR 20, applicable codes and standards, and commitments to outside agencies (American Nuclear Insurers, Institute of Nuclear Plant Operations, etc.)

13.5.8 Special Test Instructions Instructions are prepared for special rest and experiments. These instructions are normally one time performance; however, results from these tests may generate routinely performed instructions covered by one of the other types of instructions addressed in Section 13.5.1.

13.5.9 Radiological Emergency Plan (REP) Implementing Procedures Procedures are prepared covering the site implementation of the REP.

13.5.10 Vendor or Contractor Instructions Instructions are prepared to convert vendor or contractor instructions into plant instructions, as applicable. These instructions will meet TVA quality assurance program and site administrative requirements.

13.5-4

WBN 13.5.11 Radwaste Handling & Shipping Instructions are prepared covering packing and shipping of radioactive waste and materials or equipment, and the process control program for the radwaste system.

13.5.12 Modifications and Additions Instructions Instructions are prepared covering modifications and additions to plant systems and equipment.

Processes covered by these instructions include welding, pulling, splicing, and installation of cables, conduit and junction boxes, bolted connections, supports, grouting, conax connectors, coatings, and concrete.

13.5.13 Plant Security Instructions/Standard Programs and Process Instructions are prepared covering plant access, badging, vehicles, searches, physical security of vital areas of plant, security events, security degradation, and reporting and security inspections.

13.5.14 Periodic Instructions Instructions are prepared covering periodic test and inspections which are not designated in the plant technical specifications, and are scheduled by utilizing the SI matrix for periodic performances. These include but are not limited to tests designed by applicable UFSAR sections, the NPDES permit, and augmented QA/test program.

13.5.15 Safety and Health Manual Instructions are prepared covering safety measures to be taken by personnel when handling certain types of portable mechanical or electrical equipment and protective measures while inspecting electrical equipment.

13.5.16 Section Instructions, Manuals, or Equivalent Each section supervisor may prepare, as the need arises, instructions pertaining to administrative routines, responsibilities, and methods to be followed by members of his/her section in areas of activity that does not involve nuclear safety and/or the implementation of the technical specification.

13.5-5

WBN 13.5.17 Power Escalation Tests Written procedures cover the conduct of tests performed during physics testing and power ascension testing following core alterations. Instructions also cover core reloading, initial criticality, incore power distribution measurements and power ascension.

13.5.18 Fire Protection Instructions Instructions are prepared covering the implementation of the administrative fire protection program as required by the Fire Protection Report and Insurance Carrier requirements. These instructions are to minimize the potential for loss and to minimize actual events.

REFERENCES None.

13.5-6

NUCLEAR POWER SPPs, AND SOPs, STANDARDS NUCLEAR QUALITY ASSURANCE PLAN FSAR/TECHNICAL SPECIFICATIONS System Abnormal General Alarm Fuel Administrative Emergency Operating Procedures Operating Operating Response Handling Instructions Instructions Instructions Instructions Instructions Instructions Maintenance Instructions Technical Radiological Surveillance Offsite Dose Fire Operating Technical (Including Requirements Control Instructions Instructions Requirements Instructions Instrumentation) Instructions Instructions Radioactive Emergency Waste Plant Power Modifications Periodic Fire Protection Preparedness Management Security Escalation Instructions Instructions Instructions Instructions Instructions Instructions Tests WATTS BAR NUCLEAR PLANT FINAL SAFETY ANALYSIS REPORT System of Written Procedures FIGURE 13.5-1

Area 1 I Normal surveillance area for the "RO" (includes Operator workstation) WATTS BAR NUCLEAR PLANT FINAL SAFETY Area 2 E Areas entered occasionally to verify alarms and/or initiate corrective actions and entered ANALYSIS REPORT in the event of an emergency affecting the safety or major equipment or personnel.

Unit 1 &2 Control Room Operating Areas FIGURE 13.5-2

WBN 13.6 PLANT RECORDS 13.6.1 Plant History TVA's records program observes all acts of Congress, executive orders and regulations of Federal agencies having jurisdiction in records administration (for the particular case of nuclear plants, this includes 10 CFR 50, Appendix B, Criterion XVII). TVA complies with Department of Energy regulations concerning the preservation and disposal of records of public utilities and licensees, insofar as those regulations apply to TVA records relating to the generating, transmission, and sale of electric energy.

The site Management Services (MS) Manager has responsibility for 1) developing, implementing, and maintaining an integrated site program to ensure that documents are properly processed, up-to-date, and readily available for use, and 2) managing a program for storing, updating, and retrieving plant documents.

13.6.2 Operating Records Records reflecting plant or equipment performance and records of tests and inspections which support compliance with the plant licenses, including records of radioactivity release to the environs are routed to the site MS for retention. These records are originated by all plant sections.

The operators maintain journals containing details pertaining to the operation of the plant.

Operators also maintain operating data sheets which ensure their frequent observations of equipment condition and operating values. These records are examined by the plant operations management and are support documents for performance analysis. The unit logs or an acceptable electronic copy are retained in the site MS.

The station computer printouts and the operators data sheets serve as the normal source of operating data and statistics. To ensure continuity of information, provision is made for supplementary data to be maintained if the computer becomes inoperative. In addition, this information is supported by installed recording and data logging instrumentation. These records are sent to the Site MS on a regular basis for retention.

The Maintenance section initiates equipment history and inventory files. These records are maintained and updated by Site MS. These records contain complete information on repairs, modifications, tests, derangements and other data as considered necessary to provide a comprehensive material history of the item considered.

Specific records and their retention periods are controlled in the Reference [1].

13.6-1

WBN 13.6.3 Event Records Records of individual radiation exposure and plant and environs radiation levels are retained by Radiation Control Section.

Records of results of surveillance and maintenance requirements are retained by Site MS.

Records of radioactive effluent discharges and quantities of radioactive wastes shipped for offsite disposal are retained by Site MS.

REFERENCES

1. Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A.

13.6-2

WBN 13.7 NUCLEAR SECURITY 13.7.1 Physical Security and Contingency Plan TVA's plan for protection of Watts Bar Nuclear Plant is contained in separate controlled documents. These documents require submission as separate submittals to ensure compliance with 10 CFR 73.21[1] and paragraph 2.390(d) of 10 CFR part 2.[2] These separate submittals provide a comprehensive description of the physical security program for the plant site which include physical barriers and means of detecting unauthorized intrusions; provisions for monitoring access to vital equipment and access control; provisions for selection and training of personnel for security purposes; communication systems for security; provisions for maintenance and testing of security systems; arrangements for law enforcement assistance; provisions for responding to security threats; and required organizational charts and drawings that depict the site layout. These documents may be withheld from public disclosure pursuant to paragraph 2.390(d) of 10 CFR part 2.[2] These documents are identified as:

A. The Physical Security Plan/Contingency Plan as specified by 10 CFR Parts 50.34(c),[3] 50.34(d),[4] and 73.55(b).[5]

B. The Security Personnel Training and Qualification Plan as specified by 10 CFR 73.55(d).[6]

13.7.2 Personnel and Program Evaluation TVA's Nuclear Power organization is responsible for protection of power properties with functional responsibility delegated as shown in the Nuclear Power Organization Description.[7]

The Watts Bar Security Program is evaluated by individual(s) who are knowledgeable of security requirements and independent of both security management and supervision. The review is conducted to determine the effectiveness of security procedures and personnel practices as they relate to the implementation of licensed security documents. Based on the review, a detailed report is submitted to appropriate management recommending corrective action and improvements, if any, to ensure the successful implementation of the security program[8].

13.7.3 Physical Security of TPBARs Physical Security for tritium production is identified within a Department of Energy (DOE) approved security plan for WBN that is a separate plan from the NRC Physical Security Plan required by 10 CFR 50. DOE will continue to be the cognizant security agency for physical security concerning protection of the tritium producing burnable absorber rod (TPBARs). NRCs security oversight and responsibilities will remain the same.

13.7-1

WBN REFERENCES

1. 10 CFR 73.21(b), Protection of Safeguards Information: Performance Requirements.
2. 10 CFR 2.390(d), Public Inspections, Exemptions, Requests for Withholding.
3. 10 CFR 50.34(c), Contents of Applications: Technical Information; Physical Security Plan.
4. 10 CFR 50.34(d), Contents of Applications: Technical Information; Safeguards Contingency Plan.
5. 10 CFR 73.55(b), Requirements for Physical Protection of Licensed Activities in Nuclear Power Rectors against Radiological Sabotage; General Performance Objective and Requirements.
6. 10 CFR 73.55(d), Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors against Radiological Sabotage; Security Organization.
7. Nuclear Power Organization Description, Topical Report, TVA-NPOD89.
8. 10 CFR 73.55(gm Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors against Radiological Sabotage; Security Program Reviews.

13.7-2