ML20112H036

Application for Amends to Licenses DPR-77 & DPR-79,revising Section 6, Administrative Controls, to Be More Closely Aligned W/Requirements of STSs

ML20112H036
Person / Time
Site:	Sequoyah
Issue date:	06/07/1996
From:	Shell R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20112H039	List: ML20112H036 ML20112H043
References
NUDOCS 9606140219
Download: ML20112H036 (14)

Text

Hl4 Tennessee Vaney Authonty Post of5ce Box 2000. Soccy Daisy Temessee 37379 June 7,1996 TVA-SON TS-95-19 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket No. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SON) - TECHNICAL SPECIFICATION (TS)

CHANGE 95-19, "SECTION 6 - ADMINISTRATIVE CONTROLS DELETIONS" In accordance with 10 CFR 50.90, we are enclosing an amendment to Licenses DPR-77 and 79 to change the TSs of SON Units 1 and 2. The proposed changes revise Section 6, " Administrative Controls," to be more closely aligned with requirements of the standard TSs. Additionally, these changes are consistent with NRC Administrative Letter 95-06," Relocation of Technical Specification Administrative Controls Related to Quality Assurance," in that applicable paragraphs will be relocated to TVA Nuclear Quality Assurance Plan (NOAP).

Enclosure 1 contains the justification for the proposed change and a proposed determination of no significant safety hazards consideration performed pursuant to 10 CFR 50.92. The revised TS changes are identified in the Enclosure 2. The Quality Assurance Plan pages which are revised as a result of this TS and a description are contained in Enclosure 3. Enclosure 4 contains the updated TS pages. This includes a complete set of each unit's Section 6 due to the extent of the revisions.

Typographical errors have also been corrected on the pages provided in Enclosure 4. l TVA requests a 45-day implementation period for this TS change following issuance.

140031 pgo l 9606140219 960607 PDR ADOCK 05000327 P PDR

U. S. Nuclear Regulatory Commission Page 2 June 7,1996 Please direct questions concerning this matter to M. L. Hellums at (423) 751-2695.

Sincerely,

- k, N,

. R. H. Shell Manager SON Site Licensing

'Sworgt and subscri before me

's / - day of hML 1996

$fYYl0 ~~

mad

/

Nota 7/Iublic

]

My Commission Expires O/ /kh Enclosures cc (Enclosures):

Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr. Michael H. Mobley, Director (w/o Enclosures)

Division of Radiological Health 3rd Floor L&C Annex 401 Church Street Nashville, Tennessee 37243-1523 NRC Resident inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 d

Regional Administrator U. S. Nuclear Regulatory Commission

' Region 11.

101 Marietta Street, NW, Suite 2900 '

. Atlanta, Georgia 30323-2711

~ M = .eJ.e M .+t-A J.M aL -,+3F.*h1 , A _a_e. 4 _ 45t- A.a.=h6- - -.e 4 emA e-A 43

• _e b--w= 64 e

i ENCLOSURE 1 JUSTIFICATION FOR THE PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT (SON) UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SON-TS-95-19)

=___1-__..

Qascriotion of the Prooosed Chance TVA proposes to revise the Sequoyah Nuclear Plant (SON) Units 1 and 2 technical specifications (TSs) to eliminate sections of Section 6, " Administrative Controls," by relocating them to the Nuclear Quality Assurance Plan (NOA) (TVA-NOA-PLN89 A).

When approved, the Administrative Section of the TS will be similar to the Improved Standard Technical Specifications (STSs). Requirements for the Plant Operating Review Committee (PORC), Nuclear Safety Review Board (NSRB), Reporting and Audit Requirements, independent Safety Reviews, and Record Keeping are being relocated into the Nuclear Quality Assurance Plan and will be subject to the requirements of 10 CFR 50.54 (a). Other subjects, which have been deleted, are based upon direction provided by the staff to the owners group in a letter dated October 25,1993, which discussed the content of STS, Section 5.0, " Administrative Controls." The staff concluded that a significant number of the sections can be relocated to other licensee documents for which those provisions are adequately controlled by other regulatory requirements. Further details of the changes are as follows:

Eg_q.tiDD Prooosed Chanae Index Deleted Sections 6.2.3, 6.4, 6.5, 6.10, 6.11, and 6.13. and the pages will be renumbered as appropriate.

1.23 TS page 15, the revised specification will delete the definition for the

" Process Control Program."

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.

6.1.3 TS page 6-1 is a new section, which replaces Section 6.5.0 in its f entirety. The revised specification will read: "The President, TVA Nuclear and Chief Nuclear Officer is responsible for the safe operation of all TVA nuclear power plants."  ;

l 6.2.1.a TS page 6-1, the last sentence currently reads:

"These requirements shall be documented in the FSAR and will be (

updated in accordance with 10 CFR 50.71(e)." l The revised specification will change the wording to read: "These requirements shall be documented in the Nuclear Power Organization Topical Report (TVA-NPOD89-A)."

6.2.2.d TS page 6-2, currently reads:

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

The revised specification will delete section 6.2.2.d.

- . _-. . . . ~ . -- - ..

6.2.3 TS page 6 5, The independent Safety Engineering (ISE) requirements will be relocated to the TVA Nuclear Quality Assurance Plan f

6.3 TS page 6-5, currently reads:

"Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions except for the RADCON/ Chemistry Control Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975."

The revised specification will change the wording to read: "Each member of the Facility staff shall meet or exceed the minimum qualification of ANSI N18.1-1971 for a comparable position as specified in the TVA Nuclear Quality Assurance Plan (TVA-NOA-PLN89-A)."

6.4 TS page 6-6, the revised specification will delete Section 6.4.

6.5.0 TS page 6-6, the revised specification will delete this section and will be relocated to a new section (Section 6.1.3).

6.5 thru TS pages 6 3 thru 6-12, the revised specification will delete the Plant 6.5.2.10 Operations Rc <iew Committee, Technical Review and Control, and the Nuclear Safety Review Board sections and will be relocated to the TVA NOAP.

6.8.1.d,.e,g Unit 1 TS page 6-15 and Unit 2 TS page 6-14, the revised specification will delete these sections in their entirety.

6.8.2 &.3 TS page 6-15, the revised specification will delete these sections in their entirety.

6.8.4 TS page 6-15, currently reads:

"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:

"The following programs shall be established, implemented, and maintained."

6.8.4.b TS page 6-16, the revised specification will delete this section in its entirety.

6.8.4.g TS pages 6-18 and 6-19, the revised specification will delete this section in its entirety.

6. 9.1.1, . 2, . 3 TS page 6-19, the revised specification will delete these sections in their entirety.

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.

6.11 TS Unit 1 page 6-14 and Unit 2 page 6-25, the revised specification will delete this section in its entirety.

6.13 TS Unit 1 page 6-25 and Unit 2 page 6-26, the revised specification will delete this section in its entirety.

6.14.1 TS Unit 1 page 6-25 and Unit 2 page 6-26, currently reads:

"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 SON PORC."

The revised specification will change the wording to read:

"1. Shall be documented and records of reviews performed shall be a 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-NOA-PLN89-A."

6.15.1. TS Unit 1 page 6-26 and Unit 2 page 6-27, currently reads:

"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. Shall become effective upon review and acceptance in accordance with Section 6.5.1. A.

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-NOA-PLN89-A. The discussion of each change shall contain:"

"2. Shall become effective upon review and acceptance in accordance with TVA-NOA-PLN89-A."

The word " Deleted" has been added to appropriate sections to preserve the section numbering.

Reason for the Proposed Chanae in general, administrative controls are those requirements not covered by other TSs, but are necessary to assure operation of the facility in a safe manner. However, some of the Section 6 administrative requirements are broad descriptions of regulatory requirements, which are covered in more detail by other regulatory controls which

include the Nuclear Quality Assurance Plan (TVA-NOA-PLN89-A), Final Safety Analysis Report (FSAR),10 CFR 50.59,10 CFR 50.54, and applicable licensee controlled documents. These documents are used to ensure control of the removed provisions. Thus, the proposed TS change will reduce the need for future amendments, allow for adequate NRC control through other regulatory channels, and provide for consistent administration of these requirements at the TVA nuclear sites.

Justification for the Prooosed Chanae A number of provisions in Section 6 have been identified, which are adequately controlled by other regulatory requirements. The relocation of these provisions does not diminish the effectiveness of ~ enforcement of the relocated provisions. The NOA plan (TVA-NOA-PLN89 A), FSAR, Generic Letter (GL) 93-07,10 CFR 50.59, 10 CFR 50.54, and applicable licensee controlled documents are used to ensure change control of the removed provisions. Additionally, these changes are consistent with NRC Administrative Letter 95-06," Relocation of Technical Specification Administrative Controls Related To Quality Assurance." The following is a retention and relocation summary and further justification for each proposed Section 6 TS change.

RETENTION AND RELOCATION

SUMMARY

OLD NEW 6.1 Responsibility Same 6.1.1 Plant Manager Same 6.1.2 SOS Delete the Annual Management Directive (See C.1)

N/A 6.1.3 (Moved Section 6.5.0 to This Location, See C.2) 6.2 Organization Same 6.2.1 Offsite Organization Same (Clarification to Section 6.2.1.a) 6.2.2.a Shift Crew Composition Same 6.2.2.b Licensed Operator in Control Same Room 6.2.2.c Radcon Technician Same 6.2.2.d Core Alterations (See C.3) 6.2.2.f OPS Supt. SRO Same 6.2.2.g Working Hours Same Table 6.21 Minimum Shift Composition Same z_ -

6.2.3 ISE TVA-NOA-PLN89-A (C.5) 6.2.4 STA Same 6.3 Facility Staff Qualifications TVA NOA-PLN89-A 6.4 Training (See C.4) 6.5 Review and Audit TVA NOA-PLN89-A (See C.5)

(Moved 6.5.0 to Section 6.1.3 Responsibility) 6.5.1 PORC TVA-NOA-PLN89-A(See C.5, item 1) ,

6.5.1 A Technical Review and Control TVA-NOA-PLN89-A (See C.8) 6.5.2 NSRB TVA-NOA-PLN89-A (See C.5, item 2) 6.5.2.8 Audits TVA-NOA-PLN89-A (See C.5, item 3) 6.6 Reportable Event Action Same 6.7 Safety Limit Violation Same 6.8 Procedures and Programs Same 6.8.1.a Same 6.8.1.b Same 6.8.1.c Same  ;

j 6.8.1.d Physical Security Plan (See C.6) 6.8.1.e REP (See C.6) 6.8.1.g Process Control Program (See C.7) 6.8.1.h Effluent and Env. Monitoring Same 6.8.1.i ODCM Same 6.8.2, 6.8.3.a, b, c SSP 2.03, SSP 2.04, Master Site Procedure List, TVA-NOA-PLN89-A, (C.8) 6.8.4 Same (Clarification Provided) 6.8.4.a Primary Coolant Sources Outside Same Containment 6.8.4.b In-Plant Rad Monitoring (See C.9) 6.8.4.c Secondary Water Chemistry Same 6.8.4.e PASS Same l 6.9.4.f Rad Effluent Controls Program Same

6-6.8.4.g Rad Env. Monitoring Program (See C.10) 6.9.1 Routine Reports Same

6. 9.1.1, . 2, . 3 Start-up Reports (See C.11) 6.9.1.4, .5 Annual Reports Same 6.9.1.6 Annual Rad Env Operating Same Report 6.9.1.8 Annual Rad Effluent Release Same Report 6.9.1.10 Monthly Reactor Operating Same Report 6.9.1.14 COLR Same 6.9.2.1 Special reports Same 6.9.2.2 D/G Reliability Improvement Same Program 6.10 Record Retention TVA-NOA-PLN89-A (See C.12) __

6.11 Radiation Protection Program (See C.13) 6.12 High Radiation Area Same 6.13 Process Control Program (See C.7) 6.14 ODCM Same (Clarification to Section 6.14.1.2) 6.15 Major Changes to Radwaste Same (Clarification to Section 6.15.1.1 Treatment System &.2) (

C.1 - 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. I Repeating the organization responsibilities via an internal management directive only increases the administrative burden on the facility with no resulting benefit.

C.2 - Section 6.5.0 was moved to this location for consolidation of functions.

1 C.3 - The requirements for a senior reactor operator (SRO) to be present during fuel I handling and to supervise all core alterations should not be retained in the TS.

Duplication 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."

C.4 - The requirements on training may be deleted from the TS on the basis that they are adequately addressed by other Section 6 administrative controls, as well as by regulations. TS Section 6.3, " Facility Staff Qualifications," provides adequate requirements to assure an acceptable, competent operating staff. Each member of the f acility staff shall meet or exceed the minimum qualifications of specific regulatory guides or ANSI standards acceptable to NRC As described in TVA-NPOD89 A, the training program is maintained and under the direction of the Plant Manager.

In addition,10 CFR 50.54 describes the minimum shift crew composition and delineates which positions require an reactor operator (RO) or SRO. Training and requalifications of those positions are as specified in 10 CFR 55. Based upon these considerations, duplicating the provisions relating to training in Section 6.4 of the TS is not necessary to assure safe operation of the facility.

C.5 - The review and audit functions may be relocated from the TS on the basis that they can be adequately addressed elsewhere. The TS provisions are not necessary to assure safe operation of the f acility, given the requirements in the Quality Assurance (OA) Program implementing 10 CFR 50.54 and 10 CFR Part 50, Appendix B to control the requirements for all review and audit functions. The following points summarize the reasons for removing the review and audit requirements from the TS.

1. The onsite review function, composition, alternate membership, meeting frequency, quorum, responsibilities, authority and records are all covered in equivalent detailin ANSI N18.7-1976. These requirements are also proposed to be covered in the OA Program. Equivalent change controlis provided by 10 CFR 50.54(a).

2. The offsite review group is also addressed, although with less detail, in ANSI N18.7-1976. The OA Program willinclude the requirements for the offsite review group. Their organization is not necessary to assure safe operation of the facility. Relocation of the requirements from the TS to another document with equivalent change controlis appropriate.

3. Audit requirements are specified in the OA Program to satisfy 10 CFR 50, Appendix B, Criterion XVlli and will be included in the TVA NOAP. Audits are also covered by ANSI N18.7, ANSI N45.2,10 CFR 50.54(t), and 10 CFR 50.54(p). Duplication of the requirements contained in the above documents by the Administrative Controls section of the TS does not enhance the level of nuclear safety for the plant. Therefore, the provisions relating to audits are not necessary to assure safe operation of the f acility.

4. The independent Safety Engineering requirements are being placed in the TVA NOAP in accordance with the STS technical review requirements. This is consistent with the Watts Bar Nuclear Plant TSs and the TVA NOAP revision approved by NRC.

C.6 - The Security and Emergency Plan Program requirements are relocated to their respective plans in accordance with GL 93-07. Further changes in these 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. The extensive requirements for emergency planning in 10 CFR 50.47 and 50.54 and for security in 1

8-10 CFR 50.54 and 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 while providing for a more appropriate change control process. The net effect of the change is that the level of safety of plant operation is unaffected and NRC and facility resources associated with processing licenso amendments to this administrative control are optimized.

C.7 - The Process Control Program and appropriate plant procedures implement the requirements of 10 CFR Parts 20,61, and 71. These regulatory controls provide sufficient control of this requirement and removing these provisions from the TS is acceptable.

C.8 - The review and approval process and the temporary change process for procedures are adequately addressed in TVA-NOA-PLN89-A and SON plant procedures. This proposalis based on the existence of the following requirements which duplicate 10 CFR 50.36 in these areas.

The requirements for procedure controlis mandated by 10 CFR 50, Appendix B, Criterion 11 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 requirements 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 requires 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 requirements 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.

C.9 - The In-Plant Radiation Monitoring Program provides controls to ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program was developed to minimize radiation exposure to plant personnel (postaccident). 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 basis accident. Therefore, this program has been relocated to a number of different plant procedures. 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 the chemistry and radiation protection procedures. The provisions do not satisfy the policy statement guidance for inclusion in TSs.

Therefore, the control of these provisions under 10 CFR 50.59 is acceptable.

l

s 1 .

i

. 9-1 I This proposal is consistent with the guidance provided in the NRC letter dated October 25,1993.-

1 C.10 - The Radiological Environmental Monitoring Program requires that procedures be l 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 j procedures are developed to ensure that radioactive effluents are restricted to levels 1 ~ as low as reasonably achievable, and have no impact on plant nuclear safety. The

' details and description of the program are already contained in the Offsite Dose j - Calculation Manual, as specified by existing TS 6.8.1.i. These regulatory requirements provide sufficient control of these provisions and removing them from the TS is acceptable.

]

This proposal is consistent with the guidance provided in the NRC letter dated October 25,1993.

l C.11 - The requirement to submit a start-up report has been deleted from the improved TSs. The report was a summary of plant start-up and power escalation testing following: receipt of the Operating License, an increase in licensed power i level, the installation of nuclear fuel with a different design or manufacturer than the 1 current fuel, and modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. The report provided a mechanism for l the staff to review the appropriateness of licensee activities after-the-fact, but j

!. contained no requirements for staff approval. The approved 10 CFR, Appendix B, QA )

Plan and Start-up Testing Program (Chapter 14 of the Updated Final Safety Analysis Report) provide assurance that the listed activities are adequately performed.

l - Since this report was required to be provided to staff within 90 days following I completion of the respective milestone,it was clearly not necessary to assure  ;

[ operation of the facility in a safe manner for the interval between completion of the i start-up testing and submittal of the report. Additionally, because there was no j requirement for the staff to approve the report, the start-up report is not necessary to

!_ assure operation of the facility in a safe manner. Therefore, the removal of this requirement is considered acceptable.

C.12 - The requirements on record retention is being relocated from the TS on the

basis that they will be adequately addressed by the OA Program (10 CFR Part 50, i Appendix B, Criterion XVll) and the related QA Plan.

L ,

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 c

- radiation control. Facility records document appropriate station operation and activities. Retention of these records provides documentation and capability of being L - retrieved 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. 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, t Therefore, it can be concluded that these regulatory requirements provide sufficient t

g -m-=w2--+-r s - -

-, ,.--.x-

control of these record keeping provisions and removing them from.the TS is acceptable.

4 C.13 The Radiation Protection Program requires procedures to be prepared for personnel radiation protection consistent with the requirements of 10 CFR Part 20.

The requirements to have procedures to implement Part 20 is also contained within l

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.

4 These provisions do not satisfy the policy statement guidance for inclusion 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.

1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of SON Units 1 and 2 in accordance with the proposed changes to the TS does not involve a significant hazards consideration.

TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91 (a)(1),

of the three standards set forth in 10 CFR 50.92 (C).

A. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated. l The proposed TS change is administrative. TVA has evaluated the proposed TS changes and has determined that the proposed changes are administrative in nature. Certain sections are being relocated into other licensee documents for which those provisions are adequately controlled by regulatory requirements.

These changes do not affect any of the design basis accidents. They do not involve an increase in the probability or consequences of an accident previously evaluated.

B. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed TS change is administrative. TVA has evaluated the proposed TS changes and has determined that the proposed changes are administrative in nature. Certain sections are being relocated into other licensee documents for which those provisions are adequately controlled by regulatory requirements.

These changes do not affect any of the design-basis accidents. No modifications to any plant equipment are involved. There are no effects on system interactions j made by these changes. They do not create the possibility of a new or different kind of accident from an accident previously evaluated.

. - -- _ _-_ - = -

_11 C. The proposed amendment does not involve a significant reduction in a margin of safety.

The proposed TS change is administrative. TVA has evaluated the proposed TS changes and has determined that the proposed changes are administrative in nature. Certain sections are being relocated into other licensee documents for which those provisions are adequately controlled by regulatory requirements. The margin of safety as reported in the basis for the TSs is not reduced. The proposed change is administrative and does not impact any technical information contained in the bases of the TS.

Environmental imoact Consideration The proposed changes does not involve a significant hazards consideration, a 4

significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or a significant increase in the individual or cumulative occupational radiation exposure. The proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed changes is not required.

4 1

?

i a

4 1

9 4

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _