ML20214H951

Discusses Implementation of Facility Independent Safety Engineering Group (Iseg),Per 870504 Telcon.New Iseg Organization Will Be Implemented by 870522.Bases for Implementation of Iseg Encl

ML20214H951
Person / Time
Site:	Sequoyah
Issue date:	05/15/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-R00124, TAC-R00125, TAC-R124, TAC-R125, NUDOCS 8705270555
Download: ML20214H951 (3)

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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 37401 SN 157B Lookout Place MAY 151987 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of the ) 50-327 Tennessee Valley Authority ) 50-328 IMPLEMENTATION OI' SEQUOYAH INDEPENDENT SAFETY ENGINEERING GROUP By our letter dated May 27, 1986, TVA requested approval of changes to the Sequoyah technical specifications which would reflect the current organization. These changes included a restructuring of the Independent Safety Engineering Group (ISEG) to be consistent with NUREG-0737 and SECY-80-242.

It is our understanding the Nuclear Reactor Regulations (NRR) staff had found the changes acceptable, but final approval was delayed by questions on whether the changes were given appropriate public notice. TVA staffed the ISEG with the expectation of a March 16, 1987 approval of the above technical specifications and stands ready to implement the ISEG function.

On May 4,1987, telephone conversations with your staff indicated that using regulatory discretion is appropriate in this instance. TVA considers implementation of ISEG to be consistent tfith our Nuclear Performance Plan, Volumes 1 and 2 and the technical specifications reviewed by NRR. These changes will enhance the ISEG function and should not be delayed. We therefore plan to implement the new ISEG organization by May 22, 987, and have enclosed the bases for this decision. We understand you will use regulatory discretion. If this is not accurate, please telephone R. H. Shell at (615) 751-8099.

Very truly yours, TENNESSEE VA AUTHORITY R. Gr diey, Dir ctor l Nuclear Safety and Licensing I 1

Sworn tp pJi ubscribed t before me this /O da f & fl987 i hf Notary Public 9

My Commission Expires bk$0

'O Enclosure cc: See page 2 sl g 87052705S5 870515 7 DR ADOOK 0500 An Equal Opportunity Employer

e U.S. Nuclear Regulatory Commission MAY 15 M7 cc (Enclosures):

Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814 Mr. G. G. Zech, Assistant Director for Inspection Programs Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379

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• ENCLOSURE BASES FOR IMPLEMENTATION OF INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

BACKGROUND Currently the Sequoyah Nuclear Plant (SQN) Technical Specification Administrative Controls require five ISEG engineers onsite. TVA accepted the requirement based on the implementation plan described in our August 11, 1980 letter to NRC and referenced by NRC in the Safety Evaluation Report (SER).

This understanding provided that the ISEG function would be performed by the plant compliance staff as an adjunct.

As part of the overall plan to enhance plant operations, TVA decided to establish an ISEG which was consistent with NUREG-0737 and SECY-80-242 guidelines. Specifically, each plant would have a staff of three ISEG engineers and would be supplemented by a central office ISEG staff.

DISCUSSION TVA's position during SQN licensing wac that several of the functions of ISEG were already being performed by the plant compliance staff. Specifically, review of. industry and NRC experience information was already processed by compliance. The group reported to the plant manager and performed safety reviews at his request and af ter certain operating events. This arrangement met the intent of providing a staff which would werk to improve plant safety.

NRC's position, as detailed in SECY-80-242, NUREG-0737, and the SQN SER, was that a staff of five onsite engineers would probably be worthwhile. As a result, ISEG became a requirement but NRC would later review the concept for value. As it related to SQN, NRC allowed TVA to implement the ISEG function using the compliance staff in a dual role.

Subsequently, NRC began to question the efficacy of this implementation plan.

Concerns were raised by resident inspectors and central office reviewers that the ISEG staff did not have sufficient independence.

As part of TVA's overall plan to enhance plant safety, TVA decided to establish ISEG staffs at each site. This was described in our Nuclear Performance Plans and was also formally requested in our May 27, 1986 SQN technical specification change request. The implementation plan would place three ISEG engineers at each site with support from a central office staff and reporting to the Director of Nuclear Safety and Licensing. This proposal was understood to be amenable to NRC and is consistent with SECY 80-242 (page 2, paragraph 3).

SUMMARY

l The changes proposed for ISEG should enhance the function by removing non-ISEG ,

activities from personnel responsibilities and by providing an independent reporting chain. The changes are consistent with those described in our Nuclear Performance Plans, and they have been reviewed by NRC. Your staff indicated it should be a positive change, and that NRC is receptive to

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immediate implementation and regulatory discretion is warranted. For these .

reasons, implementation will begin after NRC has had a reasonable opportunity to comment.

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