ML20065S334

Proposed Tech Specs Re Overtime Limit Requirements in Generic Ltr 82-16

ML20065S334
Person / Time
Site:	Sequoyah
Issue date:	12/14/1990
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20065S332	List: ML20065S329 ML20065S334
References
GL-82-16, NUDOCS 9012200213
Download: ML20065S334 (31)

Text

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4 ENCLOSURE 1 PROPOSED TECIINICAL SPECIFICATION CIIANGE SEQUOYAll NUCLEAR PLANT UNITS- 1 MD 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-90-22)

LIST OF AFFECTED PAGES Unit 1 6-1 6-2 6-5 66 6-8 6-9 6-12 6-13 6-14 6-21 6-24 Unit 2 6-1 6-2 0-5 '

6-6 6-8 6-9 6-12 6-13 6-14 6-22 6-25 j ,

P

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

. 6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Plant Manager shall be responsible for overall unit operation R62 and shall d egate in writing the succession to this responsibility during his absence w pe.r.d e 6,1.2 The4 Manager of Radiological Control shall be responsible for imple-menting ie cad %g cal environmental program and dose calculations and R62 projections as described in the Offsite Dose Calculation Manual (ODCM).

6.1.3 The Shift Supervisor (or during his absence from the Control Room a designated function. A management individual) shall to directive bethisresponsible effect, signedfor by the theSitControl 04+eete Room

, com shall be reissued to all station personnel on an annual basis. R&

, a pgd

6. 2 ORGANIZATION w%

6.2.1 0FFSITE AND ONSITE ORGANIZATIONS 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 -

R73 intermediate levels to and including all operating organization- i positions. These relationships shall be documented and updated, as appropriate, in the form of organizational charts, 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 accordan , with 10 CFR 50.71(e),

b. The Senior Vice President, Nuclear Fower shall have 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. The Plant Manager shall be responsible for overall unit' safe operation and shall have control over those onsite 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 suf ficient organizational freedom to ensure their independence from operating pressures.

6.2.2 FACILITY STAFF

a. Each on-duty unit shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

b. AtleastonelicensedReactorOperatorshallbeintheunitControi R78l Room when fuel is in 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.

SEQUOYAH - UNIT 1 6-1 Amendment No. 32, II N

. June 30, 1988

. j ADMINISTRATIVE CONTROLS 4

c. A Radiological Control technician # shall be onsite when fuel is in the R62 reactor,

d. All CORE ALTERATIONS shall be observed and direq)y supervised by either a licensed Senior Reactor Operator or Senlo. Reactor Operator FP Limited to Fuel Handling who has no other concurrent responsibilities during this operation, i

e. AFireBrigadeofatleast5membersshallbemaintainedonsiteat all times. The Fire Brigade shall not include the Shift Supervisor l

and 2 other members of the minimum shift crew necessary for safe R62 shutdown of the unit or any personnel required for other essential functions duripg-p fichemergency.

ssperintendco t

f. The Operatio sAH anager shall old a Senior Reactor Operator license. >

wem R78 g, A dd InseM A . ,

4 1

1. The Radiological 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 accommoe te unexpected absence provided immediate action is taken to-fill the requiret positions.

SEQUOYAH *

- UNIT 1 6-2 Amendment No. 32, SN74 June 30, 1988

' ^

INSERT A Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions (i.e.,

senior reactor operators, reactor operators, assistant unit operators, Radiological Control, and key maintenance personnel).

Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a normal 8-hour day. 40-hour week while the unit is operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance, or major plant modification, on a temporary basis the following guidelines shall be followed

1. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time.

2. An individual should no/ be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor . sore than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time.

3. A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods, including shift turnover time.

4 Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

Any deviation from the above guidelines shall be authorized by the Plant Manager (or Duty P! ant Manager), or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation. Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Plant Manager or his designee to assure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.

e 4 .

ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAF_ETY ENGINEERING (ISE) R123 FUNCTION 6.2.3.1 The ISE shall function to examine plant operating characteristics, R123 NRC issuances, industry advisories, Licensee Event Reports and other sources which may indicate areas for improving plant safety.

COMPOSITION ,

6.2.3.2 The ISE shall be composed of at least 3 dedicated full-time engineers located onsite. These engineers will be supplemented as necessary by full-time R123 engineers shared among all TVA nuclear sites to achieve an equivalent staffing of 5 full-time engineers performing the ISE functions applicable to Sequoyah.

RESPONSIBILITIES 6.2.3.3 The ISE shall be responsible for maintaining surveillance of plant activities to provide indepencent verification

• that these activities are lR123 performed correctly and that human errors are reduced as much as practical.

AUTHORITY 6.2.3.4 The ISE shall make d1 tailed recommendations for revised procedures, equipment modifications, or 6ther means of improving plant safety to the f123 Manager of Nuclear Managers Review Group.

p123 6.2.4 SHIFT TECHNICAL ArdISOR (STA) Y%hm 6.2.4.1 The STA shall serve in an advisory capacityShif +

to th 4M+ +0aperdsw unentserd R16

}

on niatters pertaining to the engineering aspects of assuring s hi% ) N ot the unit.

6.3 FACILITY STAFF OUALIFICATIONS R78 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifi-cations of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in Section A and C of Enclosure 1 of the March,p 40 MR&iett to all licensees, except for the Site Radiological Contro wc, , R62 n hall meet or exceed the qualifications of Regulatory G . ,

• Not responsible for sign-off function.

SEQUOYAH - UNIT 1 6-5 Amendment No. 12, 58, 74, 119 July 5, 1989 l

T ADMINISTRATIVE CONTROLS 6.4 TRAINING 6.4.1 A retraining and replacement training rog m fog e fa f shall be maintained under the direction of ede M E4Mendw4 nd R78 shall meet or exceed the requirements and rehamendatioWofdectis&5rS f ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55 and the supplemental requirements specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees,.and shall include familiarization with relevant W industry operational experience.

6.5 REVIEW AND AUDIT

6. 5. 0 The Senior Vice President, Nuclear Power is responsible for the safe R78 operation of all TVA power plants.

6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The PORC shall function to advise the Plant Manager on all matters K62 related to nuclear safety.

COMPOSITION 6.5.1.2 3 p gRC 4 a2 p y g Chairman: P1 ant Manager 14 ember: Oper4Wnt-Gttperifttendent- D_;)

Member: Operations Manager iR76 Member: Site Radiological Control -SttpenntendentManager I Member: Maintenance 6ttperintendent Marw3er

( Member: Technical Support Stiperintendent Mormger , ,

Member: Quality Engineering 14anagar- and Mon,ereng Svpervisc , 73 Member: -tWhien-of Nuclear Engineering Representative A % t w v\./% K , y y 3er,qx,w&

R78 SEQUOYAH - UNIT 1 6-6 Amendment No. 58, 74 June 30, 1988

. AD'MINISTRATIVE CONTROLS

7. Performance of special reviews, investigations or analy.ses and *

^)

reports thereon as requested by the Plant Manager or the Nuclear /

Safety Review Board,

i. Review of every unplanned onsite release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendations a of the corrective action to prevent recurrence to the S Lo the Nuclear Safety Review Board. Ye....terac htuccurq AUTHORITY 6.5.1.7 The PORC shall: .

a. Recommend in writing to the Plant Manager approval or disapproval of items considered under 6.5.1.6(a), (b) and (c) above.

R62

b. Require a determination in writing with regard to whether or not each item considered under 6.5.1.6(b), (c), and (e) above constitutes an "

unreviewed safety question. '

c. Y Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the S te _jyj;;hesioEM* .

and the Nuclear Safety Review Board of disagreement be ween e RC and the Plant Manager; however, the Plant Manager shall have responsi-  !

bility for resolution of such disagreements pursuant to 6.1.1 above.

RECORDS >

srm -

6.5.1.8 The PORC shall maintain written minutes of each PORC meeting that, at +

a minimum, document the results of all PORC activities performed under the responsibility and authority provis of these technical specifications.

% t:r Copies Board. shall be provided to the Si eji IRtMDcwr the Nuclear Safety Review VKE , i 6.5.1A TECHNICAL REVIEW AND CONTR0t ACTIVITIES R62 6'. 5.1 A.1.-- Activities which affect nuclear safety shall be conducted as follows:

a. -Procedures required'by Specification 6.8.1 and other procedures-

-which affeet plant nuclear safety, and changes thereto, shall be prepared, reviewed and approved. Each such procedure or procedure change shall be reviewed by a qualified individual other than the individual who prepared the procedure or procedure change, but who j may be from the same organization as the individual who prepared the '

. procedure or procedure change. Procedures shall be approved by the appropriate respJo 11hlaajna

,, ManagGPlant Manager,gsp-es-des Op;r:ti:n: 4gpteddTrwitip tha -D

.up:rtit:nd:nt. aint::::::

49et+*ttadent. Technicel Suppe t. Lperintendent, ;r Sit: hdi:- OA Duty 78 Nhe.te,10^ t t:1 C ntrol p rint:nd:ne shall approve designated Administra-tive Proceo _A -

SEQUOYAH - UNIT 1 6-8 xi6 Amendment No. /96 74 Jiine 30,1988

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_ADMlHISTRATIVE CONTROLS (Continued) b.

vv-Weekpl v > v 4

Jroposed changes or ons to structures, systems, and components that affect plant nuclear safety .

L shall be reviewed by a qualified individual / group other than the i

L individual / group which designed the modification, but who may be from the same ot,,anization as the individual / group which designed R62 the modifications. . Proposed modifications to structures, systems, and components that affect plant naclear safety :nd th: 'g k unting a:riphn: shall be approved prior to implementation by the Plant Manager, Spee&t4ene--Supet4ntendenty-Meintenence-Super 4*tendent&

-Technical bp;crt 5 p:rht:nd:nt2 0s S=Ae# DuTyvlh AC,c1t.. R78 't A > m Panv-

c. Individuals responsible fo'r reviews performed in accordance with Specifications 6.5.1A.la and -b, shall be designated by approved written procedures. Each such review shall be performed by qualified perronnel of the appropriate discipline and shall include R6 a determination of whether or not additional, cross-disciplinary review is necessary. Each such review s5all also include determina-g73l tion of whether or not an unreviewed safety question is involved ,

pursuant to Section 10 CFR 50.59._.

6.5.2 NUCLEAR SAFETY REVIEW BOARD (NSRB) ,

FUNCTION ,

' 67 . 6. 5. 2.1 The NSRB shall function to provide for ind6 pendent review and audit to assure adequacy of designated activities in the areas of: 462

a. nuclear power plant operations

b. nuclear' engineering i

c. chemistry and radiochemistry *

(

d. metallurgy .

c. '

instrumentation and control f.. -radiological safety '

g.= mechanica' and electrict.1 engineering _ i

h. quality assurance practices ,

COMPOSITION 3

6.5.2.2 The NSRB shall be composed of at east- bersrincluding the p.p Chairman. Members'of the NSRB may be fro A; 0,,,cc Nuclear Power, or

'other TVA organization or external to TVA, -

a q

3 SEQUOYAH - UNil 1 6-9 Amendment No. EI8 74 R78 June 30, 1988 0

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j.  :

• ADMINISTRATIVE CONTROLS

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

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

1

m. The PROCESS CONTROL PROGRAM and implementing procedures for SOLIO!FICATION of radioactive wastes at least once per 24 months.

n. The performance of. activities te ' *ed by the Quality Assurance ,

Program.to meetithe: criteria of i mlatory Guide.4.15, December 1977 R46 or Regulatory Guide 1.21,'Rev. 1, 1974 and Regulatory Guide'4.1, i

Rev. 1,-1975,_at least once per 12 months. j AUTHORITY 6.5.2.9 The NSRB shall report to and advise the Senior Vice President, Nuclear .R78

- Power 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 shall be prepared, approved'and distributed

)

q-as indicated below:-

a. Minutes of each NSRB meeting shall be prepared, approved and forwarded to the Senior Vice President, Nuclear Power within 14 days following R78 I.

each meeting.~ f

b. Reports of: reviews encompassed by Section 6.5.2.7 above, shall be i prepared, approved and forwarded to the Senior Vice President,  ;

Nuclear Power within 14 days following completion of the review. R76

c. Audit' reports encompassed by Section 6.5,2.8_above. sha.11 be' forwarded to the Senior.Vice President, Nuclear Power and to the management R7p ; ~

positions responsible for the areas; audited within 30 days after com- --

pletion of the audit. ,

6.5;3' RA010l0GICAL ASSESSMENT REVIEW COMMITTEE (RARC)

Function _ .

. eomnca e--- l 6.5.3.1 The SQN RARC shall function-to advise' th adiological-Con-trolandthePlantManageronall'mattersrelabeAManaerof R62-t4.ca~ cal assessments.

involving dose calculations and projections and environmental _ monitoring.

Composi ti'on 6.5.3.2 The SQN RARC'shall be composed of the: j Chai'rman: Technical Assistance Section Supervisor R62 Member: Health Physicist,--Gaseous, Radiological Control

- M3mber: Health Physicist, Liquid, Radiological Control .j SEQUOYAH -_ UNIT 1 6-12 gdgntg st2, 5,B/ 74 .R70, 1

ADMINISTRATIVE CONTROLS Member: Meteorologist, Air Quality Branch R62 Member: Chemical Engineer, Chemistry Section, SQN Member: Health Physicist, Environmental Monitoring, Radiological Control A_lternates 6.5.3.3 All alternate members shall be appointed in writing by the SQN RARC R62 Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in SQN RARC activities at any one time. R62 Meeting Frequency 6.5.3.4 The SQN RARC shall meet at least once per six months or as requested R62 by the SQN RARC Chairman, his designated alternate, or a plant representative.

.9P.ET.um 6.5.3.5 The minimum quorum of the SQN RARC necessary for the performance of the SQN RARC responsibility and authority provisions of these technical specifica- h62 tions shall consist of the Chairman or his designated alternate and 4 members ,

(including alternates) as long as one is a plant representative.

Responsibilities R62 6.5.3.6 The SQN RARC shall be responsible for: ,

a. Review of changes to the OFFflTE DOSE CALCULATION' MANUAL.

b. Review of procedures required by Specification 6.8.4 and changes R62 thereto.-

c. Review for information purposes - .e. *s of any audits, reviews, or evaluations of the Quality Assurance Program for effluent R62 and environmental monitoring and radiological assessments involving dose evaluations and projections. '

d. Review of proposed changes to the Technical Specifications related to radiological assessments involving dose calculations and projections R62 and environmental radiological monitoring.  ;

Authority 62 6.5.3.7 The SQN RARC shall:

a.

[ cer P" C-Recommend-in writing ty theAManager of R,diological Control and the R62 Plant Manager, approvaQ(ipppf6saVof items considered under 6.5.3.6 above,

b. Render determinations in writing with regard to whether or not each item considered under 6.5.3.6 constitutes an unreviewed safety question.

SEQUOYAH - UNIT 1 6*13 AmendmentNo./)p74 R76 June 30, 1988

l.  ;

j

, 4. . . l /. -

i

.o ADMINISTRATIVE CONTROLS  ;

I c. Provide written notification within yMtqhe Senior Vice ll PresidentgA6chrRr ower and the N l ept,.54f RhiewBoardofdis. R78 agreemen however beggg$e)r heTMana$f Radiologi SQN RARC N

} Cogtrol sh e

and theA ana5[gt ffadiol  !

. for res tion ch disagreemen 5ursuRDt%'g.D have- responsibility 6.1.2 above.

Re_ cords I I 6.5.3.8 The SQN RARC shall maintain written minutes of each SQN RARC meeting that at Rt a minimum, document the results of all SQN RARC activities performed under the responsibility and. authority provisions of these technical specifications.

_ Copies shall be provided to the Senior Vice President, Nuclear lower; PORC; and R7Bl t

the Nuclear Safety Retiew Coard.

, 6. 6 REPORTABLE _ EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVEN'S. I 4 " R4C 4

a. The Commission shall- be notified and a report submittid 5'Jrsuant

• to the requirements of Section 50.73 to 10 CFR Part 50, atd ,

b. Each REPORTABLE EVENT shall be reviewed by the PORC and h%

of this review shall be submitted to-the NSRB and the. ite fFneter. 3\[.

~

6.7 $AFETY LIMIT VIOLATION W

• 6.7.1 The following actions shall be taken in the ' event a Safety Limit is violated:

a. .The unit shall be placed in at least HOT' STANDBY within one hour.-

b. :The NRC Operations Center shall'be notified by.t ,

possible and in all cases within one. hour. The' ite Oiyecter and-the i NSRB shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.- Yv 'ict PecWde.nt R6:

c. A Safety Limit Violation Report = shall be prepared. The report shall W f

,. be reviewed by-the PORC.. This report shall describe (1) applicable circumstances precedh; the vim ation, (2) effects of the violation

.upon facility components, systems or structures, and (3) corrective E

action taken to prevent recurrence. ,

d. The Safety Limit Vip ati n Report al be submitted to the Commission, .

R6.

theNSRBandthe.Sfte0ir:ctorwithin y ' days of the' violation..

Vice President p 6.8' PROCEDURES & PROGRAMS; 6.8.1.. Written procedures shall:be established, implemented and maintained covering the ' activities referenced below: '

a, 'The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

-SEQUOYAH._- UNIT 1 6-14 Amendment No, JE//ES/ 74 R78 June 30, 1988 r . , ,. . _,n. _......____._,.u.___.u__...._-_..._ . _ _ _ _ _ _ _ . _ -

I

. ADM)NISTRATIVECONTROLS i

! MONTHLY REACTOR OPERATING REPORT l 6.9.1.10 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the PORVs or Safety Valves, shall R76 r

be submitted on a monthly basis no later than the 15th of each month following Y [

. Any ch:nge; to the OFFSHE 005E CAtttttAt!0M-MANttAt- thall b; cbdtted with the r

-Menthly Operating Reper i. within @ days in which the chen;e(s) was made effec h  !

h :ddition, traport of any-majee-chcages te th; radioact49eanash-t ::'=nte. t 6yst :: chal1 be TutiTnRTethdth-the M0ntMy Operating hpcrt- fethe peried in -  !

which the whtet4en. e. revia.;d and =cepted by4he PORO.

. RADIAL- EAKI

- 6.9.1.14 The W(z) function for normal operation shall be provided at least 60 days prior to cycle initial criticality. In the event that these values R76 would be submitted at some other time during core life, it will be submitted

-60 days prior to the date the values would become effective unless otherwise ,

exempted by the Commission.

Any information needed.to suport W(z) will be by request from the NRC and need not be included in this report. '

SPECIAL REPORTS -

t

' 6. 9. 2.1 : 15pecial reports shalifbe ' submitted within the time period specified a76 '

for each report =,.in accordance with 10 CFR 50.4.

6.9.2.2 Diesel Generator' Reliability Improvement Program I As a minimum-the Reliability _ Improvement Program report for NRC audit, required l by_LCO 3.8.1.1, Table 4.8-1, shall-include: RS6 i

(a) a summary of all: tests (valid'and! invalid) that.occarred within the l time period over which.the.last 20/100 valid tests were performed ,j

-(b) 1 analysis of-failures and determination of root causes of failures' (c) : evaluation of each of the recommendations of NUREG/CR-0660, " Enhancement of 0nsite Emergency Diesel Generator Reliability in Operating Reactors,"

with respect to their application-to-the Plant I (d) identification of all actions taken or to be taken to 1) correct the root causes of. failures defined in b) above and 2) achieve a-general ..

-improvement of diesel generator ieliability

-(e) the schedule-fo'r implementation of each action'from d) above (f) an assessment of the existing reliability of electric power to engineered-

[ safety-feature equipment i-R121 SEQUOYAH - UNIT 1 6-21 Amendment Nos. 52,58,72,74,117 l June 19, 1989

_ .-__.u.. _ _ u._ _ ._ . _ _ _ . _ . __ _2._ _ _ _ _ _ . _ , _ . , _ - . _ . . , - .

2, -

4

. ADMINISTRATIVE CONTROLS 6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA

-)

6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be control' led by requiring issuance of a Special (Radiation)

Work Permit *. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area,

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them,

c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over the activitics within the area and shall perform control over the activities within the area and shall perform periodic radiation surveillance at he

,requens s cified by the facility Site Radiological Control M m e cR.

4gewtends - in the Special (Radiation) Work Permit.

v 6.12.2 The requirements of 6.12.1, above, shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr.

In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative egl rvisor on duty and/or the Site Radiological Control I

• Radiological Control personnel or personnel escorted by Radiological Control personnel in accordance with approved emergency procedures, shall be exempt from the SWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation  !

protection procedures for entry into high radiation areas. )

i SEQUOYAH - UNIT 1 6-24 Amendment No. 42, 58, 74, 148 i l

) e 6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Plant Manager shall be responsible for overall unit operation and R50 shall delegatednprip g the succession to this responsibility during his absenceq/ { g 6.1.2[The^ManagerofRadiologicalControlshallberesponsibleforimplement-R50 ing t e r4diRogjQlimfironmental program and dose calculations and projec-tions s descrTbed in the Of fsite Oose Calculation Manual (00CM).

6.1.3 The Shif t Supervisor (or during his absence from the Control Room,. a h .

oGe'ndYunc designated individual) shall to bethis responsible forby the theControl Room}A4*c, tee sha tion. A management directive ef fect, signed Si e be reissued to all station personnel on an annual basis. Wce, Preddent - fR50 j

6. 2 ORGANIZATION k.A V 6.2.1 0FFSITE AND ONSITE ORGANIZATIONS 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. R66

a. Lines of authority, responsibility, and communication shall be '

established and defined from the highest management levels through ,

intermediate levels to atd including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organizational charts, 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. The Senior Vice President, Nuclear Power shall have 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. The Plant Manager shall be responsible for overall unit' safe operation, and shall have control over those onsite resources ,

necessary for safe operaticn and maintenance of ?.he 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.

6.2.2 FACILITY STAFF

a. Each on duty unit shift shall be composed of at least the minimum ,

shift crew composition shown in Table 6.2-1.

b. At least one licensed Reactor Operator shall be in the unit Control l Room when fuel is in 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.

SEQUOYAH - UNIT 2 6-1 Amendment No. 24, 40 66 June 30, 1988

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

. ADMINISTRATIVE CONTROLS

c. A Radiological Control technician # shall be onsite when fuel is in the reactor, R$0

d. All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator 8.imited to Fuel Handling who has no other concurrent responsibilities during this operation,

e. AFireBrjgadeofatleast5membersshallbemaintainedonsiteat all times . The Fire Brigade shall not include the Shif t Supervisor s ,

and.the 2 other members of the minimum shift crew necessary for safe shutdown of the unit'or any personnel required for other essential functions during a fire emergency.

f.

W' The Operati ns-Manager shal f

h T~d a Senior Reactor Operator license. R66

g. Add in s er + A. g ,

l e

1. ihe Radiological Control technician and fire brigade composition may be less R50 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 fill the required positions.

SEQUOYAH - UNIT 2 6-2 Amendment No. ![6 66 June 30, 1988

• INSERT A s .

Adnanistrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safecy-related functions (i.e.,

senior reactor operators, reactor operators, assistant unit operators, Radiological Control, and key maintenance personnel).

Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a normal 8-hour day, 40-hour >;eek while the unit is operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance, or major plant modification, on a temporary basis the following guidelines shall be followed:

1. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time.

2. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time.

3. A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods, including shift turnover time.

4. Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift. '

Any deviation from the above guidelines shall be authorized by the Plant Manager (or Duty Plant Manager), or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation. Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Plant Manager or his designee to assure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.

a o

ADMINISTRATIV.E CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING (ISE) 4108 FUNCTION 8

6.2.3.1 The ISE shall eunction to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources which mcy indicate areas for improving plant safety, j COMPOSITI0t{

6.2.3.2 The ISE shall be composed of at least 3 dedicated full-time engineers located onsite. These engineers will bt- supplemented as necessary by full-time 0 08 engineers shared among all TVA nuclear sites to achieve an equivalent staffing of 5 full-time engineers performing the ISE functions applicable to Sequoyah.

RESPONSIBILITIES -

6.2.3.3 The ISE shall be responsible for maintaining surveillance of plant u08 activities to provide independent verification

• that these activities are performed correctly and that human errors are reduced as much as practical.

AUTHORITY 6.2.3.4 The ISE shall make detailed recommendations for revised procedures, p08 equipment modifications, or other means of improving plant safety to the Manager of Nuclear Managers Review Group.

l R108 6.2.4 SHIFT TECHNICAL ADVISOR (STA)

Shh Supervisn~

6.2.4.1 The STA shall serve in an advisory capacity to t eAshHt +uperavr D R66 ma rs pertaining to the engineering aspects of assuringd o fte

6. 3 FACILITYSTAFFQUALIFICATI0!s 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for coi. sble positions and t MemptiTh

<quirements specified in Section A and C o. Enclosure 1 of Mar -8, 980 NRC letter to all licensees, except for the Site Radiological Cont ) Superintendent- Maragen h R50 or exceed the qualifications of Regulatory Guide L1,8

• Not responsible for sign-off function.

SEQUOYAH - UNIT 2 6-5 Amendment No. 50, 66 , 108 July 5, 1989

t ADMINISTRATIVE CONTROLS 6.4 TRAINING 6.4.1 A retraining and replacement training M PyWGN shall be maintained under the direction of t ogrgr,jppmjplity 0-f sta 4 R66 and shall meet or exceed the requirements and ebeene r5 $bnt-&ttpehntendentsDeritNfivet1en' .5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55 and the supplemental require-ments specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC R50 letter to all licensees, and shall include familiarization with relevant industry operational experisnce.

6.5 REVIEW ANr. AUDIT 6.5.0 Senior Vice President, Nuclear Power is responsible for the safe opera-tion of all TVA power plants. R66 6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The PORC shall function to advite the Plant Manager on all matters R50 related to nuclear safety.

COMPOSITION

6. 5.1. 2 The PORC shall be compesed of the:

V M %QsN Chairman:

M Plant Manager

-Hember. Operatires SuperiidenUtmt Member: Operations Manager R66 Member:

Member: Site Radiological Control Gupeektendent Monaju Maintenance Supenntendent Manger Member: Technical Support Superintendent manag ? .

Member: Quality Engineering knager and Modring SugerW ser Member: Division vi Nuclear Engineering Representative R66 WW M '"

R66 SEQUOYAH - UNIT 2 6-6 Amendment No. 50, 66 June 30, 1988

• ADMINISTRATIVE CONTROLS

4.

i. Reyiew of every unplanned onsite release of radioactive material to <

the environs-including the preparation and forwarding of reports-covering evaluation, recommendations an s ositio f the corrective action to prevent recurrence to the S e ...::.;r and to the Nuclear Safety Review Board. YLE. PfdstbeHT 1 j - -- -

AUTHORITY 6.5.1.7 The PORC shall: o

a. Recommend in writing to the Plant Manager approval or disapproval of items consi6cred under 6.5.1.6(e), (b) and (c) above.

b. Require a determination in writing with regard to whether or not each item considered under 6.5.1.6(b), (c), and-(e) above constitutes an unreviewed-safety. question.

c. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Si ..rt:' r "'

and the Nuclear Safety Review Board of disagreement between ie ORC -

and the Plant Manager; however, the Plant Manager shall have respon-

• sibility for resolution of such disagreements pursuant to 6.1.1 ' '

above.

R50 RECORDS 6.5,1.8_' The PORC shall maintain written minutes of each PORC meeting that, at a_ minimum, document the results of all'PORC activities performed under the [m,.!4 responsibility-andauthorityprovisingirc:teran Copies shall be.provided to theLSit .

of ese technical specifications -

the Nuclear _ safety Review

(

Board. WE PRESIDENT

,6.b.1A TECHNICAL REVIEW AND CONTROL ,

ACTIVITIES-

~

6.5.1A.1. Activities which af fect nuclear safety shall be conducted = as follows:

-a, Procedures-required by-Specification ~6i8.1 and other procedures which affect; plant nuclear safety, and changes thereto,.shall-be prepared, reviewed:and approved. Each such procedure or procedure change shall be reviewed by;a qualified individual other than the individual who prepared the procedure or procedure change, but who may-be from the same organiza-tion as the-individual who prepared the procadure or procedure change.

Q s4gnet,cd-4 Procedures shall be approved by the appropriate respoQ1e m g 'as n

on bmy -tf- ; sup;pintende,,yy-the4QptM4aWPlant Manager,

, ggat-enance Superintendent, Techni:M Op;r -

Support R66 PadT MANYeMatendeM, or site nadiological Contro! SuperiF.tendent shall approve designated. Administrative rocedure A

~ v wv- p -

-b. Workp hn: ned to imph;cnb pr osed changes er modifications to struc-

,systemsh co e s that affect plant nuclear-safety shall be reviewed'by.a qualified individual / group other than the individual / group which designed the modification, but who may be from the same organization 4

55QV0YAH - UNIT 2 6-3 Amendment June No 50 66 K66 I 30, 1988 i

3

- . ADMINISTRATIVE'CONTR0tS-f as the individual / group which designed the modifications. Proposed modifications to structures, systems, and components that affect plant-nuclear safety-end-the Spk;:nting w:rkphn:- shall be approved prior to implementation by the Plant Manager,-Oper:ti:n: Sperint:ndent, M:inten:M+-

p;rintendent, or Technical-Suppeet M AN AGER R66 n ,

per,intendent or.- M;M DaTpa

c. Individuals responsible for reviews performed in accordance with Specifica- .

tions 6.5.1A.la and -b, shall be designated by approved written procedures.

Each such review shall be performed by qualified personnel of the appro-priate discipline and shall include a determination of whether or not  !

additional, cross-dsciplinary review is necessary. Each_such review shall R66l also-include determination of whether or not an unreviewed safety question is involved pursuant to Section 10 CFR 50.59, 6.5.2 NUCLEAR SAFETY REVIEW BOARD (NSRB)

FUNCTION ,,,

6.5.2.1 The NSRB shall function to provide for independent review cnd audit toiassure adequacy-of designated activities in the areas of: ,

RSO

a. = nuclear power plant operations

b. nuclear engineering htm ; .,

ch (chemistry and radiochemistry

d. metallurgy e._ instrumentation and control ,

-f. radiological-safety .

g. mechanical-and electrical engineering ,

h. quality ansurance practices

' COMPOSITION 6.5,2.2 -The NSRB shall be composed of at ast f ve me bers,; including the Chairman, Members of the NSRB may be from th: Off;;; cf Nuclean Power, or other TVA' organization or; external to 'TVA. R50

-QUAllFICATIONS 6.5.2.3~ The Chairman, members, and alternate members of the NSRB shall be appointed in writing by the Senior Vice President, Nuclear Power and shall R66 havel an academic degree in engineering or a physical science- field, or the

- equiv~alent; 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 ,

i shall participate as voting members in NSRB activities at any one time.

SEQUOYAH~- UNIT 2 6-9 Amendment No. 60 66 R66-June 30, 1988

. . _ _ - _ _ . _ ._ . m __ _ _ _ . _ . _ _ _ _ _ _ . . _ . _ _ . _ _ ._._. _ .._ -._

e. ...; ,

4:

P . ADMINISTRATIVE CONTROLS-

, f AUTHORITY 6.5.2.9 The NSRB shall report to and advise the-Senior Vice President,  !

Nuclear Power.on _those areas of responsibility specified in Sections 6.5.2.7 R66 and 6.5.2.8.

I RECORDS-6.5.2.10, Records of NSRB activities shall be prepared, approved-and distributed-as-indicated below:

a .- Minutes of each NSRB' meeting-shall be prepared, approved and forwarded .

f to.the Senior Vice President, Nuclear Power within 14 days following R66l each meeting. l

b. Reports of reviews encompassed by Section 6.5.2.7 above, shall be sprepared, approved and forwarded to the Senior Vice President, " R66 Nuclear Power within 14 days following completion of the review.

• Audit reports encompass (d by Section 6.5.2.8 above, shall be forwarded c.

to the Senior Vice President, Nuclear Power and to the management R66l positions responsible for the areas audited within 30 days:after completion of the audit. 4 6.5.3 RADIOLOGICAL-ASSESSMENT REVIEW COMMITTEE (RARC) I l Function ,

c.orporqi C-6.5.3.1 The SQN RARC .shall function to advise heAManager of Radiological R50 Control and'the Plant Manager on all matters re. ehd logical assess-ments involving dose calculations and projections and environmen,tal-monitoring.

Composit%n .

7 16.5 3.2' The SQN RARC shall be composed of The:

Chairmani Technical Assistance Section Supervisor _ ..

RSC

- Member: Health -Physicist, Gaseous, Radiological Control'

-Member: Health Physicist,- Liquid,: Radiological-Control Member: Meteorologist, Air Quality Branch l Member: . Chemical. Engineer; Chemistry Section~, .SQN .

. Member:

Health Physicist, Environmental-Monitoring,-Radiological Control. R50 Alternates 6.5.3.3 :All alternate members shall be appointed in writing.by ths SQN RARC .R50 '

iChairman to serve on a temporary-basis; however, no-more than two alternates-u , shall participate as voting members-in SQN RARC activities at any one time. R50 Meeting Frequency 6.5.3.4 SQN'RARC'shall meet at least once per six months or as requested RSC' by the Sb RARC Chairman, his designated alternate, or a plant representative. '

SEQV0YAH - UNIT 2 6-12 Amendment' No. N 66 - R66 June 30, 1988

, a

.. 7 .. ,

ADMINISTRATIVE CONTROLS 1 Quorum 6.5.3.5 The minimum quorum of _ the SQN RARC necessary for the performance of ,

the'SQN RAEC responsibility and authority provisions:of these.-technical speci-

-fications-shall consist of the Chairman or-his designated alternate and R50 1 4 members (including alternates) as long as_one is a plant representative.  !

e

-Responsibilities R50

.6.5.3.6 TheiSQN RARC shall be responsible for: -

a. Review of changes- to the OFFSITE DOSE CALCULATION MANUAL.

b .' Review of. procedures required by. Specification 6.8.4 and changes R50 thereto.

c. -Review for information_ purposes of the:results of any audits,, reviews, '

or evaluations of the Quality Assurance Program for effluent and- ., R50' "

environmental monitoring and radiological assessments involving dose ,

evaluations and projections. ,'

d. Review of praposed changes to the Technical Specifications related to' radiological: assessments involving dose calculations and projections- .

-and environmental radiological monitoring.: R50 t Authority .

R50'

-6.5.3.7!-The SQN-RARC shall:- P cor parat c'. >

a. -Recommend in_ writing to eAMana er o, adiological Control and the-

-Plant Manager,' approval o . proval'of items considered under R50-6'.5.3.6 above.

b, JRender determinations in writing with regard to whether. or not each .

item c'onsidered under:6.5.3.6 constitutes an unrev_iewed'- safety )

question. t

-c. Provide written notification within 24 urset e-Senior Vice - . - R66 President, ,

Power and'the Nt; e r p fphy) v'ew Board of dis-agreement ypgr}.4 SQN RARC and (the anager o adiological Control; _t however,, Manager f- Radiologic A-CoMf6 all.have responsibility for resol -

@ h disagreement pursuant to-6.1.2-above.

Records 6.-5.3.81 The SQN.RARC-shall-maintain written minutes 1of each SQN RARC meeting.

that at a' minimum, Ldocument the results of.all SQN RARC activities performed under the responsibility- and authority provisions of these technical- specifi-cations._ Copies _shall be provided.to the Senior Vice President,-Nuclear Power; PORC; and the Nuclear Safety Review Board.

R66l.

SEQUOY,AH - UNIT 2 6-13 AmendmentNo./J/66 R66 June 30, 1988

a i

+. . .,;

l

• 1

, ADMINISTRATIVE CONTROLS l

6.6 REPORTABLE ~ EVENT ACTION. .

6.6.1 The_.following actions shall be-taken for REPORTABLE EVENTS: l R28 -!

a. The Commission shall be notified -and/or a report submitted pursuant to the requirements of Section 50.73 to 10 CFR Part 50, and

b. Each. REPORTABLE EVENT.shall be reviewed by the PORC and hh of this review shall be submitted to the NSRBLand the te,0irector. . R50 We R eddent.

6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is l violated:

l

a. :The unit shall be placed in at least HOT STANDBY within one' hour, i

b. The NRC Operations Center shall be notified by tele nev eneona .

.possible and in all cases within one hour. The t .irector and th .

NSRB ~shall: be-notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. _ 56'ce President -

c._ A Safety-Limit Violation Report shall be prepared, he report shall i be reviewed-by.-the:PORC. This report shall describe (1) applicable-circumstances preceding the violation,--(2) effects of the violation upon facility components, systems or structures, and (3) corrective -

action taken to prevent. recurrence. '

r d,- The LSafety: Limit- Vi a djib a 11_be submitted to the Commission,

~theNSRBand:theSiefirecterwithi 14 days of the violation; R50-Wes President .

6.8 PROCEDURES AND= PROGRAMS .

.6.8.1 Written procedures: shall be established, implemented and m'aintained - ,

covering the activitiesfreferenced below: ' ,

a.- The applicable procedures recommended inLAp'pendix "A" of Regulatory Guide 1.33,-Revision-2,; February 1978.

b. ' Refueling operations.-- .

-c. Surveillance and test activities of safety related equipment.

d! Plant-Physical Security Plan implementation.

e. Site Radiological Emergency Plan implementation._

f. Fire, Protection Program implementation.

g. PROCESS CONTROL PROGRAM implementation.

SEQUOYAH - UNIT 2 6-14 Amendment Nm Wg by 66R66 June 30, .988 ] .

. O

.~ ADMINISTRATIVE CONTROLS MONTHLY REACTOR OPERATING REPORT 6.9.1.10 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the PORVs or Safety Valves, shall be submitted on a monthly basis no later than the 15th of each month following the calendar _m_onth covered _by_th @ - -

^% .hanges-to-the-OFFSITE-DOSE-CAlCULAT40N-MANUAL-shah-be-submittcd with th

[ -MontMy-Operat4ng-Repoet within-901 days-4n-whkh-the-change (:) w:: made ef4est4ves

/ 4n-addit 4on r-a-report-of-any-majon-changes-to-the-eadhaethe-waste-t+eatment

--systems-tha H-be-subm R ted-wRh-the-Mont-bly-Opeeat4eg-Reportt40 e-the-per4ed-in-

-which-the-evehat4en-wa; reviewed-and-aecepted by the PORCr

.h .- A . .s f RADIAL PEAKING FACTOR LIMIT REPORT 6.9,1.14 The W(z) function for normal operation shall be provided at least 60 days prior to cycle initial criticality. In the event that these values would be submitted at some other time during core life, it will be submitted 60 days prior to the date the values would become effective unless otherwise exempted by the Commission.

Any information needed to suport W(z) will be by request from the NRC and need not be included in this report.

SPECIAL REPORTS 6.9.2.1 Special reports shall be submitted within the time period specified for each report, in accordance with 10 CFR 50.4.

6.9.2.2' Diesel Generator Reliability Improvement Program As a minimum the Reliability Improvement Program report for NRC audit, requi.ed by LCO 3.8.1.1, Table 4.8-1, shall include:

(a) a summary of all tests (valid and invalid) that occurred hthin the .

time period over Jhich the last 20/100 valid tests were pu rormed t (b) analysis of failures and determination of root causes of failures (c) evaluation of each of the recommendations of NUREG/CR-0660, " Enhancement of Onsite Emergency Diesel Generator Reliability in Operating Reactors,"

with respect to their application to the Plant (d) identification of all actions taken or to be taken to 1) correct the root causes of failures defined in b) above and 2) achieve a general improvement of diesel generator reliability (e) the schedule for implementation of each action from d) above (f) an assessment of the existing reliability of electric power to engineered-safety-feature equipment SEQUOYAH - UNIT 2 6-22 Amendment Nos. 44, 50, 64, 66, 107, 134

. ~ .

.r .

^ w ADMINISTRATIVE CONTROLS 6.11 RADIATION PROTECTION PROGRAM

.r Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph '

20.203(c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be ~

barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Special (Radiation)

Work Permit *. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area. ,

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device-may be made af ter the dose rate level in the area has been estab-lished and personnel have been made knowledgeable of them,

c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This indi-vidual shall be responsible for providing positive control over the activities within the area and shall perform control over the activ-ities within the. area and shall perform periodic radiation surveil-lance at th f qup.ne Control ^^r aten _g specified by the in the Special facility Site (Radiation) Radiological Work Permit.

hiAuAoss. ,

- 6.12.'2 The requirement of 6.12.1, above, shall also apply to each high radiation area in which the. intensity of radiation.is greater than 1000 mrem /

hr. In addition, locked' doors shall be provided to prevent' unauthorized entry into such areas and the keys shall be maintained under the administrative contro f the Sh ft Su ervisor on duty and/or the Site Radiological Control aper.ntendcat. M Aw6cm,

• Radiological Control personnel or personnel escorted by Radiological. Control personnel =in accordance with approved emergency procedures, shall be exempt from the SWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

'l SEQUOYAH - UNIT 2 6-25 Amendment No. 34, 50, 66, 134

.0 .,

4-ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION C.'ANGE t SEQUOYAll NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-90-22)

DESCRIPTION AND JUSTIFICATION FOR SEu1 ION 6.0 CHANGES k

4 l

l l

A; W . ' .

.- ENCLOSURE 2 t

?

Description of Change Tennesseo Valley Authority proposes to mo'dify Section 6.0 of the Sequoyah Nuclearc Plant'(SQN) Units l'and 2 Technical Specifications (TSs) to incorporate the overtime limit _ requirements that were provided in Generic -

Letter 1(GL) 82-16,-."NUREG-0737 Technical Specifications," to delete the requirement for reporting Offsite Dose Calculation Manual changes and radiological-waste treatment system changes in the monthly report, to i change _ position titles, to_ change Plant Operations Review Committee (PORC) membership, to specify Plant Manager or Duty Plant Manager. to approve [

administrative procedures.and proposed p7 ant modifications that affect '

plant nuclear safety, to revise wording regarding review and approval of proposed modifications, and to correct typographical errors.

Reason for Change t

Overtime requirements as specified in GL 82-16 have been previously

-defined inisiteJprocedures at SQN. NRC issued Violation 87-78-01 to SQN-Unita 1: and 2 on March 14, 1988, for exceeding overtime limits without

-proper authorization. On July 26, 1990, Violotion- 90-22-01 was also issued-for-exceeding = overtime limits without proper authorization. As a

' result ofLthe recurrent procedural _ implementation problem._NRC requested in-its October 18, 1990,_ letter that SQN submit TSs consistent with

-GL 82-16xto' control overtime.

• To-incorporate the-recommendations of GL 89-01, " Implementation of Programmatic Controls _for Radiological Effluent Technical Specifications

? Lin the' Administrative Controls Section of-the Technical Specifications and

'the Relocation:of-Procedural Details of RETS to=the Offsite Dose

' Calculation Manual'or to the Process Control Program," TVA submitted TS :l Change 90-03.' LThe GL recommends providing Offsite Dose Calculation Manual l changes andLradioactive waste.. treatment system' changes--in the Semiannual rRadioactive'EffluentLRelease Report. TVA' proposed the necessary TS changes?to incorporate the GL. 89-01 reporting: recommendations in TS ' change-90-03, but neglected to remove' the redundant monthly _ reporting requirement. ,

~

0perations'fmanagement is configured such thatothe Operations Manager reports.to.the Plant Manager.--The OperationsLSuperintendent..among others.freports'to the Opsrations-Manager.. Given this organization,-there  ;

is no need to designate both the Operations Manager;and Opers,tions '

Superintendent.for membership on PORC.

1The change of approval authority _for administrativ'e procedures and

, _ proposed changes;or modifications'to structures,jsystems,-and components (to only the" Plant Manager or Duty Plant Manager _ removes the allowance for individualsLwho'directly report to the Plant, Manager to approve these-items; unless ' designated as;the Duty Plant Manager. This more restrictive level.of approval is~ desired by TVA1 management.-

w- . - ,~ -- - .

, a ,

The modification process at SQN is in the process of being changed such that workplans will not be used for modification implementation. The new process will incorporate the functions of the workplan into the modification package with the exception of the field activities to physically install the hardware. Since the currently defined workplan will not exist in the planned process, the present TS wording could create concerns or confusion. The changes proposed do not impact the current processes but only provide flexibility for changes in modification processes and nomenclature when this new process is implemented.

Position titles have recently changed in the SQN organization. These title changes have been updated in this proposed TS change, as well as the correction of typographical errors.

Justification for Change The proposed TS change will not alter TVA's overtime limits at SQN as currently defined in site procedures; it will act to reinforce current requirements. Additionally, the change is consistent with the guidance provided in GL 82-16 and draft Revision 5 of the Westinghouse Electric Corporation standard TSs.

The proposed change to the monthly reporting requirements is consistent with GL 89-01 and draf t Revision 5 of the Westinghouse standard TSs.

Additionally, changes to radioactive waste treatment systems are submitted as part of the annual Final Safety Analysis Report update.

The deletion of the Operations Superintendent from PORC membership does not degrade the safety review function of PORC. Operations' management is represented by the Operations Manager or his alternate, which may include the Operations Superintendent.

By requiring Plant Manager or Duty Plant Manager to approve nuclear safety-related administrative procedures and modifications, a more restrictive level of approval is implemented than the TSs presently requirel accordingly, assurance is maintained for adequate technical and safety review. The deletion of other positions to approve these items is not expected to overburden the Plant Manager; most items already receive this level of approval.

The original intent regarding review and approval of workplans was to ensure appropriate plant staff review and approval of implementation of proposed modifications. The new modification process planned for implementation in early 1991 will incorporate the portions of the current workplan document intended for review and approval into the modification package. The modification package will receive the same level of review and approval presently received by the workplan. The fieldwork portion of the workplan will be performed by the process that maintenance activities currently utilize with the corresponding review and approval process.

This portion will not recolve the same level of review and approval as the modification package.

. . -.. . .. .~ .. - . . - - - . . . - - - - . - - . - - . . .

s ..

ie '.- X , e

<. t

[ *' . .

[ -  !

However, sinceLthese-are only the field actions approved and authorized by the modification package to implement the modification, this-level of

~

' approval-;is not1necessary. This change continues to provide for the

~

appropriate review and approval of implementation of proposed modifications Lo ensure adequate safety review prior to implementation.

Thefother changes include changes to position titles-to reflect the ,

currentiorganization and typographical corrections.-

Environmental Impact Evaluation

The ~ proposed' change. request does not involve an unreviewed environmental question because operation of SQN Units 1 and 2 in accordance with this .

change would nott- "

1. Result.in a significant. increase in any adverse environmental impact La previously evaluated in the final environmental statement:(FES) as --

L - modified by'the staff's testimony to the Atomic Safety and Licensing, r

? Board. supplements to the FES, environmental impact appraisals, or J L-

- decisions-of the:AtomicLSafety and Licensing Board. .l t

2. Result in a significant-; change in effluents or power levelse 3.2 Result in-matters not previously reviewed in.the licensing basis for SQN that may have a: significant environmental impact.  ;

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.. ... 4 ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-90-22)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION OVERTIME LIMITS

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e , ENCLOSURE 3 s

, Significant Hazards Evaluation TVA has evaluated the proposed technical specification (TS) change and has determined that it does not represent a significant hazards consideration based on criteria established in 10 CFR 50.92(c). Operation of Sequoyah

, Nucicar Plant (SQN) in accordance with the proposed amendment will not (1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed TS revision will not change SQN's policy on overtime lim 1ts; it provides administrative control. Reporting of changes to the Offsite Dose Calculation Manual and radioactive waste treatment systems will still be made in the Semiannual Radiological Effluent Report and the Final Safety Analysis Report. Changing the position titles and deleting the Operations Superintendent from Plant Operations Review Committee (PORC) membership do not decrease the level of required management oversight. Further restricting the approval authority level for administrative proceduros and

, modifications and deleting workplan implementation terminology do not I

decrease level of review or approval. Correcting typographical errors is an administrative change. The proposed amendment, l therefore, will have no effect on the probability or consequences of l an accident previously analyzed in SQN's Final Safety Analysis Report.

(2) Create the possibility of a new or different kind of accident from any previously analyzed.

The proposed change on overtime limits, position titles, PORC membership, procedure / modification review and approval, and typographical errors cannot in itself create an accident. Reporting of changes to the Offsite Dose Calculation Manual and radioactive waste treatment systems will still be made in the Semiannual Radiological Effluent Report and the Final Safety Analysis Report.

The proposed amendment, therefore, does not present the possibility of any new or different kind of accident.

l (3) Involve a significant reduction in a margin of safety.

The proposed change provides administrative control of overtime limits and does not involve a reduction in margin of safety. It is intended to minimize fatigue, which may enhance safety by improving alertness and attentiveness. Reporting of changes to the Offsite Dose Calculation Manual and radioactive waste treatment systems will still be made in the Semiannual Radiological Effluent Report and the Final Safety Analysis Report. Deleting the Operations Superintendent from the designated PORC composition is not a reduction in the margin of safety provided by PORC oversight, as Operations' management is still represented. Review and approval for. administrative procedures and modifications are not being reduced; therefore, the margin of safety is not reduced. Changing the position titles and correcting typographical errors.are administrative changes. The proposed amendment, therefore, will not involve a reduction in margin of safety.

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