ML20053E163

Forwards Response to NRC 820429 Request for Addl Info Re 820303 Request for Amend to License DPR-77 & DPR-79 to Change Tech Specs 6.4 Re training,6.5.1 Re Plant Operations Review Committee & 6.5.1.7b Re Committee Authority

ML20053E163
Person / Time
Site:	Sequoyah
Issue date:	05/27/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML20053E164	List: ML20053E163 ML20053E170
References
NUDOCS 8206070661
Download: ML20053E163 (8)

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9 TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 37401 400 Chestnut Street Tower II May 27, 1982 Director of Nuclear Reactor Regulation Attention: Ms. E. Adensam, Chier Licensing Branch No. 4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Ms. Adensam:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 On March 3, 1982, we submitted a request by letter from me to H. R. Denton to amend the Sequoyah Nuclear Plant Operating Licenses DPR-77 and DPR-79 to change the technical specifications. The proposed amendment requested changes in the plant organization and PORC composition. As a result of an April 29, 1982 telephone conversation with G. Rivenbark, NRC-NRR, we agreed to pnvide a supplement to our March 3,1982 request. Enclosure 1 provides additional information regarding NRC questions on our changes to technical specifications 6.4, 6.5.1.2, and 6.5.1 7.b.

Also enclosed (Enclosure 2) are revised figures 6.2-1 and 6.2-2 which supersede those figures provided in our previous submittal on March 3, 1982. As a result of the revision to figure 6.2-2 to clarify the Independent Safety Engineering Group, an additional change was necessary to technical specification 6.2 3, which is also provided in Enclosure 2.

If you have any questions concerning this matter, please get in touch with J. E. Wills at FIS 858-2683 Very truly yours, TENNESSEE VALLEY AUTHORITY s

. . Mil 5s, Manager Nuclear Licensing Sworn this 2 to and subscrgNqd 7#dday before me of '/ d uf-1982 )

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Notarf Public

, ji My Commission Expires E /Id sI

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Enclosures cc: See page 2 8206070661 820527 PDR ADOCK 05000327 P PDR An Equal Opportunity Employer

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Director of Nuclear Reactor Regulation May 27,-1982 I co: U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 i

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ENCLOSURE 1 RESPONSE TO NRC QUESTIONS TO PROVIDE ADDITIONAL INFORMATION FOR TECHNICAL SPECIFICATIONS (T/S) 6.4, 6.5.1.2, AND 6.5.1.7.b SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 T/S 6.4 Training NRC Comment: The word " appropriate" used in the section 6.4.1, ". . .under the direction of the appropriate Assistant Plant Superin-tendent. . ." is vague and does not specify which Assistant is responsible for each area of training.

TVA Response:

We propose to revise 6.4.1 as follows.

". . .under the direction of the Plant Superintendent and shall meet. . .

T/S 6.5.1 Plant Operations Review Committee NRC Comment: Please add the following statement to Section 6.5.1.2:

"The PORC members and alternates shall meet the qualifications of section 4.4 or ANSI N18.1-1971."

TVA Response: .

We agree with this proposal since a commitment has been made in the FSAR to meet ANSI N18.1-1971. Also, as requested by G. Rivenbark, we have provided in Attachment 1 a listing of the qualifications for each position specified in section 6.5.1.2.

Page 2 T/S 6.5.1.7.b Authority (of PORC)

NRC Comment: Provide justification for proposed change to item b of section 6.5.1 7 that was revised. Item b was changed as follows: ". .

.6.5.1.6(a) through (e). . ." was changed to read ". . 6.5.1.6(a) through (d). "

TVA Response:

We believe that the removal of item 6.5.1.6(e) from 6.5.1.7.b is justified because 10 CFR 50.59, which describes th9 basis for determining if an unreviewed eafety question (USQ) exists, pertains only to making changes in the facility or procedures as described in the safety analysis report or the conduct of tests or experiments not described in the safety analysis report. 10 CFR 50.59 at no point states that an unreviewed safety question determination (USQD) must be performed as the result of a technical specification violation.

The Standard Technical Specifications allow operation of a unit in certain degraded modes if a Limiting Condition for Operation (LCO) is not met. NRC has reviewed all questions regarding plant safety when developing the technical specification action requirements. Following an unplanned event, a Potential Reportable Occurrence (PRO) report is written to determine whether an LCO has been violated. If an LCO has not been met and the unit has entered an action statement, a Licensee Event Report (LER) is written and filed under technical specification 6.9.1 9.b. As long as the unit does not exceed the bounds of the action statement, no USQ exists because the plant remained within conditions already reviewed and approved by NRC.

When an LCO is not met and tha associated action requirements are exceeded, the licensee is required by technical specification 3.0.3 to take action within one hour that will place the unit in a mode in which the specification does not apply by placing it, as applicable, in: ,

1. At least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />;

2. At least hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; and 3 At least cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Exceeding the bounds of an action requirement requires the licensee to promptly notify the NRC by both technical specification 6.9.1.8.b (report by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and confirm by telegram, mailgram, or facsimile transmission no later than the first working day following the event with a written followup report within 14 days) and 10 CFR 50.72(a)(5)

(notify NRC Operations Center as soon as possible and in all cases within one hour by telephone). Review of technical specifications to determine the proper reporting category constitutes a review similar to a USQD.

However, the questions to be answered in a USQD do not apply to technical specification violations, and 10 CFR 50.59 does not require a USQD be performed for technical specification violations.

Page 3 Technical specification violations (failure to meet the limiting conditions for operation) may or may not involve a situtation that has been previously reviewed. Obviously, if the plant remains within the bounds of an action statement, it remains within a condition reviewed, approved, and allowed by NRC. If the plant condition exceeds the action statement either in scope or time but the requirements of specification 3.03 are met, the plant was operated within a condition reviewed, approved, and allowed by NRC. The only time a plant would be in a condition not reviewed, approved, and allowed would be a failure to meet specification 3.03 TVA believes that the technical specification reporting requirements are adequate to notify NRC-0IE of the different levels of technical specification violations.

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ATTACHMENT 1 QUALIFICATIONS FOR POSITIONS LISTED IN SECTION 6.5.1.2 Plant Superintendent At the, time of initial core loading or appointment to the active position, the plant superintendent shall have 10 years of responsible power plant experience of which a minimum of 3 years shall .be nuclear power plant experience. A maximum of 4 years of the remaining 7 years of experience may be fulfilled by academic training on a one-for-one time basis. This academic training shall be in an engineering or scientific field generally associated with power production. The plant superintendent shall have acquired the experience and training normally required for examination by NRC for a senior operator license whether or not the examinaton is taken.

If an assistant plant superintendent meets the nuclear plant

, experience and NRC examination requirments established for the plant superintendent, the requirements of the superintendent may be reduced so that only 1 of his 10 years of experience need be nuclear plant experience; and he need not be eligible for NRC examination.

The plant superintendent or an assistant plant superintendent should have a recognized baccalaureate or higher degree in an engineering or scientific field generally associated with power production.

Operations Supervisor * .

At the time of initial core loading or appointment to the active position, the operations supervisor shall have a minimum of 8 years of responsible power plant experience of which a minimum of 3 years shall be nuclear power plant experience. A maximum of 2 years of the remaining 5 years of power plant experience may be fulfilled by satisfactory completion of academic or related technical training on a one-to-one time basis. At the time of initial core loading or appointment to the ae',1ve position, the operations supervisor shall hold a Senior Operator's license.

Engineering Supervisor At the time'of initial core loading or appointment to the active i

position, the Engineering Supervisor should have a

! minimum of 8 years in responsible power plant experience or applicable indus_ trial experience of which 2 years shall be nuclear plant experience. He should have an engineering or science degree.

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Attechment 1, page 2 -

Maintenance Supervisors (Mechanical, Electrical, Instrument)

At th~e time of initial core loading or appointment to the active position, the maintenance supervisor shall have a minimum of 7 years of responsible power plant experience or applicable industrial experience, a minimum of 1 year of which shall be nuclear power plant experience. A maximum of 2 years of tne remaining 6 years of power plant or industrial experience may be

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fulfilled by satisfactory completion of academic or related technical training on a one-for-one time basis. He further should have nondestructive' testing familiarity, craft knowledge, and an understanding of electrical, pressure vessel, and piping codes. '

Health Physics Supervisor _.

The Health Physics Supervisor should have a bachelor's degree or the equivalent in a science or engineering suoject, including some formal training in radiation protection. The Health Physics Supervisor should have at least 5 years of professional experience in applied radiation protection. (A master's degree may be considered equivalent to 1 year of professional.

experience, and a doctor's degree may be considered equivalent to 2 years of professional experience where course work related to radiation protection is involved.) At least 3 years of this professional experience shou.ld be in applied radiation protection work in a nuclear facility deal'ing with radiological problems similar to those encountered in nuclear power stations, preferably in an actual nuclear power station.

Quality Assurance Staff Supervisor At the time of initial core loading or appointment to the active '

position, the supervisor or the plant quality assurance staff '

supervisor shall have seven years of responsible power plant experience or applicable q tlity assurance experience of which a i minimum of two years shall be nuclear power plant experience. He should be a graduate with a degree in engineering. A maximum of ,

two years.of the remaining five years of power plant or quality '

aasurance experience may be fulfilled by satisfactory completion of academic or related training on a one-for-one basis. Upon appointment, the supervisor shall receive training from the Office of Power Quality Assurance and Audit Staff relative to basic quality assurance theory and practice. This training shall include an orientation to the Office of Power Quality Assurance Program, as define _d in the Office of Power Quality Assurance Manual.

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J - ENCLOSURE 2 i

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(1) REVISED FIGURES F0d SEQUOYAH NUCLEAR PLANT t UNITS 1 AND 2 TECHNICAL SPECIFICATIONS

.i i (2) PROPOSED-TECHNICAL SPECIFICATION 6.2 3 FOR SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 i

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