ML20155F679

Proposed Tech Specs Deleting Organization Charts (Figures 6.2-1 & 6.2-2) & Refs in Tech Spec Section 6,per Generic Ltr 88-06.Section 6 Rev Also Changes Title of Nuclear Power Manager & Refs to Unit Staff & Organization

ML20155F679
Person / Time
Site:	Sequoyah
Issue date:	06/13/1988
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20155F674	List: ML20155F672 ML20155F679
References
GL-88-06, GL-88-6, NUDOCS 8806170011
Download: ML20155F679 (22)

Text

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6.0 ADM]HISTRATIVE_ CONTROLS 6.1 RESPONSIBillTY 6.1.1 The Nant Manager shall be responsible for overall unit operation N t' wnce. delegate in writing the succession to this responsibility during his and shall 6.1. 2 T'e Manager of Radiological Control. shall be responsible for imple-menting the radiological environmental program and dose calculation. and k62 projectioi.; as described in the Offsite Dose. Calculation Manual (00CM).

6.1. 3 The Shift Supervisor (or during his absence from the Control Room, a designated individual) shall be responsible for the Control Room command function.

A management directive to this effect, signed by the Site Director, t%11 be reissued to all station personnel on an annual basis R62

6. . ORGANIZATION

---Orff!TE cHszrr swe oy.trre ona'rwzorJ

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6.2.1/bcA::-;f tha!! f:ite 4-0rg:ri heu:- :tter for unit '.F:ger-% :nd tech-ic:1 : ppert-rigurc S.2-1.

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' 6.2.2 -The Urit Organ %t40n :ha" k -c; :h wn in Figur; 5.2-2 :ni un;f a

Each on-dutydshift shall be composed of at least the minimum sh;ft crew composition shown in Table 6.2 1,

b. and At least one licensed Reactor Operator shall be in thedContral Room when fuel is in the reactor. In accicion, while the unit i. in MODE 1, 2, 3 or 4, at least one licensed Senior Reactor ;perator shall be in the Control Room.

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Ste'? AH - UNIT 1 6-1 ^=nd="t40.

• 8806170011 880613 pis ADOCK 0500 7 P

. 1 INSERT "A" for page 6-1 An onsite and an offsite organimation shall be established for unit operation and corporate manager.ent. The onsite and offsite organization shall include the positions for ar,tivities af fecting the safety of the nuclear power plant.

a. Lines of authority, responsibility, and communication shall be established and defined frc.n the highest management levels through intermediate levels to and includinu all operating organization positions. These relationships shall be documented and u7 dated, asappropriate,intheformoforgapizationalcharts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the FSAR and will be updated in accordance with 10 CFR 50.71(e).

b. There shall be an individual executive position (corporate officer) in the offsite organization having corporate responsibility for overall plant nuclear safety. ihis individual shall take any measures noeded to ensure acceptable performance of the staff in operating, maintaining, and providing technical support in the plant so that continued nuclear safety is assured.

c. There shall be an individual management position in the onsite organization having responsibility for overall unit safe operation, and this position shall hsve control over those onsite

{ resourced necessary for safe operation and maintenance of the plant.

d. The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating prescures.

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i ADMINISTRATIVE CONTROLS

c. A Radiological Control technician # shall be onsite when fuel is in the M reactor.

d.

All CORE ALTERATIONS shall be observed and directly supervised by either a licenssd Senior Reactor Operator or Senior Reactor Operator FP Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

e. AFireBrigadeofatleast5membersshallbemaintainedonsiteat all times. The Fire Brigade shall not include the Shift Sups.* visor and 2 other members of the minimum } shift crew necessary for safe R6' shutdown of the Unit or any personnel required for other essential functions during a fire emergency.

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1. The kadiological Control technician and fire brigade composition may be less R62 than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence provided immediate action is taken to

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d fill the required positions.

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, , ,$,[ g , PLANT Moper sc ATeote PROJECT 5d',E a sct as.H uA94Aorn W A.4 Apr R MANAot*n MAIJAGER uanAo E t4Gir#E E R f* o f t s j - ---ht4 0t s 5 T nt A R. S A r t T Y_ *]

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N FIGURE 6.2-2 -

T 'D' FACILITY ORGANIZATION - SEQUOYAH NUCLEAR FLANT w

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l ADMIN!STRATIVE C0 CRC.S h .

't k 6.4 TRAININO t

hN 6.4.1 A retraining and, eolacement training programCpa** Eons .f,9z,9 444 be maintained under the cirection of the '. ;;;; 'c.(for " the e staff shall

(P") Superin- R62 tendent and shall meet or exceed the requirements and recommencations of Sec-tion 5.5 of ANSI N18.1-1971 anc Appenoix "A" of 10 CFR Part 55 and the supple-mental 28, 1980recuirements specified in Section A anc C of En

lesure 1 of the March NRC letter to all licensees, and shall in:1?ce umiliarization with relevant incustry operational experience. l R62 6.5 REVIEW AND AUDIT Sea,o'as V,'es niid 6 6.5.0 eli TVA Tne powerM:n:;;r Of Nu:iear Power is responsicie for tr'e safe coeration of plants. R62

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6.5.1 PLANT ODERATIONS REVIEV COMMITTEE (DORC)

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• TION 6.5.1.1 The POR* shall fun: tion to acvise the Plant Manager on all' matters related to nuclear safety. R62 COMDOSITION .

6. 5.1. 2 The POR; shall ce composed of ine:

Chairman: Plant Mana Memoer: L;; 'c.:n;ger  ;; P"' ".: i :: .n: n: : ) Cpe r. Y,.w I-per .aw/2

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%M Memoer: Doerations W Manager : *:: : . :. r *. ;; :'.:: : * .:

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RA N Memoer: Site' Radiological Control Superintenc l Member: Maintenance ; a; ".::.c,;;- ::;, ; ;, .ent

,, % Memoer: Technical Su:: port i:- i::,:

.fyu.:.b M-p Memoer: *

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, Quality Engineering :.n: : : ;; Manager M

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SE003YAH - UNIT 1

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ADMINISTRATIVE CONTROLE QUAllFICATIONS JIende V/ce Am / d Mtu/w #o w 6.5.2.3 The Chairman,, members, and te.rnate members of the NSRB shall be a62 appointed in writing by the-Man ger of Muclear Power and shall have an academic degree in engineering or a physical science field, or the equivalent; and in addition, shall have a minimum of five years technical experience in one or more areas given in 6.5.2.1. No more than two alternates shall participate as voting members in NSRB activities at any one time.

CONSULTAN'5 6.5.2.4 Consultants shall be utilized as determined by the NSRB Chairman to provide expert advice to the NSRB.

MEETING FREQUENCY 6.5.2.5 The NSRB shall meet at least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per six months thereafter.

QUORUM 6.5.2.6 The minimum quorum of the NSRB necessary for the performance of the NSRB review and audit functions of these teci,aical specifications shall consist of more than half the NSRB membership or at least 5 members, whichever is greater.

This quorum shall include the Chairman or his appointed alternate and the NSRB members, including appointed alternate members, meeting the requirements of Specification 6.5.2.3. No more than a minority of the quorum shall have line responsibility for operation of the unit.

REVIEW 6.5.2.7 The NSRB shall be cognizant of review of:

R62

a. The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.

b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

c. Prc. posed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR, ,

d. Proposed changes to Technical Specifications or this Operating License, ,

e. Violations of codes, regulations, orders, Technical Specifications, license requi.rements, or of internal procedures c,r instructions having nuclea,r safety significance.

4 kged: 10, :087-R62 SEQUOYAH - UNIT 1 6-11 %endment Mor-30

I ADMINISTRATIVE CONTROLS

k. The radiological environmental monitoring program and the results thereof at least once per 12 months.

1. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

j m. The PROCESS CONTROL PROGRAM and implementing procedures for i

SOLIDIFICATION cf radioactive vastes at least once per 24 months.

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n. The performance of activities required by the Quality Assurance R46 Program to meet the criteria of Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.1,1974 and Regulatory Guide 4.1, Rev. 1, 1975, at least once per 12 months.

AUTHORITY

.Sence t/;<a P<es,4f A/ru Powu 6.5.2.9 The NSRB shall report to and advise the #anager-of Nuclear-4wes on those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8. R62 RECORDS 6.5.2.10 Records of NSRB activities shall be prepared, approved and distributed as indi sted below:

a. Minutes of each NSRB meeting shall be prepared, approved and forwarded k to.ra.,6 the-Mana^%cr

' Nucle Pewcw within 14 days following each meetiag. R6

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b. Reports of reviens encompassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the-Manager-of Nuclear Power R62 within 14 days foll,0wi cogpl n gf p e feview j

c. Audit reports ncompassed by Sec tion 6.5.2.8 above, shall be forwarded to the-Managee-of-Huc4 ear Power- and to the management positions R62 responsible for the areas audited within 30 days af ter completion of the audit.

6.5.3 RADIOLOGICAL ASSESSMENT REVIEW COMMITTEE (RARC)

Function 6.5.3.1 The SQN RARC shall function to advise the Manager of Radiological Con

• R62 trol and the Plant Manager on all matters related to radiological assessments involving dose calculations and projections and environmental monit.oring.

Composition 6.5.3.2 The SQN RARC shall be composed of the:

I Chai rman: Technical Assistance Section Supervisor R62 Member: Health Physicist, Gaseous, Radiological Control Member: Health Pnysicist, Liquid, Radiological Control

. # . ,,e r 10, 1937 SEQUOYAH - UNIT 1 6-13 -Amendment-Nc. jd, 50- h62

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Table [6.2- . Minimum sh,ift crqw compo;sition With Unit 2 in Mode 5 or 6 or Oe-fueled l

Position Number of individuals required to fill position .,..,..u

, , ;a.,, e.,;;i s,. .

Modes 1, 2, 3, & 4 Modes 5 & 6 . ,

a JS l ya SRO 1 None R0 2 1 D

A0 2 2 STA 1 None i-With Unit 2 in Modes 1, 2, 3, or 4 R:

.Postion Number of individuals required to fill position Modes 1, 2, 3, & 4 Modes 5 & 6 l a

SS l ya a

SRO l None D

R0 2 1 b

A0 2 3 a

STA l None a

individual may fill the same position on Unit 2.

b 0ne of the two required individuals may fill the same position on Unit 2.

SS - Shif t Supervisor with a Sei11or Reactor Operators License on Unit 1 SR0 - Individual with a Senior Reactor Operators License on Unit 1 R0 - Individual with a Reactor Operators License on Unit 1 AO - Auxiliary Operator

• STA - Shif t Technical Advisor i

Except for the Shift Supervisor, the Shift Crew Composition may be one less than the minimum requirements of Table 6.2-1 for a period of time not to exceed 2 l hours in order to accommodate unexpected absence of on-duty shif t crew members l provided immediate action is taken to restore the Shift Crew Composition to  :

within the minimum requirements of Table 6.2-1. This provision does not permit I any shift crew position to be unmanned upon shift change due to an oncoming -

shift crewman being late or absent.  !

During any absence of the Shift Supervisor from the Control Room while the unit is in H0DE 1, 2, 3 or 4, an individual (other than the Shift Technical Advisor) with a valid SRO license shall be designated to assume the Control Room command function. During any absence of the Shift Supervisor from the Control Room while the Unit is in Mode 5 or 6, an individus) with a valid SRO or R0 license (other than the Shift Technical Advisor) shall be designated to assume the Control Room command function.

September 10, 19J7 Rb SEQUOYAH - UNIT 1 6-5 Amendment No. J2, 58

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6.0 ADMIN 151RATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Plant Manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his

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R50 absence.

6.1. 2 The Manager of Radiological Control shall be responsible for implement-ing the radiological environmental program and dose calculations and projec. R50 tions'asdescribedintheOffsiteDoseCalcplationManual(00CM).

6.1.3 The Shif t Supervisor (or during his absence from the Control Room, a designated individual) shall be responsible for the Control Room command func-tion. A management ?irective to this effect, signed by the Site Director shall g50 be reissued to all station personnel on an annual basis.

6.2 ORGANIZATION Cr"SITE OFFJzra 4ND ov.trre OR&<wru rrows 6.2.1pr T': cff:ite Orgari:: ier 'e urit m:n g:::r.t and technical :upp;rt

":!' be :: ;b^ar ^ cigu 6.2-1.

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)V4 Lit tr y JTAff 6.2.2 The L'rit Org:^!: tic.a cha!' bc :: 50e^ Or cigur 5.2-2 nd:

'1 ud 4 a. Each on dutydshift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

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b. At least one licensed Reactor Operator shall be in the Control d Room when fuel is ir the reactor. In addition, while the unit is in MODE 1, 2, 3 or 4, at least one licensed Senior Reactor Operator shall be in the Control Room, r

C... .s1....- to inO7 SEQUOYAH - UNIT 2 6-1 nt c. t

INSERT "A" for page 6-1 An onsite and an offsite organization shall be established for unit operation and corporate management. The onsite and offsite organization shall include the positions for activities affecting the safety of the nuclear power plant.

a. Lines of authority, responsibility, and-communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of orgahizational charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or ir. equivalent forms of docume,tation. These requirements shall be do;umented in the FSAR and will be updated in accordance with 10 CFR 50.71(e).

b. There shall be an individual executive position (corporate officer) in the offsite organization having corporate responsibility for overall plant nuclear safety. This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support in the plant so that continued nuclear safety is assured.

c. There shall be an individual management position in the onsite organization having responsibility for overall unit safe

, operation, and this position shall have control over those onsite j resources necessary for safe operation and maintenance of the plant.

d. The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

4 i

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ADMINISTRATIVE CONTROLS

c. A Radiological Control technician #.shall be onsite when fuel is in the reactor. .

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d. All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to F.uel. Handling who has no other concurrent responsibilities during this operation.

e. AFireBrjgadeofatleast5membersshallbemaintainedonsiteat all times . The Fire Brigade shall not include the Shift Supervisor and the 2 other members of the minimum shif t crew necessary for safe shutdown of the unit or any persornel raquired for other essential functions during a fire emergency.

A The Op ud;w /kar- dd/ AoW a Jen:o /d.nf, 9.,,,,4, /._ , ,

• The Radiological Control technician and fire brigade composition may be less than the minimum requirements for a period of time not to exceed 2 nours in g

order to accommodate unexpected absence provided immediate action is taken to fill the required positions.

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( 6.a TRAINING h 6.a.1 Cpe rs kar A retraining and replacement training program)for the wa44.#staff g,y 4) y de maintained uncer the direction of the @ .cr Pc , ; ; ' " ") Svoerintencent and N18.1-1971 ANS1 sna11 meet or exceec *he recuirements anc recommenaations of Secti shall l R50 and Appenoix "A" of 10 CFR Part 55 and the supplemental ree i ments specified la sec* ion A and C of Enclosure 1 of the March 28, 1980 NRC v re-letter to all licensees, and sns11 i A:

incustry opert.tToral experiaace. 1ude familiari:ation with relevant l R5C 6.5 REVIEW AND AUD.'T

.$defree Vei .' /r/ Mf g 6.5.0 The 9;..ege c:

all TVA power plants. Nuclear

• e Power is responsible for the saf e operation of

'u-etiera! crg:ri:3 tier 'c- 4 "i e" ear %: 4 1 4 - lR5C the + 09 figure 5.? '

6.5.1 PL ANT ODERAT10NS REVIEW CO$!H 77EE (PORC)

FUNCTION 6.5.1.1 relatec toThe PORCtafety.

nuclear sna11 function to advise the Plant Manager on all matters lR50 COMP 051T10N -

6. 5.1. 2 1he POR: sna11 ee comcosed of the:

R5U Cnai rman: Plant Manager Memeer:

Memeer:

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Y Opern1ons

} 'a+ve. Manager e- ' . :::. :; ;ti - : ;.;

A Member: Sit [RaciologicalControlSuoerintencent g% Member:

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hmot r: Tecnnical $wpport Se- ':e> C ::: ": = p - Jy,,,", 4 .,4- f Member:

N Quality Engineering : : :r :- ' Manager h n t.. , o.w.u,.,

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, LLQUOYAN - UNIT 2 6-8 *

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s ADMINISTRATIVE CONTROLS pan /;o.,s as the individual / group which.designe the raodifications. Proposed h4 3 modifications to structures, systems and components that affect plant by i nuclear safety and the implementing - rkplans shall be approved prior.to implementation by the Plant Managar, Superintendent,

• Maintenance R50 rdk Superintendent, or Teddu/ Sped f ys,.Md. 44 t, 5 c. Individual:, responsible for reviews performed in accordance with Specifica-y h tions 6.5.1A.la and -b, shall be designated by approved written procedures, y4 Each such review shall be performed by qualified personnel of the appio-priate discipline and shall include a determination of whether or not additional, cross-dsciplinary review is necessary. Eac review shall also include determination of whether or not ar. unreviewe fety question is involved pursuant to Section 10 CFR 50.59. Ja 4 6.5.2 NUCLEAR SAFETY REVIE't SOARD (NSRB)

FUNCTION 6.5.2.1 The NSRB shall function to provide for independent review and audit i to assure adequacy of designated activities in the areas of: x50

a. nuclear power plant operations

b. nuclear engineering

c. chemistry and radiochemistry

d. metallurgy

e. instrumentation and control

f. radiological safety

. g. mechanical and electrical engineering

h. quality assurance practices 4

I E COMPOSITION 6.5.2.2 The NSRB shall be composed of at least five members, including the Chairman. Members of the NSRB may be from the Office of Nuclear Power, or other TVA organization or external to TVA. R50 QUALIFICATIONS g jy g p,,,,.g &&,. b 6.5.2.3 The Chairman, memoers, an alternate members of the NSRB shall be appointed in writing by the 44anager Of heleae-Poe and shall have an academic degree in engineering or a physical science field, or the equivaleat; and in _.0 additirn, shall have a minimum of five years technical experience in one or

-more areas given in 6.5.2.1. No reore than two alternates shall participate as voting members in NSRB activities at any one time.

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SEQUOYAH - UNIT 2 6-11 M Nt d d.' R50l

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ADMINISTRATIVE CCNTROLS AUTHM Q Sesslc# Wee AmlAb AN*l" b'"

6.5.2.9 L The NSRB shall rJport to and advise theu cr.cger c' Sc!0r Pcuer orv llg50 those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.

RECORDS

,. 6.5.2.10 Records of NSRB activities shal.1 be prepared, approved and distributed as indicated below:

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a. Minutes of each NSRB meeting shall be prepared, approved and forwarded to the Mar-ager cf %^1ccr "Ouc within 14 days following each meeting. R50 Ju;w vice AmAd oVu Aar hw

b. Reports of reviews encompassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the " r.:ger Of %;100r P; cr within 14 days following comple on f th l R50

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c. AuditreportshncompassedbySection6.5.2.8above,shallbeforwarded to the ,"anager ;; %:!:a- ?caer and to the management positions l R50 re.ponsible for the areas audited within 30 days after completion of the audit.

6.5.3 RADIOLOGICAL SSSESSMENT REVIEW COMMITTEE (RARC)

Function

\ 6.5.3.1 The SQN RARC shall function to advise the Manager of Radiological ]R50 Control and the Plant Manager on all matters related to radiological assess-ments involving dose calculations and projections and environmental iaonitoring.

S Composition j 6.5.3.2 The SQN'RARC shall be composed of the: R50 Chairman: Technical Assistance Section Supervisor Member: Health Physicist, Gaseous, Radiological Control Member: Health Physicist, Liquid, Radiological Control Member: Meteorologist, Air Quality Branch Member: Chemical Engineer, Chemistry Section, SQN Lember: Health Physicist, Environmental Monitoring, Radiological Control R50 l Alternates 6.5.3.3 All alternate members shall be appointed in writing by the SQN RARC lR50 Chairman to serve on a temporary basis; however, no more than two alternates shall participite as voting members in SQN RARC activities at any one time. l R50 .

j Meeting Frequency 1 6.5.3.4 The SQN RARC shall meet at least once per six months or as requested R50 g by the SQN PARC Chairman, his designated alternate, or a plant representative.

I Sep: aher !C, 1997 SEQUOYAH - UNIT 2 6-14 ^ Oncent No. 50-

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ENCLOSURE 2 -

PROPOSED TECHNICAL SPECIFICATION CHANGE l SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-88-12) I

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DESCRIPTION AND' JUSTIFICATION FOR t

DELETION OF ORGANIZATION CHARTS FROM SECTION 6 i

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a ENCLOSURE 2 Description of Change TVA proposes to modify the SQN units 1 and 2 TSs to delete the organization charts (figures 6.2-1 and 6.2-2) from section 6 in accordance with Generic Letter (GL) 88-06. General requirements for the or,,anizational structure are added to section 6.2. Section 6 is also revised to change the title of the Manager of Nuclear Power and to change the references to the unit staff and organization.

Reason for Change The deletion of organization charts from the ISs was originally proposed by the Shearon Harris plant as a lead-plant' technical specification improvement item in a June 12, 1987 letter. NRC issued a safety evaluation report (SER) on January 27, 1988, approving the Shearon Harris proposal. GL 88-06 was issued on March 22, 1988, to provide guidance for follow-on technical specification changes by other plants. This proposed change is submitted following the guidance of GL 88-06.

The deletion of the organization charts from the TSs and the addition of general organization requirements will eliminate the need for a license amendment to implement organization name changes or changes in lines of euthority and responsibility. This will eliminate an unnecessary expenditure of valuable resources by both TVA and NRC to facilitate organization changes.

The title change for the Manager of Nuclear Power is made to reflect a change in corporate management titles. The change makes the title

} consistent to those of similar positions in other large companies.

Also, the references to unit staff and organization in section 6 are changed to facility staff and organization for consistency with other information in section 6.

Justification for Change The deletion of the organization charts (figures 6.2-1 and 6.2-2) and the addition of general organization requirements are administrative in nature. As described in GL 88-06 and the Shearon Harris SER, NRC has determined that much of the detail of the organization charts has little impact on the safe operation of the plant. Several features of the organizational structure that are important to safety are captured in other specifications. As described by GL 88-06, the information that is deleted from TS section 6 iJ currently contained in Final Safety Analysis Report (FSAR) chapter 13.

To facilitate the deletion of the organization charts, GL 88-06 provided guidance for general organization requirements that are to remain in the

~TSs. These general requirements are listed below.

I (1) A requirement that lines of authority, responsibility, and communication shall be established and defi.wd from the highest managrzent levels through intermediate levels to and including all operating organization positions. Those relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of doeurentation.

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O (2) Designation of an executive position that has corporate responsibility for overall plant nuclear safety and authority to take such measures as may be needed to ensure acceptable performance of staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

(3) Designation of a management position in the onsite organization that is responsible for overall unit operation and has control over those onsite activities necessary for safe operation and maintenance of the plant.

l (4) Designation of those positions in the onsite organization that require a senior reactor operator (SRO) or reactor operator (RO) license.

(5) Provisions of sufficient organizational treedom to be independent of operational pressures to those individuals who perform the functions of health physics, quality assurance, and training of the operating staff.

These general requirements are incorporated into section 6.2 of the TS.

The approved Shearon Harris specifications are used as a template for the wording of the general requirements. This eliminates specific position titles from the requirements, thus eliminating the need for a license amendment to change a position name.

The organization charts and descriptions of the FSAR are used to satisfy the requirements of (1) above. This document contains the necessary organizational detail and descriptions. Specifically, section 13.1.3 of the FSAR provides the necessary information to satisfy requirement (2) above. FSAR section 13.1.4.8 similarly satisfies requirement (3) above.

The functions and responsibilities for the onsite positions required to hold a SRO or R0 (see requirement (4)) license are described in FSAR section 13.1.4.8.5. The FSAR is updated annually in accordance with 10 CFR 50.71(e).

The title change for the Manager of Nuclear Power is administrative in nature. The change to Senior Vice President, Nuclear Power, is made so that the position title is consistent with similar position titles in other large companics. There are no changes in lines of authority or responsibility related to this change.

Similarly, the change in references to unit staff and organization is administrative in nature. The change to facility staff and organization is made for consistency with other information in section 6.

In summary, the proposed changes to section 6 described above are j administrative in nature. The changes implement a TS improvement item as

! described in GL 88-06 and provide consistency between various SQN TS sections.

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ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGES SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-88-12)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS E

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ENCLOSURE 3 Page 1 of 1 Significant Hazards Evaluation TVA has evaluated the proposed TS change and determined that it does not represent a significant hazards consideration based on criteria established in 10 CFR 50.92(c). Operation of SQN in accordance with the proposed amendment will not:

1 (1) involve a significant increase in the probability or consequences of an accident previously evaluated. This proposed change is administrative in nature and is intended to eliminate the need for NRC approval of a license amendment before implementation of an organization change. The changes to titles and references are also administrative in nature. The function. specified in section 6 important to the safe operation of SQN have not been altered or deleted. There are no hardware, procedure, personnel, or analysis changes represented by this proposal that adversely affect the probability of occurrence or the consequences of an accident previously evaluated in the safety analysis report.

(2) create the possibility of a new or different kind of accident from any previously analyzed. This proposed change is administrative in nature and is intended to eliminate an unnecessary expenditure of

} resources to facilitate organization changes. The changes to titles and references are also administrative in nature. The functions important to safety will continue to be performed by those individuals who are technically competent to perform these functions; therefore, the potential for the increase of a possibility of an accident or a new or different type of accident is reduccd rather than increased because of having the appropriate personnel designated for these functions.

(3) involve a significant reduction in a margin of safety. Because general organization requirements will be maintained in the TS, removal of the organizational charts represents no reduction in current safety requirements. These changes will simply allow the implementation of changes in the organization structure without obtaining NRC approval. The changes to position titles and group {

references, as an administrative change, will also not reduce the margin of safety.

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